Privacy Policy

Last updated: September 11, 2025

Whirl AI, Inc. ("Whirl AI", “we”, “us”, or “our”) is a company incorporated in the State of Delaware. This Privacy Policy explains how we collect, use, and protect your personal information when you interact with our website at whirlai.com (the “Site”) and our related services (together, the “Services”).

By accessing or using the Services, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use the Services.

1. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will:

• Post the revised policy on this page

• Update the “Last updated” date

• Take additional steps as required by law

2. Information We Collect

We collect personal information only when you voluntarily provide it via our chatbot or contact form. This may include:

• Email address

• Any other information you choose to submit

In addition, we use cookies and similar technologies to collect data automatically when you visit our site including: IP address, browser type and settings, page visited, among other metrics. This data may be collected through Google Analytics or other third-party tools. Where required by law, including the European Economic Area (EEA) and the UK, we obtain your consent before placing non-essential cookies or using tracking technologies. A cookie consent banner is deployed on our Site for users in these regions.

3. How We Use Your Information

We use the information you provide to:

• Respond to your inquiries and communicate with you

• Provide and improve our services and website functionality

• Understand user behavior and improve user experience

• Comply with legal obligations

• For limited marketing or business outreach purposes only where permitted by applicable law and/or your consent.

We do not sell your personal information

4. Legal Basis for Processing (GDPR)

For users located in the European Economic Area (EEA), we process your personal data on the basis of:

• Your consent

• Our legitimate interests

• Compliance with legal obligations

You may withdraw your consent at any time by adjusting your cookie preferences or contacting us directly.

5. Disclosure of Your Information

We do not sell or rent your personal data. We may share your information only with:

• Vendors and service providers acting on our behalf, under contractual obligations to safeguard your data

• Regulatory authorities if required to comply with legal processes

• Successors or assigns in the event of a business restructuring

6. Security and Retention

We use appropriate technical and organizational measures to protect your personal data, including:

• SSL encryption for data in transit

• Access restrictions to personal data

• Regular review of our data handling practices

We retain personal information only as long as necessary to fulfill the purposes outlined above or as legally required.

7. Your Rights

If you are in the EEA, UK, or other regions with similar laws, you may have the right to:

• Access the personal data we hold about you

• Request correction or deletion

• Withdraw consent at any time

• Object to or restrict processing

• Request data portability

To exercise any of these rights, contact us at hello@whirlai.com.

8. Children’s Privacy

Our Services are not intended for children under the age of 16. We do not knowingly collect personal data from minors. If you believe a child has submitted personal data to us, please contact us to have it deleted.

9. Third-Party Links

Our Site may include links to other websites. We are not responsible for the privacy practices or content of those third parties. We recommend reviewing their privacy policies before engaging with them.

10. Contact Us

If you have any questions about this Privacy Policy or your personal data, contact us at:

hello@whirlai.com