Privacy Policy

WILLPORT Holdings, Inc.

Effective Date: July 11, 2026 | Last Updated: July 11, 2026

1. Scope and Overview

This Privacy Policy explains how WILLPORT Holdings, Inc., a company based in Nevada ("WILLPORT," "we," "us," or "our"), collects, uses, discloses, and protects personal information when you use:

  • willport.com and other websites that link to this Privacy Policy;
  • the WILLPORT mobile application;
  • WILLPORT features and services, including gifting, messaging, calendars, WILLpay, WILLPORTmoney, WILLPORTinternational, AI-assisted greeting-card features, and other currently available features; and
  • customer support, marketing, and other interactions with WILLPORT.

Collectively, these are the "Services."

Some Services are provided with or through independent third parties, including financial institutions, payment processors, identity-verification providers, bank-linking providers, merchants, fulfillment providers, and professional-service providers. Those parties may process personal information under their own privacy notices. This Privacy Policy does not replace any privacy notice or authorization presented by such a third party.

WILLPORTtrust, WILLPORTvouchers, WILLinvest, and certain financial, trust, estate-planning, or investment-related features may be described as "coming soon," beta, pilot, or offered through a third-party institution. If a separate notice is presented for one of those services, that notice will also apply.

2. Personal Information We Collect

The information we collect depends on the features you use, the permissions you grant, and the transactions you request.

A. Information You Provide

We may collect:

  • Account and contact information, such as name, email address, telephone number, username, password or authentication credentials, physical address, shipping address, and profile photo.
  • Personal details, such as date of birth, anniversaries, birthdays, important dates, preferences, relationships, and recipient details.
  • Identity-verification information, such as date of birth, Social Security number or taxpayer identification number, government-issued identification, proof of address, selfie, video, liveness-check information, and verification results. Identity-verification providers may create or process biometric identifiers or biometric information where permitted by law and with any consent required by law.
  • Financial and transaction information, such as bank-account and routing information, payment-card details, transaction history, transfer instructions, wallet activity, recipient information, fees, refunds, disputes, and fraud or risk signals. Payment-card credentials may be collected directly by a payment processor rather than stored by WILLPORT.
  • Contacts and network information, if you choose to grant device-contact access, such as contact names, telephone numbers, email addresses, and matching or invitation status. Contact access is optional and can be withdrawn through your device settings, although related features may then be unavailable.
  • Content and communications, such as messages, voice recordings, videos, photographs, greeting cards, AI prompts and generated content, reviews, support requests, survey responses, and communications with WILLPORT or other users. When you use AI Greeting Cards, the text prompt you submit—and any reference image or other content you choose to submit if the feature supports it—is transmitted to OpenAI as described in Section 7.
  • Order and fulfillment information, such as products or services selected, gift recipients, delivery instructions, redemption details, and cancellation or return requests.
  • Professional or business information, if you interact with WILLPORT as a merchant, advisor, trustee, attorney, institution, contractor, applicant, or business representative.
  • Marketing choices, such as email, push-notification, cookie, and SMS preferences.
B. Information Collected Automatically

When you use the Services, we and our service providers may automatically collect:

  • IP address, device identifiers, advertising identifiers, browser type, operating system, app version, language, time zone, and mobile carrier;
  • pages or screens viewed, links clicked, searches, feature interactions, referring pages, session dates and times, and similar usage information;
  • crash reports, performance information, diagnostics, security events, and fraud signals;
  • approximate location inferred from an IP address and, with device permission, precise geolocation; and
  • information collected through cookies, software development kits, pixels, local storage, tags, and similar technologies.

Our website currently uses Google Tag Manager. The app and website may also use analytics, crash-reporting, advertising, attribution, user-experience, and security technologies. The specific providers and technologies may change as the Services evolve.

C. Information from Other Sources

We may receive information from:

  • other users who send you a gift, payment, invitation, message, or other content;
  • social-login or identity providers when you choose to connect an account;
  • payment processors, financial institutions, open-banking and bank-linking providers, identity-verification providers, and fraud-prevention services;
  • merchants, retailers, gift-card issuers, delivery providers, and other fulfillment partners;
  • professional partners involved in a service you request;
  • public records, sanctions and watch lists, fraud databases, and other legally available sources; and
  • advertising, analytics, and marketing partners.

If you provide personal information about another person, you represent that you have authority to provide it for the purpose requested and will not use the Services to contact that person unlawfully.

3. How We Use Personal Information

We may use personal information to:

  • create, authenticate, maintain, secure, and support accounts;
  • provide requested gifts, payments, transfers, messages, calendars, AI-generated content, and other Services;
  • match contacts, deliver invitations, and enable interactions among users;
  • process transactions, verify identity, link financial accounts, prevent fraud, comply with financial-crime requirements, and manage disputes;
  • communicate about transactions, account activity, security, support, service changes, and administrative matters;
  • personalize content, recommendations, offers, and the user experience;
  • provide marketing and advertising, subject to your choices and applicable law;
  • measure, analyze, test, troubleshoot, secure, and improve the Services;
  • develop new products and features, including through aggregated or de-identified information;
  • enforce our agreements and policies and protect users, WILLPORT, and others;
  • comply with law, legal process, regulatory obligations, audits, and recordkeeping requirements; and
  • carry out a merger, financing, acquisition, reorganization, bankruptcy, sale of assets, or similar corporate transaction.

We may combine information collected through different Services and devices for these purposes, as permitted by law.

4. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients:

  • Service providers and contractors that host data, process payments, verify identities, link bank accounts, prevent fraud, provide analytics, generate AI content, send communications, provide customer support, or perform other services for us. This includes OpenAI for the AI Greeting Cards feature.
  • Financial-services partners, including Dwolla, its financial institution partners, open-banking providers, payment processors, card networks, banks, and international-transfer providers, when needed to provide a financial service you request.
  • Merchants and fulfillment partners, such as retailers, gift-card issuers, florists, experience providers, shipping companies, and delivery providers.
  • Other users and recipients, when necessary to complete a gift, payment, invitation, group activity, message, or other user-directed interaction. Your privacy settings may control some disclosures.
  • Professional and institutional partners, such as trustees, custodians, registered investment advisers, attorneys, tax professionals, notaries, or wealth-management firms, only when you request or authorize an applicable service or as otherwise permitted by law.
  • Analytics, advertising, and marketing partners, which may collect identifiers, device information, usage data, commercial information, approximate location, and inferences through cookies, SDKs, pixels, or similar technologies.
  • Government authorities and other parties for legal or safety reasons, when we reasonably believe disclosure is required by law or necessary to protect rights, safety, security, or property; investigate fraud or unlawful activity; or enforce our agreements.
  • Parties to a corporate transaction, including actual or prospective acquirers, investors, lenders, advisers, and successors, subject to appropriate protections.
  • Other parties at your direction or with your consent.

We may disclose aggregated or de-identified information that cannot reasonably be used to identify you. We will not attempt to re-identify data maintained as de-identified except as permitted by law to test our de-identification processes.

5. Dwolla-Enabled Services and Bank Linking

To use certain payment functionality, you may be required to open a Dwolla Platform account provided by Dwolla, Inc. and accept the Dwolla Account Terms of Service and Dwolla Privacy Policy. Funds held in or transferred through a Dwolla account are held or transferred by Dwolla's financial institution partners as described in the Dwolla terms.

You authorize WILLPORT to collect and share with Dwolla information required to provide the requested service, which may include your full name, date of birth, Social Security number, physical address, email address, and financial information. You are responsible for the accuracy and completeness of that information. You access and manage the Dwolla account through the WILLPORT application. WILLPORT provides customer support and required notifications for your Dwolla-enabled account activity unless a disclosure presented to you states otherwise.

When an open-banking or bank-linking provider is used, that provider may access financial-account information under a separate authorization and its own terms and privacy policy. Review the notice presented during the bank-linking flow before connecting an account.

6. Cookies, Analytics, Advertising, and Privacy Choices

We and third parties may use cookies, SDKs, pixels, tags, and similar technologies to provide functionality, remember preferences, measure performance, prevent fraud, analyze usage, and support advertising or marketing.

Some uses of advertising or analytics technology may be considered a "sale," "sharing," or processing for "targeted advertising" under certain U.S. state privacy laws even when no money is exchanged. We do not sell personal information for money. Where required by law, you may opt out of sale, sharing, or targeted advertising by:

  • emailing service@willport.com with "Privacy Opt-Out" in the subject line;
  • enabling a legally recognized browser-based opt-out preference signal, such as Global Privacy Control; or
  • adjusting available cookie or device privacy settings.

We process recognized opt-out preference signals as required by applicable law. Your choice may apply only to the browser or device from which you submit it unless you are logged into your account or otherwise identify yourself.

You can also manage cookies through your browser and mobile permissions through your device settings. Blocking technologies may affect Service functionality.

7. AI-Assisted Features

AI Greeting Cards and OpenAI

WILLPORT's AI Greeting Cards feature uses an application programming interface provided by OpenAI OpCo, LLC and its subprocessors (collectively, "OpenAI") to generate images.

When you choose Generate, you direct WILLPORT to transmit the following information to OpenAI:

  • the text prompt, description, or instructions you enter;
  • any reference image or other content you choose to submit, if the feature allows such submissions; and
  • technical request information reasonably necessary to deliver, secure, troubleshoot, and monitor the generation request.

OpenAI processes this information to generate and return the requested image, operate and secure its API services, enforce applicable usage policies, prevent fraud or abuse, and comply with law. The generated image is returned to WILLPORT so that it can be displayed, saved, sent, or otherwise used through the greeting-card feature at your direction.

Under OpenAI's current business terms and API data controls, OpenAI does not use API inputs or outputs to train or improve its models by default unless the API customer explicitly opts in. OpenAI states that its default abuse-monitoring logs may contain prompts, generated outputs, and related metadata and may generally be retained for up to 30 days, unless a different approved data-retention control applies or longer retention is legally required. OpenAI's practices are described in its Services Agreement, Business Data Privacy materials, and API Data Controls documentation.

WILLPORT does not opt in to allow OpenAI to use AI Greeting Cards API inputs or outputs to train or improve OpenAI models. If this practice changes, WILLPORT will update this Privacy Policy and provide any additional notice or obtain any consent required by law.

OpenAI is not the recipient of the completed greeting card unless you use the AI-generation feature. OpenAI does not receive your WILLPORT contacts list, financial-account information, Social Security number, or payment credentials from this feature unless you independently place such information in a prompt or uploaded item. Do not do so.

Do not include Social Security numbers, financial-account credentials, government identification numbers, health information, confidential professional information, or other sensitive personal information in AI prompts unless a feature expressly requests it through a secure flow.

You must have the necessary rights and permissions to submit any name, likeness, photograph, logo, artwork, trademark, or other content. AI-generated images may be inaccurate, non-unique, inappropriate, or similar to content generated for others. Automated safety systems may reject or modify a request.

8. Identity Verification and Biometric Information

Certain financial or security features may require identity verification. WILLPORT and/or an identity-verification provider may collect a government identification document, selfie, video, liveness information, or a scan or measurement derived from a face or other biometric characteristic. This information is used to verify identity, prevent fraud, protect accounts, and comply with law.

Where required, we will provide a separate notice and obtain consent before collecting or disclosing biometric identifiers or biometric information. We do not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information.

To the extent WILLPORT possesses biometric identifiers or biometric information covered by the Illinois Biometric Information Privacy Act, WILLPORT will permanently destroy that information when the initial purpose for collecting it has been satisfied or within three years after the individual's last interaction with WILLPORT, whichever occurs first, unless a longer retention period is required by a valid warrant, subpoena, court order, or applicable law. WILLPORT will use a reasonable standard of care and protections that are the same as or more protective than those used for other confidential and sensitive information.

Device biometric features, such as Face ID, Touch ID, or Android biometric authentication, are provided and controlled by your device and operating-system provider under that provider's terms. This is separate from the identity-verification process described above.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing the Services, maintaining transaction and tax records, meeting anti-money-laundering and identity-verification requirements, resolving disputes, enforcing agreements, preventing fraud, and complying with law.

Retention depends on the type of information and the context in which it was collected. We consider:

  • how long you maintain an account or continue to use the Services;
  • the time needed to complete a transaction or requested service;
  • legal, contractual, audit, accounting, and regulatory requirements;
  • fraud-prevention, security, backup, and business-continuity needs; and
  • applicable limitation periods and actual or anticipated disputes.

When retention is no longer necessary, we delete or de-identify information, subject to limited backup, legal-hold, and security exceptions. Third-party financial institutions and other independent parties apply their own retention requirements.

10. Security

We use administrative, technical, and physical safeguards designed to protect personal information, taking into account its sensitivity and the risks involved. No security measure or transmission method is completely secure, and we cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your credentials, securing your devices, and promptly notifying us of suspected unauthorized account activity. Use unique credentials and enable available account-security features.

11. Your Choices and Privacy Rights

Depending on where you live and subject to legal exceptions, you may have the right to:

  • know or access the personal information we process about you;
  • confirm whether we process your personal information;
  • correct inaccurate personal information;
  • delete personal information;
  • receive a portable copy of certain personal information;
  • opt out of sale, sharing, targeted advertising, or certain profiling;
  • limit certain uses and disclosures of sensitive personal information;
  • withdraw consent where processing is based on consent;
  • appeal a decision concerning a privacy request; and
  • receive equal service and pricing without unlawful discrimination for exercising privacy rights.

You may submit a request by:

  • emailing service@willport.com.

Describe the right you want to exercise and provide enough information for us to locate your records. We will verify your identity using information reasonably related to your request and the sensitivity of the information involved. We may deny or limit a request where permitted by law, including when we cannot verify identity, an exception applies, or fulfillment would adversely affect another person's rights.

An authorized agent may submit a request where permitted by law. We may require proof of authorization and may separately verify your identity. To appeal a decision, reply to our response or email service@willport.com with "Privacy Appeal" in the subject line.

You may update certain account information, permissions, and communication preferences through the app or device settings. To stop marketing email, use the unsubscribe link. To stop marketing text messages, reply STOP. Transactional or security messages may still be sent where permitted by law.

Nevada Residents

Nevada residents may submit a verified request directing us not to make a sale of covered information as defined by Nevada law. Submit the request to service@willport.com with "Nevada Opt-Out" in the subject line.

California Residents

If the California Consumer Privacy Act, as amended ("CCPA"), applies to WILLPORT's processing, California residents may exercise the rights described above. For CCPA purposes:

  • We collect the categories of personal information described in Section 2.
  • We collect that information from the sources described in Section 2.C.
  • We use it for the business and commercial purposes described in Section 3.
  • We disclose it to the categories of recipients described in Section 4.
  • In the preceding 12 months, we may have "shared" identifiers, commercial information, internet or electronic-network activity, approximate geolocation, and inferences with analytics or advertising partners. We do not knowingly sell or share the personal information of consumers under 16.
  • We may disclose identifiers, customer-record information, protected-classification characteristics, commercial information, biometric information, internet activity, geolocation, audio/visual content, professional information, sensitive personal information, and inferences for business purposes to service providers, contractors, financial partners, merchants, professional partners, government authorities, and parties to corporate transactions, depending on the Services used.
  • We use and disclose sensitive personal information only for permitted purposes or as otherwise disclosed at collection. If our use becomes subject to the CCPA right to limit, we will provide the required method to exercise that right.

WILLPORT does not offer financial incentives or price differences in exchange for personal information unless separate terms and a notice of financial incentive are presented.

12. Children's Privacy

The Services are not directed to children under 13, and we do not knowingly collect personal information online from a child under 13 without legally valid parental consent. If you believe a child under 13 has provided personal information, contact service@willport.com.

Financial accounts and money-transfer features are available only to eligible adults, as stated in the applicable service terms. Other features may have additional age limits. We do not knowingly sell or share the personal information of a consumer under 16 for cross-context behavioral advertising.

13. International Use

The Services are primarily offered in the United States. If you access the Services from another country, your information may be processed in the United States and other locations where we or our providers operate. Those locations may have data-protection laws different from the laws where you live. International-transfer services may involve providers and recipients in other countries and are subject to separate disclosures and applicable law.

14. Third-Party Services and Links

The Services may link to or integrate with third-party services. Their privacy practices are governed by their own notices, not this Privacy Policy. Review those notices before providing personal information. A link or integration does not mean WILLPORT controls or endorses the third party's privacy practices.

15. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in the Services, technology, law, or our practices. We will post the updated policy with a revised effective date. If a change is material, we will provide additional notice as required by law, such as through the app, website, email, or another appropriate method. We will obtain consent where required.

16. Contact Us

For privacy questions, requests, or complaints, contact:

WILLPORT Holdings, Inc.

Attn: Privacy

1645 Village Center Circle, Suite 200

Las Vegas, Nevada 89134

Email: service@willport.com

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