WYNGO Privacy Policy

Effective date: 11 September 2026
Last updated: 11 September 2026

WYNGO d.o.o. (“WYNGO”, “we”, “us”, or “our”) provides the WYNGO mobile application and related services (the “Service”). This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data when you use the Service.

Important Notice About Calls and Meetings

WYNGO processes microphone audio and conversation content when a user activates live or practice features. This can include the voices and statements of people who do not have a WYNGO account.

Before activating WYNGO during a real call or meeting, you must tell all participants that AI-assisted listening, transcription, and analysis will take place. You must obtain consent where required and must not use WYNGO if recording, listening, transcription, or AI processing is prohibited in the relevant country, workplace, or context. WYNGO displays a participant-consent reminder before a session, but that reminder does not replace any notice, consent, or other legal requirement that applies to you or your organisation.

1. Controller and Contact Details

For individual users of the Service, the controller is:

WYNGO d.o.o.
Trg republike 5
1000 Ljubljana
Slovenia
Email: wyngo@wyngo.ai

If an organisation provides WYNGO to its personnel under a business agreement, that organisation may be the controller of employee, customer, prospect, or call-participant data and WYNGO may process that data on its behalf. The organisation’s privacy notice and its data-processing agreement with WYNGO will then also apply.

2. Personal Data We Process

Account and authentication data

An account is required to use WYNGO. We process:

first and last name;
email address;
password, stored only as a secure hash;
authentication tokens and authentication events; and
when you use Apple or Google sign-in, the provider identifier, name, email address, identity token, and email-verification status supplied through that service.

Profile and onboarding data

We process the information you enter while configuring WYNGO, including your professional role, what you sell, sales goals and challenges, self-reported sales confidence, approximate call volume, close rate, average deal value, preferred suggestion style, and personalisation settings.

Call, meeting, and practice data

When you start a live or practice session, we process:

microphone audio and transcript text;
the voices and statements of participants;
session notes, context, goals, and saved setups;
information discussed about prospects, customers, companies, products, or services;
practice scenarios, personalities, prompts, and voice selections;
AI-generated suggestions, summaries, notes, and conversation analysis;
ratings, feedback, and saved suggestions; and
selected verbatim transcript excerpts used in session analysis.

WYNGO does not use voice data to identify a person and does not intentionally infer health, biometric identity, political views, religious beliefs, trade-union membership, sexual orientation, or other special-category data. Do not use WYNGO to process such information unless you have confirmed that it is lawful and necessary and that a valid legal condition applies.

Technical, security, and usage data

We process IP addresses, User-Agent information, timestamps, session identifiers, authentication and security events, feature-usage records, AI model and token usage, audio duration or character counts used for billing, and diagnostic information that you choose to submit when requesting support.

WYNGO does not collect a device fingerprint, advertising identifier, precise location, contacts, photos, camera data, or cross-app tracking data. The application does not contain WYNGO-operated advertising, attribution, behavioural analytics, or crash-reporting SDKs.

Purchase and subscription data

Apple App Store and Google Play process mobile subscription payments. WYNGO does not receive or store complete payment-card details. We receive product identifiers, transaction and order identifiers, purchase tokens, subscription status, transaction dates, and signed transaction or purchase information needed to verify and manage subscriptions.

3. How We Use Personal Data

We process personal data to:

register, authenticate, secure, and manage accounts;
provide live transcription and real-time AI sales assistance;
generate suggestions, notes, summaries, and conversation analysis;
provide practice and coaching features;
personalise suggestions when personalisation learning is enabled;
store session history, saved setups, and saved content;
manage subscriptions, purchases, credits, and usage allowances;
respond to support requests and diagnose submitted problems;
prevent fraud, misuse, and security threats;
maintain and improve the reliability and safety of the Service; and
comply with legal obligations and establish, exercise, or defend legal claims.

WYNGO does not sell personal data or share personal data for cross-context behavioural advertising. We do not track users across third-party applications or websites for advertising.

4. Legal Bases Under the GDPR

Where the GDPR applies, we rely on these legal bases:

Processing	Legal basis
Account administration, live and practice features, transcription, AI assistance, session history, purchases, and subscriptions requested by the user	Performance of our contract with the user
Optional personalisation learning	Consent; it can be disabled and reset in the Service
Authentication security, fraud and abuse prevention, limited diagnostics, service protection, and legal claims	WYNGO’s legitimate interests in operating and protecting the Service and its users
Accounting, tax, regulatory, and legally required records	Compliance with legal obligations
Personal data relating to other participants in a call or meeting	Where permitted, the legitimate interests of WYNGO and the user in providing the requested real-time assistance, subject to a balancing assessment; consent applies where required by the relevant law or context

Using an external provider to process data for the same purpose does not create a separate GDPR legal basis. Providers acting on our behalf process data as part of the relevant activity described above and are subject to the applicable data-processing terms.

Device permissions and app-store permissions are separate from the GDPR legal bases above. WYNGO requests microphone access before using the microphone. On Apple devices, WYNGO also provides information about third-party AI and speech processing and requests permission before transmitting personal data to those providers as required by Apple’s rules.

You may withdraw consent at any time through the relevant settings or by contacting us. Withdrawal does not affect processing that took place before withdrawal. Disabling microphone access prevents live and voice features from working.

5. Audio, Transcripts, and Stored Session Content

Raw microphone audio is transmitted from the device to the WYNGO backend through an encrypted connection and streamed to the selected speech-processing or real-time voice provider. WYNGO holds the audio transiently in memory and does not write it to disk or retain it as part of the user’s account or session history.

During a live session, the WYNGO backend keeps a rolling window of recent transcript lines. A complete transcript can also be held temporarily while post-call analysis is completed. These temporary transcript records are cleared when the relevant processing finishes.

WYNGO retains session notes, goals, AI suggestions, summaries, ratings, feedback, conversation analysis, and selected verbatim excerpts until the user deletes the relevant session or account.

External providers can process or retain audio and text according to the provider endpoint, configuration, contract, and applicable legal obligations. Section 7 explains the providers and international transfers involved.

6. Artificial Intelligence and Personalisation

WYNGO uses AI to generate real-time suggestions, summaries, analysis, and synthetic voices for practice features. AI-generated output may be inaccurate, incomplete, or inappropriate and should not be treated as professional, legal, financial, or other expert advice.

WYNGO does not train its own general-purpose AI model on call audio or conversation content. For language-model requests routed through OpenRouter, WYNGO sets data_collection to deny, restricting routing to endpoints that OpenRouter identifies as not collecting user data. Direct AI, speech, and voice providers process data under their applicable business terms, configurations, and agreements.

When personalisation learning is enabled, WYNGO uses onboarding information and interactions with suggestions—including ratings, feedback, and saved suggestions—to create a preference summary for future suggestions. You can disable personalisation learning and reset the learned information in the Service.

WYNGO does not use solely automated processing to make decisions about you that produce legal or similarly significant effects.

7. Service Providers and Data Transfers

WYNGO uses the following providers for the functions shown. The provider used in a particular session depends on the selected feature, model, language, availability, and production configuration.

Function	Providers	Data processed
Speech recognition and transcription	Deepgram, Soniox, Speechmatics, Microsoft Azure, xAI, Inworld	raw audio, transcript text, language and session configuration, and technical request data
AI suggestions, summaries, and analysis	OpenRouter, OpenAI, Anthropic, Google Gemini	relevant transcript portions, notes, goals, sales context, prompts, prior suggestions, summaries, and personalisation preferences
Synthetic and real-time voice	Soniox, xAI, Inworld, Resemble AI	text to be spoken, voice configuration, raw audio for real-time voice, session instructions, and technical request data
Authentication	Apple, Google	sign-in and account-verification data
Mobile subscriptions	Apple App Store, Google Play	purchase, transaction, and subscription data
Hosting	Hetzner Online GmbH	data stored and processed by the WYNGO backend
Transactional email	WYNGO’s configured email provider	recipient address, message content, and one-time account-action links

OpenRouter is WYNGO’s primary AI gateway. For requests routed through OpenRouter, OpenRouter passes the relevant data to the model or infrastructure provider selected for the request. OpenAI, Anthropic, and Google may therefore participate in the OpenRouter processing chain or receive data directly from WYNGO when a direct API connection is used.

Provider requests can contain pseudonymous session, practice-session, or account references needed to associate the request with the correct feature. They do not intentionally include the user’s name or email address unless that information appears in content supplied or spoken by the user or another participant.

WYNGO’s backend and database are hosted on rented Hetzner infrastructure in Germany. Other providers operate globally, so personal data can be processed outside Slovenia and the EEA, including in the United States and other countries.

Where required, we use an adequacy decision, the EU-U.S. Data Privacy Framework for a participating recipient, the European Commission’s Standard Contractual Clauses, or another legally recognised transfer mechanism, together with supplementary measures where appropriate. You may contact us for information about the safeguard used for a particular transfer.

On Android, Google Play Services components used for Google sign-in can send limited service or diagnostic telemetry to Google under Google’s own terms.

8. Other Call and Meeting Participants

When a person participates in a call or meeting during which WYNGO is active, their voice and statements are processed even if they do not have a WYNGO account. Audio is sent to the selected speech provider, and transcript text and session context are sent to the selected AI provider to generate suggestions, summaries, notes, or analysis. WYNGO does not retain their raw audio, but derived session content and selected excerpts can remain in the user’s session history.

A participant can contact wyngo@wyngo.ai to ask whether WYNGO processes personal data about them and to exercise applicable rights. To locate the relevant session, we may need the name or email address of the WYNGO user or organisation and the approximate date of the call.

9. Retention

WYNGO applies the following retention rules:

account information remains until the account is deleted;
profile, onboarding, and personalisation information remains until it is reset or the account is deleted;
raw audio is not written to disk or retained by WYNGO;
live transcript lines remain only during the session, and a temporary complete transcript remains only until post-call processing finishes or ends in a final error;
session notes, goals, suggestions, summaries, analysis, feedback, and selected excerpts remain until the relevant session or account is deleted;
access-token records expire after approximately one hour and refresh-token records after approximately 30 days, unless revoked sooner;
authentication audit events and user-submitted diagnostic reports remain until manually deleted and can be retained after account deletion when needed for security, accountability, fraud prevention, or legal claims; and
transaction, subscription, and purchase-ownership records can remain after account deletion when needed for accounting, tax, fraud prevention, and transaction integrity. Purchase-ownership records retained after deletion are dissociated from the deleted user account.

Provider-side retention is governed by the endpoint configuration, provider agreement, legal obligations, and backup cycles applicable to that provider. Where required and technically available, WYNGO initiates deletion requests with providers acting on its behalf.

10. Account and Data Deletion

You can delete individual sessions through the available session controls and delete your WYNGO account through the account settings. Account deletion removes the account and account-linked profile, sessions, suggestions, feedback, and practice data from WYNGO’s active systems, subject to the limited retained records described in Section 9.

You can also request account and associated-data deletion without the app by visiting https://wyngo.ai/delete-account and following the instructions on that page. We may verify that you control the relevant account before completing the request.

Deleting a WYNGO account does not automatically cancel an Apple App Store or Google Play subscription. You must cancel the subscription through the applicable store.

11. Your Rights

Depending on applicable law, you may have the right to:

access your personal data;
correct inaccurate or incomplete data;
request deletion;
restrict or object to processing;
receive certain data in a portable format;
withdraw consent where processing is based on consent; and
lodge a complaint with a competent data-protection authority.

To exercise a right, email wyngo@wyngo.ai. We may verify your identity before responding. Rights are subject to applicable conditions and lawful exceptions.

If you are in the EEA, you may lodge a complaint with your local supervisory authority. In Slovenia, this is the Information Commissioner of the Republic of Slovenia.

12. U.S. State Privacy Rights

If you reside in a U.S. state with an applicable comprehensive privacy law, you may have additional rights, subject to the scope, thresholds, and exceptions of that law. These can include the right to confirm whether we process your personal data, access, correct, delete, or obtain a portable copy of it, and opt out of its sale, its use for targeted advertising, or certain profiling that produces legal or similarly significant effects.

WYNGO does not sell personal data or share personal data for cross-context behavioural advertising. We do not use personal data for targeted advertising or qualifying profiling as described above.

You can submit a request by emailing wyngo@wyngo.ai. Where applicable, you may use an authorised agent and may appeal our decision by replying to our response and stating that you wish to appeal. We may take reasonable steps to verify your identity or the agent’s authority. We will not discriminate against you for exercising an applicable privacy right.

13. Security

WYNGO uses technical and organisational safeguards appropriate to the data and risks involved. These include encrypted HTTPS/WSS transport, hashed passwords and server-side authentication tokens, secure device storage for credentials, access controls, restricted administrative access, transaction-verification mechanisms, monitoring, and rate limiting.

No internet-based system is completely secure. Do not enter unnecessary sensitive or confidential information into session notes, prompts, or conversations.

14. Local Device Storage

The application uses secure device storage and local preferences for authentication, onboarding state, language, participant-consent reminders, purchase state, and application settings. These technologies support application functionality and are not used for advertising tracking.

Developer builds can store local recordings and transcript-history files when Developer Mode is enabled. Developer Mode is not intended for ordinary production use. Locally stored files remain under the device user’s control unless the user deliberately shares them or submits them to WYNGO.

15. Children’s Privacy

WYNGO is intended only for people aged 18 or older. We do not knowingly provide the Service to children or knowingly collect their personal data. If we learn that a child’s personal data has been collected contrary to this policy, we will take appropriate steps to delete it.

16. Changes to This Privacy Policy

We will update this Privacy Policy when the Service, our providers, or applicable requirements change. We will post the revised version and update the date above. If a change materially affects your rights or how we use personal data, we will provide additional notice and obtain consent where required.

17. Contact Us

For privacy questions, requests, or complaints, contact:

WYNGO d.o.o.
Trg republike 5
1000 Ljubljana
Slovenia
Email: wyngo@wyngo.ai