Privacy Policy

This Privacy Policy describes how Klugo App, LLC ("Company", "we", "us", or "our") collects, uses, processes, and discloses information in connection with your access to and use of the Klugo application, website, and related services (the "App").

Klugo is a personal finance education product. It provides interactive lessons, quizzes, and progress tracking. It does not provide financial, investment, tax, or legal advice, and it does not connect to, access, or aggregate your bank accounts, brokerage accounts, or other financial accounts.

This Privacy Policy is separate from the Terms of Service and governs data handling practices only. By using the App, you acknowledge that you have read and understood this Privacy Policy.

2.1 Personal Information

We may collect personal information ("Personal Information") that you voluntarily provide or that is generated through your use of the App, including but not limited to:

• Account identifiers (email address)
• Profile information and onboarding responses (e.g., display name, learning goals, experience level)
• Display name and avatar selection, which may be visible to other users (see Section 6)
• Authentication and security data, including identifiers provided by third-party sign-in providers (Google, Apple)
• Referral information, including whether you were referred by another user or referred others
• Communications with support

2.2 Learning & Progress Data

The App collects data generated as you use it, including:

• Lesson and unit completion, quiz answers, and accuracy
• Experience points (XP), streaks, in-app currency balances, hints used, and achievements
• Session timing and frequency of use

This data is collected to operate core features of the App, including progress tracking, streaks, leaderboards, and personalized lesson sequencing.

2.3 Non-Personal & Derived Information

We also collect non-personal information and derived data, including:

• Usage data, interaction logs, and feature engagement
• Device, browser, operating system, and technical metadata
• Aggregated analytics and performance metrics
• Advertising identifiers, where permitted (see Section 7)

2.4 Self-Reported Information & Accuracy

Certain information collected by the App is self-reported by users, including stated goals, experience level, and onboarding responses. We do not independently verify the accuracy, completeness, or truthfulness of user-provided information.

All content, lessons, examples, figures, and outputs provided through the App are for general educational and informational purposes only. They do not constitute financial, investment, tax, accounting, or legal advice, and are not a recommendation to buy, sell, or hold any security or financial product.

We are not a registered investment adviser, broker-dealer, tax adviser, or financial planner, and no fiduciary or advisory relationship is created by your use of the App. Content is general in nature and does not account for your individual circumstances, objectives, or risk tolerance. You should consult a qualified professional before making financial decisions.

We do not store full payment card details. Payments, subscriptions, recurring billing, auto-renewals, and related transactions are processed by third-party payment processors.

Purchases made on the web are processed by Stripe. Purchases made within the iOS application are processed by Apple through in-app purchase and managed via our subscription infrastructure provider. Billing information such as subscription status, plan type, entitlement state, and payment timestamps may be stored for account management, compliance, and support purposes.

All billing terms, refunds, cancellations, and payment disputes are governed by the Terms of Service and, for in-app purchases, by the applicable app store's policies.

We use collected information to:

• Provide, operate, and maintain the App
• Track learning progress, streaks, XP, and achievements
• Operate leaderboards, leagues, challenges, and social features
• Authenticate users and prevent fraud or abuse
• Process subscriptions and manage account and entitlement status
• Operate referral and rewards programs
• Send transactional messages and, where permitted, engagement reminders and notifications (see Section 8)
• Serve and measure advertising, where applicable (see Section 7)
• Improve functionality, content, performance, and security
• Comply with legal obligations

Certain information is visible to other users of the App by design. This may include your display name, avatar, league placement, XP totals, streak length, and other progress indicators shown on leaderboards, challenges, or similar social features.

Do not use a display name that reveals information you do not wish to share publicly. Your email address is not displayed to other users.

The App may display advertising, including to users on free plans. Advertising may be served by third-party advertising partners who may collect or receive device identifiers, approximate location, and usage information in order to serve and measure ads.

On iOS, we request permission before accessing the device advertising identifier where required by Apple's App Tracking Transparency framework. You may decline, and you may change this preference in your device settings at any time. Where available, users may also opt out of personalized advertising through device-level or platform-level controls.

We do not sell personal information. Depending on your jurisdiction, certain advertising activity may be considered "sharing" for cross-context behavioral advertising; where applicable, you may exercise the rights described in Section 12.

We may send transactional messages necessary to operate your account, such as authentication, receipts, and service notices. You cannot opt out of essential transactional messages while maintaining an account.

We may also send engagement communications, such as streak reminders, lesson nudges, and product updates. These are optional. Every marketing or engagement email includes an unsubscribe link, and you may opt out at any time without affecting your ability to use the App.

Where you enable push notifications, we store a device push token in order to deliver them. You may disable push notifications at any time in your device settings or in the App.

Our website uses cookies and similar technologies for authentication and session management, referral attribution, preference storage, and analytics.

Referral cookies record that you arrived through another user's referral link so that credit can be attributed correctly. You may control or delete cookies through your browser settings, though disabling certain cookies may affect App functionality.

We use trusted third-party service providers to support App functionality. These providers may process data on our behalf solely to perform services for us and subject to their own privacy and security obligations.

Our vendors may include, without limitation:

• Cloud infrastructure and database providers (e.g., Supabase)
• Hosting and deployment providers (e.g., Vercel)
• Authentication providers (e.g., Google, Apple)
• Payment and subscription providers (e.g., Stripe, Apple, RevenueCat)
• Email delivery providers (e.g., Resend)
• Push notification delivery providers (e.g., Expo, Apple Push Notification service)
• Analytics and advertising providers

We do not control third-party vendors' internal practices. You are responsible for reviewing their respective privacy policies.

We do not sell personal data. We may share information:

• With service providers for operational purposes
• With other users, to the limited extent described in Section 6
• To comply with legal obligations or lawful requests
• To protect rights, safety, or prevent fraud
• In connection with a corporate transaction or restructuring

12.1 GDPR (EEA / UK)

If you are located in the European Economic Area or United Kingdom, you may have rights to access, correct, delete, restrict, or object to processing of your personal data, as well as data portability rights.

12.2 CCPA / CPRA (California)

California residents may have the right to request disclosure, access, deletion, or correction of personal information collected about them, and to opt out of the sale or sharing of personal information for cross-context behavioral advertising. We do not sell personal information.

12.3 Account Deletion

You may delete your account from within the App. Deleting your account removes your profile and associated learning data, subject to the retention exceptions described in Section 13.

12.4 Exercising Rights

Requests may be submitted by contacting support. We may require identity verification before fulfilling requests.

We retain data only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal requirements, resolve disputes, and enforce agreements. Certain data may be retained where required to comply with legal obligations, resolve disputes, enforce agreements, or maintain security and fraud prevention records. Users may request deletion of their account and associated personal data, subject to applicable legal and operational retention requirements.

We implement reasonable administrative, technical, and organizational safeguards to protect data. However, no system is completely secure, and we cannot guarantee absolute security.

The App is not directed to and is not intended for individuals under 18. We do not knowingly collect personal data from individuals under 18. If we become aware that we have collected personal information from a child, we will delete it promptly. If you believe a child has provided us with personal information, please contact us.

The App may contain links to third-party websites, services, or platforms. We are not responsible for the privacy practices, content, or security of third-party sites. Accessing third-party services is at your own risk.

Data may be processed and stored in the United States or other jurisdictions where our service providers operate. By using the App, you consent to such transfers.

We may update this Privacy Policy from time to time. Continued use of the App after updates constitutes acceptance of the revised policy.

For questions or requests related to this Privacy Policy, please contact: hello@klugoapp.com

Klugo App, LLC
7901 4th St N, STE 300
St. Petersburg, FL 33702
United States