Privacy Policy & GDPR

Effective Date: 1 August 2023

Wing AI Technologies, Inc. (“Wing,” “we,” “us,” or “our”) is committed to protecting the privacy and security of your personal data. This GDPR-focused privacy policy (“Privacy Policy”) explains how we collect, use, disclose, and otherwise process your personal data when you use or access our websites (including wingassistant.com or getwingapp.com), our mobile applications (including but not limited to the Wing Customer application and Wing Fulfiller application) (“Application”), or any other services we offer now or in the future (collectively, the “Services”).

This Privacy Policy has been prepared in accordance with the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and other applicable European data protection laws. It supplements any other notices or statements we may provide to you.

1. Topics

What data do we collect?
How do we collect your data?
Legal bases for processing personal data
How will we use your data?
How do we store your data?
International data transfers
Marketing
What are your data protection rights?
Cookies and similar technologies
Privacy policies of other websites
Retention of personal data
Data security measures
Children’s privacy
Changes to our privacy policy
How to contact us
How to contact the appropriate authorities

2. What data do we collect? Wing collects various types of personal data (i.e., information relating to an identified or identifiable individual). The categories of data we collect include:

Identifiers: Such as name, email address, phone number, home address, and (if you register with a social account) basic profile information (e.g., name, gender, profile photo).
Profile Information: Any information you choose to include on your Wing Profile, such as fun facts, business profile, or other data you choose to share.
Payment Information: Credit card details, bank routing numbers, and other financial information necessary to process payments. (Note that we often rely on third-party payment processors and do not store full credit card numbers ourselves.)
Fulfiller or Contracted Company Related Information: For those who sign up as Contracted Companies or Fulfillers (independent contractors and businesses), additional details such as date of birth, Social Security Number (or equivalent national identification), licensing information, and background check information (depending on jurisdiction).
Location Information: Precise or approximate location data when using our Applications, including labeled addresses like “home” or “work.”
Device Information: IP address, device identifiers, browser type, operating system, mobile advertising identifiers, and similar technical data.
Usage Information: Pages or content viewed, interactions with our App, features used, dates and times of visits, call and text logs facilitated through our Services, and feedback or reviews you provide.
Communications: The content of any communications with us (emails, calls, chat messages, support inquiries).

We may also collect aggregated or de-identified information that cannot reasonably be used to identify you.

3. How do we collect your data?

We collect personal data from and about you in the following ways:

Directly from you
- When you book a demo or consultation with our experts or sales team
- When you interact with our website’s chatbot
- When you sign up for a Wing account or create a profile
- When you voluntarily provide information (e.g., completing surveys, using our chat feature, sending emails)
- When you add a payment method
- When you share business entity information (for Business Profiles)
- When Fulfillers and Contracted Companies provide additional data, including licensing and background check details
Automatically or indirectly
- Through the use of cookies and similar technologies (see section on Cookies below)
- Via your device: location data, IP address, operating system, and other technical information
From third parties
- If you sign up using your Google or Facebook or other social media account
- From third-party providers (e.g., background check services, payment processors, analytics services)
- From enterprise or partner organizations (e.g., if your employer has an arrangement with Wing)

4. Legal bases for processing personal data

Under the GDPR, we rely on the following legal bases to process your personal data:

Contractual Necessity: We process data necessary to provide you with our Services or fulfill contractual obligations (e.g., managing your account, enabling tasks between Users and Fulfillers).
Legitimate Interests: We process your data for our legitimate interests, including improving our Services, preventing fraud, maintaining security, and marketing (unless these interests are overridden by your data protection interests or fundamental rights and freedoms).
Consent: Where required by law, we rely on your consent (e.g., sending certain marketing communications or processing sensitive personal data). You can withdraw your consent at any time.
Legal Obligations: We may process data to comply with applicable legal or regulatory requirements.

5. How will we use your data?

Wing collects and processes your personal data to:

Provide and maintain the Services
Match Users and Contracted Companies, and Fulfillers, coordinate service details, and facilitate payments
Improve and develop the Services
Analyze usage, troubleshoot, and make data-driven improvements
Communicate with you
- Send transactional messages (e.g., confirmations, billing notices)
- Send marketing and promotional materials (where legally permissible)
Personalize user experience
- Provide tailored content, recommendations, and features
Protect the Wing community and the public
- Prevent fraud, detect potential threats, verify identities, and run background checks (for Contracted Companies and Fulfillers)
Comply with legal requirements
- Respond to lawful requests, enforce our Terms of Service, and cooperate with authorities

Business Data Sharing: Wing shares your data with trusted partners to provide and improve our Services. Examples include:

Payment Processors: To process payments and prevent fraud (e.g., Stripe or PayPal).
Analytics Providers: To analyze usage and improve performance (e.g., Google Analytics).
Insurance Partners: To manage claims or assess coverage.
Background Check Services: For Fulfillers, we share necessary data with partners for identity verification and compliance purposes.
Enterprise Clients: If you use Wing through an enterprise program, we may share information (e.g., usage data, service details) with your organization.

6. How do we store your data?

We store your personal data on secured servers located in the United States (or other jurisdictions where we or our service providers operate). We take steps to ensure that these servers and our practices meet applicable data protection standards.

7. International data transfers

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, your personal data may be transferred to and processed in countries outside of your home jurisdiction, including the United States. In doing so, we will ensure that adequate safeguards are in place (e.g., Standard Contractual Clauses or another valid transfer mechanism) as required under GDPR and other applicable laws, so that your personal data remains protected.

Safeguards for Data Transfers: Wing transfers personal data to countries outside the EU/EEA (e.g., the United States) under appropriate safeguards, including:

Standard Contractual Clauses (SCCs) approved by the European Commission.
Adequacy decisions for countries deemed to provide equivalent protection to GDPR. For more details on these safeguards, contact us at [email protected].

8. Marketing

Where legally permitted, Wing would like to send you information about products, services, promotions, and other updates we believe may interest you. We may also share your data (where you have consented or we otherwise have a lawful basis) with our partners for their marketing activities.

Marketing Communications: Wing relies on your consent to send marketing communications. During account registration or later, you can opt in to receive updates and promotional material. You can withdraw your consent anytime by:

Clicking “unsubscribe” in any marketing email.
Adjusting your preferences in the “Settings” section of our Applications.

Note: Withdrawing consent will not affect transactional or service-related communications.

9. What are your data protection rights?

Wing respects your privacy rights and ensures you can exercise the following rights under the GDPR:

Right to Access: You have the right to request copies of your personal data.
Right to Rectification: You have the right to request that we correct information you believe is inaccurate or incomplete.
Right to Erasure (“Right to be Forgotten”): You have the right to request that we erase your personal data, under certain conditions.
Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
Right to Object to Processing: You have the right to object to the processing of your personal data, under certain conditions (e.g., direct marketing).
Right to Data Portability: You have the right to request that we transfer the data we have collected to you or another organization, under certain conditions.

We will respond to valid requests within one month, unless the complexity or volume of requests requires an extension. To exercise your rights, please see How to contact us.

Managing Your Preferences: Wing allows you to manage how your data is used:

Push Notifications: Disable push notifications via your device settings or within the Application.
Location Tracking: Turn off location sharing through your device settings. Note that some features may not function without location data.
Mutual Friends Visibility: Adjust visibility settings for mutual friends in your Wing profile settings.
Cookie Preferences: Modify or withdraw consent for cookies and tracking technologies via the “Cookie Settings” page on our website.

10. Cookies and similar technologies

10.1 What are cookies?

Cookies are small text files placed on your device to collect standard internet log information and visitor behavior information. We also use similar technologies like web beacons and SDKs for mobile apps.

10.2 How do we use cookies? Wing uses cookies to:

Keep you signed in
Understand how you use our website and Services
Provide, improve, and secure our Services
Analyze user behavior for marketing/advertising purposes (e.g., Google Ads, Facebook Pixel)

Behavioral Tracking and Advertising: Wing uses tools like Google Ads, Facebook Pixel, and other third-party technologies to track user behavior and provide tailored advertising. These tools may collect information such as browsing history, interactions with our website, and device identifiers. Before enabling these technologies, Wing obtains your explicit consent through a cookie banner or similar mechanism.

10.3 What types of cookies do we use?

Essential / Functional Cookies: Required to provide the Services.
Analytics / Performance Cookies: Track usage to improve performance and user experience.
Advertising Cookies: Collect information about your browsing activities so we can show you relevant ads on other sites.

You can learn more about the types of Cookies Wing uses by referring to our Cookie Policy (EU)

10.4 How to manage cookies

You can set your browser not to accept cookies and remove cookies from your browser. However, some features of our Services may not function properly as a result. For more information, visit allaboutcookies.org. You may manage your cookie preferences through the website’s cookie banner.

11. Privacy policies of other websites Our Services may contain links to third-party websites, plug-ins, and applications. This Privacy Policy applies only to Wing’s Services. When you click on links to other websites, you should read their privacy policies. We are not responsible for the data processing practices or content of such third-party services.

12. Retention of personal data

We keep your personal data only as long as is necessary for the purposes described in this Privacy Policy or to comply with applicable legal, accounting, or reporting obligations. Specific retention periods include:

User Accounts: Retained for the duration of your account. Data is deleted within 2 years of account termination, for the purposes of fraud prevention and legal compliance, unless explicitly requested by you, or required for legal purposes.
Payment Information: Retained for up to 7 years to comply with financial recordkeeping requirements.
Communications: Retained for 5 years to address user inquiries and disputes.

Exceptions may apply for legal disputes, fraud prevention, or compliance with regulatory requirements.

13. Data security measures

We use various administrative, technical, and physical security measures to protect your personal data against unauthorized access, disclosure, or destruction. These measures include:

Encrypted transmission of sensitive data via Secure Socket Layer (SSL)
Limiting access to personal data to authorized personnel with a legitimate need
Regular security assessments and updates
Malware scanning to prevent unauthorized access

While we strive to protect your data, no security system is impenetrable. If you have questions about our security, please contact us using the details below.

Breach Notification: In the event of a personal data breach, Wing will notify affected users without undue delay and, where required by law, notify the relevant supervisory authority within 72 hours of becoming aware of the breach. Notifications will include the nature of the breach, affected data categories, potential consequences, and steps Wing is taking to mitigate risks. Users will be informed via email or through the Services.

14. Children’s privacy

Our Services are not directed to individuals under the age of 16, and we do not knowingly process personal data from children. If you learn that a minor has provided us with personal data without proper parental consent, please contact us, and we will take steps to remove such data.

Handling Unauthorized Minor Accounts: If we discover that a minor has created an account without proper parental consent, we will:

Suspend the account immediately.
Notify the parent or guardian (if identifiable).
Delete all associated data unless required by law to retain it.

15. Changes to our privacy policy

Wing keeps this Privacy Policy under regular review. We may update it from time to time in response to changing legal, technical, or business developments. Any changes will be posted on this page with an updated effective date. Where required by applicable law, we will notify you via email or through the Services.

16. How to contact us

If you have questions about Wing’s privacy practices, the data we hold on you, or you would like to exercise any of your data protection rights, please reach out to:

Email: [email protected]
Phone: +1 (855) 805-8057
Mail: Wing Assistant Attn: Martin Gomez, COO
2150 Shattuck Ave Berkeley, CA 94704 United States

If you would like to exercise your rights as they relate to making a Data Request, you may do so by using this form: https://forms.gle/jTWKXftaJH8kfbqZ7

For any questions or accessibility concerns, please contact us at [email protected].

Contacting Supervisory Authorities: If you have concerns about how we handle your personal data, you have the right to lodge a complaint with your local supervisory authority.