Wingman recognizes the importance of protecting the privacy of your personal information, and we have prepared this Privacy Policy to provide you with important information about our privacy practices. For purposes of this Privacy Policy, “Personal Information” means any information from or about a person that either identifies that person directly or that makes that person identifiable when it is combined with other information from or about that person from any source. Personal Information stops being personal information when it has been aggregated or otherwise anonymized sufficiently that the individual is no longer identified or identifiable using reasonable efforts, resources, and technology (“Anonymized Data”).

This Privacy Policy applies when (1) you use the Wingman website (the “Site”), on a computer, mobile, tablet application, or other device ; or (2) you use the Wingman sales assistant and coach product (collectively, the “Services”). It does not govern or apply to information collected or used by Wingman through other means.  For example, this Privacy Policy does not apply to the extent Wingman processes Personal Data in the role of a processor on behalf of our customers.  For detailed privacy information related to a Wingman customer who uses the Services as the controller, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers.European Economic Area (“EEA”) or Switzerland Users: please see Users in the EEA, and the United Kingdom.


This Privacy Policy covers the following:
1. Information We Collect
2. How We Use Information
3. Sharing of Information
4. Data Security
5. Children’s Privacy
6. Data Retention
7. International Transfers
8. Users in the European Economic Area (EEA) and the United Kingdom (UK)
9. Changes to Our Privacy Policy

1. Information We Collect

We may collect Personal Information about our users in various ways. For example, we may collect information that you provide to us and information that we collect automatically through your use of the Services.
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Information You Provide to Us.
We collect certain contact and professional information when you register for Wingman:
Contact information such as your name, e-mail address and phone number
Professional Information such as job title, company, and related information
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Video and Call Recordings.
We may collect audio and video recordings (through the Wingman sales assistant and coach product).  In such cases, we will request consent if required by applicable law.

Automatically Collected Information.
If you are a visitor to the Site, we may collect information on your use of the Site, such as pages visited, links clicked, text entered, and mouse movements, as well as information more commonly collected such as the referring URL, browser, operating system, and Internet Protocol (“IP”) address. We use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address. We use the term “Usage Data” to refer to this information about your use of the Site that we collect. Our purpose in collecting Usage Data is to better understand how visitors use the site.
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Additionally, we and our service providers (third party companies that work on our behalf), may use cookies, web beacons, and other tracking technologies.  For more details about how we use these technologies, and your opt-out opportunities and other options, please see our Cookie Policy.

Wingman’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. How We Use Information

To contact you.We may periodically contact you with information about the Services, such as security and fraud notices, online surveys, legal notices, news stories, new features that you are entitled to access, and other important information. You may opt out of receiving commercial email messages from us by following the instructions contained in those email messages.
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Billing, Account Management and Other Administrative Matters.
‍We may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.

‍To Comply with the Law.
‍We may use your Personal Information if we require it to comply with any applicable law, legal process or regulation, or enforceable governmental request.

‍Security.
‍We may use your Personal Information to investigate, detect, prevent, or otherwise address fraud, security, or technical issues.  Additionally, we may use information to understand and resolve technical issues, app crashes and other issues being reported.
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To Personalize, Monitor, and Improve the Services.
‍We may use your Personal Information to tailor and personalize your user experience; and monitor our Services to ensure our services are working as intended, and to make improvements.
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To Protect the Rights of the Services and others.
‍We may use your Personal Information as we believe is necessary or appropriate to secure, protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, its employees or agents, or other users and to comply with applicable law.
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Delivering the Services.
‍We use your Personal Information so that we can deliver the Services to you in an effective, efficient and accurate way. Without it we would not be able to deliver a tailored service to you or respond to issues with these Services that are identified by us or you, or ensure you get the most out of your experience.
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Internet Advertising.
‍We may use your Personal Information to facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us.
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Internal Training.
‍We may use your Personal Information to provide internal development and training to our staff to improve customer experience.
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Analytics.
We may use your Personal Information to perform data analytics (such as research, trend analysis, and financial analysis).
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Anonymized Information.
Wingman may use Anonymized Data for any business purpose.

3. Sharing of Information

The following provides information about entities with which we may share information. Our practices vary depending on the type of information.

‍Affiliates.
‍We may share information within our family of affiliated companies, parents and/or subsidiaries.
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Business Partners.
‍We may also share your information with business partners to provide you with services that you request.
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Service Providers.
‍We may share the information we collect with vendors providing contractual services to us, such as virtual computing and storage services, hosting vendors, advertising service providers, and list managers. We also may share your information, including your payment information, as appropriate, to process your payments for the Services or complete a transaction.
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Other Parties When Required by Law.
‍We may share your personal information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, our employees or agents or users or to comply with applicable law or legal process, including responding to requests from public and government authorities.
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Acquisitions or Divestitures.
‍Circumstances may arise where Wingman decides to sell, buy, divest, merge or otherwise reorganize businesses in some countries. We may disclose information we maintain about you to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, divestiture or sale of all or a portion of the Wingman’s assets.

4. Data Security

We have in place physical, technical and administrative procedures to protect the information we collect online. However, as effective as these measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet.

5. Children’s Privacy  

Our websites are not directed at children. We do not knowingly collect any personal information from children under the age of 16 without parental consent, unless permitted by law. If we learn that a child under the age of 16 has provided us with personal information, we will delete it in accordance with applicable law.

6. Data Retention

Wingman will retain Personal Information about use of our Services only as long as it is being retained to accomplish the business purpose for which it was collected and to comply with Wingman’s legal and contractual obligations.
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When you instruct Wingman to delete your Personal Information Wingman’s may (1) dispose of that information securely or (2) convert it into non-Personal Information by aggregating it, deidentifying it, or otherwise anonymizing it so that it does not directly or indirectly identify you and cannot, with reasonable efforts, resources, and technologies, be used to re-identify you.

7. International Transfers

The Services are headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Services may be collected in your country and subsequently transferred to the United States or to another country in accordance with applicable law. ‍

8. Users in the European Economic Area (EEA) and the United Kingdom (UK)

If you are a user in the EEA or the UK, the following information applies with respect to personal data collected through your use of our Services.

‍Data Controller.
‍Under the General Data Protection Regulation and other applicable data protection laws, Wingman is considered the “data controller” of the personal data we handle under this Privacy Policy. In other words, Wingman is responsible for deciding how to collect, use and disclose this information, subject to applicable law.  This Privacy Policy does not apply to personal data for which Wingman is a Processor, as defined in the GDPR and applicable data protection laws. Our contact information appears at the end of this Privacy Policy.

‍Legal Bases for Processing.
We process personal data on the following legal bases: (1) with your consent;
(2) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy; or
(3) performance of a contract: where use of your information is necessary to provide you with Services under a contract, for example the relevant Terms of Service.

‍International Transfers.
‍We will ensure that transfers of personal data to a third country or an international organization are subject to appropriate safeguards.  Wingman offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the EEA and the United Kingdom.

‍Individual Rights.
If you are a resident of the EEA or the UK, you have certain rights under Chapter 3 of the EU General Data Protection Regulation. These rights include:

• The right to request access to any personal information we hold about you (“Subject Access Request”) as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making;
  
• The right to obtain without undue delay the rectification of any inaccurate personal information we hold about you;
• The right to request that personal information held about you is deleted;
• The right to object to the processing of your personal data at any time.
• The right to restrict processing of your personal information; and
• The right to request transfer of personal information to the individual or directly to a third party where that is technically feasible (the “right to data portability”).
• The right not to be subject to a decision based solely on automated processing, including profiling.

To make a request or otherwise exercise any of these rights, you can contact us atprivacy@trywingman.com.  In order to respond to your request, we will need to verify your identity and residency and may require you to provide us with supporting information.

‍Data Protection Authority.
‍Where you believe that Wingman has not complied with its obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority.

9. Changes to Our Privacy Policy

We may modify this Privacy Policy from time to time. If we do so, we will update the “effective date” at the top.  We will notify you of changes by posting changes here, or by other appropriate means. Any changes to the Privacy Policy will become effective when the updated policy is posted.

10. Contacting Wingman

Please feel free to contact Wingman if you have any questions about this Privacy Policy or Wingman’s practices, or if you are seeking to exercise any of your statutory rights mentioned in this Privacy Policy. Wingman will respond within a reasonable timeframe. You may contact us at privacy@trywingman.com.