Effective Date: 5 November 2018

Our Privacy Policy explains:

• What information we collect and how.
• Why we collect it.
• How we store, use and share that information.
• The choices we offer, including how to access and update information.
• How you can make a complaint if you are concerned about your privacy.

This Privacy Policy applies to information Wing Aviation LLC and its subsidiaries (“Wing”) collect when you use our websites and other products and services that link to this Privacy Policy (collectively, the "Services"). We may supply a different privacy policy in relation to some of our Services, and that the policy will apply to any information provided to or collected by us pursuant to those Services.

A Google Account may be required to use some of Wing’s services. Where a Google Account is required, Wing will have access to information associated with your Google Account, and Wing’s use of that information will be governed by this Privacy Policy.

Information we collect.

We collect information to provide better services to all our users.  We collect information in the following ways:

• Information You Provide to Us:  We collect information you provide directly to us.  For example, we collect information when you participate in any interactive features of the Services, fill out a form, provide feedback, participate in a contest or promotion, communicate with us via third party sites, request customer support, or otherwise communicate with us.  The types of information we may collect include your name, email address, postal address, phone number, delivery information and any other information you choose to provide.
• Information in Your Google Account: Where you use Wing’s services using your Google Account, we will have access to certain information associated with your Google Account. 
• Information We Collect Automatically When You Use the Services:  When you access or use our Services, we automatically collect certain information, including:

• Device information: We collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your Wing user account.
• Log information: When you use our services or view content provided by Wing, we automatically collect and store certain information in server logs. This includes:
• Details of how you used our service.
• Order information.
• Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL. 
• Cookies that may uniquely identify your browser or your Wing customer account.
• Location information: When you use our services, we may collect and process information about your actual location, the location of the Wing aircraft, the location of your order, and the delivery location. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers.
• Unique application numbers: Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to Wing when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.
• Cookies and similar technologies: We and our partners use various technologies to collect and store information when you use our Services or visit our website, and this may include using cookies or similar technologies to identify your browser or device.
• Images:  Our Wing aircrafts use cameras to confirm terrain data, improve our control and guidance systems, and for safety purposes.  When you use our services, the cameras on the Wing Aircraft may incidentally capture black-and-white overhead images of you when completing the delivery process.  These images may be associated with your Wing account. 

• Information We Collect From Other Sources:  We may also obtain information from other sources and combine that with the information we collect through our Services. For example, we may collect information about you from third parties, including but not limited to identity verification services and publicly available sources. Information we obtain about you from merchant partners may be associated with your Wing customer account. When information is associated with your Wing customer account, we treat it as personal information. 

Payment information.

In order to use the Services, you will need to provide your credit card information directly to our third party payment processor.  This information will be governed by the payment processor’s privacy policy and terms of service.   

How we use the information we collect.

We use the information we collect to provide, maintain, protect, promote and improve our Services, to develop new ones, and to protect Wing and our users. 

We may use the information we collect to help us solve any issues you might be facing with the Wing services. 

We may use the information we collect  to inform you about our services, for example, letting you know about upcoming changes or improvements.

We use the information collected to improve your user experience and the overall quality and safety of our services, to improve navigation and to inform the development of new features or services. 

We may also use the information we collect to:

• Comply with any applicable law, regulation, legal process or enforceable governmental request.
• Enforce applicable terms of service, including investigation of potential violations.
• Detect, investigate, prevent, or otherwise address safety, fraud, security or technical issues.
• Protect against harm to the rights, property or safety of Wing, our users or the public as required or permitted by law.  

Legal basis for processing your personal information.

If EU data protection law applies to our processing of your personal information, it is important that you know the lawful basis on which we process your personal information. 

We rely on the following legal basis, under EU data protection law, to process your personal data: 

Where it is necessary to perform our contract with you to provide the Services. 

Where we have obtained your consent, for example to action a request from you or respond to your specific query. You can withdraw your consent at any time, but we may still need to retain a record of your correspondence with us. 

Where it is necessary for the purposes of our legitimate interests, including: 

• Providing, maintaining, and protecting our services to meet the needs of our users
• Developing new products and features
• Detecting, preventing, and otherwise addressing fraud, abuse, security, safety and technical issues with our service
• Protecting against harm to the rights, property or safety of Wing, our users or the public as required or permitted by law
• Performing research that improves our services for our users and benefits the public
• Enforcing legal claims, including investigation of potential violations of applicable Terms of Service

Where it is necessary to comply with a legal obligation, for example under anti-money laundering or anti-bribery legislation.

Accessing and updating your personal information.

People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how you interact with our Services. You can also review and update your Wing activity record to decide what types of data you would like saved with your account when you use our Services. 

Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly.  In some circumstances you may alternatively be able to delete it – unless we have to keep that information for legitimate business or legal purposes. If EU data protection law applies to our processing of your personal information, you also have the right to object to the processing of your information or export your information to another service.

We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

You may request access to the information we hold about you or request correction of that information by sending a written request to wing-privacy@wing.com.

Information we share.

We do not share personal information with companies, organizations and individuals outside of Wing unless one of the following circumstances applies:

• With your consent: We will share personal information with companies, organizations or individuals outside of Wing when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.
• To related companies in our group:  Wing may share personal information with its affiliates (other companies in our group of companies).
• For external processing: We provide personal information to our affiliates or other trusted businesses or persons to process it for us based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.
• For legal reasons: We will share personal information with companies, organizations or individuals outside of Wing if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
• Comply with any applicable law, regulation, legal process or enforceable governmental request.
• Enforce applicable terms of service, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of Wing, our users or the public as required or permitted by law.
• Obtain legal advice.

In some cases, the organizations that we share your information with will be based outside the country where you live or access the Services. For example, we may share your information with third parties in the United States. See below for more information about where your data may be stored and accessed. 

We may share non-personally identifiable information publicly and with our partners. For example, we may share this information publicly to show trends about the general use of our services, or we may share Wing aircraft location data for the purpose of unmanned traffic management services.

We may share your personal information in connection with a merger, acquisition, or sale of Wing’s assets. We will take reasonable steps to ensure that your personal information continues to be subject to the same protections set out in this Privacy Policy.

Information storage and security.

We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage and application data caches.  Wing also stores personal information on our servers in many countries around the world, including the United States. It is therefore highly likely we will store and process your personal information on servers outside the country where you live. Data protection laws vary among countries, with some providing more protection than others. The laws of some countries may provide a lower standard of protection than under the laws of your country.  

We work hard to protect Wing and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:

• We encrypt many of our services using SSL.
• We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
• We restrict access to personal information to Wing employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

When this Privacy Policy applies.

Our Privacy Policy applies to information collected by Wing in relation to the Services.  Our Privacy Policy does not apply to services or products offered by other companies or individuals, including companies you may transact with through our services.

Compliance, complaints and cooperation with regulatory authorities.

We regularly review our compliance with our Privacy Policy. We also adhere to several self regulatory frameworks. 

If you wish to make a complaint about how we have handled your personal information, you may do so by writing to wing-privacy@wing.com. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly. You can also contact your local data protection authority if you have concerns regarding your rights under local law.

Retention and deletion.

We retain personal information for as long as necessary for legitimate business or legal purposes. Sometimes business or legal requirements oblige us to retain certain information for extended periods of time. Reasons we might retain some data for longer periods of time include:

• Security, safety, fraud & abuse prevention, detection and resolution
• Financial records keeping
• Complying with legal or regulatory requirements
• Ensuring continuity and safety of our services
• If you communicate directly with Wing

We try to ensure that our services protect information from accidental or malicious deletion. Because of this, there may be delays between when you delete something and when copies are deleted from our active and backup systems. You can submit a deletion request by contacting wing-privacy@wing.com.

We also keep information which will help us improve our services, and conduct further research and product development. Wherever possible, we avoid retaining personal information for this purpose.   

Changes to this privacy policy.

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification).  We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

Contacting us.

If you have any questions about this Privacy Policy or any requests concerning your personal information, please contact us at wing-privacy@wing.com.