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 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 the 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 We Collect Automatically When You Use the Services: When you access or use our Services, we may 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 may automatically collect and store certain information in server logs. This includes:

  • Details of how you used our service,
  • Order information,
  • Internet protocol addresses,
  • 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 and the location of your order. 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 aircraft use cameras to assist them in the delivery process, analyze any issues and improve our control and guidance systems. When you use our services, the cameras on the Wing Aircraft may indirectly capture black-and-white overhead images of you when completing the delivery process. We may associate this data 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 partners may be associated with your Wing customer account. When information is associated with your Wing customer account, we treat it as personal 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 terms of the payment processor’s privacy policy. 

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. 

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 of our 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, 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. 

We will ask for your consent before using the information for a purpose other than those related to the purposes set out in this Privacy Policy.

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.

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.

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.
• 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.

In some cases, the organizations that we share your information with may be based overseas. For example, we may share your information with third parties in the United States. 

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.

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. We may therefore store and process your personal information on servers outside the country where you live. 

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 all 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. 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.

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.