Privacy Policy - Global – Wing drone delivery

Effective Date: 4 November, 2022

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 to make an inquiry or complaint if you have concerns about your privacy.

This Privacy Policy applies to information Wing Aviation LLC and its subsidiaries (“Wing” “we” or “us”) collect about you when you use our websites, mobile applications and other products and services that link to this Privacy Policy (collectively, the "Services") and when you contact or otherwise interact with us. Our Services include, for example, services we provide in connection with the operation of drones, including air space-related information and drone traffic planning services (collectively, “OpenSky Services”) as well as delivery services provided by Wing’s drones, which may be fulfilled through orders submitted through our Services or other parties. Our Privacy Policy does not apply to the data practices of companies or individuals other than Wing, including companies you may transact with through our Services.

Information we collect

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. For OpenSky Services, this may include information you provide about your pilot or organizational license information (such as issue and expiration date and license number), the drone you are operating, your proposed flight destination and plan.
Information We Collect Automatically Through the Services: When you access, use or otherwise interact with our Services, we automatically collect certain information, including:
- Device Information: We collect device-specific information, such as a unique application number (if applicable to the Services you are using), your hardware model, operating system version, unique device identifiers, and mobile network information including phone number.
- Transactional Information: When you request a delivery, we collect information about the transaction, such as the items ordered, merchant details, package details (e.g., type), purchase price, date, delivery destination and other similar order details.
- Log Information: We automatically collect and store certain information in server logs. This includes: details of how you use our Services (including search terms you enter and the results), IP address, and device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
- Device Location Information: Depending on your mobile device and browser settings, we may collect information about the location of the device you use to access our Services, including precise location through our mobile app (in accordance with permission requirements of your mobile device), and your approximate location based on IP address. 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.
- Information about Your Drone and Flights: If you choose to connect your drone to a device while you are using our OpenSky Services, we may collect information about your drone, such as your drone’s serial number and model information. We may also collect information about the flight destination you selected, the flight plan generated, your drone’s location, and information about your past flights (i.e., logbook information).
- Cookies and Similar Technologies: We and our service providers use various technologies to collect and store information when you use our Services, and this may include using cookies or similar technologies to identify your browser or device. For example, Wing uses Google Analytics to understand how visitors engage with our site and apps. If you don’t want Google Analytics to be used in your browser, you can install the Google Analytics Opt-out browser add-on. Learn more about Google Analytics and privacy. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
- Images: Wing drones use low-resolution cameras in our navigation systems, to confirm terrain data and for safety purposes. The cameras on Wing’s drone may incidentally capture low-resolution black-and-white overhead images when fulfilling deliveries, which may include images of individuals or other objects within the field of view of our drones. For delivery services ordered directly through Wing, in limited instances we may associate these images with the Wing account of the user that requested the delivery, such as to confirm the delivery location.
- Information We Collect From Other Sources: We may also obtain information from other sources, third parties, or publicly available data, including as follows:
- We may collect information about you from our third-party social media channels if you choose to engage with these channels.
  If you log into our Services through your Google account, we will have access to limited profile data (such as email address, phone number, name and profile picture associated with your Google account).
- In connection with our delivery Services, we may collect information, such as delivery address, from our partners.
- In connection with certain OpenSky Services, we may collect information about you from:
  - Participating third-party RID services providers. The information we collect from them is similar to the information described above about your drone and flights. If you are located in the US, drone and flight information may be collected from approved UAS Service Suppliers (USS) and Wing will retain such data until you choose to delete it.
  - Other providers of aviation-related services and their users, such as airspace information about your proposed flight with such provider, in order to detect conflicts.

Payment information

If the Services require payment, you may need to provide your credit card information directly to our third party payment processor or through a third party’s website to which the Services link. This information will be governed by the third party’s privacy policy and terms of service.

How we use information we collect

Wing may use your data in the following ways:

Provide, maintain, protect, promote and improve our Services, to develop new ones, and to protect Wing and our users.
Help us solve any issues you may have with the Wing Services, respond to your comments and questions and provide customer service.
Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, etc.
Inform you about our Services, for example, letting you know about upcoming changes, improvements, or for marketing purposes.
Improve and personalize 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.
Monitor and analyze trends, usage and activities in connection with Services.
Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below).
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.
Carry out any other purpose described to you at the time the information was collected.

We do not share personal information with companies, organizations and individuals outside of Wing unless one of the following circumstances applies (or unless otherwise described in this policy):

With your consent or at your direction: We will share personal information with companies, organizations or individuals outside of Wing when we have your consent or if you have directed us to do so. For example, we share information with merchant and delivery partners when you request delivery Services.
To related companies in our group: Wing shares personal information with its subsidiaries, and in more limited instances may share personal information with its affiliates (other companies in our group of companies under common control and ownership).
With vendors, service providers, advisors and consultants that access information in order to perform services for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, and marketing and advertising.
In connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
For legal reasons: We will share personal information with companies, organizations or individuals outside of Wing if we have a good-faith belief that such 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.

We also share aggregated or de-identified information that cannot reasonably be used to identify you. For example, we may share this information publicly to show trends about the general use of our Services.

In connection with our OpenSky Services, we also share your information as follows:

When you use the Services to register your drone, authorize your flight, apply for a license or request access to controlled airspace from an aviation or other government authority, we share your information with that government authority, including contact information, information about you or your company (e.g., operator license number), your drone (e.g., registration and serial number), your proposed flight plan (e.g., start time, duration, operation area, and maximum altitude).
When required to provide or enable similar services. For example, in areas where multiple providers of aviation-related services, including unmanned traffic planning services, are permitted, we will share information about your proposed flight with such service providers in order to detect conflicts.
If government authorities require that Wing provide your drone and operator information for remote identification purposes. In jurisdictions where this is required, we will share your information with the applicable government authority or provider authorized by the government authority, such as other remote identification service providers. This information could include your name, contact information, license information, drone serial number and other drone identifiers, your user ID and details of your flight (e.g., location, time and speed). If you are located in the US, this information will be shared with approved UAS Service Suppliers. If you are located in Switzerland, this information will be shared with the SUSI members listed at https://susi.swiss/susi-members/.

Advertising and analytics

We engage others to provide analytics services and serve advertisements across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Wing and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

Additional regional disclosures

Retention and deletion of personal data of Australia, EEA, Swiss or British persons.

We retain personal information for different periods of time depending on what it is, how we use it, and how you configure your settings. Some data you can delete or update whenever you like, such as your pilot license in OpenSky or your address and phone number for delivery services. Other data is deleted or anonymized automatically after a set period of time, such as application usage analytics, which we delete after 420 days. We keep some data until you delete your Wing Account, such as information about how often you use our services. And some data we retain for longer periods of time when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, complying with legal or regulatory requirements or financial record-keeping.

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 in the settings of the iOS or Android mobile app or you can contact wing-privacy@wing.com.

We also keep information which will help us improve our Services, and conduct further research and product development. We take steps to avoid retaining personal information for only this purpose.

(Our legal basis for processing the personal data of EEA, Swiss, or British persons.)

If you reside in the European Economic Area (EEA), Switzerland or the UK, certain data protection law applies to the processing of your personal data. We rely on the following legal basis 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 when you opt in to marketing communications from us. You can withdraw your consent at any time, but we may still need to retain a record of your correspondence with us. To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications). 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;
Communicating with you;
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; and
Where it is necessary to comply with a legal obligation, for example under anti-money laundering or anti-bribery legislation.

Your privacy rights

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. For certain Services, you can also review and update your Wing activity record to decide what types of data you would like saved with your Wing account when you use such 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.

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 or, for certain Services, you may export your profile and data about delivery Services you have requested from https://takeout.google.com. You can also submit a deletion request in the settings of the iOS or Android mobile app.

Subject to certain limitations, if EU data protection law applies to our processing of your personal information, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights and are unable to through the methods described above, you may contact wing-privacy@wing.com.

Processing of Information in the United States and other countries

Wing stores personal information on our servers in many countries around the world including the United States. Data protection laws vary among countries and the laws of some countries may provide a different standard of protection than under the laws of your country. We will take steps designed to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, or executing Standard Contractual Clauses. Where relevant, you may request a copy of these Standard Contractual Clauses by contacting us at wing-privacy@wing.com.

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.

Compliance, complaints and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Policy.

If you have questions or 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.

If you are in the EEA, UK or Switzerland and you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below: - For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en - For individuals in the UK: https://ico.org.uk/global/contact-us/ - For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

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 website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

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.