Privacy – WingX

Privacy Policy

Effective as of May 19, 2024

Introduction & Definitions

This page details WingX’s Privacy Policy, or “Policy,” which explains how we collect, store, protect, and share your information, and with whom we share it. The WingX mobile application and website (together “WingX” or the “App”) are operated by WingX LLC, a Massachusetts limited liability company (“we” or “us” or “the Company”), which is responsible for handling personal information collected and processed through the WingX App and Sites. Any questions can be directed to [email protected].

Information We Collect

You choose to give us certain information when using our WingX mobile application and website. This includes:

When you create an account, you provide us with at least your phone number, as well as some basic details necessary for the service to work, such as your gender, date of birth, photographs, and who you’d like to connect with.
When you complete your profile, you have the option to share your sexual orientation, ethnicity, religious beliefs, and political opinions with us. Where you provide such elements to us, you consent to us using it for the purposes identified and as laid out in this Privacy Policy. You can also share additional information with us, such as details on your bio and your interests, as well as additional content such as more photographs, videos, and audio clips. To add certain content, like pictures or videos, you may allow us to access your camera, photo album, or microphone.
When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us with information related to the purchases you make and our payment processors with information such as your debit or credit card number or other financial information.
When you participate in surveys, focus groups or market studies, you give us your insights into our products and services, responses to our questions and testimonials.
When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
If you contact us (e.g., through our customer care team or on social media), we collect the information you give us during the interaction.
If you share with us information about other people (for example, if you use contact details of a friend for a given feature), we process this information on your behalf in order to complete your request.
We may also process your chats with other users as well as the content you publish to keep our community safe.

Information we receive from others

In addition to the information you may provide us directly, we receive information about you from others, including:

Users: Users may provide information about you as they use our services, for example as they interact with you or if they submit a report involving you.

Social Media: You may decide to share information with us through your social media account, for example if you decide to create and log into your WingX account via your social media or other account (e.g., Facebook, Google or Apple) or to upload onto our services information such as photos from one of your social media accounts (e.g., Facebook or Instagram).

Other Partners: We may receive information about you from our partners where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our users’ safety and security.

Information generated or automatically collected when you use our services

Usage Information: Using the services generates data about your activity on our services, for instance how you use them (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages address and ads that you interacted with) and your interactions with other users (e.g., users you connect and interact with, and when you matched and exchanged messages with them).

Device Information: We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device’ settings and, in some cases, disable entirely), and identifiers associated with cookies or other technologies that may uniquely identify a device or browser.

Information collected by cookies and similar technologies: We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels and SDKs) to recognize you and/or your device(s). Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform.

Other information with your consent

Precise geolocation data: If you give us your consent, we can collect your precise geolocation (latitude and longitude) from your device. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your precise geolocation, we will not collect it, and our services that rely on precise geolocation may not be available to you.

Other information: We may collect other information with your permission, such as photos and videos (for instance, if you want to publish a photo or video or participate in streaming features on our services).

Use of Information

Under EU and UK data protection laws, we are required to tell you our lawful basis for using your data and we have set this out in the section below. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Privacy Policy how you can withdraw consent or opt-out of certain data uses (where applicable).

To administer your account and provide our services to you. This includes creating and managing your account and profile; providing you with customer support and responding to your requests; communicating with you about our services; personalizing pricing, offering discounts and other promotions, and completing your transactions; and administering sweepstakes and contests.

Legal basis: Provide our service to you, contractual necessity

To help you connect with other users. This includes recommending you to other users and recommending other users to you; showing users’ profiles to one another; enabling users to search for and connect with users and friends; promoting others users’ profiles by commenting on their pages; and communicating with others users and friends in the app.

Legal basis: Provide our service to you, contractual necessity

To provide offers and operate advertising and marketing campaigns. This includes performing and measuring the effectiveness of advertising campaigns on our services and marketing our services off our platform; and communicating with you about products or services that we believe may interest you.

Legal basis: Legitimate interests, consent

To improve our services and develop new ones. This includes administering focus groups, market studies and surveys; reviewing interactions with customer care teams to improve our quality of service; understanding how users typically use the services to improve them (for example, we may modify a given feature or graphical user interface based on how users engage with it); and developing new features and services.

Legal basis: Legitimate interests

To prevent, detect and fight fraud and other illegal or unauthorized activities. This includes finding and addressing ongoing, suspected or alleged violations of our Terms and Conditions of Use, notably through the review of reports and interactions between members; better understanding and designing countermeasures against violations of our Terms and Conditions of Use; retaining data related to violations of our Terms and Conditions of Use to address the violation and prevent against recurrences; enforcing or exercising our rights, for example our rights set out in our Terms and Conditions of Use; and communicating to individuals who submit a report, including what we’ve done as a result of their submission.

Legal basis: Legitimate interests, contractual necessity

To ensure legal compliance. This includes complying with legal requirements; and assisting law enforcement.

Legal basis: Comply with applicable laws and regulations

If you choose to provide us with information that may be considered “special” or “sensitive” in certain jurisdictions, such as your sexual orientation, you’re consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information such as your precise geolocation or use your information for certain specific reasons. In some cases, you may withdraw your consent by adapting your settings or by deleting your content. In any case, you may withdraw your consent at any time by contacting us at [email protected].

Disclosure of Information

With other users: You share information with other users when you voluntarily disclose information on the service, for example on your public profile. When you upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of this information and making it public to other users. Please be careful with your information and make sure that the content you share is information that you’re comfortable being visible. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings. If someone submits a report involving you (such as a claim that you violated our Terms and Conditions of Use), we may communicate to the reporter actions, if any, we took as a result of their report.

With our service providers and partners: We use vendors to help us operate, distribute, market and improve our services, such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. For example, payment processing and telecommunications companies use user information to facilitate payments for our premium services. Moderators may also have access to information to monitor activity on the App and approve content. We also share information with vendors who distribute and assist us in advertising our services. For example, we may share limited information on you in hashed, non-human readable form to advertising vendors.

For corporate transactions: We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

- With law enforcement / when required by law: We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

To enforce legal rights: We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request: We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information. We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, location in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.

Your Information Rights

You have the following options and tools available to you to manage your information:

Access / Update tools in the mobile application. Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please contact our customer care team for help.
Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Note if you do that, certain services may lose functionality.
Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does not close your account. To close your account, please use the corresponding functionality on the mobile application.
Account closure. You can close your account by using the corresponding functionality directly on the mobile application.

Depending on where you live, you may have also have the right to:

Access/know. You may have the right to request a copy of the information we keep about you, and in certain circumstances to receive this in a portable format. You can exercise your right to access directly within the service by putting in a request at [email protected].
Delete/erase. You may request that we delete the personal information we keep about you. You can exercise your right to delete by submitting a request with [email protected].
Correct/rectify/update. You can correct most information you provided to us by editing your profile directly in the service. If you believe the information we hold about you is inaccurate, you may contact us at [email protected] to rectify it.
Object/restrict. You may also have the right to object to or request that we restrict certain processing. To do so, please contact us at [email protected].

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another user, such as a copy of any messages you received from them through our service, the other user will have to contact us to submit a separate request for their information. We may also ask them to provide proof of identity before we can answer the request. Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth and thus cannot ensure that you are 18 years of age or older.

Region-specific rights:

If you are a resident of Virginia, Colorado, or Connecticut, United States of America, and if we deny your privacy request, you may be able to appeal by contacting us at [email protected], and explicitly referencing “Privacy Request Appeal.” If you have concerns about the result of your appeal you may contact the attorney general for your state. Additionally, please note that we do not “sell” your personal data, or use it for “targeted advertising” or “profiling” in furtherance of decisions that produce legal or similarly significant effects, as those terms are defined by applicable law in your state, so no opt-out choice is necessary.

In certain countries, including in the European Economic Area and the United Kingdom, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. You can find information about your data protection regulator in the European Economic Area here, and in the United Kingdom here. The data protection authority you can lodge a complaint with may be that of your habitual residence, where you work or where an alleged infringement took place.

California Privacy Rights

For Users who are California residents, you have the following rights (in addition to those listed in section 5 above) under the California Consumer Privacy Act (hereafter known as the CCPA), and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

Some of the information we collect also constitutes “sensitive personal information” under the CCPA, including information that reveals your precise geolocation, racial or ethnic origin, sex life or sexual orientation, religious or philosophical beliefs, and contents of your messages. We do not use sensitive personal information we collect for purposes other than providing and improving our services to you and protecting our services and our community, and we do not use sensitive personal information to infer characteristics about you.

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at [email protected].

From time to time, as part of a joint promotion with a third party, we may, if you participate in such promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before when you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.

In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the WingX App.

How Long We Retain Your Information and Deletion

We keep your personal information only as long as we need it for legitimate business purposes as laid out in Section 3 and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will stop being visible to other users. After your account is closed, we will delete your personal information, as laid out below:

When your Account is deleted, we make sure it is no longer viewable in the App. For up to 28 days, it is still possible to restore your Account if it was accidentally deleted. After 28 days, we begin the process of deleting your personal information from our systems, unless:

we must keep it to comply with applicable law;
we must keep it to evidence our compliance with applicable law;
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security

Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

No Children Allowed

WingX and its services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. WingX does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.

Privacy Policy Changes

WingX may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be available on our website. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within the WingX app or website.