Privacy Policy

Last updated: September 3, 2020

Wingspan Networks, Inc. (“Wingspan”, “Our”, “We”, “Us”) takes the privacy and security of personal information very seriously. As such, we have prepared the following Privacy Policy to provide you with information about how your data is collected, used, stored, shared, transferred, and protected as a result of your interaction with and use of (1) the www.wingspan.app, www.my.wingspan.app, and similar subdomain websites as applicable (the “Site”), which is owned and operated by Wingspan; (2) our mobile applications to which this Privacy Policy applies (the “Application”) and/or (3) any of the online services offered by Wingspan made available through the Site or the Application (“Services”). By using the Site, Application, and/or Services, you agree to the following Privacy Policy and our Terms of Use. The provisions contained in this Privacy Policy supersede all previous notices and statements regarding our privacy practices with respect to our Services. If you disagree with any of the provisions described below, your remedy is to stop using the Site, Application, and/or Services immediately

‍Application of this Privacy Policy

‍This Privacy Policy applies to your use of (regardless of means of access) our Site, Application, and/or Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a “Device”).

‍Information Collection

Information you provide us

In general, you can visit the Site without telling us who you are or revealing any information about yourself. When you interact with the Site, Application, and/or Services, including through submitting an inquiry through the “Contact Us” link or “Keep in Touch” box on the Site, or by registering for a Wingspan account, we may ask you to provide personal information about yourself, which may include your name, date of birth, company name, banking information, e-mail address, phone number, and other information that identifies you, including information identifying you as a benefits enrollee (collectively, “Personal Information”). It is your decision to use the Site, Application, and/or Services, and, as such, any provision of this personal information is completely voluntary. By providing your Personal Information to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy.

Information about your transactions

We may collect Personal Information about your transactions with us and others.

Information from third parties

We may also collect Personal Information about you from other companies. For instance, we may receive Personal Information about you from a consumer reporting agency.

If you choose to access, visit, and/or use any third party social networking service(s) that may be integrated or linked to the Site, you are subject to the Terms of Use and Privacy Policies of those social networking services.

Information automatically collected

We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical, non-personal information that does not identify you (“Analytics”). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

Information that we automatically collect in connection with your access or use of our Site, Application, and/or Services may include:

• Device Information. We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or your mobile phone number with your Wingspan account.
• Log Information. We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:
• The Device’s Internet Protocol (“IP”) address
• The Device’s operating system
• Identification numbers associated with your Devices
• Device event information, such as crashes, system activity, and hardware settings
• Location preferences
• Date and time stamps of transactions
• System configuration information
• Other interactions with our Services
• Other Information. We may collect information such as your browsing history on the Site, the length of time spent on certain pages, the website Uniform Resource Locator (“URL”) from the website you were visiting before coming to this Site, which URL you next visit, what browser you are using, Internet service provider, and date/time of visit information.
  

We may also collect Personal Information about you for other purposes from time-to-time, or as permitted or required by law. We will always identify any additional purpose prior to or at the time of collection.

Information Use

We may use the Personal Information collected as described elsewhere in this Privacy policy, including to:

• provide you with the Site, Application, and/or Services;
• respond to your inquiries or requests;
• communicate with you; and
• provide you with offers and promotions that we feel may be of interest.
  

We may use the Analytics information collected as described elsewhere in this Privacy policy, including to:

• conduct statistical analysis of the Site, Application, and/or Services;
• troubleshoot service issues or interruptions;
• conduct research and for commercial purposes, such as to update and improve the Site, Application, and/or Services;
• understand the demographics of our users and their browsing habits; and
• serve you with promotional messages and advertisements, both while you are on the Site and after you leave our Site and continue to browse online.
  

We may use your email address to respond to your inquiries and to provide you information about our Site, Application, and/or Services. You may elect not to receive promotional emails from us either by “unsubscribing” to an email you receive from us or by contacting us as indicated below. If you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your Wingspan account or our ongoing business relations, unless you withdraw your consent to receive electronic communications.

‍Cookies

Cookies are small files that are sent to and stored in your computer by the websites you visit. Cookies are stored in your browser’s file directory. Cookies may be stored only for the time you are in a given site or they may remain stored in your browser for a defined period of time beyond your current session. Cookies work in combination with content within the website itself, to capture and remember information. To learn more about these technologies and how they work, please see www.allaboutcookies.org.

We use cookies and other similar technologies (such as web beacons and pixels) to collect and process non-personal information, personalize our Services for you, and to collect aggregate information about the usage of our Services.

The cookies we use in connection with our Services may include:

• Session cookies. Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant users access to content and to enable actions they must be logged into their Wingspan account to perform.
• Persistent cookies. Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve our Services.
• Third-party cookies. We may permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Service to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services. For example, we utilize Google Analytics to analyze usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services, which Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our Services, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.
  

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can review the options available to manage cookies in your browser. One option is to disable, or turn-off, all cookies. If you turn cookies off, you may not be able to browse the Site or use the Services. If you disable certain kinds of cookies, some aspects of our Site, Application or Services may not function properly or as well.

Information Sharing

We may share Personal Information to the following entities and/or for the following reasons

• Affiliates/Partners. We do not currently share your personal information with affiliates or unrelated third parties. However, we may share your personal information with our affiliates or partners for the purpose of providing you with the Services, as well as additional benefits. In the event that we enter into such a partnership, we may share your personal information with those partners. If we share personal information, we will require that such partners use the personal information for the limited purpose for which we provide it, maintain reasonable security measures for the protection of such information, and comply with the provisions as outlined in this Privacy Policy.
• Unaffiliated Third Parties. We may share your Personal Information with unaffiliated third parties:
• (1) if you request or authorize it;
• (2) if the information is provided to help complete a transaction for you;
• (3) if the information is provided to: (a) enforce our Terms of Use or other agreements; or protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.);
• (4) if the information is provided to our third-party service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.);
• (5) for our everyday business purposes; or
• (6) as permitted by applicable law or otherwise described in this Privacy Policy. When you are no longer a member, we continue to share your information as described in this Privacy Policy.
• Law Enforcement. Occasionally we may be required by law enforcement or judicial authorities to provide personal information. We will disclose personal information upon receipt of a court order, subpoena, warrant, or other legal process to the extent necessary to meet legal, national security, public interest, or law enforcement obligations. We fully cooperate with law enforcement agencies in identifying those who use our Site for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
• Merger. In the event that Wingspan enters into an agreement to be purchased by another company or to merge with another company, we may share personal information with that company. We will require that such purchasers continue to comply with the provisions as outlined in this Privacy Policy.
  

We utilize Google Analytics to capture and analyze visits and traffic to the Site. Google Analytics collects information about your visit to the Site, any referral website, the type of web browser and operating system you are currently using, and your network location and IP address. The information collected by Google Analytics is anonymous and aggregated. We reserve the right to use this information for any lawful business purpose, including selling or sharing the aggregated and anonymized data collected by Google Analytics. We may also use this aggregated and anonymized data to analyze trends or seek third party advertisers.  

We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.

We may also share non-personal information with select third parties, such as our advertisers, for purposes of serving you with customized promotions. If you would like to learn more about the sharing of non-personal information for purposes of providing customized advertisements or promotions, please visit http://www.aboutads.info/consumers/.

As part of our Services, we may require you to link a bank account with a third party data aggregator. Your bank link will be used to identify when you receive incoming balances and to monitor your balances to ensure you have sufficient funds to withdraw. If you are required to link your bank account with a third party data aggregator, you will be subject to privacy terms from our partners, which can be found on their respective websites. If you have questions about which data aggregator is being used with your account, please reach out to us via the contact information below.

‍Your Choices

You may have choices when it comes to the collection, use, and sharing of your personal information. You may choose to “unsubscribe” from e-mail marketing communications, or you can contact us using the contact information below to be removed from our email marketing lists. Please be aware that you are not able to opt out of receiving communications about your Wingspan account or related transactions with us.

Accessing Your Information

You must notify us of any change in your Personal Information by updating your Wingspan account profile through our Site, Application, and/or Services. Any changes will affect only future uses of your Personal Information.

Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Privacy Policy.

You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.

Log-In Through Social Networks

You may have the option of signing up for the Service through Facebook, Google, or other social networks. Logging in through these social networks may allow Wingspan to access certain public information related to your profile. When you sign in through one of these social networks, you may be asked what information you would like to share. It is up to you what to share with Wingspan, or whether anything at all from your social network profile is shared at all.

Links to Third Party Sites

Wingspan may provide you with links to third party websites through the Site or Application. We may also allow third-party websites or applications to link to our Site, Application, and/or Services. Wingspan is not responsible for the collection, use, or sharing of your personal information once you leave our Site or Application and follow a link to a third party website. Please consult each linked website’s privacy policy for a description of how the website collects, uses, and shares your information.

Do Not Track

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

Children’s Information

The Site is not intended for children under the age of 18 years old. We do not knowingly collect information from children under the age of 18. If we discover that we have information from a child under the age of 18, we will delete it immediately. If you believe that a child under the age of 18 may have provided his or her information to us, please contact us using the contact information below. You are not permitted to enter any information about a minor anywhere on the Site or Application unless you are that minor’s legal guardian and consent to the practices described in these Terms of Use on behalf of that minor. We may ask you to verify that consent, and you are required to do so promptly.

Cross-Border Transfer of Data

We are located in the United States. If you are not a resident of the United States, your country’s laws governing data collection and use may differ from those in the United States; in particular, the United States may not provide the same level of protections as those in your own country. By using the Site or providing your personal information to Wingspan, you are transferring your information to the United States, and you consent to the transfer, retention, and processing of such data in the United States. If you do not agree with such transfer, retention and processing in the United States, please do not use the Site.

California Residents’ Privacy Rights.

If you live in California and have an established business relationship with us, you can request a list of the personal information we have shared with third parties for their marketing purposes. We will also give you a list of the third parties that have received your information. You can make a request one time each year.

To exercise your rights, you can e-mail us at support@wingspan.app or write to:

Wingspan Networks, Inc.

Attn: Anthony Mironov, CEO

335 Madison Ave, 16th Floor, New York, NY 10017, USA

Mention in your letter that you are making a “California Shine the Light” inquiry. We will respond within 30 days.

Security

We understand the importance of information security and will take reasonable measures to protect the security and confidentiality of your information. When your bank account information and Social Security Number are transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL). Please understand that no measures can guarantee 100% security.

You are responsible for the security of your log-on information. Please do not share your username or password with anyone. If you believe your log-on password has been compromised, please contact us immediately.

If we receive instructions using your Wingspan account login information, we will consider that you have authorized the instructions. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate Wingspan accounts, and to remove or edit content.

‍Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time and in our sole discretion. We will post changes directly to this Privacy Policy and update the date at the top of this Privacy Policy, so it is your responsibility to check back here from time to time to review. If we make a material change in the type of information we collect or its use, we will provide advance notice of such change, and obtain your consent for the new collection or use, if and as required by applicable law. The revised Privacy Policy will be effective upon posting, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Site, Application, and/or Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.

‍Contact Information

If you have any questions or concerns about this Privacy Policy, please contact us using the information below:

Wingspan Networks, Inc.

Attn: Anthony Mironov, CEO

335 Madison Ave, 16th Floor, New York, NY 10017, USA

support@wingspan.app