Privacy Policy

The Wingmate Company, LLC PRIVACY POLICY

Last Updated: December 5, 2024

INTRODUCTION

This Privacy Policy describes the types of personal information The Wingmate Company, LLC and its parent, subsidiary, and affiliate companies (collectively, “The Wingmate Company,” “The Wingmate,” “we,” “us,” or “our”) collects, as well as how it’s used, disclosed, protected, and retained through our websites from which you are accessing this Policy, our social media pages on third-party social media platforms, email, text, mail, and any offline business interactions you have with us (collectively, our “Services”). It also explains your privacy choices and rights and how to exercise them. A summary of our information practices may be found in Table 1 at the end of this Policy.

By accessing or using our Services, you signify your acceptance of this Privacy Policy and consent to the collection, use, disclosure, and other handling of your personal information as described in this Privacy Policy (except for activities for which we first require your consent to be given through other means).

The following four (4) sections serve as The Wingmate Company’s Notice at Collection under applicable US privacy laws, including the California Consumer Privacy Act (“CCPA”).

COLLECTION OF PERSONAL INFORMATION

The Wingmate Company collects and processes different types of information about you, including information that identifies, relates to, describes, or can be associated with you (known as “personal information”). This includes information we collect directly from you, through automated collection technologies, from other sources, or personal information we derive based on other types of personal information we collect, as described below.

In the preceding twelve (12) months, we have collected the following categories of personal information. Note that not all categories may be collected about every individual:

• Identifiers such as first name, last name, customer number, and unique personal identifier or similar identifier
• Demographic Data such as age range, gender, and estimated income
• Contact Information such as billing address, delivery address, email address, and phone numbers
• Commercial or Transaction Data such as order details, amount charged, payment method, products considered, purchased, returned, exchanged or registered, wish list information, as well as membership in a The Wingmate Company discount program
• Device and Network Data such as internet protocol (“IP”) address, login data, browser type and version, internet connection, time zone setting and location (including geolocation), browser plug-in types and versions, operating system and platform, logs, and other technology on the devices you use to access the websites
• Usage Data such as information about how you use our Services, like date and time of your visit to our websites, clicks, browsing history, and website traffic data
• Account Data including information to activate and maintain your The Wingmate Company  account, such as account number, account creation date, and last login date
• Behavioral and Preference Data such as preferences, tendencies, or interests based on orders made by you, items viewed, feedback or survey responses, and preference data
• Marketing and Communications Preference Data such as your preferences in receiving email, text or postal marketing from us and our partners who are authorized to communicate with you, participate in sweepstakes and other prize competitions, and other communication preferences
• User Content such as content provided or posted by you, including User Generated Content (“UGC”), product reviews, interactions with our customer service and privacy teams via email, chat and phone, and any other content you provide on The Wingmate Company webpages, social media platforms, in promotions emails and advertisements, and other initiatives. We also collect Social Media User Content Data such as any social media information that you have shared publicly, social media handle, and comments or messages you have shared with us on social
• Audio, Electronic, Visual, or Similar Data such as in-store Closed-Circuit Television (“CCTV”) and customer experience calls
• Inferences drawn from or created based on any of the information identified above
• Professional or Employment-Related Information such as employer or associated business, job title, work email (as described below), and quotes submitted
• Sensitive personal information (in limited circumstances and described further below).

The list provided above also includes Personal Information Categories Listed in the California Customer Records Statute (e.g., name, address, telephone number, personal characteristics or description, employment; some of this information may overlap with other categories) as defined under the CCPA.

Business Contacts, Vendors, and Contractors. We also collect limited personal information from our business contacts, vendors, and contractors. For example, we collect name and business contact information (including name, job title, telephone number(s), and email address) from each our business contacts, vendors, and contractors for the purpose of initiating, operating, managing, and maintaining our business relationships. For our business contacts, such as our dealers, we may also collect marketing and communications preference data and purchase or consuming histories as part of that relationship.

Ambassadors. We collect personal information from our ambassadors, including contact information, user-generated content, professional or employment-related information, and other information you provide to us. We may collect and use your personal information to manage the ambassador program, and we may disclose your personal information to others only as previously consented to.

Sensitive Personal Information

While The Wingmate Company does not collect or process precise geolocation through our websites or online services, our service providers may collect such information to find a store near you using your location data which may be considered “sensitive personal information” or “sensitive data” within the meaning of US privacy laws. In most other cases, The Wingmate Company does not ask you to provide, and we do not knowingly collect, any sensitive personal information (as defined under US privacy laws) from the typical consumer as part of the Services (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership). Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal information on or through the Services or otherwise to us. In very rare circumstances, The Wingmate Company does ask that you provide us with sensitive personal information in the form of a 1099 form solely for the purpose of legal matters to allow us to facilitate sweepstakes and giveaways of The Wingmate Company products above a certain monetary value. In addition, to participate in an investigation of unlawful conduct (e.g., fraud or counterfeiting), we may collect any personal information permitted by law, which, depending on the details of a particular investigation, could include any category of sensitive personal information.

The Wingmate Company does not “sell” or “share” sensitive personal information about Californians or other state residents within the meaning of the CCPA and other US privacy laws, and does not use “sensitive personal information” for any purposes that are incompatible with the disclosed purpose for which it was collected or other than those permitted purposes authorized by US privacy law. We do not use sensitive personal information for inferring characteristics about you.

USE OF PERSONAL INFORMATION

We and our service providers, contractors, and third parties use your personal information for the following purposes:

• Provide, operate, and maintain our websites, including The Wingmate Company’s Rescue Program
• Fulfill orders and process exchanges or returns that you have ordered or requested, and to communicate about such orders or returns
• Enable and improve customer service and address your questions, suggestions, compliments, or complaints, including monitoring of customer service calls and chats for quality or training purposes.
• Communicate with you, including sending you important information regarding the website or terms, conditions, policies, recall information and/or other administrative information.
• Send you a free gift and other benefits for registering a The Wingmate Company product.
• Share reviews, testimonials, or other user-generated content
• Register and maintain a The Wingmate Company account and communicate with you about your account and activities on or in connection with the Services
• Deliver marketing communications and advertising that we believe may be of interest to you
• Administer sweepstakes, contests, and promotions, including fundraising efforts and special discounts for friends and family, professionals, and military personnel, veterans, nurses, first responders and government officials
• Learn about customer trends and interests
• Personalize digital content and product recommendations
• Create inference data about you and your interests. We may combine the information we collect about you from different sources to create a profile about you and to infer your interests, preferences, habits and other behaviors
• Fraud prevention, security, and asset protection
• Enable our business purposes, such as license, sell and promote product, expand brand outreach, data analysis, audits, researching and developing new products and services, identifying usage trends, enhancing our websites, improving our services
• Comply with a legal matter
• Initiate, operate, manage, and maintain our business relationships
• For any other purpose, with your consent where appropriate. Please note that you may revoke your consent at any time where consent was provided to process your personal information. Please see “Your Choices and Legal Rights” below for more details.

We may also aggregate and/or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer reasonably identifies you or any other individual.

DISCLOSURES OF PERSONAL INFORMATION (INCLUDING “SALES” / “SHARING” AND TARGETED ADVERTISING)

The Wingmate Company may disclose, “share”, or “sell” your personal information (as those terms are defined under US state privacy laws including the CCPA) to service providers, contractors, and third parties for one or more purposes as described below.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, The Wingmate Company has disclosed the following categories of personal information for a business purpose:

• Identifiers
• Demographic Data
• Contact Information (note that we do not “share” or “sell” text messaging opt-in data, mobile numbers or consent with any third parties for marketing purposes)
• Commercial or Transaction Data
• Device and Network Data
• Usage Data
• Account Data
• Behavioral and Preference Data
• Marketing and Communications Preference Data
• User Content
• Audio, Electronic, Visual, or Similar Data
• Inferences
• Professional or Employment-Related Information
• Sensitive Personal Information

We disclose your personal information for a business purpose to the following categories of service providers and contractors:

• Affiliates for the purposes described in this Privacy Policy.
• Service providers engaged by The Wingmate Company to facilitate a service on our behalf, such as order fulfilment, customer service, payment processing and facilitating, IT provisioning, security, fraud prevention, and other services. See below for more information on our third-party payment processors.
• Contractors that provide consultancy and advisory services, such as our third-party auditors.
• Analytics, marketing, and advertising partners, such as third-party analytics service providers (including Google Analytics and Segment), performance, content, email, and database marketing partners, media agencies, and social media providers and networks (such as Instagram, Facebook, and YouTube), for the purpose of marketing services and products you might want. Such partners may also process your personal information for their own purposes, as described in more detail in the following section.
• Joint marketing and business partners where we may from time-to-time partner with another brand or retailer or other party to offer services, products, events, special offers, and promotions on a co-branded or cross-promotional basis. The information you provide in connection with our Services may be collected directly by, or shared with the partner, as well as with any participating sponsors or advertisers of such services. Information received by those businesses will be subject to their privacy policies.
• Entities involved in a business sale or similar transaction where we may buy, merge, or partner with other companies.
• Entities involved in the Protection of The Wingmate Company and Other Legal Compliance if required to do so by law or on a good faith belief that such disclosure is reasonably necessary to: (i) seek legal advice from The Wingmate Company ‘s in-house or outside counsel or in connection with litigation with a third party; (ii) comply with law or legal process (e.g., a subpoena or court order) and requests from public or governmental authorities; (iii) enforce our Terms of Service, this Privacy Policy or other contracts with you, including investigation or potential violations thereof; (iv) protect the rights, property, or personal safety of The Wingmate Company, its agents, affiliates, its users, and/or the public; (v) investigate security breaches; and (vi) allow us to pursue available remedies or limit the damages that we may sustain. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.

Note that your information may also be disclosed publicly when you choose to—for example, if you include personal information in any product review or social media comment.

A summary of such disclosures is provided in the table at the end of this Policy.

Targeted Advertising and “Sales” / “Sharing” of Personal Information

We do not sell consumers’ personal information for money. However, some US state laws broadly define “sales”, and certain sharing activities described below may therefore be considered a sale under certain privacy laws even though we do not receive any financial compensations from third parties in exchange.

Instead, we do share certain personal information with third parties for their own purposes in exchange for insights, certain rights, and other valuable services, such as:

• With direct mail and other marketing partners to expand our brand outreach; and
• With leagues, teams and other business partners to license, sell and promote product. 

We also share personal information with third parties for the purpose of cross-contextual (or interest-based) behavioral advertising (known as “sharing” under the CCPA) or for “targeted advertising” i.e., displaying advertisements to you based on personal information collected or inferred from your activities over time and across nonaffiliated websites, applications, or online services. These entities may use cookies, web beacons, identifiers, and other tracking technologies to collect information about your use of the Services, and other websites, including your IP address and other identifiers, web browser information, pages viewed, time spent on pages, links clicked, and conversion information. This information is used to provide a more individual and personalized experience, deliver ads targeted to your interests, analyze and track data, build propensity models, drive interaction, determine the popularity of certain content, and better understand your online activity. 

The Wingmate Company can “sell” or “share” (as defined under the CCPA) each of the following categories of personal information:

If you are a resident of certain states, you may have the option to opt out of targeted advertising or “sales” / ”sharing” (as defined by the CCPA and other US state privacy laws) by clicking on the “Your Privacy Choices” link or by following the instructions below in “Your Choices and Legal Rights”. Note that anyone may opt out of targeting cookies by toggling off or rejecting Targeting and Social Media Cookies within our “Cookies Settings” as is more specifically described in The Wingmate Company’s Cookie Policy. Please note that such choices are device and browser specific. 

Your browser may also offer a way to activate a legally recognized opt-out preference signal (or “universal opt-out mechanism”), such as the Global Privacy Control signal (“GPC”). Our websites treat qualifying browsers for which the user has activated opt-out preference signals as having opted out of what CCPA and other US privacy laws call “sales” / “sharing” of personal information or “targeted advertising”, that is collected on that site from that browser using cookies and similar technology. You can override that treatment for an opt-out preference signal by using the cookie controls available from the website’s footer, or by disabling such a signal in your browser and clearing your cookies. Consult https://globalprivacycontrol.org for more information.

RETENTION OF PERSONAL INFORMATION

We plan to retain your personal information only for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law. When we determine that we have no ongoing legitimate business need nor lawful legal ground to process your personal information, we will take steps to delete, anonymize, or aggregate it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will store your personal information until deletion is possible.

The Wingmate Company determines retention based primarily on the type of record being retained. However, because a particular category of personal information may appear in different types of records, each with different retention periods, it may not be possible to specify a universal retention period for each particular category of personal information. Instead, the criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

SOURCES OF PERSONAL INFORMATION

The Wingmate Company collects the categories of personal information listed in this Privacy Policy in a in a variety of ways, including:

Information We Collect Directly from You

We collect personal information you provide to us, such as your name, phone number, and email address, for instance when you:

• Sign up to receive updates, special promotions, sweepstakes, campaigns, or newsletters from us by text, email, or postal mail
• Opt-in to transactional texts for delivery updates on your order or inventory updates on a product you may want. Such information, as well as your opt-in consent, is not sold or shared to any third parties
• Respond to a survey or provide us with your product, pursuit, color or any other preferences
• Create an account on our website
• Contact customer service
• Purchase or register a product
• Sign up for a special discount
• Connect with us on social media
• Leave a review on our website
• RSVP or attend one of our events
• Execute a contract or initiate a business relationship

Information We Collect Automatically 

We automatically collect certain personal information through a variety of different means (e.g., tracking technologies, WIFI, CCTV) when you access or use our Services, including:

• Device and Network Data. We may automatically collect certain information about the computer or devices you use to access our Services. For example, we may collect information that is automatically sent to us by your computer or mobile web browser or your internet service provider. This information typically includes your device’s hardware model, browser type, IP address, operating system version, language settings, unique device identifiers, advertising identifiers, serial numbers, how your device interacts with the Services, network information, and mobile network data.
• Location Data. Our websites collect real-time information about the location of your device. You can choose whether to allow the website to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the website may then be inaccessible or not function properly.
• Usage Data. We and our service providers and third parties may collect information about your user activity of our Services and browser habits via cookies, web beacons, pixel tags, and other tracking technologies about your online activity, and interactions with our emails, online, and mobile advertisements. Examples of such information include your access dates and times, pages or screens viewed viewed (including mouse movements and clicks), how long you spent on a page or screen, the routes by which you access our Services, searches you conduct on the Services, information about your activity on a page or screen, your use of any hyperlinks available within our Services, and information about your interactions with our emails or social campaigns.
• Session Replay. Our websites may utilize technology often known as “session replay” technology that allows The Wingmate Company to understand how users interact with our websites, including replays of interactions with our websites. By using our Services, you represent you have read this disclaimer and understand that The Wingmate Company may use this session replay technology to record how you interact with our websites, including clicks and curser movements, which may be used by The Wingmate Company for our own internal analytical purposes, fraud prevention, and to improve and enhance our websites.
• Video Data. We also use CCTV cameras to collect and retain for a limited duration, images of our people in our stores for fraud detection, theft prevention, and security.
• Other Technologies in our Retail Stores. We have deployed WIFI access points in some of our stores, and we receive aggregate reports regarding store traffic that relies in part of information collected from the WIFI access points to track traffic patterns in our stores. If you wish to exclude your device from such in-store mobile analytics, you can opt out at any time by turning off WIFI on your device.

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our websites and stores and to deliver a better and more personalized service by enabling us to estimate our audience size and usage patterns, store information about your preferences, to customize our websites according to your individual interests, and to recognize you when you return to our websites, and we use it for the other purposes described in this Privacy Policy as well.

If you would like to learn more about the technologies we use for this automatic data collection, specifically cookies and other technologies, and how advertisers use these types of cookies and technologies, or to learn how to exercise certain choices regarding this technology, please see our Cookie Policy.

Information We Collect from Other Sources

We may receive personal information about you from other sources. We may combine that with information we have already collected from you to use for all the purposes described in this Privacy Policy. For example, we may collect personal information about you from:

• Our other customers, including when they send you a The Wingmate Company product
• Social media providers, including if you interact with us through a social media service or log in using social media credentials
• Analytics companies, and marketing or advertising providers, and other parties that provide us with information, so we can better understand you and provide you with information and offers that may be of interest to you
• Fraud prevention providers
• Other businesses in connection with any merger, acquisition, dissolution or like transaction

Information We Derive from Other Personal Information

We may derive personal information or draw inferences about you based on the other types of personal information we collect. For example, we may infer your location based on your IP address, or that you are interested in purchasing a certain type of product based on your browsing behavior on our Services.

SECURITY

We seek to use various organizational, technical, and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have any questions about security on our site or have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

YOUR CHOICES AND LEGAL RIGHTS

We strive to provide you with choices regarding your personal information.

Your Choices

We have created the following mechanisms to provide you with control over your personal information.

• Opt-Out of Email Communications. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by clicking the “unsubscribe” link at the bottom of any The Wingmate Company marketing email. Please allow 10 days for the change to take effect. Note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
• Opt-Out of Text Communications. You can opt-out of receiving further marketing text messages via the Messaging Service by responding to any of our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT.
• Opt-Out of Physical Mail Communications. If you no longer want to receive physical mail or catalogs from us on a going-forward basis, please fill out the Unsubscribe Form under Inquiry->Unsubscribe Me->Mail on our Contact The Wingmate Company page.
• Close Your Thewingmate.com Account. If you wish to close your Thewingmate.com account at any time, please contact us by using the “Contact Us” below.
• Manage Tracking Technologies and Advertising. We use several modern marketing tools in support of our advertising efforts (see our Cookie Policy for more details). You can manage how your device, mobile browser, and other devices share information with our websites, as well as how your browser handles cookies and other tracking technologies to collect information in connection with our Services and our advertisements. Note that some of the options listed below may also allow applicable users to exercise their opt out rights as described in more detail in the following section.
  • We may work with third-party advertising companies that collect and use information about your online activities across sites over time, in order to deliver more relevant advertising when you are using The Wingmate Company Services and elsewhere on the Internet. You can learn more about interest-based advertisements and certain opt-out options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs, and we work with some advertising companies that don’t participate in those programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. Opting out may make the ads you see across the internet less relevant to you.
  • You may be able to block cookies on your browser by visiting our websites with a legally recognized opt-out preference signal, such as the Global Privacy Control. Please consult the “Help” section of your browser or click https://globalprivacycontrol.org for more information. However, note that by blocking any or all cookies, you may not have access to certain Services features or offerings.
  • You may also manage your cookie preferences on our site by selecting “Cookies Settings” in the Privacy & Compliance section of the website footer. Note that existing settings are device- and browser-specific and may be reset upon clearing your cache or using a different device or browser. At such point, you will need to re-select your cookie settings to continue with your previously selected preferences. Also, if you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

The laws in certain US states may provide their residents with additional rights regarding our use of their personal information. See below for more information.

US State Privacy Rights

Depending on your state of residence in the US, you may have the right to request us to complete the following legal privacy rights. You may submit your request by completing our online Privacy Rights Form, clicking on the “Your Privacy Choices” link for any opt-out rights, or by contacting us as detailed in the “Contact Us” section described below. Further instructions on how to submit a request are located within the forms.

• Access. The right to know and request that The Wingmate Company disclose certain personal information we hold about you, as well as details about whether and to whom your personal information was disclosed, shared, or sold, subject to certain exceptions.
• Deletion. The right to request that The Wingmate Company and its service providers and contractors delete any of your personal information that we collected from or obtained about you, subject to certain exceptions.
• Correction. The right to request that The Wingmate Company correct any inaccurate personal information that we maintain, considering the nature of the personal information and the purposes of its processing. You can also review and change your personal information by signing into your account and visiting your “My Account” page. Please note that we may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
• Portability. The right to obtain a copy of your personal information that was previously provided in a portable and readily usable format, to the extent technically feasible, subject to certain exceptions.
• Opt-Out. The right to opt-out of the processing of personal information for the purposes of targeted advertising and of the “sale” / “sharing” of your personal information (as defined under the CCPA) as described in more detail below. To begin the opt-out process, click the link on our website home page “Your Privacy Choices” and follow the instructions, or email us at privacy@Thewingmate.com. If you would like your opt-out request to extend to personal information that we or third parties collect on our website using cookies, then, from each browser you use to visit our website, please reject all cookies, except those which are strictly necessary, by toggling them off or clicking the “Reject All” button at the “Cookies Settings” link at the bottom of our website. However, please note that this selection is made at the browser and device-level and must be re-selected if you later clear your cache, use a different browser or device, or use a browser that auto-clears the cache. You may also opt-out of “sales” / “sharing” or targeted advertising by visiting our Services with a legally-recognized opt-out preference signal enabled, such as GPC. Note that The Wingmate Company does not use personal information for “profiling” for which certain US privacy laws requires a “profiling” opt-out, as described in “Profiling and Automated Decision-Making” below.

We will not discriminate against you for exercising your rights.

Except for most opt-out requests, we cannot honor your request (such as to provide you with requested personal information) if we cannot verify or authenticate your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us; however, we may ask you to confirm your email address through use of our privacy tool. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

The verifiable consumer request must:

• When appropriate, provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (e.g., name, email, mailing address).
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Depending on your state of residence, you may designate an agent to exercise your rights on your behalf, including any opt-out rights. We reserve the right to take steps to verify the identity of the agent, and that your agent has been authorized to make a request on your behalf. Such steps may include requiring that the agent submit a copy of a qualifying power of attorney or requiring you to confirm the request with us directly. For legal and security reasons, we do not accept requests that would require us to visit an agent’s website.

Appeals 

Residents of certain US states may have the right to appeal a decision with regard to their privacy request—for example, you may appeal our decision to refuse or decline to take action on a request. To exercise a legal right to an appeal, please select the “Appeal Decision” button on the Privacy Rights Form. Upon receipt of such appeal, your appeal will be reviewed by our Privacy Team, and in certain circumstances the VP, Compliance or General Counsel. We will respond with a decision and the written explanation of the reasons for the decision within 45 days of your appeal.

Profiling and Automated Decision-Making

We do not profile or use any form of automated processing on your personal information in furtherance of decisions that produce legal or similarly significant effects within the meaning of applicable US privacy law.

California “Shine the Light” Disclosure

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits customers that are California residents and who provide personal information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared qualifying California personal information during the immediately prior calendar year (e.g., requests made in 2023 would receive information regarding such activities in 2022). You may request this information once per calendar year. To make such a request, please contact us by email at privacy@Thewingmate.com. 

International Rights

If you are a resident of any country outside of the US, such as Canada, the UK, or the EEA, please visit the The Wingmate Company Privacy Policies for your respective jurisdictions, for more information on your privacy rights and how to exercise them. Additional details and instructions can be found on our Privacy Rights Form.

THIRD PARTY SERVICES

Third-Party Websites

This Privacy Policy does not apply to information collected by third-party websites that may be accessible through the Services. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

Third-Party Payment Services and Facilitators

We use third-party payment providers and facilitators to process payments made through the Services, as well as for anti-fraud purposes. If you wish to make a payment through the Services, your personal information will be collected by such parties and will be subject to the party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your personal information.

USE OF SERVICES BY MINORS

Our Services are not intended for children under the age of 16, and children under the age of 16 are not permitted to use our Services. We do not knowingly collect information online from individuals under the age of 16. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 16, we will promptly delete that information. If you believe we might have any information from a child under 16, please contact us by email at privacy@Thewingmate.com. We do not knowingly “sell” / “share” (as those terms are defined under the CCPA and other US privacy laws) the personal information of consumers under 16 years of age.

NOTICE OF FINANCIAL INCENTIVE / BONA FIDE LOYALTY PROGRAM DISCLOSURE

The Wingmate Company offers our customers certain perks, rewards, exclusive offers, and other benefits that can result in superior prices, rates, levels or selections of products and services, such as our military and first responder and friends and family programs or exclusive rewards for account sign-up. These offerings, the details of which will be provided at the time of sign up or opt-in, may constitute “financial incentives” or “bona fide loyalty programs” under certain state privacy laws (collectively “Financial Incentive Programs” or “Programs”). Participation in our Programs is voluntary, and requires your prior opt in consent. If you elect to participate, you may do so through the “My Account” page or by performing certain voluntary interactions with our websites such as submitting your application to any special discount program, the details of which will be provided in the sign-up or participation instructions. While we will not discriminate against you for exercising your privacy rights, if you request deletion of your data that is essential to providing you with the financial incentive, you may not have access to continued discounts and benefits of the program, which we will explain to you at the time of your request. Your participation in any Financial Incentive Program is optional, and you may withdraw from the Program at any time by following the instructions in the applicable Program’s terms, or by contacting us at privacy@Thewingmate.com to delete your account or remove yourself from the Program.

When you sign up for one of these Programs, we may ask you to provide your contact details and other categories of personal information to provide the benefits, including the following: identifiers (like your name), contact information (like your email address), demographic data, commercial or transaction data (like your purchase history), account data, behavioral and preference data (like your purchase and product preferences and interests),  professional and employment-related information, and inferences drawn about your preferences. No sensitive personal data is required for our Financial Incentives Programs. The Wingmate Company uses the personal information of eligible participants to provide the financial incentives and to further our business in accordance with our Privacy Policy. We disclose this information to our service providers that perform services on our behalf, and to our marketing and advertising partners so we can display ads that are targeted to your interests and preferences.

The value The Wingmate Company receives from our Financial Incentive Programs (and its incidental collection of consumer personal information) includes the profits generated by, and the consumer good will and consumer relationship established through, the offering of the Financial Incentive Programs, and taking into account the costs to The Wingmate Company to provide and maintain our Programs. The estimated value will be disclosed to you at the time you sign up for the applicable program. Visit the Terms and Conditions page of each Program to view full details, including how to join.

UPDATES TO THIS PRIVACY POLICY

The LAST UPDATED legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services or indicate an effective date. We will notify you if the notice changes in any material way by placing a prominent notice on our website. 

CONTACT US

If you have any questions, requests, concerns, complaints, or suggestions about this Privacy Policy, have any requests related to your personal information pursuant to applicable laws, or otherwise need to contact us, please contact us at:

The Wingmate Company, LLC

1234 AFD

Brookhaven, GA 30319

United States

404-555-1212

thewingmate.com/contact-us-form

privacy@Thewingmate.com

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

TABLE 1 – SUMMARY OF INFORMATION PRACTICES

This table summarizes our information practices. The fourth column (“entities to whom we disclose it”) also reflects the sorts of entities to whom The Wingmate Company has disclosed particular categories of personal information in the twelve (12) months preceding the effective date of this Privacy Policy.

Please note that all personal information may be disclosed to our affiliates, entities involved in a business sale or similar transaction, as well as entities involved in the protection of The Wingmate Company and other legal compliance, where authorized by applicable law. As such these entities are not listed for each category of personal information below.