Privacy Policy

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do we collect any information from third parties? No. We collect personal information directly from users when they create an account or use our Services.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include:

• names
• phone numbers
• email addresses
• usernames
• passwords
• contact or authentication data
• profile photos
• progress photos
• body measurements, including height, weight, and body measurements
• workout and nutrition data
• messages and files shared through in-app chat
• health and fitness information
• age
• payment transaction information
• purchase and package history

Sensitive information

When necessary, with your consent or as otherwise permitted by applicable law, we process health data.

Payment data

Payments are processed by Stripe. Wings does not collect or store payment card information. Stripe collects and processes payment card details in accordance with its Privacy Policy. Wings stores only payment transaction information necessary to provide the Services, such as transaction status, purchased package, and payment identifiers.

Payments made through the Wings app are processed securely by Stripe. This includes trainer subscriptions and the purchase of coaching packages from personal trainers. Wings does not collect or store users' payment card information. Payment card details are collected and processed directly by Stripe in accordance with Stripe's Privacy Policy.

Application data

If you use our application, we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information such as your mobile device ID, model, manufacturer, operating system, version information, system configuration information, device and application identification numbers, browser type and version, hardware model, internet service provider and/or mobile carrier, and IP address or proxy server.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application. If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our applications, for troubleshooting, and for our internal analytics and reporting purposes. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity, like your name or contact information, but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more in our Cookie Notice.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files.
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data or user behavior data, Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• to facilitate account creation and authentication and otherwise manage user accounts;
• to deliver and facilitate delivery of services to the user;
• to respond to user inquiries and offer support to users;
• to send administrative information to you;
• to fulfill and manage your orders, payments, returns, and exchanges made through the Services;
• to enable user-to-user communications;
• to request feedback;
• to protect our Services, including fraud monitoring and prevention;
• to identify usage trends;
• to save or protect an individual's vital interest;
• to create and manage personalized workout plans;
• to create and manage personalized nutrition plans;
• to track fitness progress, including body measurements, workout history, progress photos, and achievements;
• to sync health data from Apple Health when the user has granted permission;
• to manage trainer-client relationships;
• to process in-app payments and manage coaching package purchases;
• to manage connected payment accounts, including Stripe accounts, payouts, and payment-related features.

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on. As such, we may rely on:

• Consent
• Performance of a Contract
• Legitimate Interests, such as analyzing usage, diagnosing problems, preventing fraud, and understanding user experience
• Legal Obligations
• Vital Interests

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We also may need to share your personal information in these situations:

• Business Transfers, such as mergers, sale of company assets, financing, or acquisition;
• Other Users, including public areas of the Services.

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies, like web beacons and pixels. We also permit third parties and service providers to use online tracking technologies for analytics and advertising. To the extent these are deemed a "sale" or "sharing" under applicable US state laws, you can opt out as described in section 12. See our Cookie Notice.

Google Analytics: We may share your information with Google Analytics. To opt out, visit Google Analytics Opt-out Browser Add-on.

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Germany. Your information may be transferred to and processed in facilities of third parties, including facilities in the United States and other countries. We have implemented measures such as the European Commission's Standard Contractual Clauses to protect your personal information for international transfers.

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it, or securely store and isolate it until deletion is possible.

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

Despite our safeguards, no electronic transmission or storage technology can be guaranteed 100% secure. Transmission of personal information is at your own risk.

In Short: We do not knowingly collect data from or market to children under 16 years of age.

By using the Services, you represent that you are at least 16 or are the parent or guardian of such a minor. If we learn personal information from users under 16 has been collected, we will deactivate the account and delete such data. Contact wings.app@yahoo.com.

In Short: Depending on your state of residence in the US or region, including the EEA, UK, and Switzerland, you have rights over your personal information. You may review, change, or terminate your account at any time.

Rights in the EEA, UK, and Switzerland may include access or copy, rectification or erasure, restriction of processing, data portability, and objection to automated decision-making. Contact wings.app@yahoo.com.

Complaints in the UK are acknowledged within 30 days, investigated without delay, and you will be kept informed of progress. If you are unhappy with our final response, you may refer the matter to the Information Commissioner's Office at ico.org.uk/make-a-complaint, Helpline 0303 123 1113, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

You can withdraw consent at any time by contacting us. This does not affect prior lawful processing.

You can log in to account settings to update information, or contact us. Upon termination request, we deactivate or delete your account, but may retain some information for fraud prevention, troubleshooting, investigations, or legal compliance.

Most browsers accept cookies by default. You can set your browser to remove or reject cookies, which may affect certain features. See our Cookie Notice.

We do not currently respond to DNT browser signals, as there is no uniform technology standard for recognizing them yet.

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information.

Categories of Personal Information Collected in the Past 12 Months

Categories A, B, C, D, F, G, H, and L are retained as long as the user has an account with us.

We may disclose personal information to service providers under written contract. We have not sold or shared personal information for a business or commercial purpose in the preceding 12 months, but have disclosed categories A, B, C, D, F, G, H, and L to third parties for business or commercial purposes.

Your rights under US state laws may include the right to know, access, correct, delete, obtain a copy, non-discrimination, opt out of targeted advertising, sale, or profiling, and depending on your state, access categories of data processed, obtain lists of third-party categories or specific third parties data was disclosed or sold to, review or correct profiling, limit use of sensitive data, and opt out of biometric or facial recognition data collection.

To exercise your rights, contact wings.app@yahoo.com, use in-app support or bug reporting, or submit a data subject access request. Authorized agents may submit requests with proof of authorization. Identity verification will be required. Appeals for denied requests can be sent to wings.app@yahoo.com. If denied, you may complain to your state attorney general.

California residents may request, once a year and free of charge, information about categories of personal information disclosed to third parties for direct marketing purposes.

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws. The updated version will be indicated by the revised date. Material changes will be notified via prominent notice or direct notification.

Email: wings.app@yahoo.com

Post:

You may have the right to request access to the personal information we collect, details on processing, correct inaccuracies, or delete personal information, and withdraw consent. To request review, update, or deletion, please fill out and submit a data subject access request or contact wings.app@yahoo.com.