Privacy Policy

About This Policy

Wingz, Inc. (Wingz, or “we”, “us”, and “our”) values and respects your privacy and shares how we collect, use, share, and protect your Personal Information by communicating this policy (“Privacy Policy”). This Privacy Policy describes how Wingz handles person information:

·        From visitors to our website or web-based applications (“Websites”)

·        From visitors to our social media on third-party websites and applications like Facebook, YouTube, Instagram, and Twitter(“Social Media”)

·        Through your phone and email communications with us

·        Through your viewing, clicking, or interacting with our online advertisements or emails

·        Contacts at our clients and/or prospective clients

·        Contacts for suppliers of goods and services to Wingz

·        From any other individual about whom Wingz obtains Personal Information in the provision of goods or services to our clients (“Client Services”)

·        From those who apply to work for us as a contractor or employee

The items outlined above are collectively called “Services”.

Your visit to our Websites or Social Media, or use of any of the Services, is subject to this Privacy Policy (“Policy”) and these Terms of Use (“Terms”).By visiting or using any of these Services, you agree to this Privacy Policy and the Terms, which may be updated by us at any time. If we update this Policy or the Terms, we will post the updated document on the Websites. Any such changes will be effective upon posting. We urge you to review the Policy and Terms each time you visit our Websites. If you do not agree with any provision of the Policy or the Terms, you should not use our Services.

Personal Information That We Collect

We may collect and process various types of information in connection with the Services we provide, including those described below which are collectively referred to herein as “Personal Information”:

·        Personal information: such as name, address, phone numbers, email address, Social Security number, driver’s license number, passport number, date of birth, online identifier, Internet Protocol address, or other similar identifiers.

·        Commercial information: such as records of products or services purchased, obtained, used, or considered, or other purchasing or consuming histories or tendencies.

·        Financial and payment data: including bank and other financial account information and other information necessary for processing payroll, payments, billing and invoicing, as well as fraud prevention.

·        Online activity and usage data: including information collected during your visits to our Websites and Social Media, including Internet Protocol address, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system, and platform. To learn more about our use of cookies, please see “Cookies and Similar Technologies” below.

·        Geolocation data: such as physical location or movements, including through the use of Global Positioning System(GPS) data when in a vehicle as a driver or passenger in the course of providing or receiving any Services.

If you provide Personal Information to us about any person other than yourself, such as your employees, suppliers, shareholders or directors, you must ensure that they understand how their information will be used and disclosed. By providing such information, you represent that you have provided any required notices and/or obtained any required consent or authorization to disclose it to us and for you to allow us, and our outsourced service providers, to use and disclose it as set forth in this Privacy Policy.

Sources of Personal Information

Wingz may collect the Personal Information described here in from a variety of sources, including:

·        Directly from you: such as forms you complete and submit to us, information you enter on our Websites or Social Media, or information you provide to use via telephone, email, written communications, or other methods.

·        Automatically: when you access or use our Websites and Social Media through various tools and technologies, including cookies, web server logs, web beacons, and other tracking technologies.

·        Third parties: information provided to us from third parties, including our business partners, clients/customers, service providers, and others. When you submit information to another party, you are solely subject to that party’s terms of use and privacy policies. Wingz is not responsible or liable for the accuracy of the information provided by other parties or for third-party policies or practices.

·        Other sources: such as publicly available and subscription-based sources, court documents and filings, event sponsors, our clients, counterparties in transactions or disputes, social media, our service providers.

Uses of Personal Information

We collect, use, and otherwise process the Personal Information referred to above for various purposes, including:

·        Providing Services: to deliver and improve our Services, process transactions, and provide customer support.

·        Work Purposes: to consider applicants, hire for employment, or engage for independent contractor services, including for onboarding, payroll, benefits, taxes and withholding, and other aspects of employment or independent contractor services.

·        Communication: to send you updates, newsletters, and other information related to our Services, including rides driven or ridden with us.

·        Personalization: to tailor our Services to your preferences and interests.

·        Security: to protect against fraud, unauthorized access, and other security issues.

·        Legal Compliance: to comply with legal obligations and respond to legal requests.

Disclosure and Sale of Personal Information

We may disclose and reserve the right to disclose Personal Information internally and to third parties including the following:

·        Our owners, employees, and agents

·        Our subsidiaries, affiliates, and joint venture partners, business partners, suppliers, and subcontractors in connection with the performance of Services for you

·        Contractors, vendors, and services providers

·        Courts, arbitrators, mediators, and others as necessary in any legal disputes

·        Legal or other advisors, consultants, and other professional experts

·        Analytics and search engine providers that assist us in the improvement and optimization of our Websites and Social Media.

We may also disclose Personal Information internally and to third parties to:

·        Comply with applicable laws and regulations

·        Cooperate with public and government authorities

·        Cooperate with law enforcement

·        Enforce our terms and conditions

·        Protect our rights, privacy, safety or property, and/or that of our affiliates, or others.

·        Effectuate any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) with a third party

Wingz does not sell any Personal Information to any other person.

Protection of Personal Information

We use reasonable and appropriate measures designed to protect Personal Information from accidental loss or destruction and from unauthorized access, use, alteration and disclosure. Unfortunately, no method of transmission or electronic storage is completely secure and while we strive to protect your Personal Information, we cannot guarantee its absolute security and Wingz makes no representation or warranty as to the security of Personal Information.

Information Relating to Minors

The nature of our services is not intended for individual sunder the age of 13. We do not collect any Personal Information from any person we actually know is under the age of 13. If we learn that we obtained Personal Information about a child under the age of 13, we will remove such information from our records once we receive actual notice that such information has been collected.

Cookies and Similar Technologies

We use cookies and similar technologies to enhance your experience on our Websites. Cookies are small data files that are placed on your device when you visit a website. They help us understand how you interact with our site, remember your preferences, and improve our services.

Types of Cookies We Use:

·        Essential Cookies: These cookies are necessary for the website to function properly and cannot be switched off in our systems.

·        Performance Cookies: These cookies help us understand how visitors interact with our Websites by collecting and reporting information anonymously.

·        Functional Cookies: These cookies allow the Websites to remember choices you make and provide enhanced, more personalized features.

·        Targeting Cookies: These cookies are used to deliver advertisements that are more relevant to you and your interests.

Managing Cookies: You can control and manage cookies through your browser settings. Please note that disabling cookies may affect the functionality of our Websites and your ability to use certain features.

Third-Party Cookies: We may also allow third-party service providers to use cookies and similar technologies on our Websites for analytics and advertising purposes. These third parties may collect information about your online activities over time and across different websites.

By using our Websites, you consent to our use of cookies and similar technologies as described in this Privacy Policy. If you have any questions or concerns about our use of cookies, please contact us through the options provided in the Contact Us portion of this Privacy Policy.

Choices and Access

You have choices regarding marketing-related communications. If you no longer want to receive marketing-related emails from Wingz, you may opt-out by following the unsubscribe instructions in our marketing emails.

If you would like to request to review, correct, update, suppress/delete, or object to or restrict processing of your Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company, please contact us in accordance with the Contact Us section below.

In your request, please make clear what you are seeking in your request, including what Personal Information is subject to your request. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

How Long We Keep Your Personal Information

We will retain your Personal Information for as long as you are a client, the performance of our Services requires, and/or as long as the law or our ethical obligations require.

Third Party Websites

Our Websites may contain links to unaffiliated third parties, such as Facebook, Twitter, and LinkedIn. This Privacy Policy does not apply to such third-party sites. When you click a link to visit a third-party website, you will be subject to their website’s privacy practices. We encourage you to review the privacy and security practices of any linked third-party website before providing any Personal Information on that website.

Non-Confidential Information

If you send us ideas, comments, suggestions, or questions regarding Wingz’s products or services or the content of this web site, we may use, disclose, or distribute the information to others without your permission or knowledge. We may use any ideas, concepts, or techniques you send us for any purpose, including to develop or market our products.

Contact Us

If you have questions or concerns regarding our Privacy Policy or practices, you may contact us using the following details:

·        Email Address: legal@wingz.com

·        Postal Address:

Wingz, Inc.

Attn: Legal

One Glenlake Parkway

Suite 650

Atlanta, Georgia30328

Changes to This Privacy Policy

We reserve the right to change this Privacy Policy at anytime. When we do, we will post the current version on this site, and we will revise the version date located at the top of this page. Any changes become effective when we post the revised Privacy Policy. Your continued use of our Services following these changes means that you accept the revised Privacy Policy.

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Supplemental Privacy Notice For Residents of Texas

This Supplemental Privacy Notice (“Notice”) supplements the information contained in the above Privacy Policy and applies solely to visitors, users, and others who reside in Texas (“consumers” or “you”). The other provisions of the Privacy Policy continue to apply except as modified in this Notice. We adopt this Notice to comply with the Texas Data Privacy and Security Act (“TDPSA”). Unless otherwise stated, any terms defined in the TDPSA have the same meaning when used in this Notice.

Categories of Personal Data Processed:

We process Personal Data under the TDPSA, including Sensitive Data, that is linked or reasonably linkable to an identified or identifiable individual. Personal Data does not, however, include deidentified data or publicly available information. In particular, we process the following categories of Personal Data that is linked or reasonably linkable to an identified or identifiable individual:

Sources of Personal Data: We process Personal Data from the sources described in the “Sources of Personal Information” section of the Privacy Policy above.

Purpose for Processing Personal Data: We process Personal Data for the purposes described in the “Uses of Personal Information” section of the Privacy Policy above, which are further described below:

·        To provide you with information, products, or Services. We engage in this activity to fulfil our ethical, legal, and contractual obligations with our clients.

·        Management of our business operations and administration of our client relationships, including to contact you and/or provide you with email alerts and other notices concerning our products, Services, events, or news that may be of interest to you. We engage in this activity to fulfil our ethical, legal, and contractual obligations with clients and suppliers.

·        Enhancing the functionality of our Websites and Social Media. We engage in this activity because we have a legitimate interest in monitoring how our Websites and Social Media are used to help us provide better services to our Website and App users, and to customize or personalize the experience for you.

·        Fraud and security monitoring purposes. We engage in this activity because we have a legitimate interest to detect and prevent fraud, crimes, and other misuses of our Websites, Social Media, and networks.

·        To carry out our obligations and enforce our rights including those arising from any contracts entered into with you including for billing, payment, and collections. This includes fulfilling contract obligations or taking steps linked to a contract, including providing Services, verifying your identity, and processing payments.

·        To provide, support, personalize, and develop our Site, products, and Services, and to create, maintain, customize, and secure your account with us;

·        Data analysis, to improve the efficiency of our Services and identify trends. We engage in this activity to manage our relationships with clients, to comply with legal obligations, and/or because we have other legitimate interests.

·        Auditing internal process for proper functioning. We engage in this activity to manage our relationships with clients, to comply with legal obligations, and/or because we have other legitimate interests.

·        For testing, research, analysis and product and service development. We may use data, including public feedback and surveys, to conduct research and for the development of the Websites and the Services, products, and information we provide.

·        To provide relevant marketing materials. We engage in this activity because we have a legitimate interest or because we have obtained consent.

·        To respond to law enforcement requests and to comply with legal and regulatory obligations. We engage in this activity to manage our relationships with clients, to comply with legal obligations, and/or because we have other legitimate interests.

·        To manage our recruiting efforts and employment and workforce relationships and to evaluate and consider individuals for employment, to manage on-boarding procedures, and to provide employment and its related. We engage in this activity because we have a legitimate interest and/or to comply with our legal obligations.

Sale of Personal Data: We do not sell any Personal Data (as “sale of personal data” is defined in the TDSPA)to third parties, although we do disclose Personal Data to third parties as described in the following section. We also do not have actual knowledge that we have sold Personal Information of minors under age 16.

Disclosure of Personal Data: We do not sell any Personal Data (as “sale of personal data” is defined in the TDSPA),but we may or do disclose Personal Data to third parties in order (a) to process Personal Data on our behalf; (b) to provide a product or Service requested by you; (c) to disclosure or transfer Personal Data to an affiliate of Wingz; (d) to disclose information to you; or (e) to disclose or transfer Personal Data to a third party as an asset that is part of a merger or acquisition. For those purposes, we disclose the following categories of Personal Data: identifiers, financial account data, commercial information, internet or other activity information, geolocation data, sensory data, professional or employment-related information, and sensitive data to the categories of recipients identified and described in the “Disclosure and Sale of Personal Information” section of the Privacy Policy above.

Retention of Personal Data: Please see “How Long We Keep Your Personal Information” above for information about how long we retain your Personal Data.

Your Rights as a Texas Resident: The TDSPA provides Texas residents the following rights:

·        To request that Wingz confirm whether it is processing your Personal Data and to access any of your Personal Data.

·        To correct inaccuracies in your Personal Data.

·        To delete Personal Data provided by or obtained about you.

·        If the data is available in a digital format, to obtain a copy of your Personal Data in a portable, and to the extent possible, readily usable format that allows you to transmit the data to another controller without hindrance.

·        To opt out of the processing of your Personal Data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of a decision that produces a legal or similarly significant effect.

How to Exercise Your Rights Under the TDSPA:

How to Contact Us and Information Needed.

To exercise your rights described above under the TDSPA, please submit a request to us by either:

·        Using the Contact Us page on our website at https://www.wingz.com

·        Emailing us at legal@wingz.com

You may designate another person to serve as your authorized agent and act on your behalf to opt out of the processing of Personal Data. Wingz will comply with an opt-out request received from an authorized agent if we are able to verify, with commercially reasonable effort, your identity and the authorized agent's authority to act on your behalf. We are not required to comply with an opt-out request received from an authorized agent under this section if: (a) the authorized agent does not communicate the request to us in a clear and unambiguous manner; (b) we are not able to verify, with commercially reasonable effort, that you are a resident of Texas; (c) we do not possess the ability to process the request; or (d) we do not process similar or identical from consumers for the purpose of complying with similar or identical laws or regulations of another state.

With respect to the processing of Personal Data belonging to a known child, a parent or legal guardian of the child may exercise the rights above on behalf of the child.

You are not required to create a new account to exercise your rights under this subpart but may be required to use an existing account that you have with us, if any.

Response Time and Format.

Wingz will respond to a request without undue delay, and generally within 45 days after the date of receipt of the request. We may, however, extend the response period once by an additional 45 days when reasonably necessary, taking into account the complexity and number of requests. In that case, we will notify you of the extension within the initial45-day response period, together with the reason for the extension.

If we decline to take action regarding a request, we will inform you without undue delay, and within the 45-day response period or extended period, of the justification for declining to take action and provide instructions on how to appeal the decision.

We will provide information in response to a consumer request free of charge, at least twice annually per consumer. However, if are quest from a consumer is manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee to cover the administrative costs of complying with the request or may decline to act on the request.

If we are unable to authenticate a request using commercially reasonable efforts, we are not required to comply with a consumer request submitted under this subsection and may request that the consumer provide additional information reasonably necessary to authenticate the consumer and the consumer's request.

How To Appeal

If Wingz declines to take action on a request as indicated above, you may appeal the decision by submitting a request for appeal within 14days after receiving notice of our decision. You may submit an appeal by contacting us through any of methods outlined above for submitting an initial request and clearly indicating the decision being appealed and the reasons for the appeal.

We will review a timely request for appeal and inform you inwriting of any action taken or not taken in response to an appeal within 60days day after the date of receipt of the appeal, including a written explanation of the reason or reasons for the decision. If your appeal is denied, our response will include information through which you may contact the attorney general.

Changes to this Notice.

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the applicable Websites and update the notice’s effective date. Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your information described here, your choices and rights regarding such use, please contact us through the methods described in the “Contact Us” section above.