Updated: 09/ 5 / 2022
INTRODUCTION:
● This privacy notice (Privacy Notice) sets out the ways in which we, Wing ME (company). (we, us, our), collect and use your personal data (your personal information) in connection with our business, including your use of the Wingme app (the “app”) and https://www.wingme.app/ (the “website”). It also explains what rights you have to access or change your personal data.
● Our website and app are not intended for children. We do not knowingly collect or maintain the personal information of children under the age of 18. If you are under the age of 18, please do not access our website or app at any time or in any manner. We will take appropriate steps to delete the personal information of persons under the age of 18.
The purpose of this Privacy
Policy is to inform you about how Wingme uses your
personal data. We recommend you read it carefully.
Policies with the collection, use, and disclosure of Personal Information if anyone decided to use our Service.
If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.
The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at Wingme.app unless otherwise defined in this Privacy Policy.
Information Collection and Use
For a better experience, while using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to Name, Date of Birth, Email address, Phone number, Instagram ID, Whatsapp username,City,Android Advertising ID. The information that we request will be retained by us and used as described in this privacy policy.
The app does use third party services that may collect information used to identify you.
Link to privacy policy of third party service providers used by the app
Google Play Services
Log Data
We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.
Cookies
Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory.
This Service does use these “cookies”. If you choose to refuse our cookies, you may not be able to use some portions of this Service.
Service Providers
We may employ third-party companies and individuals due to the following reasons:
To facilitate our Service;
To provide the Service on our behalf;
To perform Service-related services; or
To assist us in analyzing how our Service is used.
We want to inform users of this Service that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.
Security
We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
Links to Other Sites
This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Children’s Privacy
These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 18 In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.
If you have any questions or suggestions about
our Privacy Policy, do not hesitate to contact us
Account: The Member’s dedicated
personal area within the Application, which he or she accesses when he or she
registers and connects to the Application. It enables the Member to access the
Services. A Member may only have one Account.
Application: The Wingme
application, available on the Apple App Store and the Google Play Store and on
the Wingme Webapp : wingme.app
Wing Map: a function enabling Members
to increase the visibility of their profile during the time that this option is
activated.
Wingme Location (members): An organization or entity
that may or may not be a member of the wingme
platform. Location members are registered on the wingmap
with a profile that has limited or extensive information based on location.
Wing in (wingme
location Check in): A feature allowing members to check in to a location in
order to be a part and view wing me guest list.
SOS Feature: A button on a location's
profile with protocol to message appropriate authorities in case of an
uncomfortable or threatening situation during visit.
Booking Feature: A button on the location
profile that allows the user to book a location.
Guest List button: A button on the location
profile that shows a list of profiles belonging to members present at the
location
Wing (Guest) list: A list of users that are
also checked into your location or community.
Wingme Communities: You can request to be a part of
different communities, a location based peer to peer
communication forum geared around a mutual interest, ex. Business, Parties,
Sports, etc
Facebook connect: A feature enabling Members
to use their Facebook account to log in to the Application, in order to
simplify the registration process.
Female Members: Members registered on the
Application as female.
Ratio indicator: A feature on the Wingmap
and on certain location profiles indicating how many male and female guests
there are.
Wingme Guest indicator: Shows how many total Wingme user are at the location
Wingme: Wingme,
a UAE joint
stock company (Société par Actions Simplifiée) with
paid-in capital of €36,982.92 registered with the Dubai____ (trade and
companies registry) under no. ______and owner and sole operator of the Wingme application and trademark.
Wingme Premium: All charged Services offered by Wingme
in the form of a subscription whose duration is chosen by the Member.
Home page: Window on the app that
displays information related to the services of Wingme
and then locations near the member
Messages: Non-confidential function
where guests of a location or community can message each other directly.
Wingme User Profile: A users
public profile
Male Members: Members registered on the
Application as male.
Member: A person registered with
the Application.
Member Characteristics: Information provided by the
Member describing his or her lifestyle and personal characteristics on the
profile. The Member can choose the information he or she wishes to appear on
the profile
Premium Member: A Member who has a Wingme Premium subscription of which there are 3 levels
Premium Bronze, Silver and Gold.
Profile Photos: photos on your profile
enabling the easy identification of the Member. The Member accepts to, at the
very least, provide a photo of his or her face in which he or she is clearly
recognizable, and place it in first position. These two criteria combined are
an essential condition for using the Services.
If the photo of the Member’s face is not placed in first
position, it will be automatically placed in first position by default.
Services: All services, whether charged
or free-of-charge, offered by Wingme to encourage
virtual and or real-life meet-ups between Members who are checked into the same
location or community and who have a mutual interest in one another, according
to what members can see from member profiles.
TOS: These Terms of Service.
The data collected is
processed by Wingme, a company registered under number
Wingme is extremely concerned about the protection of your
personal data and respect for your privacy. The purpose of this privacy policy
(along with our terms of service and any other document it
refers to) is to inform you on the way we process the personal data you share
with us and that we collect when you use the Application and Services. Please
read this document carefully to better understand how we process your personal
data, and to know your rights.
This Privacy Policy
applies to all Services published by Wing ME that you use (with the
exception of services supplied and operated by third parties, in which case,
their privacy policy will apply).
Wingme collects and processes personal data on you when you use
the Wingme application or when you communicate with Wingme. It may be information you share with us directly,
or data we collect automatically.
To make sure our privacy policy is clear, we are providing below
an overview of the personal data Wingme collects and
processes. Information is given below for each type of data collected.
● Mandatory data
○ Identification data
○ Depending on how you signed up, email address and/or telephone number
○ Data relating to your activity on the application
○ Technical data of the cell phone or device
○ Data related to booking
● Data required for certain purposes
○ Data relating to taking part in actions to your experience and your satisfaction
○ Geographical position
○ Check in locations with other Members
○ Search preferences - locations and categories of which you would like to go to.
○ In-app messages and communication sent and received
○ Data in direct message with other members
○ Data relating to reports made and requests sent to the Wingme customer service
● Optional data
○ height, profesion, city, nationality, relationship status, looking for, favorite drink, on a friday night you..
○ Member Characteristics
○ Depending on how you signed up, email address and/or telephone number
○ Description
○ Other demographics optionally provided by you
3.1 Data you share directly
When you use our Services, you
share information with us, some of which may be used to identify you. When
you communicate this information, you accept that some of the data will be visible to the other Members of the
Application, and therefore made public on the Application. In an effort to help
you identify this information easily, it is signaled as ‘public’ below. Wing ME
cannot be held liable for data published on its platform and disclosed by a Member. However, information
not marked as Public will not be visible or accessible by other Members;
such information is signaled as ‘private’ below.
Wing ME collects and processes data relating to your
registration and data relating to your interactions with Wing ME.
3.1.1. Registration data
Information required for
registering
This is the basic data required
for you to register and access our Services.
This data is collected by Wing ME using different methods
depending on the type of registration you choose.
If you choose to register
using your Facebook, Apple or Google account, your data will be collected from
the relevant platform in an effort to reduce formalism. By selecting “Log
in with Facebook/Apple/Google,” you agree to having these platforms provide us
with such data.
In addition, you can
register using a cell phone number and, if this is the case, your data will
be sent to Wing ME directly by you.
This data relates to your identity.
Depending on how you registered, some data must be collected in order to provide our Services. If such data is
not obtained, Wing ME will not be able to provide you with its Services via the
Application, and you will not be able to create an Account. In all cases, your
first name (public), age (public), birthdate (private), gender, and at least
one Profile Photo (public) are required to register with the Application.
Subsequently, you may add or remove Profile Photos at any time, providing you
have added at least one Profile Photo containing a person’s face. As stated in
paragraph 1, “Definitions,” the first Profile Photo should be a photo of a
person’s face, otherwise one of your photos of your face will automatically be
put in first position.
If you register using your phone number, you must provide said
phone number in order to register.
When you register via Facebook, we must collect your first name
and your age. You may also allow Facebook to provide Wing ME with your last
name, birthdate, gender, email address, and to transfer your Profile Photos
from Facebook.
When you register via Apple or Google, we must collect your
first name and email address. Said platforms may also provide Wing ME with your
last name.
In addition, if you refuse the geolocation feature when
registering, and thereby the possibility for Wing ME to collect your location
data to suggest Member profiles with whom you share location you must provide
the name of your city. This information will enable Wing ME to suggest Member
profiles in a Wingme communties.
Optional information to
complete your profile
You may add additional information to improve your profile. This
information is optional, shared at your own discretion, and is your sole
responsibility. You can add this information directly to your profile on the
Application and/or via Facebook Connect by syncing your Account with Facebook.
This data is as follows:
● professional career and education (public): profession or studies;
● interests and habits (public): personal preferences, leisure activities, musical preferences, lifestyle, Member Characteristics;
● height (public);
● profile description (public): if you would like to, you can share additional information about you in the space provided for this purpose. This information will be visible to Wing ME Members. Moreover, if you so wish, you can also answer the questions on your lifestyle (aspirations on LOVE, FRIENDSHIPS, and BUSINESS connections).
Your description is a free text area, Wing ME does not encourage Members to share data that can be perceived
as sensitive with other Members, or with Wing ME through the Application.
Sensitive data refers to data that is legally qualified as “sensitive” by the
General Data Protection Regulation (“GDPR”). More specifically, it includes
information on race or ethnicity, political opinions, religious or
philosophical beliefs or affiliation with a union, along with information on
health, sexual life or sexual preferences (“Sensitive Data”). If a Member decides to share such information on
his/her profile regardless, it is deemed to have been “clearly made public”
by the Member who shared it, according to the GDPR.
3.1.2. Data relating to
interactions with Wing ME:
When you contact our customer or support services, report an
issue with our services, ask for help, exercise your personal data rights, or
participate in promotional activities, games, competitions or surveys, when you
share your experience of our services, give testimonies, or answer one of our
questionnaires, Wing ME will collect, depending on the case, the following
personal data:
● Data relating to reports and requests sent to the Wing ME customer service (private): Date and time of the report, nature and reason for the report, data relating to the reported user. Furthermore, proof of identity may be requested as part of the exercise of your rights over your personal data, and for safety/confidentiality reasons.
This data will be collected by Wing ME when you ask for help
from our customer service, exercise your rights over your personal data, report
a problem or another user. Such information is required to handle reports or answer your requests. This
information will also be handled if a report
is made about you. In fact, Wing ME has a legal obligation to collect
reports from its Members brought to its knowledge
regarding contents or behavior likely to infringe our Terms of Service.
● Data relating to taking part in games and competitions, to your experience and satisfaction (private): participation, responses, satisfaction level, suggestions, experience.
Such data is collected by Wing ME when you take part in our
games and competitions, answer our surveys and satisfaction questionnaires,
share your experiences. This data is
mandatory if you wish to take part in the games and competitions organized by
Wing ME. Without this data, Wing ME may not register you for games or
competitions. However, data on your experiences and satisfaction is optional.
3.2 Data we collect
automatically
When you use our services and features, we collect information
on your activities on the Application:
● Activity data (private) (registration date, login dates, on or offline status, interactions with Members and third-party accounts, number of transactions, notifications received, notification preferences, etc.)
When you access our Services and use the Application and its
features, information on the way you use them is collected and processed. Most of the information collected by Wing
ME is necessary to the provision of its Services. Without this data Wing ME
cannot supply the Services linked to the Wing ME application.
More specifically, this includes your registration date, login
dates, on or offline status, the type and number of interactions with other
Members (such as messages and follow ups), with the third-party accounts
connected to your Account (such as Spotify, Instagram), or the number of
transactions made (purchases of features and or subscriptions), notifications
received and notification preferences.
● Geographical location upon check in and proximity relation with other Members (public)
The Application’s main value and purpose is to allow Members to
find other Members that are present in the same location. Your Geographical
position is collected with your express
consent only. In fact, you will be asked to authorize the collection and
processing of your location data to allow Wing ME to identify your specific
location shared with other Members who have agreed to be geolocated.
Unless you have chosen stricter settings on your device, Wing ME
will collect your Geographical position regularly.
When the Geographical positions of Members are mutual Wing ME propagates your profile onto a location guest list
of which you can receive and send direct messages.
Your checked in location will be displayed on the WING page, but
Members with whom you have not been
present in same location will not see your profile. Each Member sees
his/her location when the member checks into the location after entering a
radius defined by Wing ME. They cannot see any other Member’s location unless
they also check into same location.
During your registration, if you do not provide your consent for
geolocation, you must provide the name of your city. This information will
enable Wing ME to suggest profiles of Members in WING ME COMMUNITIES.
Your check in history can be displayed as a news feed or on a
Map (Mapping).
You may, at any time, withdraw
your consent by disabling geolocation on your smartphone. If you choose to
do so, your news feed will no longer be updated, and you will not be able to
see who you is at the same location after disabling
the geolocation option.
.
● Text messages and voice messages sent and received (private)
Messages are sent and stored on Wing ME’s servers, to provide
the Service to allow Members with at same location to have a conversation or
when a Member checks into a location or community. Messages and voice messages are strictly
private and only implicate the Members involved. Wing ME’s authorized
managers do not exercise any rights to view these conversations. These Messages
are not transmitted or communicated to third parties except in cases of
judicial requests, and/or in compliance with the applicable legislative or
regulatory provisions. Moreover, Messages are strictly private and are not
accessible to other Members who are not involved in the conversation, nor to
any third party.
● Technical data of the cell phone or device (IP, mobile ID, application version, telephone version and model advertisement ID, etc.) (private)
We collect information from the devices and equipment you use to
access our Services, including server logs, which may contain information such
as IP addresses, version of the application, device version and model, language
used, operating system, application crashes, and advertisement ID. Data may be
collected with cookies or other tracking tools.
Transaction Data: Wing ME
does not collect or process any banking data. Apple’s App Store and
Google’s Play Store have opted to refrain from sending certain types data to
mobile applications, which includes any banking and financial information. This
data is collected and processed solely by the above platforms, and Wing ME does
not have the option of changing this payment method. The only information
exchanged between Wing ME and Apple’s App Store or Google’s Play Store is
technical data that does not allow us to identify you (for example, a
transaction number), and is used to validate transactions. Wing ME will
therefore retain a history of your purchases and subscriptions but will not
store any information relating to the payment methods you use.
4.1. Supply of services and
features according to our terms of service
● Creation and management of your Account as a Member:
○ Creation of your profile.
○ Registration, deregistration, deactivation of your Member profile.
○ Management of parameters and preferences.
○ Management of subscriptions.
○ Management of access to the Services proposed by Wing ME.
● Managing and storing messages exchanged between Members (Messages, social cue features, Likes, ice breakers).
● Managing subscriptions and paid Services purchased (Bronze, Silver, Gold Packages, etc.)
● Sending information messages relating to the Services or your interactions with other Members (notifications).
Legal basis: Execution of the
contract
The data collected by Wing ME is required to make sure the
Application is running smoothly and to supply the Services, which it is
contractually obliged to provide to Members under the service contract biding
the two parties (Terms of Service).
4.2. Showing profiles of
members at the same geo location mapped and defined by Wingme
● Geolocation to suggest profiles of Members checked into same location.
Legal basis: Consent
When you have given your consent, you are free to withdraw it
any time by disabling the geolocation option on your smartphone. Withdrawal of
consent does not affect any processing carried out before the withdrawal.
Additional information
The aim of the Application is to help you find other Members who
share your interest in locations.
In fact, it allows you to identify mutual presence location with
other Members who have agreed to be geolocated. These check in locations allow
Wing ME to show you profiles of Members who are also at your same location
live.
Legal basis: Execution of the
contract
Processing this data enables us to provide our Services, and
thus, to increase your likelihood of meeting Members in person with whom you
are could be a good match.
● Recommend your Profile via text to other members with whom you have shared a location.
Legal basis: Legitimate
interest
This processing is based on the legitimate interest of Wing ME
to offer Members relevant Profiles as part of its Services. You can contest
this data use at any time by contacting us (see section 11. Contact).
4.3. Suggesting relevant
offers and contents (marketing and advertisements)
● Sending marketing or
advertisement messages or contents:
○ Send the Wing ME editorial newsletter by email. We will stop sending the newsletter to Members who have not opened it in over a year.
○ Distribute marketing contents and advertisements related to Wing ME offers and services on the application and by emails.
○ Provide Members with offers and/or promotions on Wing ME’s services.
Legal basis: Legitimate
interest
This processing is based on the legitimate interest of Wing ME
to share its offers. As relates to the newsletter, you can object to receiving
emails from Wing ME at any time by clicking on the “Click here to unsubscribe”
link provided for this purpose in the emails you receive.
● Conducting marketing operations and advertising outside of the application: we conduct marketing operations and advertising outside of the Wing ME application outside of third-party sites, social networks and third-party applications. If you are already a Member of the Application, we may share you email address and telephone number with such entities to exclude you from our Marketing campaigns. This information is provided for “hashing” purposes. This can also help Wing ME disseminate its campaigns to profiles similar to yours, who may be interested in our Services. The existence of your profile will never be disclosed to these similar profiles. The social networks which may receive your data for this purpose appear in the list of our service providers, available here.
Legal basis: Legitimate
interest
This processing activity is based on Wing ME’s legitimate
interest in excluding you from its promotional content on social media and
advertising its services to non-Members on third-party websites. You may object
to your data being shared with such social networks by contacting us (see
Section 11, Contact) or in the application, by clicking “My Data” and “Manage
my Choices.” If you oppose this, we will no longer be able to exclude you from
our advertising on such platforms.
● Display personalized advertisements on the Wing ME Application with regard to third-party products and services to ensure they are relevant to the Member. These advertisements are personalized based only on your age group, gender and the country and/or city where you live. Your personal preferences will not be analyzed in disseminating such advertising. Personalized advertising also includes the restricting of identical advertisements. As a result, when a Member consents to it, repeated or irrelevant advertisements are limited and the Member will see more diverse content.
Legal basis: Consent
The advertisements displayed on the Wing ME Application are
personalized if you have given your consent. At any time, you may withdraw your
consent to personalized advertising based on your age group and your gender by
contacting wing@wingme.com
● Disseminating on the Wing ME application non-personalized advertisements (based solely on your country), on the products and services of partners and advertisements relating to the products and services of Wing ME.
Legal basis: Legitimate
interest
This processing activity is based on Wing ME’s legitimate
interest in displaying non-personalized advertising in the Application to
non-Premium Members
4.4. Improving and optimizing
our services and our knowledge of how you use them
● Improvement and optimization of the services of Wing ME, of the knowledge of its Members and the manner of using the Services:
○ Statistical studies.
○ Satisfaction survey.
○ Analyses of the use of the Application and Services by Members.
○ Understanding how our Application and its features are used
○ Improving our Application, offers and features
○ Understanding your needs
Legal basis: legitimate
interest
This processing activity is based on Wing ME’s legitimate
interest in improving and optimizing its services, knowing its users and how
its services are used.
● Provide Members with advice on which Profile Photos to publish by analyzing all Members’ profiles, so Members can, if they wish to do so, optimize the way their profile is presented.
Legal basis: legitimate
interest
This processing activity is based on Wing ME’s legitimate
interest in improving the way profiles are presented in the Application. You
may oppose this use at any time by contacting us (see Section 11, Contact).
4.5. Guaranteeing the
security of your personal data
● Detecting or preventing breaches of the security of the Services by identifying and analyzing fraudulent behavior.
Legal basis: Legitimate
interest
This processing is based on Wing ME’s legitimate interest in
guaranteeing the security of its application and the data it processes. You can
object to this use at any time by contacting us (see section 11. Contact).
However, Wing ME may continue to implement the processing if it justifies
legitimate and compelling reasons.
4.6. Preventing and combating
illegal or unauthorized activities (breaches of the terms of service), ensuring
the trust of Members and complying with legal requirements
● Analysing and processing reports of fraudulent/undesirable behavior.
● Managing undesirable behavior and warning, suspending, blocking or deleting the Member’s Account.
● Managing requests to exercise Members’ rights over their data.
Legal basis: Legal obligation
These processes are based on
Wing ME’s legal obligation, as a data host, to remove illegal content as soon
as it becomes aware of it
● Detecting or preventing
fraudulent activities or activities which breach our Terms of Service:
○ Automated analysis of profile data, application activity to detect fake profiles, fraudulent behavior or behavior that breaches the Terms of Service.
● Guarantee the quality of
profiles:
○ Automated analysis of Members’ Profile Photos in order to detect faces, and, as much as possible, exclude fake profiles from the Application, combat fraudulent behavior and guarantee Member identification. You will not be able to create an account if your face cannot be detected in one of your Profile Photos upon registering. If you are prevented from registering even though your Profile Photo does show your face, you may contact us at any time.
Legal basis: Legitimate
interest
This processing is based on Wing ME’s legitimate interest in
preventing and stopping fraudulent activities that may be carried out on its
Services or breach its Terms of Service, and in protecting users’ safety though
profile identification. You can object to this use at any time by contacting us
(see section 11. Contact). However, Wing ME may continue to implement the
processing if it justifies legitimate and compelling reasons.
● Profile certification (as defined in paragraph 1): in order to certify the profile of a member, Wing ME must, having obtained the Member’s consent, collect the his or her biometric data using a video of his or her face, and compare this data with the Member’s Profile Photos. If the faces correspond, a “Certified Profile” badge will be granted. The biometric data are immediately deleted after the comparison. However, the video will be stored in order to reverify the Member’s profile should he or she add or delete other photos. In this case, the biometric data will be collected once again from the same video, then deleted again after comparison with the Member’s new photos.
Legal basis: Consent
Your consent for the use of your biometric data for Profile
certification is requested when you start the certification process. You can
withdraw this consent at any time by clicking on “My Data” then “Manage My
Choices.” If you withdraw your consent, your video will be deleted and your
biometric data will no longer be able to be collected. If you add new Profile
Photos or delete your current Profile Photos, you may lose your “Certified
Profile” badge as the comparison with your face will no longer be possible.
4.7. Providing Members with
help and technical support
● Responding to the requests for support submitting by Members using the Application
Legal basis: legitimate
interest
This processing activity is based on Wing ME’s legitimate
interest in ensuring that its Members can use the
Application in proper technical and operational conditions.
Cookies may be used on our showcase website for technical,
advertising reasons or for measuring audiences. In the Application, cookies and
tracking tools may be used for technical reasons and for measuring audiences.
.
Only certain Wing ME
employees from customer services and authorized managers process Members’
personal data for the purposes described above. These employees and
authorized managers only have access to the data necessary to perform their
duties.
Authenticated and reliable service providers and partners, who may access and/or
process Members’ personal data, in compliance with the Privacy Policy, and
ensuring the security and privacy of the Members’ personal data. These service
providers help us operate and improve our Services, including
● our sub-contractors in charge of data infrastructure and hosting
● suppliers of the analysis software we use
● technical sub-contractors for using the Application and/or ensuring that the Application functions properly
● our customer service to provide Members with the support they need and manage reports;
● our Marketing partners to provide Wing ME Members and non-Members with relevant messages, offers and content.
● Legally binded partnering locations,
merchants, venues, organizations and communities.
As part of marketing and advertising operations outside the
Application intended for non-Members, your data may be provided to partner
social networks in order to exclude you from our campaigns, unless you oppose
that.
For more detail, please refer to the list of our
sub-contractors and partners.
In addition, at the request of state bodies, in particular the judicial authorities, and in order
to comply with any judicial or legal request, Wing ME may transmit the personal
data of its Members.
Lastly, we may be required to share your data for the purposes of corporate operations,
which include, but are not limited to, a restructuring, a change in control of
the company, a merger, an acquisition, a transfer, or a termination of the
company.
The personal data of Members processed as part of their use of
the Application is hosted in the European Union.
However, the personal data of Members are transferred to Wing ME subcontractors located outside the European
Union, for Member support, report management, advertising and marketing.
Transfers of data outside the European Union may be made to countries in relation to which
no adequacy decision has been taken by the European Commission on the
protection of personal data. Wing ME guarantees that transfers are made under
conditions ensuring the confidentiality and security of the data and providing
an adequate level of protection compliant with regulations. These transfers are governed by standard
contractual clauses of the European Commission.
To obtain a copy of these, please contact our Data Protection authoritys at wing@Wingme.com
For the exact location of our recipients, please refer to the list of our
sub-contractors and partners.
In compliance with the French Data Protection Act of January 6th, 1978 (Loi Informatique et Libertés,
78-17), and the GDPR, every Member has a right to access, rectify, and a right to data portability
and removal of his/her personal
data, along with a right to object to or limit
processing of his/her personal data, and the right to decide on the way to handle the personal data after his/her death.
In an effort to address its Members’ concerns, Wing ME
commits to respecting the protection of personal data and to process requests
as soon as possible.
Members may exercise their rights, subject to proving their
identity, by sending an email to support@WingME.app, by exercising their rights
directly via the Application, or by sending a letter to the following postal
address: for the attention of the Data Protection authority, Wing ME -Address in dubai
office. For confidentiality reasons, if there is a doubt on the
requesting party’s identity, proof of identity may be requested.
For any other claim, the Member may lodge a request with the
national authority responsible for data protection.
● The right to access allows a Member to ask Wing ME for data pertaining to him/her in an accessible format, based on the terms and conditions of Article 15 of the GDPR. Your right of access must not infringe on the privacy of third parties, which is why you will only have access to your personal data and not that of third parties (for example, only messages that you have sent will be communicated to you and not those that you have received).
● The right to correct grants a Member the right to demand Wing ME corrects, adds to, updates or removes any personal data on him/her that is inaccurate, incomplete, ambiguous, out-of-date, or whose use, communication or storage is prohibited based on the terms and conditions of Article 16 of the GDPR. You can modify or rectify some data directly on the Application. You just need to go on your profile and make changes directly in the sections “My photos”, “Work and Education (Job, Employer, School)”, and “About me”. When you have registered via Facebook Connect, to change your first name, age, or gender, go to your Facebook page and update the “About me – contact and basic info” section of your profile. When you have registered via a cell phone number, you must send a letter or contact customer support at the addresses listed above, to change your first name, age or gender. In case of error, your age can be rectified once, directly on the Application.
● The right to data portability grants a Member the right to receive the personal data he/she gave to Wing ME, in a structured, commonly used format, legible on a machine, and to forward them to another processing entity, in compliance with Article 20 of the GDPR.
● The right to contest grants a Member the right to object, free of charge and at his/her own discretion, to the use of his/her data by Wing ME for canvassing, especially commercial canvassing, and to the processing based on Wing ME’s legitimate interest, in compliance with Article 38 of the French Data Protection Act and Article 21 of the GDPR. For processing based on legitimate interest, Wing ME retains the option to justify legitimate and compelling reasons to continue processing.
● The right to delete grants a Member the right to demand the removal, free of charge and at his/her own discretion, of data transmitted to Wing ME, within the limits of the rights based on Article 17 of the GDPR. Also, you can delete your Account using the corresponding feature on the Application. We inform you that all your data will be deleted from the Wing ME application. However, Wing ME, as the host, has a legal obligation to retain your personal data for one year under Article 6-II) of the French Trust in the Digital Economy Act no. 2004-575 of 21 June 2004. Your data will be kept in an archive database kept separate from our production databases and only for the purpose of responding to a court order. Data will be permanently deleted after one year.
● The right to limitation grants Members the right to request the temporary suspension of the processing of their data by Wing ME under the conditions set out in Article 18 of GDPR.
● The right for the Member to set the guidelines for the retention, deletion and communication of his/her personal data after his/her death, in compliance with Article 85 of the French Data Protection Act.
These rights may only be exercised within the limits of Wing
ME’s resources as it relates to its use of Facebook, Google and Apple to log
into the Application. Some data sent to Wing ME by Facebook, Google or Apple
cannot be corrected without Facebook, Google or Apple’s cooperation.
Wing ME has introduced a process for automatically deleting your
account and your personal data with regard to the storage time limits defined
below. When certain data must be stored for statistical uses beyond these
storage time limits, this data is anonymized irreversibly to ensure you can no
longer be identified.
Wing ME will store the Member’s data for as long as required in
order for the Member to use his/her Account, namely:
● For the length of the Member’s registration, plus one year. After one year of inactivity on an Account, the Account will be deleted and the Member’s data will be retained for another year, before being permanently destroyed or irreversibly anonymized. An account is considered inactive when the Application of the Member has not established contact with Wing ME’s servers (including due to deactivation of the geolocation process); and the Member has not used the Application. In any event, the Account of a Premium Member is not considered inactive. Furthermore, please note that in accordance with its status as a hosting provider, Wing ME has a legal obligation to retain some of its Members’ personal data for a period of one year based on Article 6, II of the French Trust in the Digital Economy Act (Loi pour la Confiance dans l’Économie Numérique) of 21 June 2004.
● When a Member is banned, his/her Account becomes inactive. Information from this Account is retained in an active database for one year, in order cross check it with information provided with new registrations to the Application, in order to prevent, to the extent possible, banned users from registering again. Subsequently, the personal data is archived for one more year, after which it is deleted permanently or irreversibly anonymized.
● When the Member deletes his/her Account or requests its deletion from Customer Service, it will be deleted from the Application. However, the Member’s data will be kept in a separate archive for one year before being permanently destroyed or irreversibly anonymized, in order to enable Wing ME to comply with its obligation to keep it as host.
● Some of the Member’s data, such as email address and telephone number, will be retained for prospecting or Marketing purposes (see Article 4.3) or to be analyzed in order to improve and optimize our service (see Article 4.4) for one year after an Account has been inactive for one year. If a Member deletes his/her Account, this data will not be used for prospecting or marketing purposes.
With regard to your Geographical Positions and check in
location, shorter storage times apply:
- Your Geographical
Positions are stored for__from their collection in
order to determine your shared location with other members.
- Your meet data message
date and preference data is stored for ___ long.
- Wing ME undertakes to make every effort and to invest all
means at its disposal to guarantee that the stored data is kept as secure as
possible. However, it is the Member’s responsibility to take appropriate
measures to protect his/her data.
Wing ME shall not collect
data from minors. Should a Member lie about his/her date of birth, and
particularly if he/she fraudulently claims to be an adult, the parents of the
minor in question should inform Wing ME of this fact by sending an e-mail to
one of the contacts mentioned in Article 11 “Contact”, requesting the data to
be deleted. Wing ME commits to deleting all data on the minor in question as
soon as possible.
If you have any questions
regarding this privacy policy, or any other request concerning your personal
data, you can contact us:
● By sending an e-mail to our contact e-mail address wing@WingME.app.
● By sending a letter to the following address: for the attention of the Data Protection authority, Wing ME -Address