Privacy Policy

This is the Privacy & Cookie Policy for the website hosted at https://w.inboundlabs.co/ and https://wingfoil.com/ ("our site"), and for other Wingfoil site at which you may provide your personal data, such as sponsored events. The site is operated by or on behalf of Wingfoil, Inc. ("we","us"). We are committed to protecting and respecting your privacy.

This policy (together with our terms of service and any other documents referred to in it) sets out:

Information we collect about you
Cookies and other technologies
How we use your information
Our promotional updates and communications
Who we give your information to
Where we store your information
How we protect your information
How long we keep your information
Your rights
Changes to this policy
Contact us

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By engaging in our site and services, you acknowledge you have read and understood this privacy policy. For the purposes of Applicable Data Protection Laws including the European Economic Area data protection law, (the "Data Protection Law"), the data controller is: Wingfoil, Inc., 10800 NE 8th Street, Suite 600, Bellevue, WA 98004, U.S.A.

Information we collect about you

We will collect and process the following personal data from you:

Information you give us.
This is information about you that you give us directly when you interact with us.
This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, search for a product, in discussion boards or other social media functions on or via our site, enter a competition, promotion or survey, submit a query, providing information at trade shows or sponsored events and when you report a problem with our site.
The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph, login and password details.
It may also include employment details if you send us a CV, resumé or other details of your employment history in connection with an advertised job vacancy or a general enquiry regarding employment opportunities with us.

Information we collect about you from your use of our site

We may automatically collect information from you each time you visit our site. This includes:

Technical information
Information about your visit
IP Location data

Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, operating system and platform;
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
Location data - IP addresses are collected and location is inferred based on IP location.

Information we receive from other sources.

This is information we receive about you:

If you use any of the other websites or apps we operate or the other services we provide.
From third parties we work with.

In this case, we will have informed you when we collected that data if we intend to share your data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers).

Cookies and other technologies

Our site uses cookies and/or other similar technologies such as pixel tags or web beacons to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content. Our site uses cookies and similar technologies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and use our service and also allows us to improve our site. Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this. However, you may not be able to take full advantage of our website if you do so. A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser. Others are used to remembering you when you return to the site and will last for longer. We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use. The full Wingfoil Cookie Policy can be found on this document.

How we use your information

We use information held about you in the following ways:

Information you give to us:
We will use this information to:
- Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us including:
  - administering your account with us;
  - Verifying and carrying out financial transactions in relation to payments you make;
  - notifying you about changes to our service.
- Provide you with information about our products or services we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications.
- Ensure in our legitimate interests that:
  - content from our site is presented in the most effective manner for you and for your computer.
  - we provide you with the information, products and services that you request from us.
Information you give to us:
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To keep our site safe and secure.
- For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
- To allow you to participate in interactive features of our service, when you choose to do so.
Information we receive from other sources
We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Our promotional updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our products and services. You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by submitting your email address here.

Who we give your information to

We may give your information to:

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.
Selected third parties
Our selected third parties may include:
- Organisations such as Airtable (Privacy policy), Google (Privacy policy), Instagram and by extension; Facebook (Privacy policy). Who process your personal data on our behalf and in accordance with our instructions and applicable law. This includes organizations supporting the services we offer through the site, in particular organizations providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, and facilitating feedback on our services. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in the Wingfoil group of companies) will only use your information to the extent necessary to perform their support functions.
- Analytics and search engine providers such as Google (Privacy policy), that assist us in the improvement and optimisation of our site and are subject to the cookie section of this policy (this will not identify you as an individual).
- Payment processing providers who provide secure payment processing services. (Your payment card details are not shared with us by the provider.)
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets, subject to the terms of this Privacy Policy.
- If Wingfoil or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of service, terms of use, and other agreements with you; or to protect the rights, property, or safety of Wingfoil , our customers, or others.

Where we store your information

The data that we collect from you will primarily be stored in the USA and in the European Economic Area ("EEA"). Data that is transferred to, or stored at, a destination outside the EEA that may not be subject to equivalent Data Protection Law. Where your personal information originates in the EEA or Switzerland and is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy. To comply with European Union data protection laws, Wingfoil self-certified under the E.U.-U.S. Privacy Shield.

If your personal information originates in the EEA, we may transfer it outside the EEA:

In order to store it.
In order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.
Where we are legally required to do so.
In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

We may transfer your personal information to the following countries outside the EEA:

United States - Wingfoil is E.U.-U.S., so this is treated as a transfer to an ‘Adequate Country’ for EU data protection purposes

Child safety

The site is intended for use only by professionals and persons who are at least 16 years of age. By using the site, you confirm to us that you meet this requirement. If you are under the age of 18, you confirm you have received permission from your parent or guardian before using this site or sending us personal information.

Payment processing

Payment details you provide will be encrypted using secure sockets layer (SSL) technology before they are submitted to us over the internet. Payments made on the site are made through our payment gateway provider. You will be providing credit or debit card information directly to the operator which operates a secure server to process payment details, encrypting your credit/debit card information and authorizing payment. Information which you supply is not within our control and is subject to the operator's own privacy policy and terms and conditions.

How we protect your information

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

How long we keep your information

We retain personal data during any period in which you have expressed an interest in our products and services, for as long as you have an account with us in order to meet our contractual obligations to you, and for six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

EU Citizen rights under GDPR

You have the right under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data, including the right to object to marketing;
- to request that your provided personal data be moved to a third party.
You may opt out at any time from allowing further access by us to your location data by emailing legal@inboundlabs.co .
Your right to withdraw consent:

Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by going here.

You can also exercise the rights listed above at any time by contacting us at legal@inboundlabs.co

We would appreciate the opportunity to directly address any GDPR issues you may have. Please contact us at legal@inboundlabs.co

You do, however, have the right to approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html for data protection authorities in the EU).

Data processed on behalf of our Customers

Wingfoil may process personal data on behalf of its customers. We are not the controllers of this data and act as data processors. We will process such data on behalf of the customer as prescribed in the respective agreements between Wingfoil and the customer. The customer’s privacy policy or other agreement between the customer and you (or your organization) will apply to such processing, and not this policy. If your personal data is processed by Wingfoil on behalf of one of our customers and you wish to discontinue such processing, please contact the Wingfoil customer directly. To exercise any of your rights as a data subject, please contact the Wingfoil customer directly.

Customer agreements are in place with each Wingfoil customer. These agreements cover data transfers to third parties that may occur as part of Wingfoil ’s provision of its services to the customer.

Cookie Policy

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Cookies used:

WingfoilToken (required)
WingfoilTemplateToken (required)

Performance and Functional Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. Also, enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages.

All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Cookies used:

WingfoilHubspotUK (analytics, dependent on HubSpotUK third party cookie)
HubSpotUK (third party)

Privacy Shield for EU Data Transferred into the US

Wingfoil and InboundLabs (“we,” “us”) complies with the EU-US Privacy Shield Framework, Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries transferred to the United States pursuant to Privacy Shield. We have certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

Wingfoil is subject to the investigatory and enforcement authority of the United States Federal Trade Commission (FTC).

Pursuant to the Privacy Shield we acknowledge the right of EU individuals to access their personal data to inspect, update, or correct it. EU individuals wishing to exercise this right may do so by contacting the authorized agent or point of contact.

Under the Privacy Shield, may be liable for the onward transfer of personal data to third parties as described above under, “Who we give your information to.”

Note that we do not share any personal data with non-agent third parties or for uses other than those for which the information was originally provided. If this practice should change in the future we will update this policy accordingly and provide individuals with opt-out or opt-in choice, as required. We may be required to release personal data in response to lawful requests by public authorities including to meet national security and law enforcement requirements.

In compliance with the Privacy Shield Principles, Wingfoil commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield inquiries or complaints should first contact Wingfoil at: legal@inboundlabs.co") or at InboundLabs 2810 N Church St,PMB 79586,Wilmington, DE 19802-4447, USA Phone Number: 415 754 8634

Wingfoil has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Changes to this policy

Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by email. This policy was last updated on November 1, 2021.

Contact Us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

InboundLabs LEGAL
2810 N Church St
PMB 79586
Wilmington, DE 19802-4447
USA Phone Number: 415 754 8634
legal@inboundlabs.co