- Data You Give Us
Wingspan may collect different data from or about you, depending on how you use Wingspan’s Services. Some of the data we may collect includes: (1) data related to your user account, including your e-mail address, password, gender, date of birth, company name, etc.; (2) data related to any user profile you create, including a photo, website link, social media profile link, comments or posts made by you on Wingspan’s website, your testimonials about Wingspan’s product or Services, etc.; (3) which courses you enroll in or materials you request; (4) payment and billing data; (5) communications you have with Wingspan, including your communications with Wingspan support; (6) technical data related to your device, including your type of device used to access Wingspan’s services, your IP address, browner type, etc.; (7) data showing your usage of our Services, including pages you visited, materials you downloaded, etc.. We may store this information in a manner that associates it with your account.
- How We Receive Your Data
Wingspan also uses third-party browser and mobile analytics services like Google Analytics. These services use data collection tools to help us analyze your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data, and where the application was downloaded from. We use this data to improve the Services, better understand how the Services perform on different devices, and provide information that may be of interest to you.
- How We Use & Share Your Data
Wingspan uses your data in several ways, including but not limited to the following: Provide and administering the Services, including to display customized content and facilitate communication with you and others; Process your requests and orders for courses, products, specific services, information, or features; Communicate with you about your account; Manage your account preferences; Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse; Solicit feedback from users; Market and administer surveys and promotions administered or sponsored by Wingspan; Learn more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers; Identify unique users across devices; Tailor advertisements across devices; Improve our Services and develop new products, services, and features; Analyze trends and traffic, track purchases, and track usage data; Advertise the Services on third-party websites and applications; As required or permitted by law; or As Wingspan, in its sole discretion, otherwise determine to be necessary to ensure the safety or integrity of its users, employees, third parties, the public, or Wingspan’s Services.
Wingspan may share your data with third parties as follows:
- Wingspan shares your data with third-party companies who perform services on Wingspan’s behalf, like payment processing, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
- Wingspan may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.
- If Wingspan undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
Wingspan takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data. Unfortunately, however, no system can be 100% secure, so Wingspan cannot guarantee that communications between you and Wingspan regarding the Services or materials, or any information provided to Wingspan in connection with the data we collect through the Services, will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately.
- Your Rights
You can choose not to provide certain data to Wingspan, but you may not be able to use certain features of the Services. To opt out of receiving any promotional communications from Wingspan, you can use the “unsubscribe” mechanism included in the communication. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, scheduling emails, and notices about our policies. Any other “opting out” would need to be completed by you through your internet browser settings.
To request to access, correct, or delete your personal data, email us at email@example.com. Please allow up to 30 days for a response. For your protection, Wingspan may require that the request be sent through the email address associated with your account, and Wingspan may need to verify your identity before implementing your request.
- Jurisdiction-Specific Rules & Notices
If you are a California resident, you have the right to request certain details about what personal information Wingspan shares with third parties for those third parties’ direct marketing purposes. To submit your request, send an email to firstname.lastname@example.org with the phrase “California Shine the Light” or “California CCPA Request” and include your mailing address, state of residence, and email address.
In addition, know that the California Consumer Privacy Act of 2018 (“CCPA”) provides California resident consumers with specific rights regarding their personal information. Under the CCPA, you have the following rights:
Access to Information and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained (with certain exceptions). Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to: complete the transaction for which we collected the personal information; provide a good or service that you requested; take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; debug products to identify and repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.); engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; comply with a legal obligations; make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by e-mailing email@example.com. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We try to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Wingspan is headquartered in North Carolina, and to provide the Services to you we must transfer your data to the United States and process it there. By visiting or using Wingspan’s Services, you consent to storage of your data on servers located in the United States. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas. By submitting your data or using our Services, you consent to the transfer, storage, and processing by Wingspan and its processors and agents.