# Privacy Policy Wingspan Networks, Inc. (“Wingspan”, “Our”, “We”, “Us”) takes the privacy and security of personal information very seriously. As such, we have prepared the following Privacy Policy to provide you with information about how your data is collected, used, stored, shared, transferred, and protected as a result of your interaction with and use of (1) the [www.wingspan.app](https://www.wingspan.app/), [www.my.wingspan.app](https://my.wingspan.app/), and similar subdomain websites as applicable (the “Site”), which is owned and operated by Wingspan; (2) our mobile applications to which this Privacy Policy applies (the “Application”) and/or (3) any of the online services offered by Wingspan made available through the Site or the Application (“Services”). By using the Site, Application, and/or Services, you agree to the following Privacy Policy and our [Terms of Use](https://support.wingspancollective.com/support/solutions/articles/47000438531-terms-of-service). The provisions contained in this Privacy Policy supersede all previous notices and statements regarding our privacy practices with respect to our Services. If you disagree with any of the provisions described below, your remedy is to stop using the Site, Application, and/or Services immediately. ## Application of this Privacy Policy This Privacy Policy applies to your use of (regardless of means of access) our Site, Application, and/or Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a “Device”). ## Information Collection ### Information you provide us In general, you can visit the Site without telling us who you are or revealing any information about yourself. When you interact with the Site, Application, and/or Services, including through submitting an inquiry through the “Contact Us” link or “Keep in Touch” box on the Site, or by registering for a Wingspan account, we may ask you to provide personal information about yourself, which may include your name, date of birth, company name, banking information, e-mail address, phone number, and other information that identifies you, including information identifying you as a benefits enrollee (collectively, “Personal Information”). It is your decision to use the Site, Application, and/or Services, and, as such, any provision of this personal information is completely voluntary. By providing your Personal Information to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy. ### Information automatically collected We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical, non-personal information that does not identify you (“Analytics”). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy. Information that we automatically collect in connection with your access or use of our Site, Application, and/or Services may include: - **Device Information**: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). - **Log Information**: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include: - The Device’s Internet Protocol (“IP”) address - The Device’s operating system - Identification numbers associated with your Devices - Device event information, such as crashes, system activity, and hardware settings - Location preferences - Date and time stamps of transactions - **Other Information**: We may collect information such as your browsing history on the Site, the length of time spent on certain pages, the website Uniform Resource Locator (“URL”) from the website you were visiting before coming to this Site, which URL you next visit, what browser you are using, Internet service provider, and date/time of visit information. ## Information Use We may use the Personal Information collected as described elsewhere in this Privacy policy, including to: - provide you with the Site, Application, and/or Services; - respond to your inquiries or requests; - communicate with you; and - provide you with offers and promotions that we feel may be of interest. We may use the Analytics information collected as described elsewhere in this Privacy policy, including to: - conduct statistical analysis of the Site, Application, and/or Services; - troubleshoot service issues or interruptions; - conduct research and for commercial purposes, such as to update and improve the Site, Application, and/or Services; - understand the demographics of our users and their browsing habits; and - serve you with promotional messages and advertisements, both while you are on the Site and after you leave our Site and continue to browse online. ## Cookies Cookies are small files that are sent to and stored in your computer by the websites you visit. Cookies are stored in your browser’s file directory. Cookies may be stored only for the time you are in a given site or they may remain stored in your browser for a defined period of time beyond your current session. Cookies work in combination with content within the website itself, to capture and remember information. To learn more about these technologies and how they work, please see [www.allaboutcookies.org](http://www.allaboutcookies.org/). We use cookies and other similar technologies (such as web beacons and pixels) to collect and process non-personal information, personalize our Services for you, and to collect aggregate information about the usage of our Services. The cookies we use in connection with our Services may include: - **Session cookies**: Temporary cookies that expire and are automatically erased whenever you close your browser. - **Persistent cookies**: Usually have an expiration date in the distant future and remain in your browser until they expire or are manually deleted. - **Third-party cookies**: We may permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Service to you. ## Information Sharing We may share Personal Information to the following entities and/or for the following reasons: - **Affiliates/Partners**: We may share your personal information with our affiliates or partners for the purpose of providing you with the Services, as well as additional benefits. - **Unaffiliated Third Parties**: We may share your Personal Information with unaffiliated third parties if you request or authorize it, or if the information is provided to help complete a transaction for you. - **Law Enforcement**: Occasionally we may be required by law enforcement or judicial authorities to provide personal information. We will disclose personal information upon receipt of a court order, subpoena, warrant, or other legal process. ## Your Choices You may have choices when it comes to the collection, use, and sharing of your personal information. You may choose to “unsubscribe” from e-mail marketing communications, or you can contact us using the contact information below to be removed from our email marketing lists. ## Accessing Your Information You must notify us of any change in your Personal Information by updating your Wingspan account profile. You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. ## Changes to this Privacy Policy We reserve the right to make changes to this Privacy Policy at any time and in our sole discretion. We will post changes directly to this Privacy Policy and update the date at the top of this Privacy Policy. ## Contact Information If you have any questions or concerns about this Privacy Policy, please contact us: Wingspan Networks, Inc. Attn: Anthony Mironov, CEO 335 Madison Ave, 16th Floor, New York, NY 10017, USA [Email Us](mailto:support@wingspan.app?subject=Wingspan%27s%20privacy%20policy)