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Privacy Policy for Wingman

1. Introduction

Welcome to Wingman ("we," "our," or "us"). We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we collect, use, and safeguard your information when you use our Wingman mobile application (the "App").

2. Information We Collect

2.1 Information You Provide

• Account Information: Email address, name, and password when you create an account
• Profile Information: Any additional information you choose to provide in your profile
• Usage Data: Information about how you use the App, including features you access and interactions with content
• Communication Data: Messages, feedback, and other communications you send through the App

2.2 Information Collected Automatically

• Device Information: Device type, operating system, unique device identifiers, and mobile network information
• Usage Analytics: App usage patterns, feature interactions, and performance data
• Technical Data: IP address, browser type, and other technical information
• Location Data: General location information (if you grant permission)

2.3 Information from Third Parties

• Authentication Services: Information from third-party authentication providers (if you choose to sign in with them)
• Analytics Services: Aggregated usage data from analytics providers

3. How We Use Your Information

3.1 Primary Uses

• Provide Services: To deliver the App's features and functionality
• Account Management: To create and manage your account
• Authentication: To verify your identity and secure your account
• Communication: To send you important updates, security alerts, and support messages
• Improvement: To analyze usage patterns and improve the App's performance and features

3.2 Secondary Uses

• Analytics: To understand how users interact with the App
• Security: To detect and prevent fraud, abuse, and security threats
• Legal Compliance: To comply with applicable laws and regulations
• Research: To conduct research and development (using anonymized data)

4. Information Sharing and Disclosure

4.1 We Do Not Sell Your Personal Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

4.2 Limited Sharing

We may share your information only in the following circumstances:

• Service Providers: With trusted third-party service providers who help us operate the App (e.g., cloud hosting, analytics)
• Legal Requirements: When required by law, court order, or government request
• Safety and Security: To protect the safety and security of our users and the public
• Business Transfers: In connection with a merger, acquisition, or sale of assets (with notice to users)
• Consent: With your explicit consent for specific purposes

4.3 Data Processing

All data processing is conducted in accordance with applicable data protection laws and our security standards.

5. Data Security

5.1 Security Measures

We implement appropriate technical and organizational security measures to protect your personal data, including:

• Encryption: All data is encrypted in transit and at rest
• Access Controls: Strict access controls and authentication requirements
• Regular Audits: Regular security assessments and vulnerability testing
• Employee Training: Security training for all employees with data access

5.2 Data Breach Response

In the event of a data breach, we will:

• Notify affected users within 72 hours
• Report to relevant authorities as required by law
• Take immediate steps to contain and remediate the breach
• Provide guidance to affected users

6. Your Rights and Choices

6.1 Access and Control

You have the right to:

• Access: Request a copy of your personal data
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your personal data
• Portability: Request a copy of your data in a portable format
• Restriction: Request restriction of processing in certain circumstances

6.2 Opt-Out Options

• Marketing Communications: Opt out of marketing emails (though you may still receive important service messages)
• Analytics: Opt out of analytics data collection (though this may affect app functionality)
• Location Services: Disable location permissions in your device settings

6.3 Account Deletion

You can delete your account at any time through the App settings. Account deletion will:

• Remove your personal data from our systems
• Cancel any active subscriptions
• Delete your account permanently (this action cannot be undone)

7. Data Retention

7.1 Retention Periods

We retain your personal data only as long as necessary to:

• Provide the App's services
• Comply with legal obligations
• Resolve disputes and enforce agreements
• Improve our services

7.2 Data Deletion

• Account Data: Deleted immediately upon account deletion
• Usage Data: Anonymized or deleted within 30 days of account deletion
• Backup Data: Retained for up to 90 days for disaster recovery purposes

8. International Data Transfers

8.1 Data Location

Your data may be processed in countries other than your own. We ensure that all international transfers comply with applicable data protection laws.

8.2 Adequacy Measures

When transferring data internationally, we implement appropriate safeguards such as:

• Standard contractual clauses
• Adequacy decisions
• Binding corporate rules

9. Children's Privacy

9.1 Age Restrictions

The App is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

9.2 Parental Rights

If you are a parent and believe your child has provided us with personal information, please contact us immediately.

10. Third-Party Services

10.1 Third-Party Links

The App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties.

10.2 Third-Party Integrations

We may use third-party services for:

• Analytics and performance monitoring
• Payment processing
• Authentication services
• Cloud hosting and storage

These services have their own privacy policies, which we encourage you to review.

11. Changes to This Privacy Policy

11.1 Policy Updates

We may update this privacy policy from time to time. We will notify you of any material changes by:

• Posting the updated policy in the App
• Sending you an email notification
• Displaying a prominent notice in the App

11.2 Continued Use

Your continued use of the App after any changes constitutes acceptance of the updated privacy policy.

12. Contact Information

12.1 Privacy Inquiries

If you have questions about this privacy policy or our data practices, please contact us:

Email: privacy@wingman.app
Address: [Your Business Address]
Phone: [Your Phone Number]

12.2 Data Protection Officer

For GDPR-related inquiries, contact our Data Protection Officer:

Email: dpo@wingman.app

12.3 California Privacy Rights

California residents have additional rights under the CCPA. To exercise these rights, contact us at privacy@wingman.app.

13. Legal Basis for Processing (GDPR)

13.1 Legal Grounds

We process your personal data based on the following legal grounds:

• Consent: For marketing communications and optional features
• Contract: To provide the App's services and features
• Legitimate Interest: For analytics, security, and service improvement
• Legal Obligation: To comply with applicable laws and regulations

13.2 Your GDPR Rights

As a GDPR-covered individual, you have additional rights including:

• Right to lodge a complaint with a supervisory authority
• Right to withdraw consent at any time
• Right to object to processing based on legitimate interests

14. Cookie Policy

14.1 App Cookies

The App may use cookies and similar technologies to:

• Remember your preferences and settings
• Analyze app usage and performance
• Provide personalized content and features

14.2 Cookie Management

You can manage cookie preferences through your device settings or the App's privacy settings.

15. Glossary

• Personal Data: Any information that identifies or can be used to identify an individual
• Processing: Any operation performed on personal data
• Data Controller: The entity responsible for determining how personal data is processed
• Data Processor: The entity that processes personal data on behalf of the controller
• Consent: Freely given, specific, informed, and unambiguous agreement to processing

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This privacy policy is effective as of the date listed above and applies to all users of the Wingman mobile application.