Wingman Privacy Policy

Effective as of October 15, 2019

Hello, and welcome to our Privacy Policy. This Privacy Policy helps you to make informed decisions about your relationship with us, so please read it carefully. Hope you’re wearing your flight jacket; let’s soar through this. Here we go…

Introduction

Thanks for choosing Wingman. This is our Privacy Policy. We know privacy is important to you; it’s important to us. Before getting into the details, we’d like to highlight some of the key principles behind this Privacy Policy.

The purpose of the Privacy Policy is three-fold:

1. Explain the way we use the information that you share with us in order to build a great product and give you a great experience with it;
2. Ensure that you understand what information we collect with your permission, and what we do — and do not do — with it;
3. Hold us accountable for protecting your rights and your privacy under this policy.

All the information we collect is related to providing the Wingman application, its features and related services (the “Service”).

Broadly speaking, there are two categories of information we collect: 1) information that we must have in order for you to use Wingman; and 2) information that we can use to provide additional features and improved experiences if you choose to share that information.

The first category includes:

• Registration information:
  • If you register with Wingman using an email address, it is the email address you provide.
  • If you register with Wingman using SMS, it is the phone number you provide.
  • Birth date so we can determine if you are 13 years of age or older.

• IP address to monitor and respond to abuse of the Wingman service.

• Technical and sensor information necessary to operate Wingman. This includes the type of device you use and data from the touchscreen. This enables us to understand application usability in order to continually improve the Service for you.

The second category includes information that enables us to offer you additional features. We never receive any of the following information unless you expressly choose to share it with us. It’s as simple as that. Here are some examples:

• Photos: We will only access images that you specifically choose, and we will never scan or import your photo library or camera roll. This allows you to choose individual pictures of business cards to post to the Service so we may provide back to you a textual representation of the business card content.

• Camera: As an alternative to selecting pictures from your camera roll, you may choose to take pictures within the Wingman Application. We will use this camera access for the purpose of identifying and analyzing business cards that appear within the camera’s view.

• Contact information from contacts you provide us access: We never access contacts without first getting your explicit permission. If you choose to do so, we will use this information to identify duplicate contact records in your contacts. We will also use this information to link to Public Data so we may update your contact records when we collect additional and ongoing updated information about these contacts from this Public Data. So there is no confusion about what is considered Public Data, we will spell it out here. Essentially, if you can access the data over the internet from an unauthenticated browser session it is Public Data. We will share contact information in a de-identified format (for example, through the use of hashing) that does not personally identify you or your contacts.

• Public Data search requests: The Service provides you with the ability to search Public Data so that we may provide back to you information about the contacts you are searching from Public Data sources. We will make the search request content and a unique, de-identified representation of you available publicly.

• Information necessary to process payments for the Service. Only when you choose to use additional features that require payment will we ask you to provide the information necessary to process the payment. We will only collect the required information to process the payment, which may include your credit or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by us and/or the payment processors with which we work. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history, all of which are necessary to provide the Service. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, and your card’s type, expiration date, and certain digits of your card number.

The distinction between the first and second category is important. Information in the first category is information you must provide in order to use Wingman. When you agree to our Privacy Policy, you give us the right to collect this information and use it for the purposes described. Information in the second category is information we will only collect if you explicitly give us permission to do so in the future. For this second category of information, we will ask for your permission before first accessing it, this Privacy Policy describes how we will use it if you give us permission, we will only use the information for the purpose we described, and you will always have the ability to change your mind and revoke that permission. Acceptance of our Privacy Policy does not mean you have granted us permission to access or use the information in the second category; we’re just explaining to you that one day we might ask you for that permission. And if you grant us permission at that later date, you are accepting our Privacy Policy for how we will access and use the information in the second category.

We will be clear with you about how and when we might share information.

In some contexts, we will share certain information. For example, like most services, if you register with Wingman through a third party like Twitter or another provider, we share some information with them and they share some information with us in order to enable your account. And we also share information with organizations that host our cloud infrastructure and assist us with satisfying your requests of the Service. When we do use organizations to help us meet your needs, we put confidentiality agreements in place to ensure maintain the privacy of information you share with us.

We hope this helps you to understand our privacy commitments to you. Now, the details await you below, but please remember that this Introduction is part of the Privacy Policy itself — it’s our promise to you. If you ever have any questions or concerns, then please let us know at [email protected].

Throughout this Privacy Policy we refer to the Wingman Application or the Service. These terms are defined in our Terms and Conditions of Use (the “Terms and Conditions of Use”).

2. Key highlights of what you’re consenting to

By using or interacting with the Service, you are consenting to:

• the use of cookies and other technologies;
• the transfer of your information outside of the country where you live;
• the collection, use, sharing, and other processing of your information, including for promotion-related purposes (as described in the rest of this Privacy Policy, so please keep on reading!); and

In each case, you consent to the processing of data by the entities described in this Privacy Policy, including the Wingman Service provided to you by Skroot LLC, as data controller, indicated at the bottom of this document (collectively, “Wingman”, “Skroot”, “we”, “us”, “our”). If you don’t agree with the terms of this Privacy Policy, then please don’t use the Service.

3. The information we collect

We may collect and store the following information:

3.1 Registration data

When you sign up for the Service, we may ask you for information such as your email address, phone number, and date of birth. If you connect to the Service using credentials from a Third Party Application (as defined in the Terms and Conditions of Use) (e.g., Twitter), you authorise us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information available on or through your Third Party Application account, including, for example, your name, profile picture, country, hometown, email address, date of birth, gender, friends’ names and profile pictures, and networks.

3.2 Analytics information

We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

3.3 Cookies and similar technologies

When you visit the Service, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use Wingman in order to improve the Service to you.

3.4 Log file information

Log file information is automatically reported by your browser or mobile device each time you make a request to access (i.e., visit) a Wingman Application page.

When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks / touch interactions and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and to improve the Service for you.

3.5 Searches conducted

When you conduct searches within the Wingman Application both on your contacts and on Public Data, we may use a variety of technologies that collect information about the searches conducted, results provided and actions taken on these search results. This information may include:

• terms used to conduct search;
• date, time and geographic location of search; and
• search results provided to you based on the search terms; and
• your actions after the search results were delivered to you.

3.6 Your mobile device

We may provide features that rely on the use of additional information on your mobile device or require access to certain services on your mobile device that will enhance your Wingman experience but are not required to use the Service. (In other words, information that falls in the second category described in the Introduction to this Policy.) For example, you may choose to upload pictures of business cards to the Service for the purpose of analyzing the pictures and providing back to you a textual representation of the business card content. Granting us access does not mean you are granting us unlimited access to that information or that we will access specific information without your permission. To the contrary, for each type of information listed in this section, before we access this information or these features of your mobile device, we will ask for your permission. If you provide such permission, we will collect the information for the specific purposes explained at the time we ask for your permission.

In particular:

• Photos: We will not access your photo library or camera roll photos without first getting your explicit permission and we will never scan or import your photo library or camera roll. If you give us permission to access your photo library or camera roll, we will only use images that you specifically choose to share with us. (You may use our application to select the photo or photos you choose to share, but we will never import the photos you review except those you explicitly share.).
• Camera: We will not access your camera without first getting your explicit permission. If you give us permission to access your camera, we will only use the camera sensor in an attempt to detect a business card within the camera sensor’s field of view and analyze the business card. To assist with analyzing the business card and improving the Service quality, we may transmit still images of sections of the business card to the Service. (If you choose not to grant us access to the camera on your device, you may still request the Service to process images of business cards by uploading photos as described in the previous “Photos” section.).
• Location: We will not gather or use the specific location of your mobile device (by using, for example, GPS or Bluetooth) without first getting your explicit permission. And if you choose to share location information but later change your mind, you will always have the ability to stop sharing. Please note that this does not include IP address. We will continue to use your IP address as described in Section 3.2 above.
• Contacts: We will not scan or import your contacts stored on your phone without first getting your explicit permission. We will use the contact information to help you find additional information about your contacts from Public Data and provide you updates about your contacts based on updates we collect from Public Data. We may use the contact information you provide together with Public Data establish linkages within Public Data in order to improve the Service for you. We will not use the contact information for any other purpose without first getting your separate explicit permission. Local law may require that you seek the consent of your contacts to provide their personal information to Wingman, which may use that information for the purposes specified in this Privacy Policy.

3.5 Payment data

If you sign up for a Free Subscription (as defined in the Terms and Conditions of Use), purchase any of our Paid Subscriptions (as defined in the Terms and Conditions of Use), or make other purchases through the Service, your credit or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by us and/or the payment processors with which we work. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history, all of which are necessary to provide the Service. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, and your card’s type, expiration date, and certain digits of your card number.

If you choose to pay by invoice, Wingman may need to collect and store additional information, like your name, date of birth, and phone number, and provide it to payment processors we work with to issue invoices, to enable credit checks and to send you invoices.

BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY AUTHORISE WINGMAN TO USE AND SHARE WITH OTHER COMPANIES IN THE SKROOT AND WINGMAN GROUPS, AS WELL AS CERTAIN TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE OF THE COUNTRY OF YOUR RESIDENCE (INCLUDING COUNTRIES WHICH DO NOT PROVIDE THE SAME LEVEL OF PROTECTION FOR THE PROCESSING OF PERSONAL DATA AS THE COUNTRY OF YOUR RESIDENCE), THE INFORMATION PROVIDED BY YOU TO WINGMAN, EVEN IF SUCH INFORMATION IS COVERED BY LOCAL BANKING SECRECY LAWS. YOU ACKNOWLEDGE AND AGREE TO THE IMPORTANCE OF SHARING SUCH INFORMATION FOR THE PROVISION OF THE WINGMAN SERVICE AND ALSO AGREE THAT, BY ACCEPTING THIS PRIVACY POLICY, WHERE APPLICABLE AND TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOU EXPRESSLY WAIVE YOUR RIGHTS UNDER SUCH BANK SECRECY LAWS WITH REGARD TO WINGMAN, ANY COMPANY IN THE SKROOT AND WINGMAN GROUPS, AND ANY TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE YOUR COUNTRY OF RESIDENCE. THIS CONSENT IS GIVEN FOR THE DURATION OF YOUR RELATIONSHIP WITH WINGMAN.

3.6 Surveys and promotions

From time to time, we may offer you the opportunity to participate in promotions such as offers and/or surveys (“Special Promotions”) through the Service. A Special Promotion may be governed by a privacy policy and/or terms and conditions that are additional to, or separate from, this Privacy Policy and the Terms and Conditions of Use. If the provisions of the Special Promotion’s privacy policy or terms and conditions conflict with this Privacy Policy or the Terms and Conditions of Use, those additional or separate provisions shall prevail. If you participate in a Special Promotion, we may ask you for certain information in addition to what is stated in this Privacy Policy, including personal information. That additional information may be combined with other account information and may be used and shared as described in this Privacy Policy.

3.7 Third-party systems

If you choose to integrate the Service with one of the available third-party systems to exchange contact information, including Microsoft, Google, or Salesforce, the Service maintains authentication (OAuth) tokens that allow Wingman to act “on your behalf” to read and write data. These tokens are securely stored along with your personal information.

When you choose to integrate the Service with one of these third-party systems, Wingman will prompt you for authentication information. A successful authentication returns a token for that specific service, which Wingman uses to read and write data. Wingman notifies you the specific permissions you are granting Wingman when you choose to grant Wingman access to your data in these services. When you stop using Wingman or discontinue the integration with that third-party system, Wingman will no longer attempt to access the data contained within the third-party system.

3.7.1 Google Sheets

If you choose to integrate the Service with Google Sheets, Wingman will request read and write access to the file created by the Wingman app, which it populates with your contacts contained within Wingman. Wingman reads and writes to the file that it creates in your Google Drive workspace. Wingman does not access any other files within Google Drive.

4. How we use the information we collect

Consistent with the permissions you give us to collect the information, we may use the information we collect, including your personal information:

• to ensure technical functionality of the Service, develop new products and services, and analyze your use of the Service, including your interaction with applications, products, and services that are made available, linked to, or offered through the Service;
• to communicate with you for Service-related or research purposes including via emails, notifications, text messages, or other messages, which you agree to receive;
• to process your payment or prevent or detect fraud or abuse of the Service;
• to provide you with features, information, or other content which is influenced by your location and your location in relation to other Wingman users;
• to identify linkages between your contacts and Public Data sources and between Public Data sources to improve the Service to you and other Wingman users;
• to improve results searches conducted within the Wingman Application of Pubic Data;
• to develop and test new products and features;
• to train machine learning models and other system algorithms;
• to enforce this Privacy Policy, the Terms and Conditions of Use, and any other terms that you have agreed to, including to protect the rights, property, or safety of Wingman, its users, or any other person, or the copyright-protected content of the Service; and
• as otherwise stated in this Privacy Policy.

5. Sharing information

This section describes how the information collected or generated through your use of the Wingman Service may be shared by you or by us.

We will not rent or sell your information to third parties outside Wingman (or the group of companies of which Wingman is a part) without your consent, except as noted in this Policy.

5.1 Sharing by you

5.1.1 Generally

The Wingman Application and Service is a service that offers you a way to scan, upload, and analyze business cards, contact information and, more generally, learn more about people and organizations.

Searches on Public Data performed by you within the Wingman Application, with all personally-identifiable information about you removed, will be made available to Third Parties by default. Although this information is made public by default, in Your preferences below, we describe the controls that you can use, along with other relevant settings associated with your Wingman account, to limit the sharing of your information.

With your explicit permission, your information may be used to notify others, including within the Service, via email, and through Facebook and Third Party Applications, about your use of the Service.

Learn more about how to manage notifications, your publicly available information, and what you share with others in Your preferences below.

5.2 Sharing by Wingman

5.2.1 Data provider

We may share information with data provider partners who, in order to promote to you data that matches your contacts, needs this information. The information we share is in a de-identified format (for example, through the use of hashing) that does not personally identify you or your contacts.

We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

Please see the section Information about cookies, other technologies, and third-party data collection below for information about the cookies and other technologies that we and third parties use to serve you more relevant content and your options.

5.2.2 Service providers and others

We may from time to time share your information with service providers to perform functions and process user data and help provide our Services, consistent with this Privacy Policy. For example, we work with service providers to provide the technical infrastructure, networking, and hosting of the Wingman Service and to help with business card transcription. Where a third party processes user data on our behalf (e.g., a hosting service provider), it is subject to security and confidentiality obligations consistent with this Privacy Policy and applicable law.

5.2.3 Other sharing

In addition to the above, we may also share your information with third parties for these limited purposes:

• to allow a merger, acquisition, or sale of all or a portion of our assets;
• to respond to legal process (e.g., a court order or subpoena), if we believe in good faith that it is necessary to do so; to comply with the requirements of mandatory applicable law; to protect the safety of any person; to protect the rights and property of Wingman, including to enforce the Terms and Conditions of Use and any other terms that you have agreed to; and to address fraud, security, or technical issues;
• to academic researchers for purposes including statistical analysis and academic study, but only in a de-identified format;
• to publish de-identified or aggregate information about the use of the Wingman Service; and
• to allow other companies in the Wingman and Skroot groups to use your information as specified in this Privacy Policy.

5.2.4 What happens in the event of a change of control

If we sell or otherwise transfer part or the whole of Wingman or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address, User Content and any other information collected through the Service may be among the items sold or transferred. You will continue to own your User Content. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.

6. Your preferences

We provide you with settings to allow you to choose which communications you receive from us. However, as explained in the section Sharing by you, certain information may always be publicly available to others and other information is made publicly available to others by default.

7. Transfer to other countries

Wingman transfers, processes and stores information about our users on servers located in a number of countries. Wingman may subcontract processing to, or share your information with third parties located in countries other than your home country. Your personal information may therefore be subject to the privacy laws that are different from those in your country of residence. Information collected within the European Economic Area (“EEA”) and Switzerland may, for example, be transferred to and processed by third parties identified above, located in a country outside of the EEA and Switzerland, where you may have fewer legal rights in relation to your information. The Wingman group will process your information as described in this Privacy Policy.

8. Links

We may display promotions from third parties and other content that links to third party websites. We cannot control or be held responsible for third parties’ privacy practices and content. Please read their privacy policies to find out how they collect and process your personal information.

9. Children

The Wingman Service is not directed to children under the age of 13. (In some countries, stricter age limits may apply. See our Terms and Conditions of Use.) We do not knowingly collect personal information from children under 13 or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, do not use the Service and do not provide any personal information to us. If you are a parent of a child under the Age Limit and become aware that your child has provided personal information to Wingman, please contact us at [email protected] and you may request exercise of your applicable access, rectification, cancellation, and/or objection rights. If you are a California resident under the age of 18 and you wish to remove publicly available content, please contact us at [email protected].

10. Accessing and updating user information

You can view and amend much of the information we keep about you through your account and access you have granted to your contact information. If you have questions about your privacy on the Service, this privacy policy, or information we have about you, please contact us at [email protected]. You can also contact our privacy representative by sending a letter to Wingman, Attn: Privacy Officer, Legal Department, United States. We will respond to your request within a reasonable period of time upon verification of your identity in accordance with local laws. We recommend you include documents that prove your identity and a clear and precise description of the information which you request access to.

11. Changes to the Privacy Policy

Occasionally we may, in our discretion, make changes to the Agreements. When we make material changes to the Agreements, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Service or by sending you an email. In some cases, we will notify you in advance, and your continued use of the Service after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you do not wish to continue using the Service under the new version of the Agreements, you may terminate the Agreements by contacting us by sending an email to [email protected].

12. Information about cookies, other technologies and third-party data collection

This section describes the use of cookies and other technologies. For further information about how information may be shared by Wingman, please see the section Sharing by Wingman.

12.1 What are cookies and other technologies?

A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers to recognise your device the next time you visit their website. There are other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an email, which indicates that a page or email has been viewed), web bugs (similar to pixel tags), and web storage, which are used in desktop software or mobile devices.

There are also technologies such as mobile device identifiers and SDK integrations to help companies recognise your device when you return to an app or otherwise use the service.

12.2 How we use cookies and other technologies

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period of time or until you delete them). We use the following types of cookies for the purposes explained in this chart:

Cookie Type | Purpose — | — Essential Operational | These cookies are necessary to allow us to operate the Wingman Service as you have requested. For example, they let us recognise what type of subscriber you are and then provide you with services accordingly. Performance / Analytics | We use these cookies to analyse how the Wingman Service is accessed, is used, or is performing. We use this information to maintain, operate, and continually improve the Wingman Service. We may also obtain information from our email newsletters, including whether you opened or forwarded a newsletter or clicked on any of its content. This information tells us about our newsletters’ effectiveness and helps us ensure that we’re delivering information that you find interesting. Functional | These cookies let us operate certain functions of the Wingman Service in line with the choices you make. These cookies mean that when you continue to use or come back to the Wingman Service, we can provide you with our services as you have asked for them to be provided, such as knowing your email address and remembering how you have customised our services. Data recommendations | We use these cookies to serve you with data recommendation that may be relevant to you based on your contacts. The information may also be used for frequency capping purposes (e.g., to ensure we do not display the same recommendation to you repeatedly) and to help us regulate the recommendations you receive and measure their effectiveness. Third Party | We may allow our business partners to use cookies on or outside the Wingman Service for the same purposes identified above, including collecting information about your online activities over time and across different websites. We may also use service providers acting on our behalf to use cookies for the purposes identified above. Wingman Ads | We work with web publishers, advertising networks, and service providers to deliver Wingman ads on other web sites and services. Cookies may be used to serve you with advertisements that may be relevant to you and your interests on other web sites and services and to regulate the advertisements you receive and measure their effectiveness. We also use mobile device identifiers and the other technologies identified in Section 13.1 for the purposes articulated in this Privacy Policy, for example to recognise your device when you return to the Wingman Application or otherwise use the Wingman Services.

12.3 Manage your cookie and other preferences

Many web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies. You may be able to manage other technologies in the same way that you manage cookies using your browser’s preferences.

Please note that if you choose to block cookies, doing so may impair the Wingman Service or prevent certain elements of it from functioning.

There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

On your mobile device, you may also have a “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.

Please note that even if you opt out using the mechanisms above, you may still receive data recommendations when using the Wingman Service.

We work with data provider partners to serve recommendations on the Wingman Service. One of the services we use to track activity related to the Service, e.g., by placing cookies, is Google Analytics by Google (Google, Inc. a company headquartered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). We may use vendors, including Google, who use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise, and serve ads based on your past visits to our websites, including Google Analytics for Display Advertising. Google provides tools to manage the collection and use of certain information by Google Analytics at tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings at google.com/settings/ads.

You hereby consent to the use of cookies and other technologies described above.

12.4 More information

For more information about the use of cookies and how to block them, visit allaboutcookies.org, youronlinechoices.eu (Europe), or aboutads.info/choices (United States). If you have any questions or comments about our use of cookies, please contact us at [email protected].

Thank you for reading our Privacy Policy. We hope you enjoy Wingman!

Data controller:

Skroot™ LLC 1776 Peachtree St. NE, Suite 200N, Atlanta, GA 30309 USA

Skroot™ LLC