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Privacy Policy 

1. Introduction

 

Welcome to Wingfoil. We are committed to protecting your privacy and handling your personal data in an open and transparent manner. This privacy policy explains how Wingfoil (“we,” “us,” or “our”), as the Data Controller, collects, uses, shares, and protects your personal data when you use our website [www.wingfoil.com] (the “Site”) and our electronic marketplace services (the “Services”). This policy is prepared in compliance with the EU General Data Protection Regulation (GDPR).

 

2. What Personal Data We Collect

 

We may collect and process the following categories of personal data about you:

  • Personal Identification Data: Name, email address, billing address, shipping address, and phone number.

  • Account Data: Username, password (which is always hashed), and user preferences.

  • Technical Data: IP address, browser type and version, device information, operating system, and time zone setting.

  • Usage Data: Information about how you navigate and use our Site and Services, such as pages viewed and links clicked.

  • Marketing and Communications Data: Your preferences for receiving marketing from us and your communication preferences.

3. How and Why We Use Your Data (Legal Basis)

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances and on the following legal bases:

 

Purpose / Activity Type of Data Legal Basis for Processing
To register you as a new user and create your account. Account, Personal Identification Performance of a Contract
To process and deliver your orders (including managing payments and marketplace transactions). Transaction, Personal Identification, Account Performance of a Contract
To manage our relationship with you (e.g., providing customer support, notifying you of policy changes). All categories Performance of a Contract, Legitimate Interest (to keep our records updated)
To administer and protect our business and this Site (including troubleshooting, data analysis, security, and fraud prevention). Technical, Usage, Account Legitimate Interest (for running our business, network security)
To use data analytics to improve our website, services, and user experience. Technical, Usage Legitimate Interest (to improve our service offerings)
To send you marketing communications (like newsletters or special offers) if you have opted in. Personal Identification, Marketing Consent (which you can withdraw at any time)
To comply with a legal or regulatory obligation (e.g., tax and accounting laws). Transaction, Personal Identification Legal Obligation

 

4. Who We Share Your Data With

 

We do not sell your personal data. However, we may need to share your data with trusted third parties to provide our Services:

.

  • Cloud and Hosting Providers: To host our website and store our data (e.g., [Amazon Web Services, Google Cloud]).

  • Analytics Providers: To help us understand how our Site is used (e.g., [Google Analytics]).

  • Legal and Regulatory Authorities: If required by law, subpoena, or to protect our legal rights.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

 

5. International Data Transfers

 

Some of our third-party service providers may be based outside the European Economic Area (EEA). When we transfer your data out of the EEA, we ensure a similar degree of protection is afforded to it by using specific contracts approved by the European Commission, known as Standard Contractual Clauses (SCCs), or by ensuring the provider is part of a framework that guarantees an adequate level of protection.

 

6. Data Security

 

We have implemented appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way. We leverage modern, secure technologies and principles to minimise vulnerabilities. Access to your personal data is limited to those employees and third parties who have a business need to know.

 

7. Data Retention

 

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

  • For example, we must keep basic information about our customers (including Transaction Data) after they cease being customers for tax purposes.

  • Your account data will be held as long as your account is active.

8. Your GDPR Rights

 

Under the GDPR, you have the following rights regarding your personal data:

 

  • Right to Access: You can request a copy of the personal data we hold about you.

  • Right to Rectification: You can request that we correct any inaccurate or incomplete data.

  • Right to Erasure (“Right to be Forgotten”): You can request that we delete your personal data where there is no good reason for us to continue processing it.

  • Right to Restrict Processing: You can ask us to suspend the processing of your data in certain scenarios.

  • Right to Data Portability: You can request that we transfer your data to you or a third party in a machine-readable format.

  • Right to Object: You can object to our processing of your data where we are relying on a legitimate interest.

  • Right to Withdraw Consent: Where we rely on consent to process your data, you can withdraw that consent at any time.

To exercise any of these rights, please contact us at hello@wingfoil.io

You also have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, place of work, or place of the alleged infringement.

 

9. Cookie Policy

 

Our Site uses cookies to distinguish you from other users. This helps us provide you with a good experience and allows us to improve our Site.

 

  • Essential Cookies: These are required for the operation of our Site e.g., to log in.

  • Analytics Cookies: These allow us to recognise and count visitors and see how they move around our Site.

  • Marketing Cookies: These record your visit to our Site to make advertising more relevant to your interests.

We will ask for your consent before placing any non-essential cookies on your device, typically through a cookie banner.

 

10. Changes to This Privacy Policy

 

We may update this policy from time to time. We will notify you of any significant changes by posting the new policy on this page and/or by emailing you. We encourage you to review this policy periodically.

 

11. Contact Us

 

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer (DPO) / Privacy Team:

  • Email Address: hello@wingfoil.io

  • DPO/Contact Person: Jake Mitchell