Privacy Policy: User - Members

Last updated: 12-07-2019

(hereinafter, the “Policy”).

Karibuni WingX Ltd (C 79910) (“We”; “Us”; “Our” or “WingX”) is committed to respecting and protecting your privacy.

This Policy sets out the basis on which any personal data that We collect from you, or that you provide to Us, will be processed by Us. It should be read in conjunction with Our Terms of Service, accessible via , IP Address and Cookie Policy and, as applicable, either the Terms of Use relating to Our website or the Terms of Use relating to our mobile application or even the two of them combined (depending on the medium that you are using to access and avail yourself of Our services).

Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it. You must give your express consent to the terms and practices set out in this Policy in order to:

Access, browse and use our site, accessible at (the “Site”), and/or download, browse and use Our related mobile application Wingx, which may be downloaded at (the “App”); and/or register an account with Us for the purposes of the online platform which you, the user, are connected to by means of the Site and/or App (the “WingX Marketplace”), and/or avail yourself of the services that We have made available and provide via this platform. Our Terms of Service, provide the necessary details regarding where and in what context this account registration requirement shall apply.

Information that You Give Us

Basic Account Information: If you choose to create an account on the WingX Marketplace, you must provide Us with some personal information, such as your name, username, password, email address and/or phone number. Once registered, your username will always be publicly listed, including on your profile page and in search results.

Contact Information: You may use your contact information, such as your e-mail address or phone number to, for instance, (i) customise your account and enable certain account features (such as login verification), (ii) report an issue with the WingX, App and/or Site, (iii) report a problem you may have encountered in relation to any of the travel guides and/or travel service providers featured on the WingX (“WingX Hosts”), for example, an unsatisfactory service and/or (iv) contact Our customer support team or correspond with Us in general. In turn, WingX may use the contact information which you supply (be it as part of your account registration or otherwise) to get in touch with you on matters similar to those mentioned above.

Payment Information: To book and hire the services of a WingX Companion, you will be required to supply your valid credit card information as well as billing address details. The payment information that you supply is processed on Our behalf, and at Our instructions, by Our third-party payment processing and billing service provider.

Information We collect about you

Location Information: We may receive information about your location. For example, you may choose to publish your location in your User Profile and/or any posts or reviews which you publish on the WingX Marketplace. We may also determine location by using other data from your mobile device, such as precise location information from GPS, information about wireless networks or cell towers near your mobile device, or your IP address (depending on whether you are here using Our App or Site). In the case of Our App, you can turn this functionality off at any time by switching off the location services settings for the App on your device (as explained below). However, in doing so, this may impair the quality of the services provided through Our App.

Visit and Search Information: With regards to each of your visits to the WingX Marketplace (whether via the Site or the App), we collect and process information about the searches that you have placed, your browsing results, the user profiles which you may have viewed, the particular travel services you have indicated an interest in or attempted to book and your booking history.

Technical Information: With regards to each of your visits to the WingX Marketplace, we collect and process technical information about the devices which You use the App on and related software, hardware, and peripherals. Additionally, in the context of the Site, we collect and process the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time). Other technical information that we process includes your login information, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.

Information we receive from other sources

User Reviews

Communications with Travel Guides and Travel Service Providers

Information you give to us. We will use this information:

to facilitate the provision of the services available over and through the WingX Marketplace, such as by enabling contact between you (the user) and the particular travel guide or service provider (i.e. WingX Host) whose services you have requested and hired, in accordance with Our Terms of Services ();

to remit payments which you have made over the WingX  to the relevant WingX Companion;

to provide you with information about the additional services that We offer outside of those available on the WingX;

to resolve any issues which you may have reported with regards to the App or Site and/or any of Our WingX Hosts;

to provide you, or permit selected third parties to provide you, with information about other, separate services which We feel may interest you. Where you have registered an account, We will contact you by electronic means (i.e. e-mail) with information about such services;

to notify you about changes to the App or Site, and/or the services that We provide over the WingX Marketplace;

to generate reports for statistical purposes; and

to ensure that content featured and displayed on the App, Site and WingX Marketplace is generally presented in the most effective manner for you and for your devices or mediums.

Information we collect about you

We will use this information:

to administer the App, Site and WingX Marketplace, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

to improve our App, Site and WingX Marketplace, and to ensure that content is presented in the most effective manner for you and for your device and mediums;

to allow you to participate in interactive features of the WingX Marketplace, when you choose to do so;

to provide suggested guides, tours or other travel-related activities or services, based on your location data and page browsing and booking history;

as part of our efforts to keep the App, Site and WingX Marketplace safe and secure;

to measure or understand the effectiveness of advertising featured the WingX Marketplace; and

to make suggestions and recommendations about other services which may be of interest to you.

Information We receive from other sources.

The WingX Companions. In order to place and process a booking, you will need to provide, and We will need to share, your name, location and local contact details (e.g. your hotel for pick-ups and drop-offs, your mobile phone number) with the travel guide or travel service provider concerned (i.e. the WingX Companion).

The payment processing and billing service provider which We use in order to process any transaction which you carry out over the WingX Marketplace, and to remit the funds due to the WingX Companion concerned.

Any member of our group of companies, which means and includes our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Malta Companies Act (Chapter 386 of the Laws of Malta).

Additionally:

advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). Furthermore, We may also use such aggregate information to help advertisers reach the kind of audience they want to target;

web analytics and search engine providers that assist us in the improvement and optimization of our App (including in respect of email delivery);

the service providers which We use to host and maintain the WingX Marketplace;

more generally, We also share such information with vendors, service providers and other partners who globally support our business, such as (non-exhaustively) providing technical infrastructure services, information processing and assessment services, analysing how the WingX Marketplace and its related services are used, measuring the effectiveness of those services and the ads featured on the WingX Marketplace, providing customer services, managing and enhancing customer data, facilitating payments and bookings (as mentioned above), assessing your interest in the WingX Marketplace and its related services and/or conducting customer or academic research and satisfaction surveys.

In the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets;

If all of Our assets are acquired by a third party, in which case the personal data held by Us regarding the users of our Platform will be one of the transferred assets; and

If We are under a duty to disclose or share your personal data to comply with any legal obligation, judgement, court order or regulatory order, or to enforce or apply our Terms of Service or Terms of Use, or to protect Our rights, property, or safety or that of Our users or partners, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.The data that We collect from you, as outlined and described by this Policy, will remain stored on Our servers located within the European Union (“EU”), specifically the Netherlands, and shall not, at any point in time, be transferred to any destination or shared with any entity outside of the European Economic Area (“EEA”).

Add Details on the Security Features you will be implementing to secure and safeguard user information from accidental disclosure, loss, destruction. With the GDPR coming into force soon, these safeguards will need to specifically listed and defined].
We will only store your personal data that We process (as described above) for a period of five (5) years from the date of the termination of your registered account on the WingX Marketplace, so as to be in a position to use such data for the defence of possible, future legal claims and taking into account the applicable prescriptive period at law, saving your specific rights to request erasure, rectification and restriction outlined below.
You are entitled to exercise the following rights [without expense]:

Right to Withdraw Consent: You have the right to withdraw your consent to this Policy, and the processing practices described herein, at any time by sending an email to data@wingx.global. This will not however affect the lawfulness of processing which We carried out on the basis of such consent before its withdrawal.

Data Marketing: You have the right to ask us at any time not to process your personal data for marketing purposes (even if such processing activities have already commenced). We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes. You can exercise your right to prevent or object to such processing at any time by contacting Us at info@wingx.global.

Right of Access: You have the right to request confirmation from Us whether or not We Have processed personal data concerning you and, if this is the case, you also further have the right to request access to such personal data.

Right to Rectification: You have the right to obtain the rectification of any inaccurate personal data about you that We have processed, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to Erasure: You have the right to obtain the erase of the personal data We may have processing concerning you and We shall have the obligation to erase such personal data where, for instance, you have withdrawn your consent to these processing activities.

Right of Restriction of Processing: You have the right, in the following scenarios, to obtain a restriction/s to Our processing activities; namely where:

you contest the accuracy of this personal data, for a period enabling the Us to verify the accuracy of the same personal data;

Our processing is deemed unlawful, and you oppose the erasure of your personal data and request restriction of its use instead;

We no longer need your personal data for the purposes stated in this Policy, but you require it for the establishment, exercise or defense of legal claims;

You have objected to Our processing pending the verification whether the legitimate grounds of Our processing activities overrode those pertaining to you.

Right of Data Portability: You have the right receive your personal data which we have processed, in a structured, commonly used and machine-readable format from Us, and to have this data transmitted to another data controller.

Our Site and App may also, from time to time, contain links to and from the websites or related mobile applications of our partner networks, advertisers and affiliates (and other third party sites).  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

So as to improve the quality and user experience of the WingX Marketplace, we are using Google Analytics Advertising Features, including (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, or Google Analytics Demographics and Interest Reporting).

Any changes we may make to Our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

If you do not consent to the terms and practices set out in this Policy, you must immediately exit the Site and/or App, as applicable.

Therefore, please read this Policy carefully. 

For the purposes of the Data Protection Act (Chapter 440 of the Laws of Malta) (the “Act”)  and/or the General Data Protection Regulation (Regulation (EU) 2016/679) (the “Regulation”), once the latter is in force, the data controller is Karibuni WingX Ltd (C 79910) of Whitehall Mansions, Level 2, Ta’ Xbiex Seafront, Ta’ Xbiex XBX 1026, Malta.

Legal Basis for Processing Activities

We rely on three separate and overlapping legal bases to process your personal information lawfully, and to ensure conformity with Our obligations under applicable data protection laws. Firstly, it is necessary for Us to process your personal information in certain ways, in order to provide the services available over the WingX Marketplace to you, in accordance with the contract created between you and Us as a result of your acceptance of Our Terms of Service, and to ensure the full and proper performance of this contract.

Secondly, where you have given Us valid consent to use your data in certain ways (that is, affirmative, free and unambiguous consent), We will rely on such consent. Lastly, in very specific cases, We may process your information where necessary to further Our legitimate interests, and where those particular interests are not overridden by your own interests or fundamental rights and freedoms. The circumstances giving rise to this latter scenario are described under ‘Sharing and Disclosure of Your Information’.

Information We Collect From You

We will collect and process the following information about you:

As explained further in Our Terms of Services, , some of the features of the WingX Marketplace, such as searching and viewing pages, service descriptions, reviews, and profiles, do not require you to create an account.

Kindly note that the provision of all the above-mentioned information is mandatory in order to book and hire the services of a WingX Companion. 

For instance, if you fail to complete Our required field, then further use of the WingX Marketplace will be blocked. If the user profile is not completed (for the purposes of account registration), then Log-In will not be possible.

This is information We receive about you if you use any of the other websites which We operate (including, for instance, ) or the other services that We provide.

We are also working closely with third parties in order to be able to provide you with the WingX Marketplace and the particular services available through it. Namely, these third parties include the payment processing and billing service provider which we use for the purposes of the WingX Marketplace, advertising networks, analytics providers, search information providers and, needless to say, the particular travel guides and travel service providers featured on the WingX Marketplace (i.e. the WingX Companions).

Specifically, in the case of WingX Companions, the information which you provide them may be shared by them with Us, and We may likewise share your information with them, for the particular and express purpose of processing a booking which you may have placed, ensuring the proper performance of the services that you may have requested and for remitting payments made. 

Kindly note that, as a particular functionality, you (the user) are able to post reviews of the particular WingX Companion whose services you have booked and hired over the WingX Marketplace (“Guide Reviews”). These Guide Reviews should inform other users whether you found the WingX Companion’s services to be satisfactory or not; thereby improving the overall user experience of the WingX Marketplace. Your username is displayed with any Guide Review that you post on the WingX Marketplace.

As a feature of the WingX Marketplace, We also provide a method for you (the user) to communicate with Our WingX Companions (namely, those whose services you are interested in hiring and booking). As better explained in Our Terms of Service, in order to place a booking, you must first get in contact with the WingX Companion concerned and the latter must, in turn, indicate his acceptance.

We will generally store and process these communications and information relating to them, should the need arise in the future to produce them to, for example, regulatory authorities and/or law enforcement agencies.

Please note that we are neither screening nor monitoring these private communications. Therefore, should any issue arise in the course of any such communication/s, you should report it immediately it to Us, instead of waiting for Us to take action of Our own accord.

By way of a general principle, we will only collect the minimum amount of information about you that We need and shall use it for the sole and strict purpose of providing you with the services that We have made available over and through the WingX Marketplace.

Uses Made of the Information

We use information held about you in the following ways:

We will combine this information with information you give to Us and information We collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information We receive).

Sharing and Disclosure of your Information

As mentioned above, We are presently working closely with third parties and selected partners (including, in particular, the WingX Companions) in order to be able to provide you with the services available over and through the WingX Marketplace.

Such selected third parties shall include:

In most instances, the information pertaining to the WingX Companion will similarly be shared with You.

Moreover, as an added functionality, in order to locate travel guides and/or service providers within your area, you may (when using Our App) enable your smartphone to display and transmit your location and GPS data. This will generate search results regarding which WingX Companions are nearby and the services that they provide.

These partners are obligated to protect your information and must adhere to strict confidentiality obligations in a way that is consistent with this Policy and the agreements We enter into them.

Except for the instances outlined directly above, WingX shall not disclose, or otherwise make accessible, the information that you give Us or which We collect from you.

Where a third party processes user data on Our behalf (e.g. a hosting service provider), it is also subject to security and confidentiality obligations consistent with this Policy and applicable law. Where a third party processes user data on its own behalf, its processing us subject to its own privacy policy and applicable law.

Notwithstanding the above, We may also disclose your personal information to third parties:

Where We Store your Personal Data

Safeguards

Period of Storage

In cases where you are only visiting the WingX Marketplace anonymously, your personal data will only be processed and stored temporarily and shall be deleted shortly following your exit from the Site or App (as used by you to connect to the WingX Marketplace).

Your Rights

Data Protection Officer Our Data Protection Officer can be contacted at data@wingx.global. You can address any comments, queries or complaints to this e-mail address, putting the words ‘Data Protection Matter’ in the subject line

Third-Party Links

Google Analytics 

If you would like to opt-out of Google Analytics for display advertising you may do so by using the Ads Preference Manager.

In addition, there is also a Google Analytics opt-out browser add-on that you can download at https://tools.google.com/dlpage/gaoptout/.

Changes to our Privacy Policy

Please check back frequently to see any updates or changes to Our Policy.

Contact

Questions, comments, and requests regarding this Policy are welcomed and should be addressed to info@wingx.global with “Privacy Policy Query” being in the subject line.