Privacy Policy

Wingbuddy Inc. Privacy Policy 

Last Modified: January of 2025 

This Privacy Policy (the “Policy”) is issued by Wingbuddy Inc. or Camarades D’Ailes Inc. (“Wingbuddy”, “we”, “us”, or “our”) in furtherance of our commitment to respecting data privacy rights.  For purposes of this Policy, “you” or “your” means any visitor to our website, or any natural person or household whose "Personal Information" is collected by us in any way. This Policy describes how we collect, use, analyze and share Personal Information and how we ensure that your privacy rights always are honored. By using our website or Services (as defined herein), you consent to the privacy practices described in this Policy. 

1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

Protecting your privacy is fundamental to the way Wingbuddy conducts business.  Within this Policy, "Personal Information" means any information that identifies, relates to, describes, is capable of being associated with, or reasonably could be linked, directly or indirectly, to a particular individual or household. Such can include, but is not limited to, real name, postal address, Internet Protocol Address, email address, account names, or other similar identifiers, or information generated from electronic network activity, including browsing history, search history and any information concerning an individual’s interaction with an internet website. “Sensitive Personal Information” can include government identification numbers, financial account numbers, geolocation data, genetic, medical information or other similar identifiers. Personal Information does not include certain forms of publicly available information, deidentified information, or aggregated information that is not capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual or household.

In the course of providing services to our business partners (“Partners”) and customers, we may collect and receive the following categories of Personal Information: 

1. Transactional Data and Information.  This includes Personal Information related to consumers or households who purchase products or services offered by our Partners through our Services, which may encompass first and last name, address, contact information (such as phone number and email), date of birth, details of a particular transaction (including, without limitation, products and/or services purchased, purchase price, and date of purchase), government-issued identification, payment card data and other transactional information, as well as information generated by your engagement with any of our Partners, third party service providers, subcontractors, and affiliates.  This information can also result in us collecting aggregated data that identifies trends and facilitates ongoing analysis of the services we perform. In some instances, we may receive “lead lists” from our Providers, which contain Personal Information of prospective customers.

2. Compliance and Operational Information.  This includes Personal Information related to our subcontractors and their employees, which can encompass information such as first and last name, product/service and compliance training data generated from those individuals, information in what is commonly known as a "background check", as provided by a consumer reporting agency in the relevant destination country and as authorized pursuant to applicable law, and government-issued identification.

3. Information Generated from Our Website.  

   1. This includes information gathered by way of “Cookies”, web beacons, and other tracking technologies.  “Cookies” are text files that websites store on a visitor’s device to identify the visitor’s browser or to store information or settings in the browser to track activity and patterns.  Web beacons, pixel tags, or clear GIVs are typically one-pixel, transparent images located on a webpage or in an email or other message that demonstrate a user has accessed or opened certain content or that the content was viewed or clicked.  These or similar technologies may be used on our sites, in some of our digital communications (such as email or other marketing messages), as well as when you are served advertisements or you otherwise interact with advertisements outside of our online services.  They help us deliver a better and more personalized service when you browse our website and otherwise allow us to improve our website by enabling us to estimate our audience size and customize our website.  

   2. Personal Information gathered includes technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone settings, browser plug-in types and version, operation system and platform, and phone number used to call our customer service number.  Additional non-personal information about your interactions with our website, including the full Uniform Resource Locations (URLs), clickstream to and from our website (including date and time), page response times, length of visits to certain website pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from a page.  If we combine or connect and non-personal, technical, or demographic data with Personal Information so that it directly or indirectly identifies an individual, we treat the combined information as Personal Information.

   3. For more information about our use of cookies, information we collect using cookies and how that information is used, and how to manage your cookie settings, please see our Cookie Policy.  

4. Information You Provided to Us.  This includes Personal Information you submit to us, such as information submitted to us in any request or provided to us when you communicate with us or use our website (including by filling in forms or corresponding with us by telephone or via email).  If you contact us by our website, we will receive your name, email address, and any comments included in your message.  You may decline to provide us this information, but this may result in us being unable to verify or respond to your request.  

2. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION 

Personal Information is collected by us in a variety of ways and used to support our business operations. We will not retain or use any Personal Information for any purpose other than: (i) fulfilling the purposes for which you provided the data or that were described when it was collected; (ii) notifying you about changes to our sites, applications, or services; (iii) facilitating services and operations performance, security and integrity, including internally verifying transactions; (iv) complying with our legal obligations and risk management, recordkeeping, audit, investigation and reporting, fraud prevention, and other legal and compliance obligations; (v) providing information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a Provider; (vi) facilitating and targeting sales and marketing activities; (vi) managing verifications and information requested by you and our Providers; (vii) maintaining the quality of and improving our services and otherwise ensuring we are performing in accordance with our Providers’ and your expectations; (viii) administering our website and conducting internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes; (ix) carrying out our obligations and enforcing our rights arising from any contracts entered into between you and our Providers; and (x) protecting the rights, property, and safety of our business, employees, customers, and others, including for the purposes of cybersecurity, fraud protection, and credit risk reduction (collectively, the “Services”). 

1. Transactional Data and Information.  

   1. This data is generated by your transactions or activity through us, which is delivered to electronically or accessed through secured portals, and is necessary for your Services.  This data can also be provided to us by you filling in forms that are submitted to us as part of our Services).  We may be required to collect specific Personal Information about you as required by our Providers and applicable law.  If you choose not to provide us with the Personal Information requested, or not respond to specific questions, your purchase of our products or services offered by Providers through our Services may be denied or delayed, and we will inform you of such consequences.  

   2. Certain categories of de-identified transactional data are shared with our subcontractors or other third party service providers to validate the Services performed and otherwise oversee performance. We may use this data to validate sales, process payments to our subcontractors and otherwise ensure we are performing in accordance with your and our Providers’ expectations.

2. Compliance and Operational Information.  This Personal Information is collected from our subcontractors and is provided to ensure subcontractors and their employees are eligible to perform Services. Sensitive Personal Information may be delivered to us in a consumer report (also known as a "background check") through a consumer reporting agency in the relevant destination country at the direction of a subcontractor. We access this information through a portal that is used to transmit the Personal Information in a secure and protected environment. 

3. Information Generated from Our Website. Cookies, web beacons, and tracking technologies may be used for various Services, such as fraud prevention, monitoring our websites, and assessing our marketing performance.  This information is gathered by and through a visitor to our website and interactions generated from that visit. Some of these tracking tools may detect characteristics or settings of the specific device you use to access our online services. 

4. Other Information Provided to Us. This Personal Information is provided to us by you and is used to (i) provide you with information, products, or Services, (ii) verify, process or respond to any request you submit to us, and (iii) otherwise communicate with you for any other purpose.  

   1. User Contributions.  You may also provide information for us to publish or display (“post”) on our public website or transmit to other website users or third parties (collectively, “User Contributions”).  Your submission of User Contributions for posting and transmission to others at your own risk.  We cannot control the actions of any website users with whom you choose to share your User Contributions.  Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions. 

5. Aggregate Analytical Data. We may also use data that we collect on an aggregate and anonymous basis (such that it does not identify any individual customer, directly or indirectly) for various Services, where permissible under applicable laws and regulations.  This data may be used by us to (i) provide, support, improve, maintain, and otherwise operate our Services; (ii) develop new features and Services; (iii) compile statistical reports and record insights into usage patterns; and (iv) otherwise further our business objectives.

3. SHARING OF PERSONAL INFORMATION 

We never sell your Personal Information.  We share information provided to us with various trusted Providers, third party service providers, and subcontractors for the purpose of our performing our Services and otherwise facilitating our business objectives.   

1. Our Subcontractors. We share Personal Information with our subcontractors to process payments and otherwise oversee business operations. This data often is de-identified and does not contain information that would be capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual or household. We also may share information in lead lists for the purpose of targeting sales and marketing efforts.  

2. Our Providers. We share Personal Information with our Providers for the purpose of facilitating our Services, as well as to improve the quality and integrity of Services delivered and to otherwise ensure we perform effectively.  In order to fulfill travel arrangements on a customer’s behalf, we will share Personal Information with third-party suppliers who provide travel services such as flights, cruises, hotels, airport-hotel transfers, sightseeing excursions, car rentals or other activities included in packages offered through our Services.   

3. Third Party Service Providers.  We share Personal Information with third party service providers that provide essential services on our behalf or on behalf of our Providers to operate and support our business objectives. These third parties may use your Personal Information only to help us operate and deliver Services as part of our business, as authorized in our contracts with our Providers. These may include third parties providing transactional support; software to transmit, process or verify transactions; third party verification services; call center transaction processing; search information providers; data brokers or aggregators; advertising networks; analytics providers; software development; and other forms of support services necessary to operate our business.   

4. Affiliates and Related Companies. We also may disclose Personal Information to our subsidiaries, affiliates, and other third parties we use (i) to support our business; (ii) to fulfill the purpose for which you provide it; (iii) to comply with any court order, law, regulation, or legal process, including responding to any government or regulatory request; (iv) to carry out our obligations and enforce our rights arising from any contracts entered into between you and our Providers; (v) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our Providers, business partners or others; or (vi) to any other party with your consent.

4. DATA RESIDENCY AND RETENTION 

Any data we collect will reside within our secure cloud-based Google platform and servers, maintained through Google’s data centers around the world.  Data may be processed on servers located outside of the country where you are located because data is typically processed by centralized or regionalized operations.  We may have third-party service providers that reside and retain data in Canada, the United States or overseas, in which case our practice is to disclose that to any data subject whose data would be subject to this arrangement.  

Transactional Data containing Personal Information will be retained for three (3) years from the date the travel services obtained through your use of our Services has concluded. We may retain other de-identified information for seven (7) years, however this information will not be information that is capable of being associated with, or reasonably could be linked, directly or indirectly, to a particular individual or household.

Compliance and Operational Data will be retained for as long as a subcontractor and its respective employees provide services on our behalf, and three (3) years thereafter. In the event we receive Sensitive Personal Information pertaining to an employee of one of our subcontractors, such as information contained in a background check or government-issued identification, that information is retained for fourteen (14) days. 

Information generated from the use of our website is retained for no longer than thirteen (13) months.  

5. YOUR DATA RIGHTS

This portion of our Policy details your rights and how we strive to respect the data privacy rights that may apply in our business. Within this Policy, we also provide you information on how you may exercise these rights. Assuming we are able to verify your identity and the request you submit to us, you have the following rights: 

1. Right to Know. You have a right to know what Personal Information we may have collected and retained pertaining to you in the twelve (12) months prior to the date of your requests. If requested and if verified (as discussed below), we will provide you the categories, specific pieces and sources of your Personal Information we have collected, the business purpose for which we gathered the information, and the categories of any third parties with whom we have shared the Personal Information.

2. Access and Correction. You can request a copy of the categories and specific pieces of Your Personal Information collected by us in the twelve (12) months prior to the date of your requests, and to correct inaccuracies therein, if any.

3. Deletion. You can request that we delete your Personal Information, provided that no exemption to the deletion exists (discussed below). For clarity, we will retain Transactional Data for three (3) years from the date the travel services obtained through your use of our Services has concluded, notwithstanding our receipt of a verifiable data deletion request, in order to comply with retention obligations set forth by applicable law.

4. Opt-Out of the Selling or Sharing. You can request to opt out of our ability to sell or share your Personal Information.

5. Non-Discrimination. You are entitled to exercise the rights in this Policy free from discrimination as prohibited under applicable privacy laws.

6. EXERCISING YOUR DATA RIGHTS 

If you have a question as to how you can exercise your data rights under this policy, please contact us through our website, by calling our toll free number at 1-(855)-295-9200, or by emailing us at [email protected]. The requests herein are subject to certain exemptions and limitations that may limit our ability to process or grant the request. For example, we reserve the right to deny a request if the information is necessary to comply with a legal requirement or to provide you Services, of if we have a legal obligation that requires us to maintain the requested information:

1. Access to Personal Information. You may submit a request to us to identify the categories and specific pieces of your Personal Information we have gathered in the twelve (12) months prior to your request.  You may submit a data request to us by contacting our Data Manager, through any of the following methods:

Phone (toll free): 1 (855) 295-9200

Email: [email protected] 

2. Do Not Sell or Share My Personal Information.  While it is not our practice to sell any Personal Information, you may request that we not sell or share your Personal Information by contacting our Data Manager, through any of the following methods:

Phone (toll free): 1 (855) 295-9200

Email: [email protected] 

3. Limit the Use of my Sensitive Personal Information.  Certain data privacy laws provide you the right to request that we limit the use of any of your Sensitive Personal Information we may hold (if any). You may request that we limit the use of your Sensitive Personal Information by contacting our Data Manager through any of the following methods: 

Phone (toll free): 1 (855) 295-9200

Email: [email protected] 

4. Processing Requests.  

   1. Agents. To protect your privacy and security, we may take reasonable steps to verify your identity before granting any request relating to your data. Only you, or, may submit a request related to your Personal Information. To be actionable and verified, a request must (i) provide sufficient information that allows us to reasonably verify you are the person who is the subject of the data request, or a person that you authorize to act on your behalf, and (ii) describe the request with sufficient detail that allows us to properly understand and respond. If an agent submits a request on your behalf, we will require that you: (i) provide the authorized agent written permission to do so; and (ii) verify your own identity directly with us. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf. If the agent demonstrates authorization through power of attorney, we will not require written permission to make a request on your behalf. We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

   2. Timing and Process. We will acknowledge receipt of your request within ten (10) days of its receipt. We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable Consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

   3. Cost. We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

   4. Exemptions. We may not process a request if a legal exemption applies or if we have a legal reason to not process the request. We specifically reserve the right to not process a request if: your Personal Information is necessary to exercise or defend any actual or potential legal claims; your Personal Information is necessary to comply with any court order, law, or legal process, including responding to any government or regulatory request; your Personal Information is necessary to complete the transaction for which the Personal Information was collected; you previously made two (2) requests within a twelve (12) month time period; as well as any other reason allowed under applicable laws. 

   5. Verification. We can only process those requests that have sufficient information for us to verify the identity of the person submitting the request in relation to the information that we possess. A requestor’s failure to provide us complete or accurate information may prevent or delay our ability to verify a request. To verify a request, we reserve the right to request government identification, personal identifiers that allow us to match information and a declaration from the requestor under penalty of perjury. To properly verify a request, we must be provided sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

7. SECURITY

The security of your information is our highest priority. We are required by law to maintain the privacy and security of your Personal Information. We use technical, physical, and organizational security measures designed to protect your Personal Information from accidental loss and from unauthorized access and disclosure, in compliance with federal, state, and international standards. We maintain physical, electronic and procedural safeguards to limit access to your Personal Information. We also actively monitor our systems for suspicious or fraudulent activity. The use of, and access to, your Personal Information by us is restricted to employees, subcontractors, business partners, and authorized third party service providers, who need to know that information to enable us to provide our Services. Notwithstanding, security risk is inherent in all internet and information technology platforms and no part of this Policy should be interpreted as a guarantee or other legal obligation in relation to preventing all threats to networks, systems or other repositories of information.  

8. CHILDREN 

Our services and this website are not intended for children or anyone under the age of eighteen (18). In the event we learn that we inadvertently collect any Personal Information of a minor, without the required consent by law, we will delete said information immediately. If you believe that we have collected information of a minor, please contact our Data Manager through any of the following methods:

Phone (toll free): 1 (855) 295-9200

Email: [email protected] 

9. CONTACTING YOU ABOUT THE SERVICES OR OTHER MARKETING OFFERS

1. Your Authorization for Us to Contact You. You understand and agree that we have the right to contact you about your Services and any other marketing offers that we may offer. By accepting this Policy, you consent to being called, emailed, or receiving SMS texts from us about any marketing offers we may offer you at any point during your use of our Services and for thirty (30) days thereafter. This may include automated dialers, prerecorded messages, artificial voice or automatic texting systems. This consent is not required to complete any purchase. Message and data rates may apply to any communication. This authorization will apply notwithstanding any prior placement on a do-no-call registry. 

2. Right to Opt-Out of Marketing Communications. You may opt out of receiving any marketing communications from us. This will not include opting out of non-marketing communications related to your Services. You may request that we stop sending you marketing communications by contacting our Data Manager through any of the following methods:

Phone (toll free): 1 (855) 295-9200

Email: [email protected] 

10. CHANGES TO OUR PRIVACY POLICY 

We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated notice on the Website and update the effective date. Your use of our Website following the posting of changes constitutes your acceptance of such changes. 

11. PROVIDERS AND OTHER THIRD PARTIES

Please note that the Providers that provide the travel services offered through our Services may have Personal Information about you. Our Policy does not govern their use of Personal Information about you. You should review the privacy notices of your Provider(s) to understand how they collect, use, and disclose your Personal Information.  

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties 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 Information to these third parties.

12. CONTACT US

If you have any questions or comments about this Policy, the ways in which Wingbuddy collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights please do not hesitate to contact us at:

Phone (toll free): 1 (855) 295-9200

Email: [email protected]