Privacy Policy

Last Modified: November 1, 2022

Wingbuddy Inc. or Camarades D’Ailes Inc. (“we” or “Wingbuddy”) is committed to protecting the privacy rights of Consumers. For purposes of this policy, “you” or “your” means any visitor to our website or any Consumer or household whose Personal Information [1] is received by Wingbuddy in any way. Protecting your privacy is fundamental to the way Wingbuddy conducts business. This Privacy Notice explains what Personal Information is, how we receive and may use Personal Information, and, most importantly, Wingbuddy’s commitment to honor your rights under certain privacy laws. By using the Wingbuddy Website or Services, you consent to the privacy practices described in this Policy.

Personal Information

In the course of providing services to our consumers, we may receive sensitive information about their clients (“you” or “Consumer ”) that potentially identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household (”Personal Information”). Personal Information does not include publicly available information, de-identified information, or aggregated Consumer information.

Collection of Personal Information

We may receive Personal Information for the purpose of performing services on behalf of our business partners:

• By which you may be personally identified, such as first and last name, postal address, e-mail address, telephone number, or any other identifier; products/services you purchase and/or
   
• That is about a website visitor but does not identify a specific person, such as internet connection, the equipment used to access our Website, and usage details.

We may also receive Personal Information:

• From third parties, for example, our business partners or subcontractors;

• Automatically as you navigate through our website (www.wingbuddy.com). Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and/or

• If you contact us through 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 any request.

We will not retain or use any Personal Information for any purpose other than: (i) providing services to our business partners; and (ii) using the Personal Information internally to verify sales completed by our subcontractors, maintain the quality of our services, comply with legal requirements, and improve the services for our business partners.

For purposes of fulfilling travel arrangements on the consumer’s behalf, we will share personal information with airlines and suppliers.

We may disclose Personal Information we receive: (i) to our subsidiaries, affiliates, contractors, service providers, and other third parties we use 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 business partners; (v) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our business partners or others; or (vi) with your consent.

We do not engage in any of the following: (i) selling Personal Information; (ii) retaining, using, or disclosing Personal Information for any purpose other than providing services to our business partners; or (iii) retaining, using, or disclosing Personal Information outside of the direct business relationship with our business partners.

Data We May Collect About You 

We collect and use different types of data from and about you including:

• Personal data that we could reasonably use to directly or indirectly identify you, such as your full name, postal address, email address, telephone number, user name, or other similar identifier, any other identifier we may use to contact you online or offline (”personal data”).

• Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.

• 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 setting, browser plug-in types and versions, or operating system and platform.

• Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to and from our Website (including date and time), page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

If we combine or connect non-personal, technical, or demographic data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

How We Collect Data About You   

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us information about you by filling in forms or by corresponding with us by e-mail or phone.

• Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies and other similar technologies (see Cookies and Automatic Data Collection Technologies).

• Third parties or publicly available sources. We may receive information about you from third parties including, for example, business partners, subcontractors, advertising networks, analytics providers, search information providers, data brokers, or aggregators.

• User contributions. You also may provide information for us to publish or display (”post”) on public Website areas or transmit to other Website users or third parties (collectively, “User Contributions”). You submit User Contributions for posting and transmission to others at your own risk.  Additionally, 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.

 Cookies and Automatic Data Collection Technologies  

Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalized service when you browse our Website. It also allows us to improve our Website by enabling us to:

• Estimate our audience size and usage patterns.

• Customize our Website.

How We Use Your Personal Data 

We use your personal data to provide you with services, communicate with you, or to conduct other business operations. Examples of how we may use the personal data we collect include to:

• Present our Website and provide you with the information, services, and support that you request from us.

• Notify you about changes to our Website or services.

• Ensure that we present our Website content in the most effective manner for you and for your computer.

• Administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.

• Improve our Website, services, marketing, or customer relationships and experiences.

• Protect our Website, employees, or operations.

• Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you;

• We may also use personal data to contact you about our own and third-parties’ services that may be of interest to you.

• We may use non-personal data for any business purpose.

Disclosure of Your Personal Data  

We may share your personal data with:

• Any member of our corporate group, which means our subsidiaries and our affiliates.

• Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business. We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes.

• Third parties to market their products or services to you if you have not opted out of these disclosures.

• Advertisers and advertising networks that require the data to select and serve relevant ads to you and others.

• To fulfill the purpose for which you provide it.

• For any other purposes that we disclose when you provide the data.

• With your consent.

We may also disclose your personal data to third parties:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request.

• To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.

We may share non-personal data without restriction.

Consent to Personal Data Transfer   

We are based in Canada and may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. By submitting your personal data or engaging with the Website, you consent to this transfer, storing, or processing.

Your Personal Data Use Choices 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  If you do not want us to use your contact information to promote our services or third parties’ products or services, you can opt-out by emailing [email protected] 

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 data to these third parties.

Data Security

The security of your personal data is very important to us consequently Wingbuddy has implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access and disclosure. The use of, and access to, your Personal Information by us is restricted to employees and subcontractors who need to know that information to provide services to our business partners. We maintain physical, electronic and procedural safeguards to limit access to your Personal Information. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Consumer Requests

Data Privacy laws, such as the Bill 64 in Quebec and the California Consumer Privacy Act (“CCPA”), provide certain Consumers with specific rights regarding their Personal Information. When a verified request is submitted via email at [email protected], Consumers have the right to know the categories and specific pieces of Personal Information that we receive pertaining to the requesting Consumer. We will honor the legal rights provided in applicable Data Privacy laws to all verified Consumer requests. This section describes how to exercise your right to: (i) know what Personal Information Wingbuddy has collected about you; and (ii) request that your Personal Information is deleted, provided that no exception exists.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the 12 months preceding the date of your verified request. We will make all reasonable efforts to retain Personal Information no longer than necessary, which typically will be less than 12 months.

Once we receive your request and confirm you’re a verifiable Consumer, our Data Manager, within the timelines required under the Data Privacy laws, will disclose to you:

• The categories of Personal Information we received about you.

• The categories of sources from which we received the Personal Information.

• Our business purpose for receiving Personal Information.

• The categories of third parties (if any) with whom we share the Personal Information.

• The specific pieces of Personal Information we received.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.

An exception would apply if any of the following occur: (i) the request would violate evidentiary privilege; (ii) your information is necessary to comply with any court order, law, or legal process, including responding to any government or regulatory request; (iii) your information is necessary to complete the transaction for which the Personal Information was collected; (iv) you previously made two (2) requests within a twelve (12) month window.

Once we receive and confirm your verifiable Consumer request and an exception does not apply, we will delete (and direct our service providers to delete) your Personal Information from our records.

Exercising Access, Data Portability, and Deletion Rights

To exercise the rights described above, please submit a verifiable Consumer request to Wingbuddy’s Data Manager, through any of the following methods:

• Phone: 1.855.295.9200

• Email: [email protected]

Only you, or a person that you authorize to act on your behalf, may make a verifiable Consumer request related to your Personal Information. If an agent submits a request on your behalf, Wingbuddy will require that you: (1) provide the authorized agent written permission to do so; and (2) verify your own identity directly with Wingbuddy. 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, Wingbuddy will not require written permission to make a request on your behalf.

A verifiable Consumer request for access, data portability, or deletion, may only be made twice within a 12-month period. The verifiable Consumer request must:

• Provide sufficient information that allows us and our business partners to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Wingbuddy cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

You are not required to create an account with Wingbuddy to make a verifiable Consumer request. Wingbuddy will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.

Do Not Sell My Personal Information

Although it is our policy that we do not sell your personal information, the California Consumer Privacy Act (“CCPA”) gives California resident consumers the right to opt-out of allowing Wingbuddy to sell personal information in the future. In order to send an opt-out request to prevent the selling of personal information, please email us at [email protected].

Response Timing and Format

Wingbuddy will acknowledge receipt of your request within ten (10) days of its receipt. Wingbuddy endeavors to respond to a verifiable Consumer 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 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. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

Sharing Personal Information

Wingbuddy may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

Non-Discrimination

We will not discriminate against you for exercising any of your data privacy rights and we will not cause our business partners or subcontractors to:

• Deny you any services.

• Provide a different level or quality of service.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of products or services.

 Accessing and Correcting Your Personal Data

You can access, review, and change your personal data by sending us an email at [email protected] to request access to, correct, or delete personal data that you have provided to us. We may not be able to accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively affect the information’s accuracy.

Children’s Online Privacy  

We do not direct our Website to minors and we do not knowingly collect personal data from children under 18 years of age or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at [email protected].

Changes to Our Privacy Notice

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

Contact Information

If you have any questions or comments about this notice, 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  [email protected] or alternatively:

Wingbuddy Inc, Attention Chief Privacy Officer

333 Chabanel O #518,

Montréal, QC H2N 2E7

[1] “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, or that is otherwise deemed personal information under Applicable Privacy Laws.

[2] “Consumer” means an individual or household about whom we have received personal information