Last updated: October, 2023
This Privacy Notice describes how Wing Cloud Inc. (together with its affiliated companies - "Wing Cloud", "we", or "us") collects, stores, uses and discloses personal data when you interact with us, including when you visit or interact with any of our linked websites, including https://www.wing.cloud and https://www.winglang.io ("sites"), participate in any of our events, interact with any of our online ads and content, emails, sales and marketing channels, integrations or communications under our control (collectively with our cloud-oriented programming language Winglang or any ensuing Wing Cloud products or services, the "Services").
Please review this Privacy Notice carefully, and please use the information herein to make informed choices. If you have any concerns or questions about our privacy practices, please feel free to contact us. By accessing the sites, registering for an account, or making a purchase from us, you are agreeing to all of the terms set forth in this Privacy Notice.
If you do not agree to this Privacy Notice, please do not use our sites, purchase our products, interact with our Services, or otherwise provide us with any information. Your continued use of our Services means that you agree to this privacy notice.
You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our service providers, please do not provide it to us and avoid any interaction with us or with any of our Services.
Specifically, this Privacy Notice describes our practices regarding:
- Data Collection & Processing
- Data Uses & Lawful Bases for Processing
- Data Storage and Transfer
- How Long We Retain Your Personal Data
- How We Share or Otherwise Disclose Your Personal Data
- Cookies and Data Collection Technologies and Do Not Track
- Communications
- Data Security
- Your Data Subject Rights
- Data Controller/Processor
- US Privacy Notices
- Additional Notice & Contact Details
When we use the term “personal data” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or identified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Sometimes we collect personal data automatically when you interact with our Services and sometimes, we collect personal data directly from you. At times, we may collect personal data from other sources and third parties (such as our Business Customers, Partners, or Service Providers), even before our first direct interaction.
We may collect or generate the following types of personal data in relation to the Services:
- Contact details: you may provide us with contact and business information such as name, e-mail address, phone number, or job title through our Services, such as by submitting forms available on our sites (e.g. "Contact us" forms, subscription to our newsletters, etc.).
- Account data: Certain Wing Cloud products or services may require registration. When you sign up and create your account, you may provide us with certain personal data such as e-mail address, hashed password or other information used for authentication and access control, profile picture, and any additional information you will choose to share via the Services. You may also choose to sign-up and login to our Services using your GitHub account. To do so, you may provide us with information connected to this account (e.g., e-mail address, username for that account, profile picture and other information listed in the “connect” screen). Please note that the personal data related to such an account will also be subject to that third-party’s terms and privacy policy. Hence, we recommend you to carefully read the terms and privacy policies of such third parties before connecting them to your use of our Services.
- Interactions and communications: correspondence with us (e.g., for support purposes) via the Services or our social media pages (such as Twitter, Facebook), as well as via chats, surveys, feedback, calls and video recordings, and analyses thereof.
- Usage and analytics data: connectivity, technical and behavioral usage data, user agent, IP addresses, device data (such as type, OS, device ID, browser version, locale and language settings used), activity, communication and performance logs, session recordings, issues and bugs, and the cookies and pixels installed or utilized on your device as you access or otherwise use the Services.
When we offer our Services to business customers (“Business Customers”), we may also process personal data concerning their internal focal persons who directly engage with Wing Cloud concerning their organizational account, billing contacts and authorized signatories on behalf of the Business Customer; as well as the customer’s business needs and preferences, as identified to us or recognized through our engagement with such Business Customer. If you use our Services on behalf of your company which is a Business Customer of ours, please note that we may process certain aspects of your personal data as a Processor, on behalf of and under the instruction of the respective Business Customer. For additional details please refer to Section 10.
We use your personal data as necessary for the following purposes and in reliance on the lawful bases detailed in the chart below:
| Purpose | Lawful basis for processing |
|---|---|
| To facilitate, operate and provide our Services. | Performance of a Contract, Legitimate Interests, Consent (to the extent applicable) |
| To authenticate your identity, and allow you to access our Services (for Wing Cloud Services requiring registration) | Legitimate Interests, Performance of a Contract |
| To gain a better understanding on how you use and interact with our Services, and how we could improve your and others’ user experience and continue improving our offerings and the overall performance of our Services. | Legitimate Interest, Consent (to the extent applicable) |
| To provide customer service and technical support. | Performance of a Contract, Legitimate Interest |
| To support and enhance our data security measures, including for purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity. | Compliance with legal obligations, Legitimate interest, Performance of a Contract |
| To comply with court orders and warrants, and prevent misuse of the Services, and to take any action in any related legal dispute and proceeding. | Compliance with legal obligations, Legitimate interest, Performance of a Contract |
| To comply with applicable laws and regulations. | Compliance with legal obligations |
| To contact you with general or personalized Service-related messages. | Performance of a Contract, Legitimate Interest |
| To carry out, facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications, and contact you with promotional messages that may be of specific interest you. | Consent (to the extent applicable), Legitimate Interest |
| To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences. | Legitimate Interest |
| To facilitate, sponsor and offer certain events, contests and promotions. | Legitimate Interest, Consent (to the extent applicable) |
| To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, conduct research, or for any other purpose. | Legitimate Interest, Performance of a Contract, Compliance with legal obligations |
If you reside or are using the Services in a territory governed by privacy laws under which “Consent” is the only or most appropriate lawful basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing), your acceptance of this Privacy Notice will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Notice, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at [email protected].
We and our authorized service providers (further detailed below) maintain, store and process personal data in the United States of America, Europe, Israel and other locations, as reasonably necessary for the proper performance and delivery of our Services, for our internal business purposes in the locations where Wing Cloud resides, or as may be required by law.
While privacy laws may vary between jurisdictions, Wing Cloud is committed to protect personal data in accordance with this Privacy Notice and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
Wing Cloud has offices in the United States and in Israel, the latter a jurisdiction which is considered by the European Commission, the Swiss Federal Data Protection and Information Commissioner (FDPIC), and the UK Secretary of State to have an adequate level of protection for personal data originating from the EEA, Switzerland and the UK, respectively. We transfer personal data from the EEA, Switzerland or the UK to Israel on this basis. For data transfers from the EEA, Switzerland or UK to countries that are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into updated Standard Contractual Clauses as approved by the European Commission, FDPIC and UK Information Commissioner’s Office (ICO).
We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and applicable laws.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you.
If you have any questions about our data retention policy, please contact us by e-mail at [email protected].
We disclose personal data in the following ways:
- Service Providers: We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial, privacy and compliance advisors (collectively, “service providers”). Our service providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
- Partnerships: We may engage selected business and channel partners, resellers, distributors and providers of professional services related to our Services, which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our customers, users and prospects. In such instances, we may share relevant contact, business and usage details with the respective partner, to allow them to engage with those entities and individuals for such purposes. If you directly engage with any of our partners, please note that any aspect of that engagement that is not directly related to the Services and directed by us is beyond the scope of Wing Cloud’s Terms of Service and this Privacy Notice, and may therefore be covered by the partner’s own terms and policies. Please review the privacy notices and terms of services of those businesses for more information about what each of those businesses does with your personal data.
- Service Integrations: Our Services may allow or require connection or integration with third-party services, for example, GitHub. The provider of this connected or integrated third-party service may receive certain relevant data about or from your account on the Services, or share certain relevant data from your account on the third-party provider’s service with our Services, including personal data, depending on the nature and purpose of such integration. Note that we do not receive or store your passwords for any of these third-party services (but do typically require your API key in order to integrate with them).
- Event Sponsors: If you attend an event or webinar organized by us, or download or access an asset on our sites related to such an event, webinar or other activity involving third-party sponsors or presenters, we may share your personal data with them. Depending on the applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth where relevant. In these circumstances, your personal data will be subject to the sponsors’ privacy statements. If you do not wish for your personal data to be shared, you may choose not to opt-in via the event/webinar registration, or elect to not have your badge scanned, or you can opt-out in accordance with Section 7 below.
- Sharing your Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review on our sites and in our Services. If you wish to remove your public review, please contact us at [email protected].
- Business Customers: Our Business Customers may have access to any personal data we process on their behalf in our capacity as a “processor” or a “service provider”, including personal data relating to their users, as it occurs in the context of their use of our Services.
- Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
- Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Wing Cloud and our employees, any of our prospects, users or customers, or any members of the general public.
- Wing Cloud Subsidiaries and Affiliated Companies: We may share personal data internally within our group, for the purposes described in this Privacy Notice. In addition, should Wing Cloud or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. We may disclose personal data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.
For the avoidance of doubt, Wing Cloud may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
We and our service providers use “cookies”, anonymous identifiers, pixels, container tags and other technologies in order to provide our Services and ensure that they perform properly, to analyze our performance and marketing activities, for personalization purposes, for product development and improvements, and to personalize your experience.
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser tab or window. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools. We may also use HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it.
Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.
We also use the web analytics tool Google Analytics. This tool helps us understand users’ behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service provider is available at: www.google.com/policies/privacy/partners. Further information about your option to opt-out of this analytics service is available at: https://tools.google.com/dlpage/gaoptout.
Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
For more information on our cookie and data collection technologies practices, you may also use the “Cookie settings” feature available in our Services depending on your location and activity on our Services, as applicable.
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use of some of our Services (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our customer, user or prospect, subject to any necessary collection of your consent as appropriate based on applicable laws. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify us at any time by sending an e-mail to: [email protected] or by following the instructions contained in the promotional communications you receive.
We have implemented industry-standard physical, procedural and technical security measures, designed to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that our Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. If there is any unexpected activity or inaccurate information or if you have reason to believe that your information is no longer secure, or if you have any questions about our security, please contact us by e-mail at [email protected].
Individuals have rights concerning their personal data. Please contact us by e-mail at: [email protected] if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and others such as – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request correction or erasure of your personal data held with Wing Cloud, or to restrict or object to such personal data’s processing (including the right to direct us not to sell or share your personal data to third parties now or in the future, as described below), or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you). Under some regulatory frameworks, such as the GDPR, you may also have the right to lodge a complaint with the relevant supervisory authority, as applicable. These rights are also subject to various exclusions and exceptions under applicable laws.
We will not charge a fee to process or respond to your verifiable privacy 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. Alternatively, we may refuse to comply with your request in such circumstances.
To the extent applicable to you, you may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.
Please note that when you or an authorized agent ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data regarding which you request to exercise your rights. Such additional data may be then retained by us for legal, compliance and auditing purposes (e.g., as proof of the identity of the person submitting the request or proof of request fulfillment). We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal data.
Please also note that we may deny your request or we may retain certain elements of your personal data if it is necessary for us or our service providers. We will provide details of our reasoning to you in our correspondence on the matter.
Certain data protection laws and regulations, such as the EU GDPR, UK GDPR, and CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Wing Cloud assumes the responsibilities of “data controller” (to the extent applicable under law) for the processing of all the personal data listed in Section 1 above as set forth in this Privacy Notice.
However, when Wing Cloud processes personal data on behalf of its Business Customers, Wing Cloud will act as a “data processor” of such data and therefore process the data strictly in accordance with the relevant Business Customer’s reasonable instructions and as further stipulated in the Data Processing Addendum and other commercial agreements we may have with the Business Customer. As the data controllers of such personal data, our Business Customers are solely responsible for determining whether and how they wish to use our Services, and for complying with their obligations under applicable data protection laws and regulations, including handling data subject rights requests by their users and other individuals whose personal data they process through the Services.
Updates and Amendments: We may update and amend this Privacy Notice from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you. In the event consent is required based on where you reside, you will be asked to consent prior to being allowed to access our Services subsequent to a Privacy Notice update/amendment.
External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Notice applies only to our Services.
US State Laws Requirements: This Privacy Notice describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention (Section 4) and deletion (Section 9) practices. We also included information about how we may process your information, which includes “business purposes” under the CCPA and similar US State Laws. If you would like to opt out of the “sale” or “sharing” (as such terms are defined under applicable U.S. State Laws including the CCPA) of your personal information, please contact us at [email protected]. We may disclose personal information with third parties or allow them to collect personal information from our Services as described in Section 5 above, if those third parties are our Business Customers (in respect of users’ personal data processed on their behalf), or our authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or direct us to disclose your personal data to third parties. You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us at [email protected]. Note that we will not discriminate against you by withholding our Services from you or providing a lower quality of service to you for requesting to exercise your rights under the law, to the extent possible.
If you have any questions or would like to exercise your rights under any applicable US State Laws, you can contact us at [email protected].
Children: Our Services are not designed to attract minors. We do not knowingly collect personal data from minors and do not wish to do so. If we learn that a person who is considered a minor according to applicable law is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such minor. If you believe that we might have any such data, please contact us by e-mail at [email protected].
Contacting Us: If you have any comments or questions regarding our Privacy Notice, or if you have any concerns regarding your personal data held with us, please contact Wing Cloud at [email protected].