Wingsure Inc. (“Wingsure”, “We”, “Our”, or “Us”) is committed to protect the privacy of its Users (defined below). The statements included herein disclose the privacy practices (“Privacy Policy”) of Wingsure’s mobile application known as Wingsure Application (“App”) to help Users to understand what information We collect, how We handle it and what rights the Users have on their information.
1.1 What is the personal information collected by Us and why do We need to collect such information
To make use of certain features on the Website and/or the App, you voluntarily provide us certain information, i.e. name, phone number, email address, gender, age, interests, occupation, and the like, as part of the registration process whether as a visitor, contributor, subscriber or sponsored service user (“User(s)”). This information helps Us enhance Our services by allowing Us to tailor Our App to cater to your personal interests and make them more useful to you. Further, your information is required to create and maintain your accounts with Us and to contact you in case you need support. As a User, you voluntarily agree that your information may be used and handled by Us as detailed in this Privacy Policy.
We may ask for and collect the following information about you when you use the App and without such information We may not be able to provide you with all the requested services:
1.1.1 Sign Up Data
- Mobile Number
1.1.2 Profile Data (based on the service accessed)
To use certain features on the App, you may be required to provide basic contact information including but not limited to the following:
- Name;
- Gender;
- Phone;
- Email address;
- Date of birth;
- Residential Address;
- Details of Assets as required by the service provider requirements;
We may further collect and record the following personal information under the “my profile” section, which helps Us to provide customized feeds and maintain a User profile, including but not limited to land assets, crop details, farm assets including livestock, farm workers and machinery used in the farm. Details of automobiles and family members may be sought for availing services.
Mobile Device Permissions: When accessing the App on mobile device/tablet/TV or any other device having access of the App, We may request and gain access to the following:
- Contacts – used for accessing Users contact in order to share articles through the App;
- Phone – to enable User notifications on User’s device. IMEI (International Mobile Equipment Identity) number is being collected to uniquely identify every User;
- Camera – in order for the User to upload images and profile image of the User;
- Microphone – to enable voice command related actions;
- Storage – to access files and folders from inside the App; and
- SMS – to send and receive verification messages.
Permissions to these settings may be essential for adequate running of the Mobile Application. Such permissions can be managed through the respective User devices using the ‘settings’ option.
By using and/or registering on the App, you authorize Us (including Our representative, affiliates, and business partners) to contact you via e-mail or phone call or SMS and offer you Our Services for the product you have opted for, imparting product knowledge, offer promotional offers running on the App and offers by Our business partners and associated third parties, for which reasons your information may be collected in the manner as detailed under Privacy Policy. You hereby agree that you authorize Us to contact you for the above-mentioned purposes even if you have registered yourself under DND or DNC or NCPR service(s). Your authorization, in this regard, shall be valid as long as your account is not deactivated by either you or Us.
1.1.3 We shall collect additional information like:
- information pertaining to the insurance policy opted by the User, in any physical, digital or electronic form inclusive of the App in connection with the insurance policy or service from Us;
- information obtained through the online tool or calculators available on the App or while availing Our services online;
- information derived by way of any transaction initiated by a User on Our Platforms or any other payment gateway links available on the App; and
- information received by Us through third parties such as employers, professionals or banks, etc. for securing the benefits and services provided by Us.
1.1.4 Information you provide Us voluntarily
If you send Us personal correspondence, such as emails or letters, or if other Users or third parties send Us correspondence about your activities or postings on the Website and/or the App, We may collect and store such information. We may also collect additional information at other times, for example, when you provide feedback(s), modify your content or email preferences, respond to surveys, or communicate with Us. This information may include your name, e-mail address, mobile number and location.
1.1.5 Information we collect automatically
We collect information about you and your use of Our services, your interactions with Us as well as information regarding your devices used to access Our services (such as mobile devices, tablets and other viewing devices). This information includes, but is not limited to:
- activities on the Website and/or the App, such as type of pages viewed, time spent on pages, search queries etc.;
- your interactions with Us via email, customer care and/or messaging platforms;
- geo-location information through IP addresses;
- device information like device ID, device model and other unique identifiers;
- advertising identifiers, such as those found on mobile devices and tablets, devices that include identifiers; and
- information collected via the use of cookies and other technologies.
To improve the responsiveness of the App for the Users, We may use cookies or similar electronic tools to collect information to assign each visitor a unique, random number as a user identification to understand the User’s individual interests using the identified device. Unless you voluntarily identify yourself (through registration, for example), We would not know who you are, even if We assign a cookie to your device. The only personal information which a cookie can hold is the information you supply. A cookie cannot read data from your hard drive. Our advertisers may also assign their own cookies to your browser(s) (if you click on their advertisements), a process that we do not control. We receive and store certain types of information whenever you interact with us via the Website or the App through your device or any other electronic device capable of connecting to internet. For more details on our cookie practices, you are requested to refer to our cookie policy at section 1.8 of the Privacy Policy.
1.1.6 User Experience and Support
We identify and use your internet protocol (“IP”) address to help diagnose any problems with Our server, and to administer Our application. Your IP address is also used to help identify you and to gather broad demographic information to customize your experience on the Website and/or the App. We will occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information (like pin code and age). We use such data to tailor your experience on the Website and/or the App, providing you with content that We think you might be interested in and to display content according to your preferences.
1.1.7 Information we collect through third parties
When you register with Us using your other accounts, i.e. Google etc., we retrieve information from such accounts to continue to interact with you and to continue providing the services. We collect the following information from the respective social media platforms, including but not limited to public information, name and email address.
1.2 Payment Information
We do not collect any payment information from the Users. Instead, Users, whenever required to make any payment to Us, are simply directed to go to a third-party website to make a transaction and hence the privacy policies for such third-party will be applicable for making any payment to Us.
1.3 Uses of Information Collected
We use your information to:
- 1.3.1 show you the most relevant content based on your interest for an improved experience;
- 1.3.2 respond to your questions or comments;
- 1.3.3 analyse and understand our audience, improve our services (including our user interface experiences), and optimize content selection, recommendation algorithms;
- 1.3.4 conduct analysis and research to improve our apps;
- 1.3.5 allow Users to participate in interactive features offered through the services;
- 1.3.6 notify Users about the change in terms of service; and
- 1.3.7 send you updates on relevant content.
However, any personal information provided by you will not be considered as sensitive if it is freely available and/or accessible in the public domain like any comments, messages, blog posts or scribbles available on social media platforms like Facebook and Twitter. Any information posted/
In case you choose to decline to submit personally identifiable information, We may not be able to provide certain services to you. In any case, We will not be liable and/or responsible for Our denial of certain services to you for lack of you providing the necessary personal information.
When you register with Our services, We shall contact you from time to time about updating your personal information to provide the users such features that we believe may benefit/interest you.
1.4 Security
We know how you care about the privacy and the security of your personal information, which is why We are committed to respect and protect your privacy and your information shared with Us from any unauthorised access or loss. All information gathered on the App is securely stored within Our controlled database. The database is stored on the servers secured behind a firewall and access to these servers is password protected and is strictly limited. If you know or have reason to believe that your account credentials have been lost, stolen, altered, or otherwise compromised, or in case of any actual or suspected unauthorized use of your account, please contact Us via e-mail.
However, be aware that in this age of digital disruption, the transmission of information via the internet is never completely impenetrable. Hence, Users should also take requisite steps to protect their personal information against any unauthorised access. Such steps include choosing a strong password, signing off after using a shared device, and keeping your log-in details, especially your password private. We shall not be held responsible for any lost, stolen, or compromised information or for any activity on your account via unauthorised password usage. Follow the following guidelines while using Our App:
- 1.4.1 don’t break Our security measures or test the vulnerability of Our systems or networks;
- 1.4.2 don’t access or use the App by means of any mechanism or technology which conceals your actual geo-location or provides incorrect details of your location (for example, use a virtual private network (VPN) to access the services);
- 1.4.3 don’t try to interfere with Our networks, like sending a virus, overloading, spamming;
- 1.4.4 don’t collect or store personally identifiable information of people on the App;
- 1.4.5 don’t provide any unauthorized personal information of third parties while providing or contributing any User-generated content on the App;
- 1.4.6 don’t share your password, allow anyone to access your account or do anything that might put your account at risk;
- 1.4.7 don’t attempt to buy or sell access to your account, or usernames, or otherwise transfer account features for compensation;
- 1.4.8 don’t create or operate accounts that aren’t authentic;
- 1.4.9 don’t create new accounts for the purpose of violating these guidelines;
- 1.4.10 don’t link your web browser to websites that are unsafe, deceptive, untrustworthy, unoriginal, or that facilitate or encourage spam; and
- 1.4.11 don’t send unsolicited messages or make irrelevant comments on the content of the App.
To maintain the quality of the App, We remove spams when We find it. We ask that you be considerate of any spamming experience you come across, if any and report to us proactively at support@wingsure.co.
1.5 Your Controls and Choices
1.5.1 Rectification of Inaccurate or Incomplete Information
You may ask Us to correct inaccurate or incomplete personal information concerning you (this is the information which you cannot update yourself within your account) by sending Us an e-mail. You can access and update some of your personal information through your account settings yourself as well. If you have chosen to connect your profile to a third-party application, like Facebook or Google, you can change your settings and remove permission for the App by changing your account settings. You are responsible for keeping your personal information up to date. We may send you periodic reminders to maintain the accuracy of your personal information.
1.5.2 Data Retention and Erasure
We retain your personal information as long as necessary for the legitimate business interests of Us to provide you the services and for Us to comply with Our legal obligations. If you no longer want Us to use your information, then you can request that We erase your personal information and close your account. Please note that if you request for the erasure of your personal information, We may:
- still retain some of your personal information as necessary for Our legitimate business interests, such as fraud detection, prevention and enhancing safety. For example, if We suspend an account for fraud or safety reasons, We may retain certain information from that account to prevent that User from opening a new account in the future.
- still retain and use your personal information to the extent necessary to comply with Our legal obligations. For example, We may keep some of your information for taxing, legal reporting and auditing obligations.
Information that you have shared with others (e.g., reviews, forum postings) may continue to be publicly visible on the App, even after your account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in Our database, but are disassociated from personal identifiers. As We maintain copies of personal information to protect from accidental or malicious loss and destruction and hence residual copies of your personal information may not be removed from Our backup systems for a limited period of time.
(Note: If you have multiple accounts with Us, you will need to raise separate requests for each of those accounts, using the associated email addresses.)
1.5.3 Withdrawing Consent and Restriction of Processing
For withdrawing your consent at any time during the tenure of your services with Us, you may choose to do so by sending Us an e-mail. We shall review your request and may ask you to verify your identity. Post verification We will withdraw the consent for which request was made by you and stop any further processing of your personal information.
1.5.4 Objection to Processing
Where your personal information is processed for direct marketing purposes, you may, at any point of time ask Us to cease processing your data for these direct marketing purposes by sending an e-mail to Us. Please be aware that if you do not allow Us to collect personal information from you, We may not be able to deliver certain experiences, products, and services to you, and some of Our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, We will make that clear at the point of collection so that you can make an informed decision whether to participate or not. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact Us via e-mail.
1.5.5 If You Fail to Provide Consent
The App is not an advertisement-free platform. Therefore, permission to use and process your personal information to provide advertisements is essential for Us to provide services to you. Use of personal information for advertisement is a binding criterion and We will not be able to provide you with our services if you fail to authorise Us to use your personal information for the purpose of advertisement and the activities related to it.
1.5.6 Opting out of outreach from Us
If you have an account or a subscription with Us, We may send periodic recommendations or informational e-mails to you. You may opt-out of such communications by following the opt-out instructions contained in the said e-mails or by contacting Us via e-mail.
1.6 Policy on Minor’s Information
We do not seek or intend to seek or receive any personal information from children. Therefore, only a person who has completed the age of 18 years is allowed to register on the App. If We become aware that any personally identifiable information of children has been collected on the App without verified parental consent, then We will take the appropriate steps to delete any such information. However, We consider it the responsibility of parents or guardian to monitor their children’s use of Our services. Should a parent or guardian have reasons to believe that a minor has provided Us with personal information without their prior consent, please contact Us via e-mail to ensure that the personal information is removed from the App.
1.7 Data Transfer, Disclosure, Storage & Processing
1.7.1 General Disclosure
We may transfer your personal information to individual companies, affiliated companies or third parties in locations around the world for the purposes described in this Privacy Policy. Wherever your personal information is transferred, stored or processed by Us, We will take reasonable steps to safeguard the privacy of your personal information. You may also stop the delivery of informational or promotional e-mail from Us by following the instructions contained in the said e-mails or by contacting Us via e-mail.
1.7.2 Service Providers
At times, We may make certain personal information available to Our third party strategic partners, or other third parties that help Us in marketing and research. When you register with the App, avail any services from therein or purchase any subscription, you authorize Us to exchange the information you provide for the purpose of provision of the services as well as to improve the services and for Our marketing aspects. Such exchange of information by Us shall be governed by this Privacy Policy. We may also carefully select other companies to send you information about their products or services which are related to the services but are not necessary to its operation (“Extended Service”). If We intend to use personally identifiable information for an Extended Service, the App will provide you with the ability and requisite instructions to decline this service if desired.
1.7.3 Advertising
When We present information to Our advertisers to help them understand Our audience and confirm the value of advertising on the App, it is usually in the form of aggregated statistics on traffic to various pages/content within the App. We use third-party advertising companies to serve ads when you visit the App.
1.7.4 Business Transfers
We provide personal information to Our affiliates and other trusted businesses or persons to process it for Us, based on Our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
1.7.5
In the event, We merge with or get acquired by another company or in case of re-organization or re-structuring of business, We and Our affiliates may share your personal information, wholly or in part, with another business entity. We will post about such transition on the App before taking effect.
1.7.6 Legal
We may access, read, preserve and disclose any information including personally identifiable information if required to do so by law or in good faith belief that such action is necessary to:
- comply with legal process or proceedings or judicial order served on the App or Us;
- protect and defend the rights or property of the App owners or of the users of the App;
- act under exigent circumstances to protect the personal safety of users of the App, Us or the public;
- enforce the Terms of Use and Privacy Policy, including investigation of potential violation of it;
- detect, prevent or address fraud, security or technical issues;
- cooperate with governmental authorities including law enforcement authorities;
- respond to User support requests; or
- protect Users’ or public’s rights, property or safety.
1.8 Cookies and Log
- 1.8.1 To enhance the user experience of the App, We or Our affiliates may store cookies when you visit Our App, in order to enable you to browse and transact at such websites. The primary purpose of these cookies is to analyze how Our App is used. Our cookies let you view customized pages while transacting with Us.
- 1.8.2 Cookies are small data files that a website stores on your device to “recognize” you on subsequent requests. Our cookies do not have confidential or personally identifiable information.
- 1.8.3 We may use various tools like chart tool and tracking tool on Our website to improve the customer experience by showing or advertising such goods/services We think may be of interest to you. Also, We use analytic tools and web beacons to gather anonymous, aggregated statistical information (e.g. unique hits and page views) about Our Website traffic. We use non-persistent cookies for managing the users’ logged in session and persistent cookies for managing the performance.
- 1.8.4 However, if you wish to not consent with the storage of these cookies, you may turn-off the cookies option in your browser settings.
- 1.8.5 We use log files that collect information which may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track User’s movement in the aggregate and gather broad demographic information for aggregate use. We may combine this automatically collected log information with other information We collect about you. We do this with an intent to improve services We offer to you and to improve marketing, analytics, or site functionality.
1.9 Card and Bank Details
- 1.9.1 You agree, understand and confirm that the bank or credit/debit card details provided by you for availing the services offered by Us on the App shall be correct and accurate, and you shall not use the bank account and/or credit/debit card which is not lawfully owned by you. You further agree and undertake to provide the correct and valid bank account and/or credit/debit card details to Us.
- 1.9.2 Further, the said information shall not be stored, utilized and shared with any of the third parties by Us unless required by law, regulation or court order. You shall fully indemnify Us from any loss or damage arising out of a non-compliance of this condition by you.
1.10 Limitation of Liability
The Privacy Policy is not intended to and does not create any legal rights in your favour or in the favour of any other person. We reserve the right to change the Privacy Policy at any time without any prior notice to you. Our liability shall be limited to removal of data that is sensitive and personal in nature from the system of the App and removal of personally identifiable elements of the other data.
1.11 Amendment to the Privacy Policy
The Privacy Policy is subject to amendment from time to time. We reserve the right, at our sole discretion, to modify the terms of this Privacy Policy from time to time in order to ensure compliance with applicable laws (“Updated Terms”). The Updated Terms shall be effective immediately and shall supersede the terms of the Privacy Policy. We will notify you of any changes to the Privacy Policy if the changes made to the Privacy Policy significantly affect your rights or as may be required by law. You shall be solely responsible for reviewing the Privacy Policy from time to time for any modifications. By continuing to use the App after the Updated Terms have been published, you affirm your agreement to the Updated Terms.
1.12 Contact Information
Support: If you require any information or clarification or make any request regarding the use of your personal information or the Privacy Policy, please e-mail Us at support@wingsure.co.
1.13 Conditions of Use
Please note that if you decide to visit the App, your visit and any possible dispute over privacy is subject to the Privacy Policy.