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PRIVACY POLICY
[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
(a) 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:
(a) Name;
(b) Gender;
(c) Phone;
(d) Email address;
(e) Date of birth;
(f) Residential Address;
(g) 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 maybe 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:
(a) Contacts - used for accessing Users contact in order to share articles through the
App;
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(b) Phone - to enable User notifications on User’s device. IMEI (International Mobile
Equipment Identity) number is being collected to uniquely identify every User;
(c) Camera - in order for the User to upload images and profile image of the User;
(d) Microphone - to enable voice command related actions;
(e) Storage - to access files and folders from inside the App; and
(f) 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 matter 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:
(a) 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;
(b) information obtained through the online tool or calculators available on the App or while
availing Our services online;
(c) 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
(d) 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:
(a) activities on the Website and/or the App, such as type of pages viewed, time spent on
pages, search queries etc.;
(b) your interactions with Us via email, customer care and/or messaging platforms;
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(c) geo-location information through IP addresses;
(d) device information like device ID, device model and other unique identifiers;
(e) advertising identifiers, such as those found on mobile devices and tablets, devices that
include identifiers; and
(f) 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- partywill 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;
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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/ uploaded/ conveyed/ communicated by Users on the public sections of the Website and/or
the App becomes published content and is not considered personally identifiable information
subject to this Privacy Policy.
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 the 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;
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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 to 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:
(a) 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.
(b) 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
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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 platforms.
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 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
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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:
(a) comply with legal process or proceedings or judicial order served on the App or Us;
(b) protect and defend the rights or property of the App owners or of the users of the
App;
(c) act under exigent circumstances to protect the personal safety of users of the App,
Us or the public;
(d) enforce the Terms of Use and Privacy Policy, including investigation of potential
violation of it;
(e) detect, prevent or address fraud, security or technical issues;
(f) cooperate with governmental authorities including law enforcement authorities;
(g) respond to User support requests; or
(h) 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,
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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 collects 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 affects 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.
