FMT Travel Inc. and its subsidiaries, divisions, and affiliates (collectively, “FMT”, “we”, “us”, and “our”) recognize the importance of protecting the privacy of the personal information you provide to us. Accordingly, we have developed this Privacy Policy (the “Policy”) so that you can make educated and informed decisions about the personal information that you entrust to us by engaging our services on the websites, social media, email exchanges, mobile apps, and other online services on which this Policy is posted or linked (the “Service”), and understand how we collect, use, disclose, and otherwise manage this information.

Your use of the Service is conditioned upon your agreement to this Policy and our Terms of Service. Before using our Service, please read this Policy carefully as it contains important information on who we are and how and why we collect, store, use, and share your personal information. This Policy also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

This Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Policy. To the extent that any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall control.

Due to the nature of the Service, personal information about children may be required to comply with the law, including federal aviation or security regulations, and to otherwise provide the goods and services (i.e., plane tickets) purchased by a parent or legal guardian on their child’s behalf.

However, while parents or legal guardians traveling with children may provide their child’s name, date of birth, and passport number (for international flights only) on the Service, the Service is not otherwise meant for individuals under the age of eighteen, and the Service may use mechanisms to prevent the registration and use of the Service by such underage individuals.

FMT will never knowingly request or directly collect personal information from any child, and only parents and legal guardians may provide a child’s information to us for the purposes outlined in this Policy. If you are under eighteen years old, please do not provide your information on our Service. Upon notification that a child has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records. If you believe we might have any information from a child that was not provided by a parent or legal guardian, please contact us.

If you provide any information about a child on our Service, you represent and warrant that you are the parent or legal guardian of such child and hereby consent to the use and disclosure of such child’s information in order to travel with that child and for the purposes described herein or as otherwise required or permitted by law.

Information you provide to us

FMT will collect personal information from you directly when you interact with our Service, contact us, use our services, create an account, subscribe, share reviews, sign up to receive offers or emails from us, complete surveys, or order or purchase our products.

Information we obtain indirectly

We may receive personal information about you from our third-party affiliates or partners and from marketing companies that provide us with such information as a part of their relationship with us.

We may combine this with data that we already have collected about you. Such collected data could include contact details (such as email address) and previous purchase history or interests.

Information collected automatically

When you use our Service, we collect certain information about you automatically through our use of cookies and similar technologies.

FMT collects the following categories of personal information: (1) contact and demographic information including your name, date of birth, telephone number (if you opt-in to receive text messages), email address, and mailing address;

(2) passenger information, including the names and dates of birth of your travel companions (who may also be children);

(3) authentication information, including the user name and password that you use to register an account on the Service;

(4) comments, reviews, suggestions;

(5) personal preferences including product preferences, online preferences, and interests;

(6) online behavior information including online activity, preferences, and time spent viewing features;

(7) device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, general geolocation, information about how and when you use our Service and other technical information.

We use a third-party processor to collect payment information, such as a valid credit card number, type, expiration date or other financial information, to process payments for customer transactions. This information is required to be submitted as part of our checkout process. We do not have access to any of this financial information; it is submitted directly to our third-party payment processing company, which uses the information to process your payment. The use and storage of that information is governed by Duffel’s Website Terms and Privacy Policy.

Unless you are a job applicant, employee, owner, director, officer, or contractor of FMT, are flying to an international destination, or as otherwise stated in a separate agreement, FMT does not collect sensitive personal information such as your social security, driver’s license, or state identification card; your account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; your racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of your mail, email and text messages, unless we are the intended recipient of the communication; your genetic data; your biometric information for the purpose of uniquely identifying you; and personal information collected and analyzed concerning your sex life or sexual orientation. We ask that you not send nor disclose this sensitive personal information to us.

If you are flying internationally and such number is required to book a plane ticket and travel to your international destination, FMT may also collect passport numbers, which is considered sensitive personal information. FMT will only collect, use, and disclose passport numbers with your consent or as otherwise required or permitted by law. For example, we may share passport numbers with our third-party payment processors when you purchase a plane ticket so that they can process your purchase with your selected airline and provide the information needed by that airline (i.e., your passport number and the passport numbers of your travel companions) to book your flight.

FMT only collects and processes the minimum amount of personal information from you that is necessary to the purposes of our information processing activities and retains such information only if required to fulfill such purposes. Our information processing activities include conducting our business, processing orders, personalizing your experience on our website, marketing, customer communications and support, user verification, payment processing, quality management services, Service maintenance and improvements, and complying with legal requirements. We conduct such processing operations to perform the contract that you have with us, or to take steps at your request before entering into a contract, and for our legitimate interests or those of a third party. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

Where applicable, if FMT intends to further process your personal information for a purpose other than that for which the personal information was initially collected, FMT shall, prior to such processing, provide you with any relevant information on such additional purpose, and, to the extent required by applicable law, obtain your consent for this. To the extent you provide consent to FMT for any purpose, you may withdraw such consent at any time by contacting us at privacy@wingmates.ai or at the mailing address listed below.

The table below describes the relevant categories of personal information that we process and explains why we use this information, how we process the information, and our lawful bases for processing the information:

FMT does not trade, rent, or sell your personal information to third parties, share your personal information with third parties for cross-context behavioral advertising, or process it for targeted advertising or consumer profiling, and in the preceding twelve months, we have not sold or shared any personal information.

While we have not shared or disclosed your personal information for the reasons listed below within the last twelve months, we may share or disclose, and have within the preceding twelve months shared or disclosed, your personal information for the following limited purposes:

Third Parties Providing Services on Our Behalf: We may share information with vendors, suppliers, and similar third parties (collectively, “Service Providers”) who perform services and functions on our behalf to support our interactions with you. Our Service Providers may also help us facilitate or improve the Service, offer additional goods and services, provide customer support, perform website-related services (e.g., without limitation, maintenance services, database management, web analytics, and improvement of the Service’s features), or assist FMT in analyzing how the Service is used. These Service Providers have access to your personal information only to perform these tasks on FMT’s behalf and do not have the right to use personal information we share with them beyond what is necessary to assist us. Additionally, these Service Providers must adhere to confidentiality, security, and legal obligations in a way that is consistent with this Policy and any applicable law.

Aggregate Information: We may also share non-identifying information, such as aggregate statistics or usage information, with third parties in order to demonstrate how FMT is used, spot industry trends, or provide marketing materials for FMT. Any aggregated information shared in this way will not contain any personally identifiable information, and FMT is not limited in its use of aggregate information that does not permit direct association with any specific individual, such as the number of users of our services and the geographic distribution of our users.

Your Consent to Have Your Personal Information Shared with Travel Partners, Airlines, and Other Third Parties: FMT may share personal information with third parties when we have your consent to do so. For instance, if you would like to enhance your travel experience, we may share information with third parties that can provide you with additional goods or services that FMT does not otherwise provide on its own (each a “Travel Partner” and, collectively, “Travel Partners”). Examples of such Travel Partners include third-party travel insurance companies who can provide you with travel protection insurance. With your consent, we may also share your information with the appropriate airline, hotel, or other business with whom you make a booking or reservation via the Service. If you agree to have your personal information shared with these third parties, your personal information will be disclosed to the third party and will be subject to the privacy policy and business practices of that third party. To the extent that we obtain your consent to process or share your personal information, you may withdraw this consent at any time by emailing us at: privacy@wingmates.ai.

Legal Disclosure: FMT cooperates with government and law enforcement officials and private parties to enforce and comply with the law. Accordingly, we may disclose any information about you to government or law enforcement officials or private parties as FMT, in its sole discretion, believes necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of FMT, a user of the Service, or a third party, to protect the safety of the public or any person, to take emergency action, or to prevent or stop activity FMT considers to be or to have the potential to be, illegal, unethical, or legally actionable. In addition, FMT may disclose information about you to counter or prevent any malicious access or use of the Service or to prevent harm or loss to any user of the Service.

Transfer in the Event of Sale or Change of Control: FMT may provide your personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of FMT’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information maintained by the Service is among the assets transferred. In such a case, unless prohibited by applicable law, your information would remain subject to the privacy policy applicable at the time of such transfer, unless you discontinue use of our Service.

The table below lists the specific third parties with whom your information is disclosed, the processing operations related to such disclosure, and the relevant categories of personal information that we disclose:

We may use “cookies” to help us process your order and to customize information that we may present to you. We may also use web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your online activity and interactions with our emails, online and mobile advertisements, and to allow us to keep track of analytics and certain statistical information that enables FMT to improve our services and provide you with more relevant content and advertising offered by FMT or through or linked from our services.

You may, however, disallow receiving cookies at any time through your web browser. Similarly, you may set your mobile device to refuse to provide certain information, but certain features of the Service may not work without such information. It is not our intention to use cookies to retrieve information that is unrelated to our Service or your interaction with our Service.

The table below lists the specific cookies we use, the type of cookies they are, the purpose of each cookie, and the categories of information or data each cookie tracks:

At this time, we do not respond to browser “do-not-track” or “DNT” signals.

If you would like more information about who we share our data with and why, please contact us using the information provided below.

Our Service may contain links to other websites owned and operated by third parties, including without limitation social media websites, we think you might be interested in (each a “Linked Site”). When you click on a link to a Linked Site, you will leave our Service and go to that Linked Site, and another entity may collect personal information or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these Linked Sites or their content. Please be aware that the terms of this Policy do not apply to these Linked Sites or their content, or to any collection of your personal information by third parties through the Linked Sites. FMT is not responsible for the privacy practices or the content of such Linked Sites. Please be aware of where you are at all times. FMT expressly disclaims any liability that may arise from your use or provision of any of your information whatsoever to Linked Sites. You understand and agree that by clicking on a link to a Linked Site that you have left our Service.

Some features of the Service may now or in the future allow you to provide content, such as written comments or reviews, to be published or displayed on public areas of the Service (“User Contributions”). Be careful about giving out information in public areas of the Service. The information you share in public areas may be viewed by any user of the Service. We cannot control the actions of other users of the Service with whom you may choose to share your User Contributions.

If you give FMT your contact information over this website, and you wish to have your name and contact information removed from FMT’s database, please send us an email to privacy@wingmates.ai, and we will remove your name and contact information from where possible. Additionally, when you register, subscribe, create an account, sign up to receive offers or emails from us, or otherwise communicate with us through our Service, you may “opt out” of receiving future communications from us for direct marketing purposes by indicating that you decline such communications. You may choose to stop receiving our emails by following the unsubscribe instructions included in these emails or contacting us at privacy@wingmates.ai.

If you opt-in to FMT’s Mobile Messaging Program (the “Program”), as defined in our Terms of Service, we will only use information you provide through the Program to transmit your mobile messages and respond to you, if necessary. This includes, but is not limited to, sharing information with platform providers, phone companies, and other vendors third-party service providers, who assist us in the delivery of mobile messages. When you sign up to receive text messages, we will send you information about your upcoming flight, your hotel reservations, and any other travel plans that you may book through the Service. To the extent you voluntarily opt to have SMS/MMS notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number and when you read a text message. You may opt out of receiving text messages at any time by texting “STOP” to any mobile message from us or by emailing us at privacy@wingmates.ai. For more information about text messages, see our Terms of Service.

WE DO NOT SELL, RENT, LOAN, TRADE, LEASE, OR OTHERWISE TRANSFER FOR PROFIT ANY PHONE NUMBERS OR CUSTOMER INFORMATION COLLECTED THROUGH THE PROGRAM TO ANY THIRD PARTY. However, as with all information collected by FMT, we reserve the right at all times, and to the extent permitted by law, to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property. When you complete forms online or otherwise provide information in connection with the Program, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If, in FMT’s sole discretion, we believe that any such information is untrue, inaccurate, or incomplete, or you have opted into the Program for an ulterior purpose, we may refuse you access to the Program and pursue any appropriate legal remedies.

California Civil Code Section 1798.83 permits users of the Program that are California residents to request certain information regarding our disclosure of the information you provide through the Program to third parties for their direct marketing purposes. To make such a request, please contact us at privacy@wingmates.ai.

We reserve the right to change or modify this Policy or our Service at any time, and any changes are effective upon being posted unless we advise otherwise. If we make any material changes to this Policy, we will notify you by email or post notice on this website before the change becomes effective.

We encourage you to frequently review this website for the latest information on our privacy practices. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. You are bound by any changes to our Privacy Policy when you use the Service after such changes have been first posted. If you do not accept the terms of our Privacy Policy, we ask that you do not register with us and that you do not use our Service. Please exit the FMT Service immediately if you do not agree to the terms of this Privacy Policy.

If you choose to provide us with your personal information, you understand that we are transferring it to FMT’s locations and systems in the United States or to the locations and systems of FMT’s service providers around the world. FMT uses reasonable security measures to protect the loss, misuse, and alteration of the information under its control. Such measures may change from time to time, depending on industry standards and perceived security risks.

However, despite such security measures, FMT cannot guarantee the security of your information and disclaims liability for loss, misuse, and alteration of your information under its control to the maximum extent permitted under applicable law. By using the Service, you agree to assume any security risk related to personal information. You should report any security violations to us by sending an email to privacy@wingmates.ai.

The security of your FMT account relies on your protection of your user profile information. You are responsible for maintaining the security of your user profile information, including your password and for all activities that occur under your account. You may not share your password with anyone. We will never ask you to send your password or other sensitive information to us in an email. Any email or other communication purporting to be from one of our websites requesting your password or asking you to provide sensitive account information via email, should be treated as unauthorized and suspicious and should be reported to us immediately by contacting us. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and report it immediately by contacting us.

FMT is a U.S.-based business and may process, transfer, and store information about users of the Service on servers located in a number of countries, including the United States. As a result, your personal information may be subject to data protection and other laws that may differ from your country of residence. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate. By using the Service, or by providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside or are a citizen.

Your personal data may be stored or transferred to countries outside of the U.K. and E.U. that may not offer an adequate level of protection, such as the United States. When we store or transfer your personal data outside of the U.K. or E.U., we will do so in accordance with applicable law, and we will ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. Transfers of personal data are made either to countries recognized as providing an adequate level of protection or, if the country does not offer adequate protection, such transfers are subject to standard data protection clauses adopted by the EU Commission or UK Information Commissioner to guarantee that your personal data is adequately protected in any cross-border transfer. To obtain any relevant information regarding any transfers of your personal data to third countries (including the relevant transfer mechanisms), please contact us.

We transfer personal information to the recipients and for the processing operations listed in the section of this Policy titled “Disclosure of Personal Information.” The table below lists the specific third countries in which those recipients are located and where personal data is transferred as well as the lawful safeguards in place for each third country to effectuate such transfer:

If you would like to submit a Consumer Request, you can contact us at privacy@wingmates.ai. If you choose to submit a Consumer Request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information if we cannot verify that the person making the Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

“Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Personal information” does not include publicly available information.

• Request to Correct. You may correct or update your personal information at any time by logging into your account or by contacting us.

• Request to Access. You may submit a Consumer Request to obtain a copy of or access to the personal information that we have collected on you.

• Request to Know. You may submit a Consumer Request to receive information about our data collection practices.

  • Right to Know what Personal Information is being Collected. You may request information on the categories of personal information we have collected about you; the categories of sources from which the personal information is collected; our business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom we have disclosed personal information, if any; and the specific pieces of personal information it has collected about you.

  • Right to Know what Personal Information is Sold or Shared and to Whom. You may also request the categories of personal information that we have collected about you; the categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared, and the categories of personal information that we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Please note that the categories of personal information, sources, and disclosure will not exceed what is contained in this Policy. Additionally, we are not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. We are also not required to reidentify personal information if it is not stored in that manner already, nor is it required to provide the personal information to you more than twice in a twelve-month period.

• Request to Limit the Use of Your Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information, except passport numbers, where required for international travel. However, if you believe that we may have collected any other sensitive personal information about you, you may request that we limit the use or disclosure of your sensitive personal information.

• Request to Delete. You may request that we delete personal information it has collected from you. Subject to certain exceptions set out below we will, on receipt of a verifiable Consumer Request, delete your personal information from our records, direct any service providers to do the same, and notify all third parties to whom we have shared your personal information to delete it unless this proves impossible or involves disproportionate effort.

• Please note that we may not delete your personal information if it is necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by the consumer within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.

  • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.

  • Debug to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

  • Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent.

  • To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information.

  • Comply with a legal obligation.

• Right to Access Information About Automatic Decision-Making. We do not currently engage in automated individual decision-making. However, in the event we ever do so, we will inform you of such change and you may request information about and opt out of such automated decision-making.

• Right to Data Portability. You may also request that we transfer your personal information to another entity, to the extent such transfer is technically feasible.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.

We do not sell, rent, or lease your personally identifiable information to third parties. However, if you are a resident of Nevada and would like to submit a request not to sell your personally identifiable information, you may do so by emailing us at privacy@wingmates.ai.

Personal information or “personal data” means “any information that is linked or reasonably linkable to an identified or identifiable natural person.” “Personal data” does not include de-identified data or publicly available information.

• Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

• Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

• Request to Delete. You may request that we delete the personal data it has collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

• Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Virginia Attorney General or submit a complaint online at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

• Withdraw Consent for Your Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information, except passport numbers, where required for international travel. However, if you believe that we may have collected any other sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you like to make any of the above requests, you can contact us at privacy@wingmates.ai. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified or identifiable individual.” “Personal data” does not include de-identified or publicly available information.

• Request to Access: You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

• Request to Correct: You may correct or update your personal data at any time by logging into your account or by contacting us.

• Request to Delete: You may request that we delete the personal data it has collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

• Request to Opt-Out: You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.

• Right to Data Portability: You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

• Appeal: If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Colorado Attorney General.

• Withdraw Consent for Your Sensitive Personal Information: We do not collect, use, or disclose sensitive personal information, except passport numbers, where required for international travel. However, if you believe that we may have collected any other sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you like to make any of the above requests, you can contact us at privacy@wingmates.ai. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified or identifiable individual.” “Personal data” does not include de-identified or publicly available information.

• Request to Access: You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you, including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies, in which case we will provide you with the reasons why the personal data no longer exists where possible.

• Request to Correct: You may correct or update your personal data at any time by logging into your account or by contacting us.

• Request to Delete: You may request that we delete the personal data it has collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

• Right to Data Portability: You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

• Request to Opt-Out: You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.

• Appeal: If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Connecticut Attorney General or submit a complaint online at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.

• Withdraw Consent for Your Sensitive Personal Information: We do not collect, use, or disclose sensitive personal information, except passport numbers, where required for international travel. However, if you believe that we may have collected any other sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you would like to make any of the above requests, you can contact us at privacy@wingmates.ai. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you, and if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you, charge different rates for goods or services, provide a different level quality of goods or services, or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual.” “Personal data” does not include deidentified data, aggregated data, or publicly available information.

• Request to Access: You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you, including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies, in which case we will provide you with the reasons why the personal data no longer exists where possible.

• Request to Delete: You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

• Right to Data Portability: You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

• Request to Opt-Out: You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising.

• Withdraw Consent for Your Sensitive Personal Information: We do not collect, use, or disclose sensitive personal information, except passport numbers, where required for international travel. However, if you believe that we may have collected any other sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you would like to make any of the above requests, you can contact us at privacy@wingmates.ai. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you, and if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you, charge different rates for goods or services, provide a different level quality of goods or services, or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual.” “Personal data” does not include deidentified data, aggregated data, or publicly available information.

• Request to Access: You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies, in which case we will provide you with the reasons why the personal data no longer exists where possible.

• Request to Delete: You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

• Right to Data Portability: You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

• Request to Opt-Out: You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising.

• Appeal. If we notify you that no action is to be taken in response to your request to access, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Iowa Attorney General.

• Withdraw Consent for Your Sensitive Personal Information: We do not collect, use, or disclose sensitive personal information except passport numbers, where required for international travel. However, if you believe that we may have collected any other sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you would like to make any of the above requests, you can contact us at privacy@wingmates.ai. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual.” “Personal data” does not include deidentified data, aggregated data, or publicly available information.

• Request to Access: You may submit a request to confirm or to obtain a copy or representative summary of or access to the personal data that we have collected on you, including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies, in which case we will provide you with the reasons why the personal data no longer exists where possible.

• Request to Correct: You may correct or update your personal data at any time by logging into your account or by contacting us.

• Request to Delete: You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

• Request to Opt-Out: You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.

• Appeal: If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Indiana Attorney General.

• Withdraw Consent for Your Sensitive Personal Information: We do not collect, use, or disclose sensitive personal information except passport numbers, where required for international travel. However, if you believe that we may have collected any other sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you would like to make any of the above requests, you can contact us at privacy@wingmates.ai. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you, and if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

“Personal information” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual.” Personal information does not include deidentified data, aggregated data, or publicly available information.

• Request to Access: You may submit a request to confirm or to obtain a copy of or access to the personal information that we have collected on you, including what the information is, how it’s been used, whether it’s been sold, and who it’s been disclosed to. Your personal information may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies, in which case we will provide you with the reasons why the personal data no longer exists where possible.

• Request to Correct: You may correct or update your personal information at any time by logging into your account or by contacting us.

• Request to Delete: You may request that we delete the personal information that you have provided to us. We will delete your personal information from our records and direct any service providers to do the same unless retention is required by law.

• Request to Opt-Out: You may submit a request to opt out of the sale of your personal information. We do not sell, rent, or lease your personal data to third parties and do not process your personal information for targeted advertising or consumer profiling.

• Appeal: If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Tennessee Attorney General.

• Withdraw Consent for Your Sensitive Personal Information: We do not collect, use, or disclose sensitive personal information, except passport numbers, where required for international travel. However, if you believe that we may have collected any other sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you would like to make any of the above requests, you can contact us at privacy@wingmates.ai. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you, and if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual.” “Personal data” does not include deidentified data or publicly available information.

• Request to Access: You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you, including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies, in which case we will provide you with the reasons why the personal data no longer exists where possible.

• Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

• Request to Delete: You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

• Right to Data Portability: You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

• Request to Opt-Out: You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising.

• Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Montana Attorney General.

• Withdraw Consent for Your Sensitive Personal Information: We do not collect, use, or disclose sensitive personal information, except passport numbers, where required for international travel. However, if you believe that we may have collected any other sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you would like to make any of the above requests, you can contact us at privacy@wingmates.ai. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you, and if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual” and includes pseudonymous data when such data is used with additional information. “Personal data” does not include deidentified data or publicly available information.

• Request to Access: You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

• Request to correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

• Request to Delete: You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

• Request to Opt-Out. You may submit a request to opt out of the sale of your personal data; however, we do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling. We also do not collect, use, or disclose sensitive personal information (also referred to herein as “sensitive data”), except passport numbers, where required for international travel, but if you believe that we may have collected any other sensitive data about you, such as precise geolocation, you may withdraw your consent to any use or disclosure of your sensitive data and opt-out of the collection and processing of such sensitive data. We further do not collect personal data through the operation of a voice recognition or facial recognition feature; however, you may also opt out of such collection in the event we do use such features.

• Appeal: If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Florida Attorney General.

If you would like to make any of the above requests, you can contact us at privacy@wingmates.ai. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you, and if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you, charge different rates for goods or services, provide a different level quality of goods or services, or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual” and includes pseudonymous data when such data is used with additional information. “Personal data” does not include deidentified data or publicly available information.

• Request to Access: You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

• Request to correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

• Request to Delete: You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

• Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.

• Appeal: If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Texas Attorney General.

• Withdraw Consent for Your Sensitive Personal Information.We do not collect, use, or disclose sensitive personal information, except passport numbers, where required for international travel. However, if you believe that we may have collected any other sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you would like to make any of the above requests, you can contact us at privacy@wingmates.ai. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and mailing address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you, and if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you, charge different rates for goods or services, provide a different level quality of goods or services, or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

If you would like to submit a Data Subject Request, you can contact us at privacy@wingmates.ai. If you choose to submit a Data Subject Request, you must provide us with enough information to identify you and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information if it cannot verify that the person making the Data Subject Request is the person about whom we collected information, or someone authorized to act on such person’s behalf. Please specify clearly which information you would like us to provide you with, review, amend, stop processing, or delete.

“Personal data” means any information relating to an identified or identifiable natural person.

• Request to Access and Data Portability. You may request a copy of your personal data shared with us as well as confirmation as to whether or not personal data concerning you is being processed, access to your personal data, and information on the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom the personal data have been or will be disclosed, and the period of time the data will be stored. We may charge a reasonable fee to cover the administrative costs of providing you with a copy of your personal data.

• Request to Rectify or Complete. If you notify us, or we otherwise become aware, that the personal data we hold is inaccurate, we will not use it, and will not allow others to use it, until it is corrected. You can ask us to correct or complete our record of your personal data by contacting us at any time. To the extent possible, we will inform anyone who has received your personal data of any corrections.

• Request for Erasure. You may, in certain limited circumstances where the processing is not necessary in the context of the services we provide to you, ask to have the personal data we directly or indirectly process deleted or removed. If the request is founded, we will try to do so promptly, and, to the extent possible, will inform anyone who has received your personal data of your request.

• Request for Restriction of Processing. You may request that we limit the way in which we process your personal data where (i) you contest the accuracy of the personal data we have for you, (ii) you believe our processing of your personal data is unlawful (but you oppose the erasure of your personal data and prefer that our processing be restricted instead), (iii) we no longer need your personal data but you require such personal data for the establishment, exercise or defense of legal claims or (iv) you have objected to our processing pending the verification of our legitimate grounds for processing. If the request is founded, we will try to do so promptly, and, to the extent possible, will inform anyone who has received your personal data of your request.

• Request for Data Portability and Transfer. You may request to receive a copy of your personal data, and have it transferred to another controller, where technically feasible, in certain limited circumstances, where a) you provided the data to us, b) our processing is based on your consent or is necessary to fulfill a contract with you, and c) our processing is automated. We may refuse your request if these criteria are not met.

• Objection to Processing. You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data. If we have sufficiently compelling legitimate grounds for processing your personal data, or we need your data to establish, exercise or defend legal claims, we may continue to process it. Otherwise, we will stop using your personal data. You may also object at any time to your personal data being processed for direct marketing, and we will stop processing the data for such purposes.

• Withdrawal of Consent to Processing. Where we have relied on your consent as the legal grounds for processing, you may withdraw your consent at any time. Withdrawal does not invalidate the consent-based processing that occurred prior to withdrawal.

• Automated Individual Decision-making. We do not currently engage in automated individual decision-making. However, in the event we ever do so, we will inform you of such change and you may request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects that concern you or that similarly significantly affect you, except were the automated individual decision-making is necessary for entering into, or the performance of, a contract between you and us; is authorized by law; or is based on your explicit consent.

You may contact us at any time where you believe that we are in breach of data protection laws or where you wish to make a complaint about our data processing. Furthermore, if you believe that our processing of your personal data is in breach of data protection laws, you have the right to lodge a complaint with the relevant data protection supervisory authority (i.e., in the U.K. or Member State of your habitual residence, place of work or place of the alleged infringement), if you are of the opinion that any of your personal data is processed in a manner constituting an infringement of the U.K. or E.U. GDPR or where you believe that we have not resolved an issue you have raised with us.