1. Introduction

Wingspay ("we", "us", "our") is committed to protecting the privacy of individuals who visit our website at wingspay.net (the "Website") and those who contact us through it. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have in relation to your data.

This policy applies to all visitors and users of wingspay.net and is governed by the EU General Data Protection Regulation (GDPR) and applicable national data protection laws.

2. Who We Are (Data Controller)

The data controller responsible for your personal data is:

Wingspay
Email: contact@wingspay.net
Website: https://wingspay.net

If you have any questions about this policy or about how we handle your data, please contact us at the email address above.

3. What Data We Collect and Why

3.1 Contact Form

When you submit the contact form on our Website, we collect the following personal data:

  • Full name — to address you appropriately in our response.
  • Email address — to send you a reply to your enquiry.
  • Message content — to understand and respond to your enquiry.

Legal basis: Article 6(1)(b) GDPR — processing is necessary to take steps at your request prior to entering into a contract, and Article 6(1)(a) GDPR — your explicit consent given by ticking the consent checkbox before submitting the form.

Retention period: We retain contact form submissions for up to 12 months. After this period, data is deleted unless ongoing business correspondence requires otherwise.

3.2 Automated Email Response

Upon submitting the contact form, your name and email address are used to send you an automated confirmation email ("auto-reply") via Resend, a third-party email delivery service. This is done solely to confirm we have received your enquiry.

Third-party processor: Resend (resend.com). Data is processed under Resend's Data Processing Agreement. For more information, see Resend's Privacy Policy.

3.3 Website Analytics

We use the following analytics tools to understand how visitors use our Website. These tools collect anonymised or pseudonymised data about your browsing behaviour using cookies and similar technologies.

Google Analytics 4 (GA4)
Provider: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Data collected: pages visited, session duration, approximate geographic location (country/city), device type, browser, referral source. IP addresses are anonymised before processing.
Legal basis: Article 6(1)(a) GDPR — your consent, provided via continued use of the Website after being informed of this policy.
Data transfer: Google may transfer data to the United States. Such transfers are protected by Standard Contractual Clauses (SCCs).
Opt-out: Google Analytics Opt-out Browser Add-on.
More information: Google Privacy Policy.

Microsoft Clarity
Provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, USA.
Data collected: session recordings (mouse movements, clicks, scrolling), heatmaps, pages visited, session duration. Clarity automatically masks sensitive content (form fields, passwords).
Legal basis: Article 6(1)(a) GDPR — your consent.
Data transfer: Microsoft may transfer data to the United States, protected by SCCs.
More information: Microsoft Privacy Statement.

3.4 Form Submission Processing

Contact form submissions are processed via Web3Forms (web3forms.com), a third-party form backend service. Your name, email, and message are transmitted to Web3Forms servers solely for the purpose of forwarding the enquiry to us.

More information: Web3Forms Privacy Policy.

4. Cookies

Our Website uses cookies — small text files stored in your browser — to enable analytics functionality. We do not use advertising or tracking cookies across third-party websites.

Cookie Provider Purpose Duration
_ga, _ga_* Google Analytics Distinguishes unique users, tracks sessions 2 years
_clck, _clsk Microsoft Clarity Records session behaviour for heatmaps 1 year / session

You can control or delete cookies through your browser settings. Please note that disabling cookies may affect the functionality of certain websites you visit.

5. How We Use Your Data

We use personal data collected through the contact form exclusively to:

  • Respond to your enquiry.
  • Send an automated confirmation of receipt.
  • Follow up on potential business discussions, where relevant.

We do not sell, rent, or share your personal data with third parties for marketing purposes. We do not use your data for automated decision-making or profiling.

6. Data Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. Our Website is served over HTTPS (TLS encryption). Email communications are handled via services with industry-standard security practices.

However, no method of transmission over the internet is 100% secure. If you have concerns about the security of your data, please contact us directly.

7. Your Rights Under GDPR

If you are located in the European Economic Area (EEA) or United Kingdom, you have the following rights regarding your personal data:

  • Right of access — you may request a copy of the personal data we hold about you.
  • Right to rectification — you may request correction of inaccurate or incomplete data.
  • Right to erasure — you may request deletion of your personal data, subject to certain conditions.
  • Right to restriction of processing — you may request that we limit how we use your data.
  • Right to data portability — you may request your data in a structured, machine-readable format.
  • Right to object — you may object to processing based on legitimate interests.
  • Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at contact@wingspay.net. We will respond within 30 days.

You also have the right to lodge a complaint with your local data protection authority. In the EU, you can find the relevant authority at edpb.europa.eu.

8. International Data Transfers

Some of our third-party service providers (Google, Microsoft, Resend, Web3Forms) may process data outside the EEA, including in the United States. Such transfers are made in accordance with applicable data protection law, using Standard Contractual Clauses (SCCs) or other appropriate safeguards approved by the European Commission.

9. Third-Party Links

Our Website may contain links to third-party websites (e.g. LinkedIn). We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies separately.

10. Children's Privacy

Our Website and services are directed exclusively at businesses and professional individuals. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that we have collected data from a minor, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date of the latest revision is shown at the top of this page. We encourage you to review this page periodically. Continued use of the Website after any changes constitutes acceptance of the updated policy.

12. Contact

For any questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact us:

Wingspay
Email: contact@wingspay.net
Website: wingspay.net/contacts.html