Privacy Policy

CCPA Notice at Collection

We collect the following categories of personal information when you interact with our services:

• Identifiers (e.g., name, email, IP address)
• Internet Activity (e.g., pages viewed, time spent, referring URLs)
• Commercial Information (e.g., purchase history, payment details)

The purpose of collection is described in Section 3.

Lawful Bases & Purposes (APP 3, APP 6)

We process Personal Information under the following legal bases:

Personal Information We Collect (APP 3-4)

1. Business Contacts
   • Name, job title, company, business address
   • Work email, work phone number
   • Communication preferences
2. Website Visitors
   • IP address (anonymized where possible)
   • Browser type/version, device OS
   • Pages viewed, time spent, referring URLs
3. Employee & Contractor Data
   • Information for recruitment and hiring
   • Payroll and tax information
   • Performance and training records

Use of the WingSpanAi Website

When you visit our website, we collect certain data automatically, such as:

• IP address
• Browser type and version
• Device operating system
• Pages viewed, time spent, referring URLs

This information helps us improve performance, troubleshoot issues, and optimize content. It is processed under our legitimate interest in better understanding user behavior and improving service delivery.

Cookies & Tracking (APP 5)

We use the following tracking technologies:

Manage your preferences at: Cookie Policy

Sharing & Subprocessors (APP 8)

1. We share Personal Information with:
   • Cloud hosting providers (Firebase, Vercel, Pinecone)
   • Analytics and marketing platforms
   • Payment processors
   • Legal/regulatory authorities when required
2. Subprocessors are vetted and bound by contractual obligations.
3. Subprocessor List: For current subprocessors and objection rights, see our DPA Subprocessors List.

International Data Transfers (APP 8.2)

1. When transferring data overseas, we implement safeguards:
   • OAIC-approved contractual clauses (s 16C Privacy Act)
   • Binding Corporate Rules
   • Jurisdictions with adequacy decisions
2. We review and challenge legal-access requests (e.g., U.S. CLOUD Act) where possible.

Data Retention (APP 11.2)

1. Retention Periods:
   • Customer data: Duration of contract + 5 years post-termination
   • Prospect data: 3 years after last engagement
   • Archived data: Up to 7 years (anonymized)
2. Deletion Requests:

   Contact: privacy@wingspanai.com.au

Your Privacy Rights (APP 12–13)

1. Your Rights Include:
   • Be informed (this policy)
   • Access your data
   • Rectify inaccuracies
   • Erase your data
   • Restrict or object to processing
   • Receive data in portable format
   • Withdraw consent
   • Not be subject to automated decisions without explanation
2. Response Time:
   • Requests handled within 30 days
   • Fees (if any) comply with APP 12.3
3. How to Exercise Your Rights:

   Contact our Privacy Officer at privacy@wingspanai.com.au

Security Measures (APP 11.1)

We implement technical and organizational measures to protect your data:

• Encryption in transit (TLS 1.3) and at rest (AES-256)
• Multi-factor authentication (MFA) for all employee accounts
• Regular security audits and penetration testing
• Role-based access controls (RBAC)
• Secure development lifecycle (SDL) practices

Children's Privacy

Our services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16, we will take steps to delete such information. Parents or guardians can contact us at privacy@wingspanai.com.au to request review or deletion of their child's information.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this policy. We will also provide notice through our services or via email for material changes. You are advised to review this Privacy Policy periodically for any changes.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact our Privacy Officer:

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.