Date of Policy: 04.06.2021

At Wing Tel Inc., we appreciate our customers and value safeguarding their privacy while maintaining transparency. The following document, called a “Privacy Policy,” is meant to help customers and users understand how we handle information submitted by both.

This Privacy Policy (“Policy”) describes how Wing Tel Inc. (“Wing” “we” “our” or “us”) will collect, access, use, or disclose your personal information, including on its website, www.wingalpha.com . It applies to all of our products, services, applications, and websites (“Services”). Some of our Services may be covered by different privacy policies and, in the event of a conflict between this Policy and another Wing privacy policy, the product or service-specific policy governs. This Policy is also incorporated by reference into the Terms of Service that govern your use of the Services (collectively, the “Terms”).

Our collection, use, access, disclosure, and safeguarding of your personal information is subject to U.S. law.

TYPES OF INFORMATION WE COLLECT ABOUT YOU

Personal information. Personal Information is information that we directly associate with a specific person or entity (for example, name; addresses; telephone numbers; email address; username; password; Social Security number; call records; wireless device location). Personal Information does not include “de-identified,” “anonymous,” or “aggregate” information – which is not associated with a specific person or entity.

Customer Proprietary Network Information (CPNI). CPNI is a type of personal information that is generated in connection with the telecommunications services we provide to you. CPNI includes, for example, call details, call location information, and certain information about your rate plans and features. CPNI does not include your name, address, and phone number.

Payment information. Wing collects information about your credit or debit card.

Network and device information. We may collect information about your use of our network (or other carriers’ networks when roaming domestically and internationally) and the device(s) associated with your account, network data related to Wi-Fi usage, and performance information, as well as data relating to your use of our website, applications and other products and services.

Location Data. We may collect your device's location whenever it is turned on (subject to coverage limitations).

Performance and Diagnostic Data. We may collect performance and diagnostic data about your use of our network, networks you roam on, Wi-Fi services, or your device. For example, we may collect information about the performance of the device, signal strength, dropped calls, data failures, battery strength and other device or network performance issues. We may also collect information about applications on your device, the fact that an application has been added, when an application is launched or fails to launch, and length of time an application has been running

HOW YOUR INFORMATION IS COLLECTED

There are several ways in which Wing collects personal and other information about you.

Information you give us: The personal information we collect includes information you provide to us, such as your name, postal address, telephone number, e-mail address, username, password, date of birth, social security number or other government identification number, demographics, activities, location information, payment information, and personal preferences. You may give us information in a variety of ways, including when you sign up for or use Wing Services, communicate with customer care, pay for services, establish or modify an online account on our site, post user-generated content, including comments, to or on any of our Services, use a device on our network or otherwise enter information on our website. Third-party providers whose sites are featured on and accessed via our website may collect information as well. Such collection and use of your information is governed by the third party's privacy policy.

If we have trouble processing your order, the contact information you provide is used to contact you. We also use this contact information to provide you with updates regarding your current services and to provide you with information about Wing promotions and special offers.

Wing may offer the opportunity to participate in contests, giveaways, or other similar promotions we sponsor. Except as explained otherwise in the rules for a particular contest, giveaway, or promotion, any personal information you provide will be used in accordance with this Policy.

Information we automatically collect: We automatically receive certain types of information whenever you use our Services. We may collect information about your device, such as the type, version of operating system, signal strength, whether it is on and how it is functioning, as well as information about how you use the device and services available through it, such as your call, text message, and data usage history, your location, web site history, applications purchased, downloaded or used, and other similar information.

We may link information we collect automatically with personal information, such as information you give us at registration and check out. We may use systems or tools to follow your use of our Services and other applications, including using cookies, web beacons and other mechanisms, along with analysis of network and device information. For example, we may allow collection by analytic service provider(s) of site click-stream and cookie data to help us track aggregate and individual use of our Services. We sometimes use cookies to enable features on our sites, such as the ability to save your shopping cart, set preferences, or serve ads to you. The information we receive through cookies, web beacons, and other mechanisms may enable us to recognize users across devices, such as smartphones, computers, tablets, or related browsers.

Advertisers, ad networks, and other third parties that serve ads on our sites may also use their own mechanisms, including cookies. These third party cookies or tools are governed by the privacy policies of the entities placing the ads and not by this Policy.

Finally, when your device’s web browser utilizes our data services to access websites other than our own, we automatically capture information associated with your browsing activities, and measure and monitor network and Internet connection performance, throughput, latency, and similar network data.

Information from other sources: We may obtain information about you from outside sources and add it to or combine it with your account information. We also may use commercially available demographic and marketing information from third parties to help us better serve or inform you about products or services that we think will be of interest. We may also purchase or obtain personal information from others.

WING'S USE OF PERSONAL INFORMATION

We use personal information for a variety of purposes, including providing you with Services. We may use your personal information to do things like:

• Route your calls or messages or otherwise provide you with services.
• Determine the appropriate pricing for your service.
• Process your orders.
• Provide and bill for services you purchase and charge to your account.
• Deliver and confirm services you obtain from us.
• Verify your identity and maintain a record of your transactions and interactions with us.
• Develop or inform you of new services.
• Anonymize or aggregate personal information for various purposes like market analysis or traffic flow analysis and reporting.
• Monitor, evaluate or improve our products, Services, systems or networks.
• Customize or personalize your experience with our Services.
• Customize or personalize online advertising to bring you information about services of Wing or others that may interest you, including co-branded offers.
• Tell you about services from Wing or others that better meet your needs. More specifically, and as permitted by law, Wing may use e-mail, telemarketing, direct mail and wireless messages to inform you about products or services we think will interest you.
• Protect our rights, employees, workers, property, and those of our customers, particularly from physical harm.
• Investigate or prevent fraud or network abuse.
• Respond to legal processes and emergencies, including providing 911 service.

INFORMATION WE SHARE

DE-IDENTIFIED INFORMATION

We may share information that is de-identified or in an aggregated form that does not directly identify you for purposes such as to:

• Conduct market or traffic flow analysis and reporting or produce or facilitate the production of business and marketing reports by others to share with third parties. If you do not want us to use your information to produce de-identified and aggregated data sets in the reports we share with third parties, you may opt-out at any time.
• With your opt-out consent only, customize or personalize advertising based on information we collect about your use of your wireless device in order to provide wireless service to you. For example, we may use information about your mobile web browsing or use of mobile applications to deliver advertisements tailored to your interests, and we may share de-identified information about your use of your device with third parties so that they can tailor advertising to your interests based on that information.

PERSONAL INFORMATION

We do not share information that identifies you personally with third parties other than as follows:

With Your Consent. We may disclose personal information about you to third-parties with your consent. We may obtain your consent in writing; online, through “click-through” agreements; when you accept the terms of disclosures on your phone for certain applications or services; orally, in our stores or on the phone, including through interactive voice response, or implicitly, for example, when you purchase a product and ask that it be shipped to a submitted address, consenting to our disclosure of your name and address to a third party shipping company to complete delivery.

To the Primary Account Holder. We may disclose information about an account user to the primary account holder (the party financially responsible for the account). If a business, governmental agency, or other individual obtains service for you, that entity or individual is our customer, and we may provide information about you or your use of the service, products or devices to them or others at their direction.

Affiliates. We may share personal information and information that does not directly identify you with affiliated entities for approved business purposes. This may include payment history and transactional information.

Wing's Service Providers. We may share personal information with third parties who perform services on our behalf.

Third Party Verification Services. We may share limited personal information (e.g., address, phone number) with non-Wing entities to assist with identity verification, and to prevent fraud and identity theft.

Other Third Parties. We may share information with other third parties, however you may opt-out this sharing. For example, we may share your information with other third parties to hear about their products and services. Use of the information you agree to share will be subject to those third parties' separate privacy policies.

Disclosures to Third Party Application and Service Providers. You may choose to use services and products offered by third party providers through our Services or devices such as third party applications. When you leave our network you may also use mobile roaming services provided by third parties. Your use of such services and applications may result in these third parties collecting your personal information and obtaining information from Wing, including location information (when applicable). You may also choose to give personal information directly to third parties when using our Services. In each case, personal information that you give a third party will be subject to its terms, conditions and policies – not this Policy. You should review a third party's privacy policy and terms of service before providing your information or using their services.

Business Transfers. Personal information about you may be disclosed as part of any merger, acquisition, sale of company assets or transition of service to another provider. In the unlikely event of an insolvency, bankruptcy or receivership, personal information may also be transferred as a business asset.

Protection of Wing and Others. We may access, monitor, use or disclose your personal information or communications to do things such as:

• Comply with the law or respond to lawful requests or legal process.
• Protect the rights or property of us, our agents, members, our customers, and others including to enforce our agreements, policies and the Terms.
• Respond to emergencies.

NETWORK AND INFORMATION SECURITY

We maintain a variety of physical, electronic and procedural safeguards. These safeguards help protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Be sure to use a strong password to access your information on the site and not one you use for other services.

CHILDREN'S PRIVACY

Wing does not knowingly collect personal information from children under the age of 13. You should be aware that if you purchase a Wing service device and allow a child under the age of 13 to use it, any information collected from the usage of that device will appear to be your personal information and treated as such under this Policy.

If you have any questions about Wing's policies concerning minors, please contact Wing at legal@wingalpha.com or (818) 722-1441.

INFORMATION CHOICES AND CHANGES

In addition to the choices we offer you in the INFORMATION WE SHARE section above, we provide the following choices regarding your information:

Withholding. You can choose not to provide us with certain information, but that may result in the inability to use certain features of our websites or receive certain services. Public forums are not intended for the disclosure of personally identifiable information. To the extent you provide personally identifiable information in any public forum, it is at your own risk.

Marketing Contacts. We offer you choices regarding how we contact you for marketing-related communications.

• You may let us know that you do not want us to contact you for marketing purposes by contacting Wing at support@wingalpha.com or (818) 722-1441. You can also opt-out through the unsubscribe mechanism at the bottom of applicable emails or by texting “STOP” on your wireless device.
• If you register a do-not-contact request with us, we still may contact you for non-promotional purposes, such as emails or wireless messages related to your account, to facilitate a requested business transaction, or when you initiate the interaction.

Advertising. We do not control third parties' collection or use of your information concerning the service of interest-based advertising. You may be able to opt-out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: www.aboutads.info and www.networkadvertising.org/choices/. You may also use TRUSTe's Preference Manager at preferences-mgr.truste.com. You can set preferences for how Google advertises to you using the Google Ad Preferences page, and you can opt-out of interest-based advertising permanently using a browser plugin.

Please note that if you opt-out, you will continue to receive the same number of ads yet they will appear less relevant because they will not be based on your interests. You may still see ads related to content on a web page or based on other non-personally identifiable information. Please note that this opt-out feature is cookie-based. If you change computers or devices,web browsers, or delete retained cookies, you will need to visit the www.aboutads.info website and opt-out again.

Do Not Track Policy. Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites, web applications, and services (including behavioral advertising services) that you do not wish such operators to track certain online activities over time and across different websites. However, as the data sector is currently still working on “Do Not Track” standards, implementations and solutions, we do not recognize or respond to web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services.

Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel. If you disable or refuse cookies, please note that all or some parts of the Services may then be inaccessible or not function properly.

Account Information. If you would like to change certain Wing account information, you may create an online account and manage your account online. For more information, visit our website at www.wingalpha.com

UPDATING THIS PRIVACY POLICY

This Policy is subject to change. If we need to change the Policy at some point in the future, we will post the new policy promptly. When we change the Policy we will give notice by the date last updated or proceed as required by law. By using our website, you agree that your visit abides by the information contained in our Terms of Use Policy.

YOUR CALIFORNIA PRIVACY RIGHTS

Wing shares personal information between affiliates and marketing agents for marketing purposes. Wing does not disclose customers' personal information to third parties for the third parties' direct marketing purposes without your consent. California residents may request the categories of personal information Wing shared with its affiliates during the previous calendar year, if any. To make such a request, please send an e-mail to legal@wingalpha.com or write to us at: Wing Tel Inc., 228 Park Ave S, PMB 70192, New York, New York 10003-1502 US.

SURVIVAL

The policies indicated in this Policy will remain effective, even if the Terms and the other agreements between us are terminated and you are no longer using the Site or any of the other Wing Services.

QUESTIONS OR CONCERNS

If you have any questions about, or complaints that concern, this Policy please contact us at legal@wingalpha.com or (818) 722-1441. You may additionally write to us at Wing Tel Inc., 228 Park Ave S, PMB 70192, New York, New York 10003-1502 US.