This Privacy Policy was last updated on 10/10/2025

Privacy and cookies policy

This policy was last updated on 10/10/2025

1 . Introduction

1.1. Wingmate.com (our website) is provided by The Lifetime Value Co. LLC. acting through Internet Utility Group, LLC, d/b/a Wingmate.com (‘Wingmate.com’, ‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organization legally responsible for deciding how and for what purposes it is used. You can find out more about us in Section 17.

1.2. We are committed to safeguarding the privacy of our website visitors, service users, individual customers, customer personnel, individual contractors, consultants and freelancers.

1.3. Our website incorporates privacy controls that allow you to manage the use of cookies and similar technologies. By adjusting these settings, you can choose which types of cookies are permitted (for example, performance or targeting cookies). You can access these controls at any time through the “Cookie Settings” button in the footer of our website.

1.4. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

2 . The personal data that we collect

2.1. In this Section 2, we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

2.2. We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, and postal address. The source of the contact data is you.

2.3. We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, account creation and modification dates, payment information, purchase history, report history, technical and device information, website settings, and marketing preferences. The primary source of the account data is you, although certain elements of the account data may be generated by our website.

2.4. We may process your personal data that are provided in the course of the use of our chatbot services and generated by our services in the course of such use ("chatbot data"). The chatbot data may include the personal data that you input into our chatbot. The source of the chatbot data is you and/or our services.

2.5. We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details), and the transaction details. We do not retain full credit card numbers. The source of the transaction data is you and/or our payment services provider.

2.6. We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

2.7. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, device ID, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system, our advertising networks and search information providers.

2.9. Please do not supply any other person's personal data to us, unless we prompt you to do so.

3 . Purposes of processing and legal bases

3.1. In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2. Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services, suppliers and business.

3.3. Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, mail, online chat and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services and supplied services, and the proper administration of our website, services and business.

3.4. Marketing - We may process contact data, account data, customer relationship data, transaction data and/or usage data for the purposes of creating, targeting and sending direct marketing communications by email, making personalized suggestions and recommendations to you about our services that may be of interest to you, to deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you. The legal basis for this processing is our legitimate interests (namely to carry out direct marketing, develop our services and grow our business to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) and (where we are required by law to obtain it) consent.

3.5. Research and analysis - We may process usage data, chatbot data and/or transaction data for the purposes of researching and analyzing the use of our website and services, researching and analyzing other interactions with our business, and use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, updating, developing, improving and securing our website, services and business generally and to inform our marketing strategy.

3.6. Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.7. Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.8. Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.9. Legal claims - We may process your personal data where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.10. Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4 . Direct Marketing

4.1. During the registration process on our website, when your personal data is collected, you may be asked to indicate your preferences for receiving direct marketing communications from Wingmate.com via email and/or SMS, as required under applicable law. For users located in jurisdictions that require express consent (including the EU, UK, Canada, and certain other countries), we will only send you marketing communications where you have actively consented by selecting your preferences at registration. For U.S. users, by registering or otherwise providing your contact information, you consent to receive marketing communications from us by email, unless and until you choose to opt out. You may update your marketing preferences or opt out at any time by using the link in our emails or contacting us directly.

4.2. We may also analyze your personal data to form a view of which services and offers may be of interest to you so that we can then send you relevant marketing communications.

4.3. We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

4.4. You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the details set out at Section 17 below.

4.5. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations, updates to our Terms and Conditions, checking that your contact details are correct.

5 . Providing your personal data to others and International Transfers

5.1. In this Section 5, we provide information about the circumstances in which your personal data may be transferred to third parties and to third countries under UK and/or EU data protection law.

5.2. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. We and our other group companies have offices and facilities in the United States and Costa Rica. Where required, transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.

5.4. We disclose your personal data to the following suppliers:

Supplier	Purpose of Transfer	Location of Supplier
Customer Support Platform	CRM & Support Services	United States
Privacy & Compliance Management Tool	Cookie Consent Management	United States
Customer Care and Contact Center Providers	Customer Support Services	India; Honduras; Philippines
Web Hosting and CDN Providers	Maintaining platform integrity; Contractual obligations; Proper administration, development, improvement, and security of our website, services, and business	United States
Tag Management Systems	Maintaining platform integrity; Contractual obligations	United States; Costa Rica
Analytics and Tracking Providers	Analytics and Tracking Providers	United States

Wherever we transfer your personal data outside the EEA or the UK, we ensure a similar degree of protection by ensuring at least one of the following safeguards is implemented: the country has an adequacy decision by the European Commission/the UK’s Information Commissioner’s Office; Standard Contractual Clauses (plus UK Addendum if applicable); or other legally valid mechanism under Article 46 GDPR/UK GDPR

5.5. Financial transactions relating to our website and services are handled by our payment services providers, situated in the United States. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. Transfers to PSPs will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.

5.6. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

5.7. In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6 . Retaining and deleting personal data

6.1. This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3. We will retain your personal data as follows:

(a) Contact data (such as names, email addresses, phone numbers): retained for up to 2 years from last contact where used for marketing, and up to 10 years from last contact where held in customer relations records;

(b) Account data (such as login credentials, subscription information, an duser account history): retained for up to 10 years from the date of account closure;

(d) Transaction data (such as payment records and expense records): retained for up to 10 years from the date of transaction. We do not retain full credit card numbers;

(e) Communication data (such as customer support requests, queries, and complaints): retained for up to 10 years from closure;

(f) Usage data (such as cookie/analytics data and system monitoring logs): generally retained for up to 2 years from collection, or up to 6 years in the case of security and system monitoring logs.

6.4. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7 . Security of personal data

7.1. We will take appropriate technical and organizational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7.2. We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

7.3. The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and limited payment card details (such as the last four digits). We do not retain full credit card numbers.

7.4. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

7.5. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7.6. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

8 . Your rights

8.1. In this Section 8, we have listed the rights that you have under data protection law.

8.2. Your principal rights under data protection law are:

(a) The right to access - you can ask for copies of your personal data;

(b) The right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(d) The right to restrict processing - you can ask us to restrict the processing of your personal data;

(e) The right to object to processing - you can object to the processing of your personal data;

(f) The right to data portability - you can ask that we transfer your personal data to another organization or to you;

(g) The right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) The right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organizations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

8.4. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

9 . Third party websites

9.1. Our website includes hyperlinks to, and details of, third party websites.

9.2. In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

10 . Personal data of children

10.1. Our website and services are targeted at persons over the age of 18.

10.2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11 . About cookies

11.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

11.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

11.3. Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

12 . Cookies that we use

12.1. We use cookies for the following purposes:

(a) Authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website;

(b) Shopping cart - we use cookies to maintain the state of your shopping cart as you navigate our website;

(c) Personalization - we use cookies to store information about your preferences and to personalize our website for you;

(d) Security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(e) Advertising - we use cookies to help us to display advertisements that will be relevant to you;

(f) Analysis - we use cookies to help us to analyze the use and performance of our website and services; and

(g) Cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

13 . Cookies used by our service providers

13.1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website. In particular, we use:

(a) Analytics cookies - We use providers such as Google Analytics to help us understand how visitors use our website, improve performance, and create usage reports. Analytics cookies may track information such as pages visited, time spent on site, and referral sources.

(b) Advertising cookies - We work with advertising partners such as Google Ads/AdSense and Meta (Facebook, Instagram) to deliver relevant ads, measure ad performance, and provide personalized marketing.

(c) Social media cookies - Platforms such as Meta (Facebook, Instagram), LinkedIn, and Twitter/X may set cookies to enable integration of their services, personalize content, or measure engagement with our website.

(d) Security and fraud prevention cookies - Tools such as Google reCAPTCHA and Cloudflare may set cookies to help protect our website from abuse, detect fraudulent activity, and ensure system security.

(e) Payment service cookies - Payment processors may set cookies to enable secure transactions and prevent fraud.

(f) Customer support and communication cookies - Tools such as Zendesk or similar providers may use cookies to enable live chat, help desk services, or in-site messaging.

13.2. You can learn more about how our service providers use cookies and personal data by reviewing their respective privacy and cookie policies.

(a) https://myadcenter.google.com

(b) https://policies.google.com/privacy

(d) https://www.facebook.com/privacy/policy

(e) https://www.linkedin.com/legal/privacy-policy

(f) https://www.linkedin.com/legal/cookie-policy

(g) https://x.com/en/privacy

(h) https://help.x.com/en/rules-and-policies/x-cookies

(i) https://www.cloudflare.com/privacypolicy/

(j) https://www.cloudflare.com/cookie-policy/

(k) https://www.zendesk.com/company/agreements-and-terms/privacy-notice/

(l) https://www.zendesk.com/company/agreements-and-terms/cookie-notice/

13.3. You can manage your preferences and opt out of personalized advertising by visiting YourAdChoices or by using the privacy controls available through your browser or device settings.

14 . Managing cookies

14.1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can obtain up-to-date information about managing cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/products/firefox/privacy-and-security (Firefox);

(d) https://support.apple.com/en-gb/guide/safari/welcome/mac (Safari); and

(e) https://support.microsoft.com/en-gb/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd (Edge).

14.2. Blocking all cookies will have a negative impact upon the usability of many websites.

14.3. If you block cookies, you will not be able to use all the features on our website.

15 . Cookie preferences

15.1. You can manage your preferences relating to the use of cookies by clicking on the Cookie Settings button in the footer of our website.

16 . Amendments

16.1. We may update this policy from time to time by publishing a new version on our website.

16.2. You should check this page occasionally to ensure you are happy with any changes to this policy.

17 . Our details

17.1. This website is owned and operated by The Lifetime Value Co. LLC.

17.2. If you have any questions about this Privacy Policy, the data practices of Wingmate.com, or your dealings with Wingmate.com, please feel free to contact us at: [email protected], or at 1-786-482-6762. All communications with us or our authorized agents may be monitored or recorded.

17.3. Our representative within the EU with respect to our obligations under data protection law is European Data Protection Office (EDPO), and you can contact our representative by using EDPO’s online request form: https://edpo.com/gdpr-data-request/, or by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.

17.4. Our representative within the UK with respect to our obligations under data protection law is EDPO UK Ltd (EDPO UK), and you can contact our representative by using EDPO UK’s online request form: https://edpo.com/uk-gdpr-data-request/, or by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.

17.5. Our data protection officer's contact details are: [email protected].