Wings IL Website Privacy Policy
Last updated: September 2024
Introduction
Welcome to Wings IL website. Wings IL is an exclusive, membership-based angel club comprising global industry experts, entrepreneurs, professional investors, and family offices. Some sections of the Website allow you to contact us, submit inquiries, subscribe to our newsletter and marketing communications and sign up/log in to manage your profile and stay in contact with other club members (the “Website”).
This Privacy Policy (“Policy”) explains how information about you is collected and used by the Website, which is developed and operated by Wings IL (“Wings” or “we”, “us”, “our”).
We are committed to complying with applicable data protection laws, including the EU and the UK General Data Protection Regulation (GDPR).
The Website is not directed to users under the age of 18. We do not knowingly collect information or data from children under the age of 18 or knowingly allow minors under the age of 18 to use the Website.
This Policy may be amended from time to time. We will post any change to this Policy on our Website at a reasonable time in advance of the effective date of the change, and we will also make efforts to proactively notify you by email of the changes if we have your email address.
Contact us
If you have any questions, comments or concerns regarding this Policy or our processing of your personal information, please contact us at info@wingsil.com.
What we collect and why
Scenario
Purposes
Categories of information processed
When you choose to register to our membership-based angel club and joining our CRM/lists
Providing you with access to the membership-based angel club, allowing you to manage your profile and stay in contact with other club members, contacting you regarding administrative issues related to the club, the Website, this Policy, our terms, support and maintenance.
Email address, full name, mobile phone number, account username, user’s address, domain expertise.
Providing consent to use or share your information for marketing purposes
When you choose to use or share your information for marketing purposes, as requested.
Email address, full name, mobile phone number, account username, user’s address, domain expertise.
Subscribing to our newsletters
Providing you with the newsletter you requested, such as information about events, educational materials, marketing materials, news.
Email address, full name.
Contacting us with an inquiry through our email
Responding to your inquiry, our business development.
Your mobile phone number, email address, full name, user address, the subject of your inquiry and the text of your message.
When you provide us with your feedback and reviews
Responding to your feedback and reviews, our business development.
Mobile phone number, email address, full name, user address and the feedback or review.
Use of cookies on the Website
Facilitate a Website feature that you specifically requested, analyze the Website usage to evaluate and improve its performance, improve user experience on the Website, inform and serve personalized ads more relevant to user interests.
IP address from which you access the Website, time and date of access, type of device and browser used, language used, links clicked via a mouse or a touch screen, and actions taken while using the Website.
You have the right to review the personal information we collect and process about you, request its correction (according to Sections 13 and 14 of the Protection of Privacy Law, 5741 – 1981). You are not legally obligated to provide us with your personal information, but if you do not, we will not be able to handle or respond to your inquiry, to send you our newsletter with information about our business and offers, or fulfill your request to register or to use our Website functionalities.
Methods and sources for collecting your personal information
We collect the personal information from several sources:
- Directly from you when you register to our club or when provided to us through other supported means, such as our email.
- From our service providers helping us to operate the Website.
- Through the device you use to access our Website, including through third party cookies and analytics tools, such as Google Analytics.
Sharing your personal information
We will not share your information with third parties, except in the events listed below or when you provide us with your explicit and informed consent.
Scenario
Purposes
Third parties involved
We will share your information with our service providers who assist us with the internal operations of the Website. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes
Operating the Website, the club and our business.
G suite CRM (Zoho, attio)Subject to the following additional Policies:
https://policies.google.com/privacy
https://www.zoho.com/privacy.html
https://attio.com/legal/privacy.
With other members of the membership-based angel club
Allowing you to manage your profile and stay in contact with other club members, in accordance with your settings.
Other members of the membership-based angel club
If you abused your rights to use the Website or violated any applicable law while doing business with us
Responding to, handling, and mitigating suspected violations of law in connection with our business.
Competent authorities, legal counsels, and advisors.
If a judicial, governmental, or regulatory authority requires us to disclose your information
Complying with a binding request from a competent authority.
Competent authorities.
If the operation of the Website or our business is organized within a different framework, or through another legal structure or entity
Enabling a structural change in the operation of the Website and our business.
The target entity of the merger or acquisition, legal counsels, and advisors.
Data retention and security
We retain your information for as long as needed to operate the Website, and thereafter as needed for record-keeping matters.
We will retain your information for as long as needed to operate the Website. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish, and defend legal claims and enforce our agreements. The overall period of retention is approximately 7 years.
We implement measures to secure your information.
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, there is no guarantee that it will be immune from information security risks.
Additional information for individuals in the EU or UK
Controller, GDPR and UK representatives
Wings IL is the data controller of the personal information collected via the Website
Name
Address
EU GDPR Representative
UK GDPR Representative
Wings IL
Hamaalit 6, Kadima, 6092000, Israel,
info@wingsil.com
International data transfers
To facilitate processing your information through the Website and by our service providers, we will transfer your information to countries outside the EU or the UK. We do so to countries which are recognized by the European commission as having adequate protection for personal data, or under the terms of a data transfer agreement which contains standard data protection contract clauses with adequate safeguards determined by the EU Commission and UK Information Commissioner’s Office.
Legal basis for processing your personal data
Purpose or Scenario
Legal Basis
Register to our membership-based angel club and joining our CRM/lists
Performance of our Terms of Service contract with you, facilitating your request and our legitimate interest in the operation of the Website and club.
Processing and sharing your information for marketing purposes
Consent
Subscribing to our newsletters or
Consent.
Responding to your inquiry
Our legitimate interest in responding to your inquiry, our business development.
When you provide us with your feedback and reviews
Our legitimate interest in developing and enhancing our business and the Website, responding to your feedback or reviews.
Use of cookies on the Service
Our legitimate interests in providing you with the Service you requested, tailoring the Service to your preferences.
Marketing and third-party cookies
Consent.
Responding to, handling, and mitigating suspected violations of law in connection with our business
Legitimate interests in defending and enforcing against violations and breaches that are harmful to our business.
Complying with a binding request from a competent authority
Legitimate interests in complying with mandatory legal requirements imposed on us.
Enabling a structural change in the operation of the Website and our business
Legitimate interests in our business continuity.
Data subject rights
If you are in the EU or the UK, you have the following rights under the GDPR:
Right to Access and receive a copy of your personal information that we process.
Right to Rectify inaccurate personal information we have concerning you and to have incomplete personal information completed.
Right to easily and at any time withdraw your consent to us processing your personal data to email you with our newsletters or to use your information for marketing purposes. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Right to easily and at any time withdraw your consent to the use of non-essential cookies on our Website. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Right to Data Portability, that is, to receive the personal information that you provided to us, in a structured, commonly used, and machine-readable format. You have the right to transmit this data to another person or entity. Where technically feasible, you have the right to have your personal information transmitted directly from us to the person or entity you designate.
Right to Object to our processing of your personal information based on our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or if we need to process such personal information for the establishment, exercise, or defense of legal claims.
Right to Restrict us from processing your personal information (except for storing it): (a) if you contest the accuracy of the personal information (in which case the restriction applies only for a period enabling us to determine the accuracy of the personal information); (b) if the processing is unlawful and you prefer to restrict the processing of the personal information rather than requiring the deletion of such data by us; (c) if we no longer need the personal information for the purposes outlined in this Policy, but you require the personal information to establish, exercise or defend legal claims; or (d) if you object to our processing based on our legitimate interest (in which case the restriction applies only for the period enabling us to determine whether our legitimate grounds for processing override yours).
Right to be Forgotten. Under certain circumstances, such as when you object to our processing of your personal information based on our legitimate interest and there are no overriding legitimate grounds for the processing, you have the right to ask us to erase your personal information. However, notwithstanding such a request, we may still process your personal information if it is necessary to comply with our legal obligations, or for the establishment, exercise, or defense of legal claims. If you wish to exercise any of these rights, please contact us through the channels listed in this Policy.
When you contact us, we reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in the Member State of your residence, place of work or place of alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
If you are in the UK, you can lodge a complaint to the Information Commissioner’s Office (ICO) pursuant to the instructions provided here.