Privacy Policy

1. Overview and Scope

This Privacy Policy (this "Policy") explains how Wingu Technology LLC, a Florida limited liability company ("Wingu Technology", "we", "us", or "our"), collects, uses, discloses, processes, and safeguards personal information obtained through our website located at www.wingutechnology.com (the "Site"), our multi-tenant customer management portals, mobile/endpoint management interfaces, billing nodes, and cloud infrastructure operations (collectively, the "Products and Services").

This Policy applies to all website visitors, account holders, administrative users, prospective clients, and enterprise clients who interact with our platform (collectively, "Users", "Customers", or "you"). Please read this Policy carefully to understand our data protection practices and your legal rights regarding your personal information.

2. Operational Role: Data Controller vs. Data Processor

To ensure strict legal clarity under US and global data privacy frameworks (including the Florida Digital Bill of Rights, CCPA/CPRA, and EU GDPR):

• Wingu Technology as a Data Controller: We act as a Data Controller (or "Business") with respect to account administrative data, business contact information, billing records, lead generation entries, and website analytics collected directly from Users who register for our platform or browse our Site.
• Wingu Technology as a Data Processor: We act as a Data Processor (or "Service Provider") with respect to all customer-owned databases, virtual machine disks, backup archives, application data, call logs, and network files hosted within or transmitted across our infrastructure (collectively, "Customer Hosted Content"). Customer Hosted Content is governed strictly by our Data Processing Agreement (DPA) and Master Services Agreements executed with the respective Customer entity. Wingu Technology does not inspect, sell, license, or analyze Customer Hosted Content except as explicitly authorized by the Customer or required by law.

3. Categories of Information Collected

We collect several distinct categories of information necessary to operate a sovereign, secure cloud infrastructure platform:

A. Information You Provide Directly

• Corporate Identity and Administrative Contact Data: Legal entity name, business address, registered domain name, primary administrative email address, phone numbers, and job titles provided during account setup or form submissions.
• Authentication and Account Credentials: Usernames, salted/hashed passwords, multi-factor authentication (MFA) parameters, security questions, and access tokens.
• Billing and Transactional Data: Credit card details, bank routing information, billing contacts, payment histories, tax identifiers, and transaction logs processed through our encrypted merchant gateways.
• Communications and Support Data: Content contained within support tickets, chat logs, bug reports, legal consents, and correspondence directed to our support or administrative teams.

B. Information Collected Automatically

• Infrastructure and Telemetry Data: IP addresses, system logs, bandwidth consumption, API interaction timestamps, user agent strings, browser types, operating system profiles, and referrer URLs.
• Managed Endpoint Diagnostic Metadata: Machine identification numbers, hardware GUIDs, endpoint operating system build levels, agent heartbeat metrics, and patch compliance levels for devices enrolled in our endpoint management services.
• Cookies and Local Storage: Technical cookies, session tokens, and local web storage necessary to enforce session persistence, security boundaries, and authenticated portal access.

4. How We Use Collected Information

Wingu Technology utilizes collected personal information strictly for legitimate, verifiable operational and contractual purposes, including:

• Service Provisioning and System Delivery: Processing onboarding workflows, provisioning multi-tenant cloud instances, configuring VoIP extension routing, executing backup schedules, and deploying managed endpoint policies.
• Billing and Financial Administration: Processing recurring subscription payments, issuing periodic utility invoices, assessing setup fees, and recovering unpaid accounts.
• Security and System Integrity: Monitoring network health, detecting malicious activity, mitigating Distributed Denial of Service (DDoS) attacks, enforcing mutual exclusivity policy rules, and preventing unauthorized system access.
• Legal and Regulatory Compliance: Complying with statutory reporting requirements, satisfying tax audits, enforcing our Terms of Use and AUP, and responding to valid subpoenas, court orders, or criminal law enforcement mandates.
• Client Communication: Transmitting deployment confirmations, administrative alerts, scheduled maintenance notices, security patches, and critical invoice updates.

5. Disclosure and Sharing of Information

We restrict access to your personal information to authorized personnel on a strict need-to-know basis. We may disclose personal information to third parties solely under the following defined legal conditions:

• Vetted Sub-processors and Utility Service Providers: Third-party vendors providing essential backend capabilities, such as payment gateway processing, transactional email relays, SMS/VoIP trunking carriers, and hardware colocation facilities. All such sub-processors are bound by strict contractual obligations to keep information confidential and secure.
• Legal Process and Law Enforcement: If required to do so by applicable federal, state, or local law, or in the good-faith belief that such action is necessary to respond to a search warrant, court order, civil discovery subpoena, or formal legal demand.
• Protection of Rights and Safety: When necessary to investigate, prevent, or take action regarding illegal activities, fraud, threats to physical safety, or imminent harm to our network infrastructure, employees, or third parties.
• Corporate Reorganization or Assignment: In connection with any merger, acquisition, sale of corporate assets, or bankruptcy, provided that the acquiring entity agrees to honor the privacy commitments set forth in this Policy.

6. Security Controls and Risk Allocation

Wingu Technology maintains comprehensive technical, physical, and administrative safeguards designed to protect personal data against accidental loss, unauthorized access, destruction, or disclosure. Our defense-in-depth security measures include:

• TLS/SSL cryptographic transport encryption for all data in transit across our portals and API endpoints.
• Restricted physical access controls at primary data center facilities incorporating biometric validation and surveillance.
• Isolated multi-tenant boundaries separating customer virtual machines, network tunnels, and storage pools.
• Systematic hashing and salting of user authentication credentials.

Risk Acknowledgment: While Wingu Technology employs robust, industry-standard security protocols, no internet transmission or electronic storage medium can be guaranteed as 100% immune from attack. Customers remain responsible for maintaining secure passwords, protecting local endpoint environments, and deploying proper encryption on custom applications.

7. Data Retention and Destruction

We retain personal information only for as long as necessary to fulfill the operational purposes for which it was collected, satisfy our contractual commitments under active account agreements, or comply with statutory retention mandates (e.g., tax, financial accounting, and regulatory audit laws).

Upon account termination or verified written request for deletion:

• Administrative contact and billing records will be archived or anonymized in accordance with applicable statutory record retention schedules.
• Customer Hosted Content, virtual machine snapshots, and managed backup archives (including Arbor Vault instances) will be purged and overwritten from operational storage systems within sixty (60) days following account termination, unless a legal hold or court order dictates otherwise.

8. US Consumer Privacy Rights (Florida & Federal Frameworks)

Under applicable US federal and state privacy statutes—including the Florida Digital Bill of Rights (FDBR), California Consumer Privacy Act (CCPA/CPRA), and similar state consumer privacy acts—eligible Users possess specific legal rights regarding their personal information:

• Right to Know / Access: The right to request confirmation of whether we process your personal data and to access specific pieces of collected information.
• Right to Correct: The right to request correction of inaccurate or incomplete personal data stored within our active records.
• Right to Delete: The right to request deletion of personal information provided directly to us, subject to statutory retention exemptions.
• Right to Opt-Out of Targeted Advertising: Wingu Technology does not engage in cross-context behavioral advertising or sell personal data.
• Right to Non-Discrimination: We will not discriminate against any User (e.g., through altered pricing or degraded service quality) for exercising any of their statutory privacy rights.

To submit a verifiable privacy rights request, please contact our administrative team at support [at] wingutechnology [dot] com. We will verify your identity before fulfilling any request.

9. European and International Data Subjects (GDPR / UK GDPR)

Where Wingu Technology processes personal data belonging to individuals located within the European Economic Area (EEA) or the United Kingdom (UK), such processing is conducted in compliance with Applicable Data Protection Laws (including Regulation (EU) 2016/679 and UK GDPR).

International data transfers originating from the EEA/UK to our US-based infrastructure are governed by valid transfer mechanisms, such as Standard Contractual Clauses (SCCs) incorporating Module II (Controller-to-Processor) or Module III (Processor-to-Processor) execution terms, as set forth in our Data Processing Agreement.

10. Health Insurance Portability and Accountability Act (HIPAA) Notice

Wingu Technology's standard cloud infrastructure and website offerings are not intended to process or store unencrypted Protected Health Information (PHI) under HIPAA regulations unless a specific, formal Business Associate Agreement (BAA) has been negotiated, executed, and counter-signed in writing between Wingu Technology LLC and the Customer. Customers are strictly prohibited from uploading PHI into non-designated or unencrypted tenant environments without a signed BAA.

11. Children's Online Privacy Protection Act (COPPA)

Our Products and Services are directed exclusively to commercial businesses, enterprise clients, and adult administrative users. The Site and our platform are not directed to or intended for children under the age of eighteen (18). We do not knowingly collect or solicit personal information from children under 18 years of age. If we learn that we have inadvertently collected personal information from a minor, we will delete that information immediately.

12. Cookies and Tracking Technologies

Our Site utilizes functional and technical session cookies necessary for system navigation, security authentication, and portal interaction. You can configure your web browser to reject non-essential cookies; however, disabling core functional cookies may impair portal functionality or prevent access to authenticated administrative dashboards.

13. Revisions and Policy Amendments

Wingu Technology LLC reserves the right to revise, update, or modify this Privacy Policy at any time at our sole discretion. When updates are published, we will revise the "Last Updated" timestamp at the top of this document. Material changes will be communicated via administrative email or through prominent notices posted across our portal interfaces prior to becoming effective. Your continued use of the Products and Services following the posting of modifications constitutes your formal acceptance of the revised Policy.

14. Contact Information and Privacy Inquiries

If you have questions, concerns, or legal inquiries regarding this Privacy Policy or our data handling practices, please contact our legal and administrative operations department at:

Wingu Technology LLC
Attn: Legal & Data Protection Operations
Wesley Chapel, Florida, USA
Email: support [at] wingutechnology [dot] com
Website: www.wingutechnology.com