We"/"Us"/"Our"/”Organisation” individually and collectively refer to Winglr Private Limited having CIN U72900MH2021PTC359088. Winglr is a new age social networking platform that helps You make real connections, in real places, in real time. Winglr is a mobile application (“Application”) for connecting link-minded people socially and professionally. We have a unique blend of AI services for helping You initiate and facilitate conversations online.
⦁ We publish this Privacy Policy in compliance with Digital Personal Data Protection Act, 2023, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”); and Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
⦁ This is to ensure that users (“You”, “Your”, Users”) are aware of the information collected, shared and how is it processed by Us. We at Winglr are committed to protecting Your privacy and creating a safe space for You and Your data. We recommend You read this policy in its entirety.
To make any of Our Services (as defined in the Terms of Use) available, We have to collect certain information from You. By now You must have been well-versed with this drill. However, it is Our responsibility to convey You the kind of data collected by Us. Here's a comprehensive list of data that may be collected from You by Us or Our Third-Party Service Providers (please refer Terms of Use)
⦁ Registration – Name, username, age, email address, social media accounts, phone number, date of birth, sexual orientation, relationship status, profession, personality traits, industry-based skill sets, soft skills, photograph, preferences, likes, dislikes or any other interactive details.
⦁ Geolocation – Your precise location collected from Your device’s GPS or Bluetooth information. This information is mandatory to provide in order to avail location-based networking. Certain Services may not be available, unless You grant access Us to Your location. It helps Us to recommend You people and places nearby. You can turn off access to Winglr from Your device’s settings. It will track the location even when the app is in the background to keep you updated on nearby locations and events and facilitate auto-checkout.
⦁ Customer Support – Mobile Number, Account details, email address, Your complaints, data for retrieving Your password, any complaints received for Your account.
⦁ Links – In case of partnering with Our integrators, We may collect data including but not limited to type of device, location, browser, device information, session analytics or any other such details collected, for discharging Our integrator’s services. Such collection of data may result in sharing of some information with our integrators, in order to provide you with the Services on the Application.
⦁ Data Collected when You use Our Services - Your activities on the Application including but not limited to the number of Mings (refer Terms of Use) sent, Your preferences and patterns as to other Users or any other such details provided by Our integrators.
From Others – The reason of reporting and blocking Your account, basic details from Your social media used for logging in for instance Google Account.
⦁ Data collected from You is primarily utilized for delivering Our Services. However, certain data is collected for various other functionalities for instance legal compliances, processing information and other services that are enumerated in detail below:
⦁ Providing Our Services and for making it highly personalized for You to be able to achieve Your goal of registering on Our Application.
⦁ Notifications and information of change in Terms of Use, Privacy Policy, Services, new features, newsletters, updating You on Your request to report a User.
⦁ Payment processing, We only share data that is required to be shared for processing, cancellation of payment and its record keeping.
⦁ Research, analytics, reviews, studying User behavior and trends.
⦁ For functioning of the matchmaking algorithm or any such filters for providing You Services per Your preferences.
⦁ Dispute resolution, troubleshooting.
⦁ Supporting law enforcement agencies with evidence or enforcement of the Terms of Use and Privacy Policy.
⦁ Winglr is committed to upholding the protection of the User’s privacy. Any information gathered and shared under these circumstances within the Application will exclusively be used in accordance with the Policy as well as in compliance with relevant laws, rules, regulations, and standards.
⦁ Given the evolving privacy laws in India, We make every effort to ensure Our compliance with existing and forthcoming laws. Additionally, We will keep You informed if any new terms or privacy measures are introduced per the directions of the government.
⦁ Please be assured that We do not disclose Your data unless it's required in limited circumstances.
⦁ We understand that You might have concerns about accessibility of Your chats, please know that Your chats are end-to-end encrypted.
⦁ As mentioned earlier, We process Your information for various purposes. We may partner with various functionaries in handling, processing and supervising Your data. In certain situations, Your data may be shared with law enforcement agencies, if mandated by the law. Hereinbelow is a list of data that may be shared with certain entities:
⦁ It is at the sole discretion of the Company to change or amend this Section. It is Your responsibility to keep checking this Privacy Policy to be updated on the data transferred.
⦁ Upon deletion of Your Account, You may restore Your Account 30 days after the date of deletion. This cure period is not available for Accounts that are reported and blocked by Us;
⦁ We may retain Your Account details for up to a period of 90 days from the date of Deletion of the Account for the purposes of legal compliance. However, certain data may be retained for longer periods based on current and forthcoming legal compliances;
⦁ We may retain certain data of Your Account for extended periods in the event of Your Account being reported by another User for reasons that are legitimate and/or verified by Our Application’s mechanism or our compliance team.
⦁ You certainly have several rights with respect to how Your data should be used or not used. Here are some of the rights at your disposal:
⦁ Access Settings: - You can access Your Application settings to change, update or remove (only optional ones) information.
⦁ Change device permissions: - At any given point of accessing Our Services You may disable any permissions granted by You from Your device’s settings.
⦁ Uninstall: - You may install Our Application from Your device. However, uninstalling the Application does not mean deletion of Your Account on the Application and deletion of Your data.
⦁ Deletion of Account: - You may at Your discretion deleted Your Account at any given point. Please refer Section 5 to understand Our retention policy.
⦁ We implement commercially acceptable and certified standardised technology to ensure Your privacy. We have put in place several physical and technological measures to safeguard Your personal information;
⦁ Your information is stored in secured cloud servers which are password-protected;
⦁ We have taken appropriate steps for the security and protection of all Your personal data and Our digital platforms including internal applications. User must understand that there is no such thing as complete security. We do not guarantee that there will be no unintended disclosures of personally identifiable information;
⦁ Your password is Your first line of defence once You set up Your Account. We recommend that You set a strong password, which shall not be disclosed.
⦁ You must understand that security of Your data is a two-way street. While We comply with the laws and the industry standards, You must actively seek out to filter the information You put up on the Application, share with other Users (whether online of offline). We expect and urge You to exercise a rational internet user’s judgement. We remind You that the information You choose to share on the application whether it is viewable publicly or not may be visible to the non-users (back-end of the Application.
⦁ We are not responsible for the privacy standards of respective Third-Party Service Providers or any security lapses of their hardware or software, or any loss of data stored by them.
⦁ “Force Majeure” shall mean and include any event beyond Our control including but not limited to fire, flood, explosions, an act of god, computer hacking, computer crashes, breach of security, unauthorised access to computer data, and storage devices or due to governmental regulations. We or Our directors, promoters, employees, key-managerial persons or any of our Third-Party Service Providers or Our Affiliates shall not be responsible in the event of occurrence of a Force Majeure event.
⦁ We will not be responsible for third-party websites or applications if You choose to access them;
⦁ If You provide any data to such website/application, please ensure You read their policies given that You will no longer be bound by this Policy in doing so; and
⦁ We may receive data when You visit a third-party link through Our Application which includes the date and time of Your visit to the third-party website, the web address or URL, technical information about the IP address, browser, and the operating system You use.
⦁ We may amend this Privacy Policy from time to time. The use of information We collect now is subject to the Privacy Policy in effect at the time such information is used. If We make changes in the way We use personal information, We will notify You by posting pop-up notification Our Application. You are bound by any changes to the Privacy Policy when You use the Application, or Service after such changes have been first posted;
⦁ You may request access, correction or updating, and deletion of the data by contacting/referring contactus@winglr.com
⦁ You may note that deletion of certain data or withdrawal of consent may lead to cancellation of Your registration with Us or Your access to Our Services; and
⦁ You may opt out of Our marketing emails by clicking on the ‘opt-out’ link provided in the emails. However, We may still send You non-marketing emails about Your accounts or any other transactions with You.
⦁ In case of any queries with respect to the Privacy Policy, please feel free to reach out to Our Grievance Officer;
⦁ If You do not wish to receive email or other mail from Us, please email us at: compliance@winglr.com or contact Our Grievance Officer; and
⦁ Please note that if You do not want to receive legal notices from Us, such as this Privacy Policy, those legal notices will still govern Your use of the Application and the Services, and You are responsible for reviewing such legal notices for changes.
⦁ The appointment of Consent Manager aligns with the regulations set forth in the Digital Personal Data Protection Act, 2023;
⦁ You have the option to grant, manage, review or withdraw Your consent to Us through a Consent Manager;
⦁ You may contact the Consent Manager at: compliance@winglr.com and
⦁ The Consent Manager will be responsible to You and will operate in Your behalf, following the designated guidelines and obligations.
