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UK Privacy Policy

Last Updated: 9/1/2020
This policy (“Privacy Policy”) describes the practices of The Wing (UK) 14-16 Great Portland Street Limited (d/b/a ‘The Wing’) (“The Wing”, “Company“, “we” or “us“) for collecting, using, maintaining, and disclosing Personal Information that we collect from you or that you provide to us when you visit our website (our “Site“), purchase and use our mobile application (“App”), membership with The Wing (“Membership”) and retail items (“Products”), along with access to any other products and services made available by us. The Site, App, Products and all other products and services made available by us to you are herein referred to collectively as the “Services”.

Before you use our Services, please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. The use of Personal Information collected through our Services shall be limited to the purposes described under this Privacy Policy.

This Privacy Policy may change from time to time. If we make any changes, we will post the changes on this page and indicate at the top of this page the date the policy was last revised. We will also notify you of any material changes either through a pop-up notice, e-mail or through other reasonable means. Any such changes are effective immediately when we post them, and apply to all access to and use of the Services thereafter.
We collect Personal Information from you. Personal Information is information that relates to you and can - either on its own or in combination with other information - identify you as an individual. Personal Information does not include information that has been aggregated or made anonymous such that you can no longer be identified using any means reasonably available to us. We may collect the following categories of Personal Information, depending on the Services that you use:

Contact Information. This includes your name, address, phone number, email address and other information that enables us to contact you.

Professional Information. This includes your company name, title, role, team and other information about your profession.

Communications. If you contact us by phone, email, social media, or by some other means, we may keep a record of the correspondence and data or files that you input, upload or store with the Services, such as search queries that you submit, and documents that you upload to the Services.
Other Personal Information. This category includes Personal information such as screen names, usernames, passwords, and photographs.. We will also process personal data included in content and information that you add to public areas of the Site (i.e. comments or blog) and information that you input into the App.

User Engagement Information. If you use our Services, we may collect information about how you use and interact with the Services. For example, we may automatically collect information about your location, your internet connection, your browser, when you access the Services, the website address that linked you to our Site, the website that you visit after using our Services, and details of how you used our Services, such as how often you used our Services and which features of the Services you used. When we send you emails, we may also track whether you open them to determine how to deliver more helpful emails and improve our Services.
Below are the various ways in which we may collect Personal Information from you. We collect information that:

you provide to us directly;

about your devices and their location, and your use of our Services, including through cookies, pixels, web beacons, logs and other Internet technologies (for more information about these technologies, please see our Cookie Policy, below);

that we obtain from other sources.
Third-party service providers acting on our behalf and advertising partners. This may include third-party analytics service providers and third-party advertisers, whom may incorporate technology such as “pixel tags”, “web beacons”, and “cookies” that allow us to track the actions of users of our Services automatically. These advertising partners use this information (and similar information collected from other websites) to deliver future targeted advertisements to you when you visit other related websites within their networks.

Information from Third-Party Sources. If you visit a physical location of The Wing as a guest of a member, or register to attend an event at a physical location of The Wing via a third-party service not hosted on The Wing Site, we collect Personal Information about you from such member or third-party services (as applicable).

Google Analytics. We use a tool called “Google Analytics” to collect information about use of our Site (e.g., Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site). Google Analytics collects only the IP address assigned to you on the date that you visit the Site, rather than your name or other identifying information. The information collected through the use of Google Analytics is not combined with your Personal Information.

Mobile Computing.
How we use your Personal Information depends upon your relationship with us. We will only collect, use and share your Personal Information where we are satisfied that we have an appropriate legal basis to do so, for example:

Provide you with our Services. Our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you, i.e. to provide you with our Services to meet our contractual obligations.

Ensure the quality of and improve the Services. We may use information that we collect about you or that you provide to us, including Personal Information, to measure usage of the Services, to analyze the effectiveness of our Services, to conduct research, to improve and enhance functionality of the Services, to provide support for the Services and respond to requests and inquiries, to provide you with notices, such as updates or changes that we may make to the Services. Our use of your Personal Information is in our legitimate interest as a commercial organisation to provide our Services to our members, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Information.
Marketing and Advertising. We may also use your Personal Information to contact you about Services and to market and advertise the Services, including through promotional e-mail messages, directly or in partnership with other parties, and by displaying our advertisements on other websites that you visit or use. We generally rely on legitimate interests in marketing our Services to you where permitted by applicable law, and where we cannot it will be where you have consented to this. In each case, we ensure that we do not use your Personal Information in ways you would not expect by allowing you to opt out of receiving all such communications (unless they are solely related to the Services to you and have no marketing element and, where required by applicable law, we will not send you any such communications without your consent.

We may also use this information to offer you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioural advertising).

Complying with Legal Obligations. Amongst other things, we use your Personal Information to comply with relevant legal or regulatory obligations that we have. Some of these obligations include making reports to tax authorities or law enforcement agencies. This is further discussed in section 5 below.

We may from time to time aggregate information in certain data analysis, reports, or other interpretations of trends for both internal and external purposes. Aggregated data is not Personal Information.
We want you to know that we will never sell or pass on your personal information to third parties for their own marketing purposes. There may be some third parties that we need to share personal information with in order to help us provide services and products to you and to run our Services.

Service Providers. We may disclose your Personal Information to service providers or other third parties, such as vendors, technical agents, subcontractors and consultants, to perform certain business-related functions that help make the Services and our offerings available and functional, including, but not limited to, design services, installation services, web site hosting, data analysis and metrics services, maintenance and technical services, customer service and support, email delivery services, infrastructure services and to help us in our marketing efforts, including managing and delivering contextual and tailored advertisements.

Other Parties When Required by Law and as Necessary to Provide and Protect Our Services. We will disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms or to protect the security or integrity of our Services; and/or (c) to exercise or protect the rights, property, or personal safety of The Wing, our users or others.
Other Parties in Connection with a Corporate Transaction. We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, and other User information related to our Services may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Third Party Advertising Partners. We share limited Personal Information with third parties that serve our advertising online, so that they can display our adverts to individuals who may find them most relevant. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

In addition:

The Wing Community. If you post information on public areas of the Site (i.e. comments or blog), that information is visible to and may be collected, stored and used by anyone. By posting information, you agree that you have obtained all necessary consents to make such information public and that doing so will not violate any laws. If you remove information that you have made public through our Services, copies may remain viewable in cached and archived pages of our Services or if other users have copied or saved that information. We are not responsible for the actions of any third parties with whom you share Personal Information.
Social Media. The Services may allow you to post information to various third-party services or platforms, such as social networking services like Instagram, Twitter and Facebook. You acknowledge that if you choose to use this feature, your friends, followers and subscribers on these third party services or platforms will be able to view such activity. The use of the information by such social networking websites will be governed by their privacy policies, and we do not control their use of the shared data. We are not responsible for the actions of any third parties with whom you share Personal Information.

Cookies and Other Internet Technologies. When you use the Services, certain third parties may also use cookies or other automatic information collection technologies to collect information, including Personal Information, about you and your online activities over time and across different websites. We do not control these third parties’ tracking technologies or how they may be used. If you have questions about their data collection practices, you should review the privacy policies of those third parties or contact them directly.
Marketing Communication. We provide a means to unsubscribe in our marketing-related email communications. Note that we will continue to send transaction-related emails regarding products or services that you have requested following an unsubscribe. We may also need to send you certain communications regarding operation and administration of the Services, and you will not be able to opt out of those communications, e.g., communications regarding updates to our Terms of Use or this Policy. To receive marketing or promotional communications, you can also opt-in by clicking the “subscribe” link in any such promotional emails, checking the relevant box located on the form on which we collect your data or emailing us at [email protected]

Cookies. You have the option to accept or disable cookies at any time through your browser. You may refuse to accept browser cookies by activating the appropriate setting on your browser. If you choose to disable your cookies, your user experience may be limited.

Google Analytics. You can opt out of tracking by Google Analytics by using Google’s Ads Settings or going to this website. You may also opt out of Google marketing products, but please note that this does not opt you out of being served generic ads.
Mobile Analytics. If you are using our App, we use Mobile Device IDs, instead of cookies, to recognize you. We use the Mobile Device IDs and other mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. These Mobile Device IDs are only tracking and collecting Non-Personal Information. The software may record information such as how often you use the Services, the events that occur within the App, aggregated usage, performance data, and where the App was downloaded from.

Third-Party Advertising. If you are interested in more information about tailored advertising and your choices to prevent third parties from delivering tailored web advertisements, you may visit the following websites: www.allaboutcookies.org and www.youronlinechoices.com/uk/. These opt-out tools are provided by third parties. We do not control or operate these tools or the choices that advertisers and others provide through these tools. Please note that you may still receive advertisements from third parties within our Services even if you opt out of tailored advertising but they will not be based on your activity across unrelated web sites.

Do Not Track Signals. Third parties may keep track of your browsing activities across third party websites. Certain web browsers enable users to activate a “Do Not Track” signal but we do not currently respond to the “Do Not Track” signal or other similar mechanisms.
This Privacy Policy applies only to the Services. The Services may contain advertisements or links to other web sites not operated or controlled by us (the “Third Party Sites”), and the policies and procedures described in this Privacy Policy do not apply to those Third Party Sites, even if you access them through the Services. The links from the Services or the Third Party Sites’ displays of The Wing’s logo or other intellectual property elements do not imply that we endorse, have reviewed, or are in any way affiliated with the Third Party Sites. We cannot control or be held responsible for third parties’ privacy practices and content and we are not responsible for the data collection, privacy, and information sharing policies and procedures or content of such third-party websites. We encourage you to carefully review the privacy policies of any Third Party Sites you access so you know how they will use and share your information.
Our Services are intended for users who are 18 years of age and older, and we do not knowingly collect Personal Information from anyone under the age of 18. If you are under the age of 18, you are not permitted to submit any Personal Information to us. If you believe we might have any information from or about an individual under 18, please contact us at [email protected] If we become aware that a person under 18 years old has provided us with Personal Information, we will delete such information from our files.
We strive to keep your Personal Information only as long as we need it and as permitted by applicable legal requirements. When determining how long this retention period will last, we take into account the length of time Personal Information is required: for analytical purposes and recordkeeping integrity (including audit purposes); to continue to develop and improve our Services; to comply with record retention requirements under applicable law; to prevent fraud; to enforce our Terms of Use; to take actions we deem necessary to protect the integrity of our Services or our users; to defend or bring any legal claims or potential legal claims; to address any complaints; or to take other actions otherwise permitted by law.
Personal Information collected through the Services may transferred out of the European Economic Area where we consider it reasonable to do so. It may also be stored and processed in the United States or any other country in which The Wing or its subsidiaries, affiliates, or service providers maintain facilities. We will ensure that appropriate safeguards are in place to protect your personal data and that transfer of your personal data is in compliance with applicable data protection laws. Where required by applicable data protection laws, we have ensured that service providers sign standard contractual clauses as approved by the European Commission or other supervisory authority with jurisdiction over the relevant data exporter. You can obtain a copy of any standard contractual clauses in place which relate to transfers of your personal data by contacting us at [email protected]
We take reasonable steps to protect the Personal Information provided to us from loss, misuse, and unauthorized access, disclosure, alteration, or destruction and we make sure we manage it in accordance with our legal responsibilities under applicable data protection laws. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Information to us via the Internet. In the event that Personal Information is compromised as a breach of security, The Wing will promptly notify our customers in compliance with applicable law.
We want to make sure you’re in control of how we use and keep your information. You have a number of rights in relation to your Personal Information that we hold and process.

Subject to certain exceptions prescribed by law, you may: (a) request access to or obtain a copy of your Personal Information that we hold, and details of how we use it, the type held and any recipients; (b) seek correction of your Personal Information if you think anything is inaccurate; (c) request erasure of your Personal Information; (d) request an electronic copy of your Personal Information to be sent to you, or another organisation; (e) restrict our uses of your Personal Information or object to those uses; and/or (f) withdraw your agreement to us processing your Personal Information based on ‘consent’.

Although you are encouraged to contact us if you would like to exercise your rights, some of these rights are only available in certain circumstances and so we may not be required to comply with every request.

If you wish to access, update, correct or delete any Personal Information in our possession or control, you may log into your account and make updates. If you wish to make changes not available through your account settings, please contact us at [email protected]
We do not currently use your Personal Information in such a way that automated decisions are made about you without any human input.
Our physical sites have CCTV installed to meet our legitimate business interests in protecting the safety of our employees, members, and guests and their property. These recordings may be shared with competent authorities in accordance with applicable laws, if required. The recordings are retained for a limited period of time, but may be kept longer for the investigation of an incident or when competent authorities request us to retain them.
If you have any questions about this Privacy Policy, please contact us at [email protected]
If you have any concerns or complaints as to how we have handled your Personal Information, please don’t hesitate to get in touch (you can find the details above) and we will endeavour to investigate. You may also lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted at: www.ico.org.uk/global/contact-us/ or by writing to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
We, as well as third parties that provide content, advertising or other functionality on our Services, may use cookies, pixel tags, local storage and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone or other devices that allow us to record certain pieces of information whenever you visit or interact with our website, services, applications, messaging and tools, and to recognize you across devices.

Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt-out of Google’s collection and Processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:

Operationally Necessary. We may use Technologies that are necessary to the operation of our Site, Services, applications, and tools. This includes Technologies that allow you access to our Site, Services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of functions such as shopping carts, saved search or similar functions.

Performance Related. We may use Technologies to assess the performance of our Site, applications, Services and tools, including as part of our analytic practices to help us understand how our visitors use our Site, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services or tools.

Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Sites, Services, applications or tools. This may include identifying you when you sign into our Sites or keeping track of your specified preferences, interests or past items viewed so that we may enhance the presentation of content on our Sites.

Advertising or Targeting Related. We may use first-party or third party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our Sites, Services, applications or tools, you may do so by blocking, deleting or disabling them as your browser or device permits. See Section 5 for additional opt-out options. Please note that blocking, deleting, or disabling these Technologies will affect the functionality of our Services, and may prevent you from being able to access certain features.