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fix(docs): update Privacy.md (#5722)
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## Checklist

- [X] Title matches [Winglang's style guide](https://www.winglang.io/contributing/start-here/pull_requests#how-are-pull-request-titles-formatted)
- [X] Description explains motivation and solution
- [ ] Tests added (always)
- [X] Docs updated (only required for features)
- [ ] Added `pr/e2e-full` label if this feature requires end-to-end testing

*By submitting this pull request, I confirm that my contribution is made under the terms of the [Wing Cloud Contribution License](https://github.com/winglang/wing/blob/main/CONTRIBUTION_LICENSE.md)*.
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Expand Up @@ -61,7 +61,7 @@ We use your personal data as necessary for the following purposes and in relianc
| To facilitate, sponsor and offer certain events, contests and promotions. | Legitimate Interest, Consent (to the extent applicable) |
| To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, conduct research, or for any other purpose. | Legitimate Interest, Performance of a Contract, Compliance with legal obligations |

If you reside or are using the Services in a territory governed by privacy laws under which “Consent” is the only or most appropriate lawful basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing), your acceptance of this Privacy Notice will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Notice, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at [privacy@wingcloud.com](mailto:privacy@wingcloud.com).
If you reside or are using the Services in a territory governed by privacy laws under which “Consent” is the only or most appropriate lawful basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing), your acceptance of this Privacy Notice will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Notice, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at [privacy@wing.cloud](mailto:privacy@wing.cloud).

## Data Storage and Transfer

Expand All @@ -79,7 +79,7 @@ To determine the appropriate retention period for personal data, we consider the

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you.

If you have any questions about our data retention policy, please contact us by e-mail at [privacy@wingcloud.com](mailto:privacy@wingcloud.com).
If you have any questions about our data retention policy, please contact us by e-mail at [privacy@wing.cloud](mailto:privacy@wing.cloud).

## How We Share or Otherwise Disclose Your Personal Data

Expand All @@ -89,7 +89,7 @@ We disclose personal data in the following ways:
- **Partnerships:** We may engage selected business and channel partners, resellers, distributors and providers of professional services related to our Services, which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our customers, users and prospects. In such instances, we may share relevant contact, business and usage details with the respective partner, to allow them to engage with those entities and individuals for such purposes. If you directly engage with any of our partners, please note that any aspect of that engagement that is not directly related to the Services and directed by us is beyond the scope of Wing Cloud’s Terms of Service and this Privacy Notice, and may therefore be covered by the partner’s own terms and policies. Please review the privacy notices and terms of services of those businesses for more information about what each of those businesses does with your personal data.
- **Service Integrations:** Our Services may allow or require connection or integration with third-party services, for example, GitHub. The provider of this connected or integrated third-party service may receive certain relevant data about or from your account on the Services, or share certain relevant data from your account on the third-party provider’s service with our Services, including personal data, depending on the nature and purpose of such integration. Note that we do not receive or store your passwords for any of these third-party services (but do typically require your API key in order to integrate with them).
- **Event Sponsors:** If you attend an event or webinar organized by us, or download or access an asset on our sites related to such an event, webinar or other activity involving third-party sponsors or presenters, we may share your personal data with them. Depending on the applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth where relevant. In these circumstances, your personal data will be subject to the sponsors’ privacy statements. If you do not wish for your personal data to be shared, you may choose not to opt-in via the event/webinar registration, or elect to not have your badge scanned, or you can opt-out in accordance with Section 7 below.
- **Sharing your Feedback or Recommendations:** If you submit a public review or feedback, note that we may (at our discretion) store and present your review on our sites and in our Services. If you wish to remove your public review, please contact us at [privacy@wingcloud.com](mailto:privacy@wingcloud.com).
- **Sharing your Feedback or Recommendations:** If you submit a public review or feedback, note that we may (at our discretion) store and present your review on our sites and in our Services. If you wish to remove your public review, please contact us at [privacy@wing.cloud](mailto:privacy@wing.cloud).
- **Business Customers:** Our Business Customers may have access to any personal data we process on their behalf in our capacity as a “processor” or a “service provider”, including personal data relating to their users, as it occurs in the context of their use of our Services.
- **Legal Compliance:** We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
- **Protecting Rights and Safety:** We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Wing Cloud and our employees, any of our prospects, users or customers, or any members of the general public.
Expand Down Expand Up @@ -121,15 +121,15 @@ We engage in service and promotional communications, through e-mail, phone, SMS

**Promotional Communications:** We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our customer, user or prospect, subject to any necessary collection of your consent as appropriate based on applicable laws. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify us at any time by sending an e-mail to: [privacy@wingcloud.com](mailto:privacy@wingcloud.com) or by following the instructions contained in the promotional communications you receive.
If you do not wish to receive such promotional communications, you may notify us at any time by sending an e-mail to: [privacy@wing.cloud](mailto:privacy@wing.cloud) or by following the instructions contained in the promotional communications you receive.

## Data Security

We have implemented industry-standard physical, procedural and technical security measures, designed to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that our Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. If there is any unexpected activity or inaccurate information or if you have reason to believe that your information is no longer secure, or if you have any questions about our security, please contact us by e-mail at [privacy@wingcloud.com](mailto:privacy@wingcloud.com).
We have implemented industry-standard physical, procedural and technical security measures, designed to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that our Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. If there is any unexpected activity or inaccurate information or if you have reason to believe that your information is no longer secure, or if you have any questions about our security, please contact us by e-mail at [privacy@wing.cloud](mailto:privacy@wing.cloud).

## Your Data Subject Rights

Individuals have rights concerning their personal data. Please contact us by e-mail at: [[email protected]](mailto:[email protected]) if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and others such as – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request correction or erasure of your personal data held with Wing Cloud, or to restrict or object to such personal data’s processing (including the right to direct us not to sell or share your personal data to third parties now or in the future, as described below), or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you). Under some regulatory frameworks, such as the GDPR, you may also have the right to lodge a complaint with the relevant supervisory authority, as applicable. These rights are also subject to various exclusions and exceptions under applicable laws.
Individuals have rights concerning their personal data. Please contact us by e-mail at: [[email protected]](mailto:[email protected]) if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and others such as – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request correction or erasure of your personal data held with Wing Cloud, or to restrict or object to such personal data’s processing (including the right to direct us not to sell or share your personal data to third parties now or in the future, as described below), or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you). Under some regulatory frameworks, such as the GDPR, you may also have the right to lodge a complaint with the relevant supervisory authority, as applicable. These rights are also subject to various exclusions and exceptions under applicable laws.

We will not charge a fee to process or respond to your verifiable privacy request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Alternatively, we may refuse to comply with your request in such circumstances.

Expand All @@ -153,10 +153,10 @@ However, when Wing Cloud processes personal data on behalf of its Business Custo

**External Links:** While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Notice applies only to our Services.

**US State Laws Requirements:** This Privacy Notice describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention (Section 4) and deletion (Section 9) practices. We also included information about how we may process your information, which includes “business purposes” under the CCPA and similar US State Laws. If you would like to opt out of the “sale” or “sharing” (as such terms are defined under applicable U.S. State Laws including the CCPA) of your personal information, please contact us at [email protected]. We may disclose personal information with third parties or allow them to collect personal information from our Services as described in Section 5 above, if those third parties are our Business Customers (in respect of users’ personal data processed on their behalf), or our authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or direct us to disclose your personal data to third parties. You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us at [email protected]. Note that we will not discriminate against you by withholding our Services from you or providing a lower quality of service to you for requesting to exercise your rights under the law, to the extent possible.
**US State Laws Requirements:** This Privacy Notice describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention (Section 4) and deletion (Section 9) practices. We also included information about how we may process your information, which includes “business purposes” under the CCPA and similar US State Laws. If you would like to opt out of the “sale” or “sharing” (as such terms are defined under applicable U.S. State Laws including the CCPA) of your personal information, please contact us at [email protected]. We may disclose personal information with third parties or allow them to collect personal information from our Services as described in Section 5 above, if those third parties are our Business Customers (in respect of users’ personal data processed on their behalf), or our authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or direct us to disclose your personal data to third parties. You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us at [email protected]. Note that we will not discriminate against you by withholding our Services from you or providing a lower quality of service to you for requesting to exercise your rights under the law, to the extent possible.

If you have any questions or would like to exercise your rights under any applicable US State Laws, you can contact us at privacy@wingcloud.com.
If you have any questions or would like to exercise your rights under any applicable US State Laws, you can contact us at privacy@wing.cloud.

**Children:** Our Services are not designed to attract minors. We do not knowingly collect personal data from minors and do not wish to do so. If we learn that a person who is considered a minor according to applicable law is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such minor. If you believe that we might have any such data, please contact us by e-mail at [privacy@wingcloud.com](mailto:privacy@wingcloud.com).
**Children:** Our Services are not designed to attract minors. We do not knowingly collect personal data from minors and do not wish to do so. If we learn that a person who is considered a minor according to applicable law is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such minor. If you believe that we might have any such data, please contact us by e-mail at [privacy@wing.cloud](mailto:privacy@wing.cloud).

**Contacting Us:** If you have any comments or questions regarding our Privacy Notice, or if you have any concerns regarding your personal data held with us, please contact Wing Cloud at [privacy@wingcloud.com](mailto:privacy@wingcloud.com).
**Contacting Us:** If you have any comments or questions regarding our Privacy Notice, or if you have any concerns regarding your personal data held with us, please contact Wing Cloud at [privacy@wing.cloud](mailto:privacy@wing.cloud).

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