Privacy Policy

This Privacy Policy explains how [WINGM legal entity name] ("WINGM", "we", "us") collects, uses, and protects personal data when you visit wingm.io, contact us, download our materials, or when we conduct outbound prospecting on behalf of our clients.

We are the data controller for the processing described below, except where stated otherwise. For processing carried out on behalf of our clients (outbound campaigns), the roles are described in the "Outbound prospecting" section.

Contact details
[WINGM legal entity name]
[Registered address]
[KvK / Chamber of Commerce number]
[Privacy contact email, e.g. privacy@wingm.io]

What data we collect

When you use our website. Our site runs on WordPress and uses Google Tag Manager, which can load analytics and marketing tags. Depending on your cookie choices, we may collect your IP address, browser and device type, pages visited, referral source, and interaction data. See the Cookies section below.

When you contact us or book a meeting. Your name, email address, phone number, company, role, and anything you choose to write in a message or share during a call.

When you download a resource (for example, the expansion playbook). The email address you submit, and the fact that you requested that resource.

When you apply for a job. Your CV, contact details, work history, and any other information you provide. [Confirm whether careers applications run through this domain or a third-party ATS, and name it here.]

Outbound prospecting (data we process on behalf of clients)

WINGM books sales meetings for B2B SaaS and AI companies, primarily through cold calling and targeted prospecting. To do this we collect and use business contact data about decision-makers at target companies, such as name, job title, employer, business phone number, and business email.

For these campaigns, our client is typically the data controller and WINGM acts as a processor under a data processing agreement, or we act as joint or independent controllers depending on the engagement. [Confirm your standard contractual arrangement, this materially affects the legal basis and who handles data subject requests.]

Where WINGM relies on legitimate interest to process business contact data for B2B outreach, you have the right to object at any time. [Describe the opt-out mechanism, e.g. an email address or a request handled during the call.] Note that national rules on cold calling differ across the markets we operate in (Benelux, DACH, Scandinavia, UK & Ireland), and we aim to comply with the applicable local rules in each.

Why we use your data and the legal basis

We process personal data for the following purposes, under the GDPR (and UK GDPR where relevant):

• Responding to enquiries and booking meetings — to take steps at your request before entering a contract, or our legitimate interest in responding to you.

• Sending requested materials — consent (when you submit the form) and our legitimate interest in following up on a download.

• Website analytics and marketing — consent, via the cookie banner.

• Outbound B2B prospecting — legitimate interest, or processing on behalf of a client under contract. [Verify.]

• Recruitment — taking steps before a possible employment contract, and our legitimate interest in assessing candidates.

• Legal and accounting obligations — compliance with the law.

Cookies and tracking

We use cookies and similar technologies, including Google Tag Manager, to run the site and measure how it's used. [List the actual cookies and tags once a scan is done, e.g. Google Analytics, LinkedIn Insight Tag.] You can accept, reject, or manage non-essential cookies through our cookie banner, and you can change your choice at any time via [link / settings]. Essential cookies that make the site work do not require consent.

Who we share data with

We share personal data only where needed:

• Service providers that host our site, run our analytics, manage email and CRM, and support our outbound operations. [List the categories or names: hosting provider, CRM, email tool, dialer/prospecting tools, calendar booking tool.]

• Our clients, where we book a meeting on their behalf and pass on the relevant contact and meeting details.

• Authorities or advisers, where required by law.

We do not sell personal data.

Some providers may process data outside the European Economic Area. Where that happens, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses. [Confirm which providers and which mechanism.]

How long we keep data

We keep personal data only as long as needed for the purpose it was collected, or as required by law. [Set concrete retention periods, e.g. enquiry data X months after last contact, prospect data Y months, recruitment data Z months unless you consent to longer.]

Your rights

Under the GDPR you have the right to access, correct, delete, or restrict processing of your data, to object to processing based on legitimate interest, to data portability, and to withdraw consent where processing relies on it. To exercise any of these, contact us at [privacy contact email].

You also have the right to lodge a complaint with a supervisory authority. In the Netherlands this is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). [If you target the UK, also reference the ICO.]

Security

We take reasonable technical and organisational measures to protect personal data against loss, misuse, and unauthorised access. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

Changes to this policy

We may update this policy from time to time. The "Last updated" date at the top shows the latest version. Material changes will be communicated [state how, if at all].