Privacy Policy

Who We Are

The data controller responsible for your personal data is WINGUARDIAN.NET LLC, a limited liability company organised under the laws of the State of California, United States, California Secretary of State entity number 202201110795. 'WinGuardian.net' is a trading name of WINGUARDIAN.NET LLC and is not a separate legal entity; references to 'WinGuardian.net' mean WINGUARDIAN.NET LLC.

How to contact us about your personal data. By email at legal@winguardian.net, or by post to WINGUARDIAN.NET LLC, 6816 Katella Ave #1026, Cypress, CA 90630, United States. We aim to acknowledge privacy enquiries within five (5) business days. You also have the right to lodge a complaint with your local data protection supervisory authority.

1. Introduction

At WINGUARDIAN.NET LLC, we view data privacy as a fundamental component of our Ethical Innovation pillar. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and your rights in relation to it. It applies to all users of our platform, including clients and participants in the WinGuardian.net Partner Program.

2. Data We Collect

2.1 General Platform Data

When you use the WINGUARDIAN.NET LLC platform, we may collect: account registration information (name, email address, company name); usage data from our AI tools (such as Aria) to refine scoping accuracy and improve service quality; communications you send us; and technical data collected automatically via cookies and third-party analytics, including IP address, browser type, granular device details, and city-level location derived from your IP address. We do not collect precise geolocation.

2.2 Partner Program Data

If you apply to or participate in the WinGuardian.net Partner Program, we additionally collect: business profile information submitted during onboarding (company name, website, industry, company size, country, partnership model preferences, marketing channels, estimated referral volume, and technical integration preferences); your electronic agreement acceptance record, including your typed full legal name, the timestamp, and the IP address at the time of acceptance of the Partner Program Agreement; referral submissions (client names and contact information you provide when submitting a referral); your rolling 12-month Annual Referral Value (ARV) as calculated from approved referral data; and commission and payout records.

2.3 Referral Tracking

We use cookie-based tracking to attribute client referrals to Partners. When a prospective client visits the WINGUARDIAN.NET LLC platform via a Partner's unique referral link, a cookie is set on that visitor's browser (30-day persistence) to associate any subsequent engagement with the referring Partner. This is a core operational feature of the WinGuardian.net Partner Program.

3. How We Use Your Data

We use the data we collect to: provide and improve our services and the WinGuardian.net Partner Program; calculate, verify, and process commission payments; evaluate Partner tier eligibility on a rolling 12-month ARV basis; communicate with you about your account, applications, tier changes, and payouts; maintain a legally binding record of your agreement acceptance; comply with our legal obligations; and detect and prevent fraud or misuse of the Program.

4. AI and Data Sovereignty

Unlike standard SaaS providers, we prioritise Data Sovereignty. Data processed by our proprietary AI frameworks for client projects is siloed and never used to train, fine-tune, or improve public or foundational AI models without explicit, written consent. All client data remains the exclusive property of the client and is processed solely for service fulfilment. Partner data is used exclusively for Program administration.

5. Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Partner onboarding data and agreement records — including the electronic signature record comprising the typed name, timestamp, and IP address — are retained for a minimum of five (5) years from the date of acceptance to support legal, audit, and commission verification requirements. Commission and payout records are retained for seven (7) years for financial compliance purposes.

6. Data Sharing

We do not sell or share your personal data, as the terms 'sell' and 'share' are defined under California law. See our CCPA notice for detail. We may share data with: service providers who assist us in operating our platform (e.g., Supabase for database hosting, Resend for email delivery, and Google for website analytics) under appropriate data processing agreements; independent contractors engaged by WINGUARDIAN.NET LLC on client projects, who are bound by confidentiality obligations under our Data Processing Agreement; professional advisors (legal counsel, accountants) under duties of confidentiality; and law enforcement or regulatory authorities when required by law. Partner referral data may be shared internally between WINGUARDIAN.NET LLC teams to verify and process commission claims.

7. Your Rights

Under applicable data protection law (including GDPR and CCPA), you have the right to: access the personal data we hold about you; correct inaccurate data; request deletion of your data, subject to our legal retention obligations; object to or restrict our processing of your data; and data portability. To exercise any of these rights, contact us at legal@winguardian.net or by post at the address in the 'Who We Are' section above. For requests under the GDPR we will respond within one month, extendable by up to two further months for complex requests, and we will tell you if we need that extension. For requests under the CCPA we will confirm receipt within 10 business days and respond within 45 calendar days, extendable by a further 45 days with notice to you.

8. Cookies

We use essential cookies for authentication and session management, functional cookies to remember your preferences, third-party analytics cookies set by Google Analytics to understand how our website is used, and partner referral tracking cookies as described in Section 2.3. Analytics and referral cookies are non-essential. If you are visiting from the European Economic Area, the United Kingdom, or Switzerland we will not set them unless you consent. A full breakdown is available in our Cookie Policy.

8a. International Data Transfers

WINGUARDIAN.NET LLC is established in the United States, and our service providers are located in the United States. If you access our services from outside the United States, your personal data will be transferred to and processed in the United States, which may not provide the same level of data protection as your home country. Where we act as a processor for a client established in the European Economic Area or the United Kingdom, we put in place an appropriate transfer mechanism before any transfer begins. You may request details by writing to legal@winguardian.net.

9. Security

We implement industry-standard technical and organisational measures to protect your data, including encrypted connections (TLS), row-level security on all database tables, and access controls scoped to the minimum necessary privilege. Despite these measures, no system is completely secure; we encourage you to use strong, unique passwords and report any suspected breach to security@winguardian.net immediately.

10. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated to registered users and Partners by email or platform notification. The 'Last Updated' date at the top of this document reflects the most recent revision.