Privacy Policy

1. Introduction

At WNGUARDIAN.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 Partner Program.

2. Data We Collect

2.1 General Platform Data

When you use the WNGUARDIAN.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 (IP address, browser type, device information) collected automatically via cookies and analytics.

2.2 Partner Program Data

If you apply to or participate in the WinGuardian 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 WNGUARDIAN.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 Partner Program.

3. How We Use Your Data

We use the data we collect to: provide and improve our services and the WinGuardian 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 your personal data. We may share data with: service providers who assist us in operating our platform (e.g., Supabase for database hosting, Resend for email delivery) under appropriate data processing agreements; independent contractors engaged by WNGUARDIAN.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 WNGUARDIAN.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. We will respond within 30 days.

8. Cookies

We use essential cookies for authentication and session management, functional cookies to remember your preferences, and partner referral tracking cookies as described in Section 2.3. A full breakdown of cookies used is available in our Cookie Policy.

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.