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Legal & Privacy

Your data.
Your terms.

Effective: April 1, 2025 Entity: Phipps Custom Solutions LLC Product: WingsGotYou Contact: [email protected]

1. Introduction

Phipps Custom Solutions LLC ("we," "us," or "our") operates the WingsGotYou service, available at WingsGotYou.com (the "Service"). WingsGotYou is an AI-powered telephone agent — Wing — that navigates automated phone systems (IVR systems) on behalf of our users.

This Privacy Policy describes how we collect, use, store, and protect your personal information when you use our Service. Please read this policy carefully. By using the Service, you agree to the practices described herein.

If you have any questions about this policy, please contact us at [email protected].

2. Who We Are

Data Controller: Phipps Custom Solutions LLC

Product Name: WingsGotYou

Website: WingsGotYou.com

Privacy Contact: [email protected]

3. Eligibility and Age Requirement

The Service is intended solely for users who are 18 years of age or older. By using the Service, you represent and warrant that you are at least 18 years old. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that a user is under 18, we will promptly terminate that account and delete any associated data.

4. Information We Collect

We collect information in the following categories:

4.1 Account and Registration Information

When you create an account, we collect:

4.2 Payment and Billing Information

To process subscription payments, we collect billing details including credit or debit card information and billing address. Payment card data is processed by our third-party payment processor and is not stored directly on our systems. We retain transaction records, subscription status, and billing history for account management and legal compliance purposes.

4.3 Call and Interaction Data

When you initiate a call through the Service, we collect and may store:

This data is used exclusively to complete your requested tasks and to maintain records of Service activity within your account.

4.4 Usage and Technical Data

We automatically collect certain technical information when you use the Service, including:

4.5 Communications

If you contact us for support or other inquiries, we retain the content of those communications and your contact information in order to respond and maintain records of our interactions.

5. How We Use Your Information

We use the information we collect for the following purposes:

We do not use your personal information for general marketing or advertising purposes. We never use your personal identifying information — such as your name, contact details, account profile, or any data that could identify you — to train AI or machine learning models. However, call recordings and transcripts may be used internally in anonymized and de-identified form to improve Wing's performance, refine our audio detection algorithms, detect scam activity, and train our staff and internal systems. Before any such use, personal identifying information is scrubbed from the data. Our focus is always on improving service quality — not on identifying individuals.

6. What We Do Not Do With Your Data

We want to be unambiguous about this:

7. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information. We share your data only in the limited circumstances described below:

7.1 Service Providers (Sub-Processors)

We work with trusted third-party companies that help us operate the Service. These companies act as service providers and are contractually required to process your data only as directed by us, solely for the purpose of delivering the Service, under appropriate confidentiality and security obligations. Categories of service providers include:

7.2 Legal Compliance and Safety

We may disclose your information if we believe in good faith that such disclosure is necessary to: (a) comply with applicable law, regulation, legal process, or governmental request; (b) enforce our Terms of Service; (c) protect the rights, property, or safety of Phipps Custom Solutions LLC, our users, or the public; or (d) detect, prevent, or address fraud or security issues.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or asset sale, your information may be transferred as part of that transaction. We will notify you via email or prominent notice on our website before your personal information becomes subject to a different privacy policy.

7.4 With Your Consent

We may share your information for any other purpose with your explicit prior consent.

8. Call Recording, Consent, & Legal Compliance

WingsGotYou places automated telephone calls on your behalf, which may result in the recording of those calls. Call recordings and transcripts may also be used by us for the following internal purposes:

Why we record: Recordings are used to improve Wing's performance, refine our audio detection and speech recognition algorithms, identify and protect against scam activity, and train our staff and internal systems. Before any recording or transcript is used for these purposes, all personal identifying information is scrubbed. Our focus is on improving service quality and safety — not on identifying the individuals involved in any call. Call recordings and transcripts are never sold or shared with third parties for any purpose.

You acknowledge and agree to the following:

9. Data Retention

9.1 Active Accounts

We retain your personal information for as long as your account is active or as needed to provide the Service. Specific retention periods:

9.2 Account Cancellation

If you cancel or close your account, we will retain your personal information for 12 months following the date of cancellation — to resolve billing disputes, comply with legal obligations, and respond to any legal claims. After this period, your data will be deleted or anonymized.

9.3 Legal Hold

We may retain certain data for a longer period if required by law or in connection with a legal proceeding, investigation, or regulatory requirement.

10. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards, including:

No method of transmission over the Internet is 100% secure. If you believe your account or data has been compromised, please contact us immediately at [email protected].

11. Your Rights and Choices

We honor the following rights for all users:

11.1 Access

You may request a copy of the personal information we hold about you by contacting us at [email protected].

11.2 Correction

If any of your personal information is inaccurate or incomplete, you may request that we correct or update it. Many account details can be updated directly from your account settings.

11.3 Deletion

You may request that we delete your personal information, subject to our retention obligations in Section 9 and applicable legal requirements.

11.4 Portability

You may request a copy of your call transcripts and account data in a machine-readable format.

11.5 Opt-Out of Communications

You may opt out of non-essential communications at any time via the unsubscribe link in any email or by contacting us directly. Transactional communications (billing receipts, security alerts) cannot be opted out of while your account is active.

11.6 Account Closure

You may close your account at any time through your account settings or by contacting us. Data is retained for 12 months post-closure per Section 9.2.

To exercise any of the above rights, contact us at [email protected]. We will respond within 30 days.

12. Notice to California Residents (CCPA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

12.1 Categories of Personal Information Collected

In the past 12 months, we have collected:

12.2 No Sale or Sharing of Personal Information

We do not sell your personal information, and we do not share your personal information with third parties for cross-context behavioral advertising. Opt-out rights related to the sale or sharing of personal information do not apply here — because we simply do not engage in those activities.

12.3 Your CCPA Rights

California residents have the right to:

To submit a CCPA request, email [email protected] with the subject line "California Privacy Request." We will verify your identity and respond within 45 days.

13. Cookies and Tracking Technologies

13.1 Types of Cookies We Use

13.2 Managing Cookies

You can control and manage cookies through your browser settings. Disabling essential cookies may prevent you from using certain features of the Service.

14. Third-Party Links and Services

The Service may contain links to third-party websites or services. This Privacy Policy applies solely to our Service. We are not responsible for the privacy practices or content of third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Effective Date" at the top of this page.

For material changes, we will provide notice via email to the address on your account or via a prominent notice within the Service at least 30 days prior to the effective date. Your continued use of the Service after that date constitutes acceptance of the updated policy.

16. Contact Us

Questions, concerns, or requests regarding this Privacy Policy? We're here.

Phipps Custom Solutions LLC

Privacy Inquiries: [email protec