Privacy Policy

This Privacy Policy applies to information processed through:

• mywingbook.com;
• WingBook™ applications and software;
• Customer and Authorized User accounts;
• childcare-management features;
• uploaded records and documents;
• optional integrations;
• customer support;
• sales and subscription administration; and
• related WingBook™ products and services.

WingBook™ is currently focused primarily on childcare providers located in New Hampshire. We may expand to additional jurisdictions and update this Privacy Policy as our geographic availability and legal obligations change.

WingBook™ handles information in different legal capacities depending on the circumstances.

Customer Data

Childcare providers use WingBook™ to manage information about their programs, children, families, staff, schedules, records, and operations.

For this information, the childcare provider generally determines why the information is collected and how it is used.

WingBook™ generally processes this information on the provider's behalf in order to deliver the WingBook™ Services.

WingBook™ Business Data

WingBook™ separately determines how certain information is used for WingBook™'s own legitimate business operations.

This may include:

• Customer account information;
• subscription information;
• sales inquiries;
• business contact information;
• support communications;
• application security information;
• technical telemetry;
• product usage information;
• website activity; and
• information necessary to administer WingBook™'s own business.

WingBook™'s role is determined by the actual processing activity and not merely by labels used in this Privacy Policy.

Customer

A "Customer" is a childcare provider or other organization that subscribes to or is otherwise authorized to use WingBook™.

Authorized User

An "Authorized User" is a person permitted to access WingBook™ through a Customer.

Authorized Users may include:

• owners;
• directors;
• administrators;
• teachers;
• staff;
• parents;
• guardians; and
• other individuals authorized by the Customer.

Customer Data

"Customer Data" means information submitted to, maintained in, generated through, or otherwise processed through WingBook™ on behalf of a Customer.

Customer Personal Data

"Customer Personal Data" means Customer Data that identifies or is reasonably capable of being associated with an individual.

Depending on the WingBook™ products and features being used, information may include:

• Provider and Account Information

This may include:

• name;
• business name;
• business address;
• email address;
• telephone number;
• account identifiers;
• role and permissions;
• authentication information;
• subscription information;
• payment status; and
• support history.

Parent and Guardian Information

This may include:

• names;
• addresses;
• email addresses;
• telephone numbers;
• family relationships;
• emergency contacts;
• authorized pickup information;
• communication preferences;
• account activity; and
• billing or account information where applicable.

Child Information

Customers may maintain information such as:

• name;
• date of birth;
• age;
• classroom;
• enrollment status;
• schedules;
• bookings;
• attendance;
• family relationships;
• authorized pickups;
• emergency contacts;
• care needs;
• classroom observations;
• learning observations;
• developmental observations; and
• progress information.

Children do not create or independently operate WingBook™ accounts.

Child profiles are created and managed by childcare providers or authorized adults.

Health and Safety Information

Depending on the features enabled, Customer Data may include:

• immunization records;
• health assessments;
• medical conditions;
• allergies;
• sensitivities;
• medications;
• medication authorizations;
• treatment or emergency plans;
• dietary restrictions;
• illness information;
• injury information; and
• other health and safety records.

Uploaded Documents

WingBook™ may process:

• enrollment forms;
• immunization records;
• health forms;
• medication records;
• emergency plans;
• custody documents;
• court documents;
• photographs;
• administrative records; and
• other documents uploaded by Customers or Authorized Users.

Usage and Technical Information

WingBook™ may collect:

• IP addresses;
• browser information;
• device information;
• operating-system information;
• login timestamps;
• feature usage;
• user actions;
• audit events;
• error reports;
• security events; and
• application-performance information.

WingBook™ is designed for childcare providers and authorized adults.

WingBook™ is not intended to be independently used by children.

Children may have profiles within WingBook™, but children do not create or operate WingBook™ accounts.

Child information is generally supplied or created by:

• childcare providers;
• parents;
• legal guardians;
• other authorized adults; or
• provider personnel acting in connection with childcare services.

WingBook™ does not sell children's personal information.

WingBook™ does not use identifiable children's health records, developmental records, classroom observations, or similar sensitive child information for advertising or retargeting.

Customers are responsible for providing legally required notices and obtaining required parental or guardian permissions for information the Customer directs WingBook™ to process, except where WingBook™ expressly assumes that responsibility in writing.

WingBook™ may process Customer Data as reasonably necessary to:

• provide WingBook™ features;
• host records and documents;
• authenticate users;
• maintain user permissions;
• schedule and manage childcare;
• maintain child and family information;
• support health and safety workflows;
• process documents;
• generate reports;
• administer integrations;
• provide support;
• troubleshoot technical issues;
• identify and repair errors;
• protect application security;
• prevent misuse and fraud;
• maintain audit records;
• comply with lawful requests;
• enforce agreements; and
• perform documented instructions from the applicable Customer.

WingBook™ may also use Customer Data internally where reasonably necessary, proportionate, and legally permitted to develop, test, repair, secure, and improve WingBook™ products and technology.

Where reasonably practicable, WingBook™ will use de-identified, aggregated, sampled, or minimized information for product-development activities rather than identifiable child or family records.

WingBook™ will not use identifiable child health information or similar sensitive child records for unrelated marketing.

WingBook™ may create de-identified or aggregated information from Customer Data and other information processed through the Services.

WingBook™ may use de-identified or aggregated information for lawful purposes including:

• product development;
• analytics;
• research;
• service improvement;
• testing;
• benchmarking;
• industry analysis;
• trend analysis;
• business planning;
• marketing insights; and
• development of future products.

When WingBook™ maintains information as de-identified, WingBook™ will:

• take reasonable measures to prevent association with an identifiable individual;
• maintain the information in de-identified form;
• not attempt to reidentify it except where legally permitted to test de-identification protections; and
• require recipients of de-identified information to maintain appropriate protections where required by law.

De-identified information may be retained after the underlying identifiable Customer Data is deleted.

WingBook™ may use adult business contact information and provider account information to market WingBook™ products and services to Customers and prospective Customers.

WingBook™ may use information about a childcare provider's use of WingBook™ to recommend additional WingBook™ functionality to that provider.

WingBook™ will not use a parent's contact information obtained solely through a childcare provider's Customer Data to independently market unrelated WingBook™ products to the parent unless the parent has separately requested, consented to, or otherwise permitted those communications.

WingBook™ does not use identifiable child information to select advertising.

If WingBook™ later introduces cross-site targeted advertising or advertising pixels that create additional privacy obligations, WingBook™ will update its disclosures and provide legally required privacy choices before implementing that processing.

Some WingBook™ functionality may use artificial intelligence, machine learning, optical character recognition, or other automated technologies.

AI-assisted features may help with:

• document extraction;
• immunization record review;
• health-record organization;
• identification of potentially incomplete records;
• document summaries;
• mock inspection workflows;
• administrative summaries;
• observations and progress reports;
• regulatory organization;
• customer support; and
• other administrative functions.

WingBook™ currently uses OpenAI for certain AI functionality and may use additional AI providers in the future.

WingBook™ uses API-based services configured so that Customer Data is not used to train general-purpose OpenAI models unless WingBook™ expressly elects a different arrangement and provides any legally required notice or consent.

Depending on the service configuration and feature used, an AI service provider may retain limited information for security, abuse prevention, or service-operation purposes.

AI output may be incomplete, inaccurate, or inappropriate for a particular situation.

AI-assisted features do not replace:

• childcare-provider judgment;
• medical advice;
• diagnosis;
• professional developmental evaluation;
• legal advice;
• regulatory advice;
• official licensing determinations; or
• state inspections.

Customers remain responsible for reviewing AI-assisted results before relying upon them.

WingBook™ may provide tools allowing childcare professionals to document learning, milestones, development, classroom observations, or progress.

These tools are intended for childcare and educational communication purposes.

They are not medical, psychological, developmental, therapeutic, or diagnostic assessments.

WingBook™ does not diagnose developmental delays, disabilities, medical conditions, or psychological conditions.

WingBook™ may provide:

• Quality Score or similar metrics;
• mock inspections;
• regulatory summaries;
• licensing checklists;
• compliance dashboards; and
• other self-assessment tools.

These tools are informational.

They are not official determinations by any government or licensing authority.

A WingBook™ score, checklist, assessment, or mock inspection:

• does not guarantee regulatory compliance;
• does not guarantee childcare quality;
• does not predict an inspection result;
• does not represent approval by the State of New Hampshire or another government agency; and
• does not replace professional or legal advice.

WingBook™ may use de-identified and aggregated information from these tools to improve WingBook™ and understand industry trends.

WingBook™ will not publicly identify a Customer with a particular Quality Score or negative assessment for WingBook™ marketing without the Customer's authorization, except where the Customer has itself made the information public.

WingBook™ may allow users to connect optional third-party services such as Google Calendar.

Connecting an integration is voluntary.

When Google Calendar functionality is enabled, WingBook™ may request only permissions reasonably necessary to provide the feature selected by the user.

Depending on the feature, WingBook™ may:

• identify the connected Google account;
• display the connection status;
• create WingBook™-related calendar events;
• update those events when WingBook™ information changes;
• synchronize applicable booking information; or
• provide reminders.

WingBook™ does not use Google Calendar information for:

• advertising;
• retargeting;
• creditworthiness determinations;
• unrelated marketing;
• building unrelated consumer profiles; or
• unrelated AI training.

WingBook™ does not use Google Calendar authorization to access Gmail, Google Drive, Google Contacts, or unrelated Google services unless a future feature expressly requests that permission and the user affirmatively authorizes it.

WingBook™'s use of information obtained through Google APIs will comply with applicable Google API Services User Data Policy requirements.

Users may revoke or disconnect supported integrations.

WingBook™ uses Stripe to process subscription payments.

Stripe may process:

• payment card information;
• bank account information;
• billing details;
• transaction information;
• fraud-prevention information; and
• payment status.

WingBook™ does not directly store complete payment-card or bank-account numbers.

WingBook™ may receive information necessary to determine:

• whether payment was completed;
• invoice status;
• subscription status;
• entitlements;
• transaction identifiers; and
• limited billing information.

WingBook™ uses service providers to support:

• hosting and infrastructure;
• authentication;
• payment processing;
• customer relationship management;
• artificial intelligence;
• application monitoring;
• communications; and
• related technical functions.

Current providers are identified on WingBook™'s Subprocessors page.

A particular provider does not necessarily receive every category of Customer Data.

WingBook™ seeks to limit information disclosed to each service provider to information reasonably necessary for that provider's function.

Authorized WingBook™ personnel may access Customer accounts or Customer Data when reasonably necessary to:

• provide support;
• investigate reported problems;
• repair data or account issues;
• investigate security incidents;
• maintain the platform;
• respond to lawful requests; or
• protect WingBook™ or its users.

Administrative access is limited to legitimate business purposes.

WingBook™ uses administrative, technical, and organizational safeguards designed to protect information appropriate to its sensitivity.

Current protections may include:

• secure authentication;
• role-based permissions;
• access controls;
• encrypted network connections;
• encryption provided by hosting and database infrastructure;
• separation of user roles;
• audit logging for supported activities;
• infrastructure monitoring; and
• restricted administrative access.

WingBook™ currently uses Replit infrastructure and Clerk-based authentication.

No online system is completely secure.

WingBook™ does not promise a specific uptime level, recovery time, backup schedule, or recovery-point objective unless agreed in writing.

WingBook™ retains identifiable Customer Data only for as long as reasonably necessary for the purposes for which it is being processed, subject to Customer instructions, legal requirements, security obligations, dispute resolution, and applicable contractual requirements.

Customers are responsible for maintaining records required by childcare licensing laws.

WingBook™ should not be relied upon as a permanent legal archive after a Customer's subscription ends.

Unless otherwise agreed, WingBook™ may make Customer Data available for export for up to 60 days following termination or expiration of a Customer subscription.

After that period, WingBook™ may delete or de-identify remaining Customer Data unless:

• retention is required by law;
• retention is necessary to establish or defend a legal claim;
• the Customer has purchased or entered into a separate archival arrangement; or
• limited residual copies remain temporarily in infrastructure backups or technical systems pending normal deletion cycles.

WingBook™ may retain de-identified or aggregated information for longer periods.

Customers may request a reasonable export of Customer Data by contacting:

hello@mywingbook.com

Customers should request and preserve records they are legally required to maintain before their post-termination export period expires.

The available export format may depend on the nature of the records and technical feasibility.

Individuals may contact WingBook™ regarding:

• access;
• correction;
• deletion;
• export;
• consent;
• marketing preferences; or
• other privacy questions.

Requests may be sent to:

hello@mywingbook.com

When WingBook™ processes the information on behalf of a childcare provider, WingBook™ may direct the individual to that provider.

WingBook™ will reasonably assist Customers with legally required privacy requests.

WingBook™ will not delete provider-controlled childcare records in response to a direct request from an Authorized User when doing so would conflict with the Customer's lawful instructions, regulatory obligations, or applicable law.

Where New Hampshire's consumer privacy law applies, eligible consumers may have rights to:

• confirm whether their personal data is being processed;
• access their personal data;
• correct inaccuracies;
• request deletion;
• obtain a portable copy;
• opt out of certain targeted advertising;
• opt out of certain sales of personal data;
• opt out of certain automated profiling;
• revoke applicable consent; and
• appeal certain privacy-request decisions.

A parent or legal guardian may exercise applicable rights concerning a known child.

Where applicable, WingBook™ will respond within the periods required by law.

A privacy appeal may be submitted to hello@mywingbook.com with the subject line "Privacy Appeal."

If a legally required appeal is denied, WingBook™ will provide information concerning any further rights available under applicable law.

WingBook™ may use cookies and similar technologies necessary to:

• authenticate users;
• maintain sessions;
• remember preferences;
• operate the website;
• secure accounts; and
• understand technical performance.

WingBook™ may introduce additional analytics or marketing technologies as the business grows.

Before introducing processing that materially changes our privacy practices, we will update applicable notices and implement legally required privacy controls.

WingBook™ maintains procedures intended to identify, investigate, contain, and respond to security incidents.

If WingBook™ discovers unauthorized acquisition of Customer Personal Data requiring notice under applicable law or contract, WingBook™ will notify the applicable Customer as required and cooperate in addressing the incident.

Information may be transferred in connection with:

• a merger;
• acquisition;
• financing;
• reorganization;
• sale of assets;
• bankruptcy; or
• similar corporate transaction.

Any successor will remain subject to applicable legal obligations concerning the information transferred.

WingBook™ may update this Privacy Policy as its products, vendors, technology, business practices, or legal obligations change.

The current version will be posted with a revised "Last Updated" date.

Material changes may also be communicated by email, in-product notification, or another reasonable method.

Where applicable law requires new consent for a materially different use of personal information, continued use of WingBook™ alone will not substitute for that consent.

WingBook LLC

hello@mywingbook.com