Wingspan Innovative Technologies

 

PRIVACY POLICY

Effective Date: July 20, 2025

 

  1. Scope
    This Privacy Policy outlines our commitment to the lawful collection, processing, storage, disclosure, and protection of personal data in compliance with the Personal Data Protection Act (Cap. 44), the Personal Data Protection (Complaints Settlement Procedures) Regulations, 2023, and all applicable directives of the Tanzania Communications Regulatory Authority (TCRA).

 

 

  1. Data We Collect
    • First Name, Last Name,
    • Contact information including email address, phone number, Country, City.
    • Mobile identifiers, subscription and payment history.
    • IP address, device identifiers, operating system, and browser type.
    • User activity logs, course progress, and support correspondence.

 

  1. Legal Grounds for Processing

Personal data is processed lawfully and fairly on the following legal bases:

3.1 The data subject has provided explicit and informed consent.

3.2 Processing is necessary for the performance of a contract (subscription).

3.3 Processing is required to comply with legal obligations under Tanzanian law.

3.4 Processing is necessary for the legitimate interests of Wingspan in improving user experience, ensuring platform security, and evaluating service performance.

 

 

  1. Data Sharing

Personal data may be shared under strict controls with:

  • Designated payment service providers for transaction processing and reconciliation.
  • Technology providers hosting our systems under data processing agreements.
  • Governmental, regulatory, or enforcement authorities upon lawful request.
  • Legal advisors, auditors, or compliance consultants bound by confidentiality.

           Under no circumstances will Wingspan sell or lease your personal data to third parties.

 

  1. Data Security and Storage

We implement technical and organizational measures to ensure the confidentiality, integrity, and availability of data, including:

5.1 End-to-end encryption of data in transit and at rest.

5.2 Secure access controls with user authentication protocols.

5.3 Regular vulnerability testing and system audits.

5.4 Role-based access to personal data and data minimization principles.

 

  1. User Rights

You have the following rights under the Personal Data Protection Act:

6.1 Right to be informed about the purpose and legal basis of data processing.

6.2 Right to access and request copies of your personal data.

  • Right to rectification of inaccurate or outdated data.
  • Right to erasure where processing is no longer lawful.
  • Right to restrict or object to specific types of processing.

        6.6 Right to file a complaint with the Personal Data Protection Commission.

To exercise your rights, contact us at: info@wit.or.tz.

 

 

  1. Cross-Border Data Transfers

We do not transfer personal data outside of Tanzania unless:

  • The recipient jurisdiction provides adequate data protection.
  • The data subject has provided explicit written consent; or
  • The transfer is necessary for the performance of a lawful contract.

 

  1. Retention and Disposal

We retain personal data only as long as necessary for the lawful purpose it was collected:

  • Transaction and financial records: 10 years (for statutory compliance).
  • Course progress and certification records: 6 years.
  • Support and communication logs: 2 years.
  • Personal data is securely deleted or anonymized upon expiry of the retention period.

 

  1. Breach Notification

In the event of a data breach, Wingspan shall notify the Personal Data Protection Commission and affected users within 72 hours, outlining:

  • Nature and extent of the breach.
  • Data categories affected.
  • Likely consequences.
  • Mitigation steps taken.

 

 

  1. Breach Notification

Wingspan reserves the right to revise this Privacy Policy as required by law or organizational change. Users will be notified through email and platform notices of material updates at least fourteen (14) days before enforcement.