PRIVACY POLICY

 

Effective Date: July 20, 2025

1. Scope

This Privacy Policy explains how Wingspan Innovative Technologies (“Wingspan,” “we,” “our,” or “us”) collects, uses, processes, stores, discloses, and protects personal data in compliance with the Personal Data Protection Act (Cap. 44), the Personal Data Protection (Complaints Settlement Procedures) Regulations, 2023, and applicable directives issued by the Tanzania Communications Regulatory Authority (TCRA) and other competent authorities.

This Policy applies to all users of our website, learning platforms, digital services, mobile applications, and related support channels.

2. Personal Data We Collect

We may collect and process the following categories of personal data:

2.1 Identity Data

  • First name and last name

2.2 Contact Data

  • Email address
  • Phone number
  • Country and city of residence

2.3 Account and Transaction Data

  • Subscription details
  • Payment history
  • Billing-related records

2.4 Technical Data

  • IP address
  • Device identifiers
  • Browser type
  • Operating system
  • Login timestamps and access logs

2.5 Usage Data

  • Course enrollment and progress
  • Assessment results
  • Platform activity logs
  • User preferences and interactions

2.6 Communication Data

  • Support requests
  • Feedback
  • Email and other correspondence with Wingspan

3. Legal Grounds for Processing

We process personal data lawfully, fairly, and transparently on the following grounds:

3.1 Consent
Where the data subject has given explicit, informed, and voluntary consent.

3.2 Contractual Necessity
Where processing is necessary for the performance of a contract, including subscriptions, course delivery, certification, and support services.

3.3 Legal Obligation
Where processing is required to comply with applicable laws, regulations, lawful requests, tax obligations, or compliance requirements.

3.4 Legitimate Interests
Where processing is necessary for Wingspan’s legitimate interests, including:

  • Improving platform performance and user experience
  • Maintaining security and fraud prevention
  • Monitoring service quality
  • Conducting internal reporting and analytics

4. Purpose of Processing

We use personal data for the following purposes:

  • To create and manage user accounts
  • To deliver educational content and services
  • To process subscriptions and payments
  • To communicate with users regarding services, support, and updates
  • To improve system functionality, performance, and security
  • To generate certificates, reports, and learner records
  • To comply with legal and regulatory obligations

5. Data Sharing and Disclosure

Personal data may be shared only where necessary and under appropriate safeguards with:

  • Payment service providers for payment processing and reconciliation
  • Technology and hosting providers acting under binding data processing agreements
  • Governmental, regulatory, or law enforcement authorities where required by law
  • Legal advisors, auditors, and compliance consultants under strict confidentiality obligations

Wingspan does not sell, trade, or lease personal data to third parties.

6. Data Security and Storage

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure, including:

6.1 Encryption of personal data in transit and, where applicable, at rest
6.2 Secure authentication and access control measures
6.3 Role-based access restrictions
6.4 Regular system monitoring, vulnerability assessments, and audits
6.5 Data minimization and need-to-know access principles
6.6 Secure storage and backup procedures

7. Rights of Data Subjects

Under applicable data protection law, you may have the right to:

7.1 Be informed about the collection and use of your personal data
7.2 Access your personal data and request a copy
7.3 Request correction of inaccurate, incomplete, or outdated personal data
7.4 Request deletion of personal data where processing is no longer lawful or necessary
7.5 Object to or restrict certain forms of processing
7.6 Withdraw consent where processing is based on consent
7.7 Lodge a complaint with the relevant Personal Data Protection authority or Commission

To exercise any of these rights, please contact us at: info@wit.or.tz

8. Cross-Border Data Transfers

Wingspan does not transfer personal data outside Tanzania unless one or more of the following conditions apply:

  • The receiving country or entity provides an adequate level of data protection
  • The data subject has given explicit written consent
  • The transfer is necessary for the performance of a lawful contract
  • The transfer is otherwise permitted or required by applicable law

Where cross-border transfers occur, appropriate safeguards will be implemented.

9. Data Retention and Disposal

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal, contractual, and regulatory obligations.

Typical retention periods include:

  • Transaction and financial records: 10 years
  • Course progress and certification records: 6 years
  • Support and communication records: 2 years

Upon expiry of the applicable retention period, personal data will be securely deleted, destroyed, or anonymized.

10. Breach Notification

In the event of a personal data breach, Wingspan will take appropriate response measures and, where required by law, notify the relevant authority and affected data subjects within the legally prescribed timeframe.

Such notification may include:

  • The nature and scope of the breach
  • Categories of personal data affected
  • Likely consequences of the breach
  • Steps taken or proposed to mitigate risks and prevent recurrence

11. Cookies and Similar Technologies

Our website and digital platforms may use cookies and similar technologies to improve functionality, analyze usage, remember preferences, and enhance user experience.

Users may control cookies through browser settings, although disabling certain cookies may affect platform functionality.

12. Children’s Privacy

Where our services are accessed by minors or students under the age of majority, personal data will be processed in accordance with applicable legal requirements and, where necessary, with parental, guardian, or institutional authorization.

13. Changes to This Privacy Policy

Wingspan reserves the right to update or revise this Privacy Policy from time to time to reflect legal, regulatory, operational, or organizational changes.

Where material changes are made, users will be notified through appropriate channels, including email or platform notices, at least fourteen (14) days before such changes take effect, unless a shorter period is required by law.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact:

Wingspan Innovative Technologies
Email: info@wit.or.tz
Website: https://wit.or.tz