Privacy Policy
This Privacy Policy explains how Wingman (Pty) Ltd (“Wingman”, “we”, “us” or “our”) collects, uses, shares and protects your personal information when you use our platform at www.onwingman.com (the “Platform”) or otherwise deal with us. Wingman is a recruitment business: we match candidates with organisations that are hiring. Please read this Policy together with any other notice we give you when we collect your information.
We are based in South Africa and provide our services to natural and juristic persons in several countries. This Policy is intended to explain our privacy practices in a way that is consistent with the Protection of Personal Information Act, 2013 (POPIA) in South Africa and, where applicable, the data-protection laws of the United Kingdom, the United States, Australia and New Zealand. The country-specific sections near the end of this Policy set out the additional information and rights that may apply depending on where you are situated.
1. About this Policy and who it applies to
1.1 Who we are. Wingman operates the Platform and provides recruitment and talent services. For most processing described in this Policy, Wingman is the “responsible party” (also called the data controller) for the personal information described in this Policy. In some limited cases, we may process information on behalf of a client under that client’s instructions, in which case we may act as an operator or processor. Our registered office is 222 Bowling Avenue, Woodmead, Johannesburg, 2191, South Africa, and you can contact us about privacy at privacy@onwingman.com.
1.2 Who this Policy applies to. In this Policy, “you” means any individual whose personal information we handle, namely:
• candidates – people who register on, or are sourced for, the Platform to be considered for roles;
• client and company representatives – individuals at organisations that use Wingman to hire;
• partners – individuals at organisations we work with; and
• applicants – people who apply for a role at Wingman itself.
1.3 “Personal information” (also called personal data) means information that identifies or relates to you. “Sensitive information” (also called special personal information or special-category data) means more sensitive categories such as race or ethnic origin, health, biometric and criminal-history information. “Process” means anything we do with personal information, such as collecting, storing, using, sharing or deleting it.
2. The personal information we collect
2.1 We collect only the information we need for the purposes set out in section 4. What we collect depends on how you deal with us.
2.2 Candidates. Identity and contact details (name, email address, phone number, location); profile and professional information (CV, work history, education, qualifications, skills, languages, salary expectations, notice period, eligibility or right to work, and professional links such as LinkedIn); assessment results, where applicable; application and placement information (the roles you are matched to or submitted for, the recruitment stage, relevant dates, salary offered and start date); and your communications with us.
2.3 Client and company representatives. Name, work contact details, job title and organisation, your hiring requirements, and a record of our dealings with you.
2.4 Partners. Name, business contact details, organisation, and details of our working relationship.
2.5 Applicants for roles at Wingman. The same kinds of information as candidates, together with the role you apply for and related application information.
2.6 Sensitive information. We collect certain more sensitive information only in defined circumstances and, where the law requires, with your consent:
• Diversity information, including race or ethnic origin – we collect this from candidates to support fair recruitment and employment-equity reporting for our clients. Providing it is voluntary and based on your consent; you may decline or withdraw consent at any time without affecting your use of the Platform. We do not use this information to match you to roles or to make decisions about you.
• Background-screening information, including criminal-history information – only where a hiring organisation requires it for a specific role, and with your consent. This may be collected by a screening provider (such as MIE).
• Biometric information, such as facial verification – only where a hiring organisation requires it for a specific role, and with your consent.
• Identity and right-to-work documents, such as ID or passport numbers – only where required for a specific role or to verify your identity or eligibility to work, to comply with legal or client requirements and with your consent.
2.7 We do not ordinarily request or collect health or disability information. If you choose to provide it, or if it is required for reasonable accommodation, legal compliance or a specific requirement process, we will process it only where permitted by law and with appropriate safeguards.
3. Where we get your personal information
3.1 Directly from you – when you register, build your profile, apply, or communicate with us.
3.2 From other sources – in particular:
• business contact-data, sourcing and professional-networking providers (such as ZoomInfo, Lusha, Apollo and LinkedIn Sales Navigator), which we use to identify potential candidates and client contacts;
• background-screening providers (such as MIE), where screening is required for a role;
• people you nominate as referees, and references they provide;
• hiring organisations, which may share information about you in connection with a role; and
• publicly available sources, such as professional networking profiles.
3.3 Where we obtain your information from a source other than you, we take reasonable steps to make you aware of it, as the law requires.
4. How and why we use your personal information
4.1 We use your personal information for the purposes set out below. Where the law requires us to have a lawful basis (or “justification”) for using your information, the table sets out the basis we rely on.
5. Automated processing and recommendations
5.1 We use automated tools, including machine learning and third-party artificial-intelligence services, to help us carry out an initial qualification of candidates and to recommend roles and opportunities.
5.2 These tools support our team and platform processes; they do not make final hiring, employment or placement decisions about you on their own. Where an automated output materially affects whether you are introduced to a hiring organisation or progressed in a recruitment process, we use appropriate human review.
5.3 We do not use your diversity information (such as race or ethnic origin) in this automated qualification or in matching.
5.4 You can ask us how this works, ask a person to review an outcome, give us your point of view, or object to this processing, by contacting privacy@onwingman.com. If in future we introduce decisions made solely by automated means that significantly affect you, we will tell you and explain the additional rights that then apply.
6. Marketing communications
6.1 Service messages. We send messages that are necessary or reasonably related to providing the service - for example, account notifications, platform updates, role matches, assessment links, interview coordination or introductions These are not marketing.
6.2 Electronic marketing. We send marketing by electronic means (such as email and WhatsApp) only where you have consented. Every marketing message includes a way to opt out, and we honour opt-outs across all channels.
6.3 Introductory contact. Where we obtain your contact details from another source and you have not registered, we may contact you where permitted, including to ask whether you wish to receive further communications or join the Platform. If you object, opt out or do not provide your consent, we will not send you further electronic marketing unless we later have another lawful basis to contact you.
6.4 Channels and preferences. We use Odoo’s email tools and WhatsApp to communicate; WhatsApp messages are also subject to WhatsApp’s own terms. You can change your preferences or opt out at any time through the message or by contacting privacy@onwingman.com.
7. How we share your personal information
7.1 With hiring organisations. We do not make your profile openly searchable. We match you to roles and only share your information with a particular hiring organisation once you have agreed to be introduced to that organisation. Introductions are made by email or through the Platform, depending on the organisation’s preference.
7.2 With our service providers. We use trusted providers to help us run the Platform and our business, under contracts that require them to protect your information and use it only on our instructions and for authorised purposes. They include, but are not limited to, providers of cloud hosting and infrastructure, the recruitment platform, artificial-intelligence and machine-learning services, communications and messaging, analytics and advertising, software development tools, and background screening. Our key providers include Google Cloud, Odoo, Namecheap, GitHub, Anthropic, Google (Gemini), WhatsApp and MIE.
7.3 With professional advisers, such as our lawyers, auditors and insurers, where needed.
7.4 Where required or permitted by law, such as to regulators, courts or authorities, to protect rights and safety, or in connection with a corporate transaction such as a merger or sale of the business.
7.5 We do not sell your personal information, and we do not share it for cross-context behavioural (targeted) advertising.
8. International transfers of your information
8.1 Because we are based in South Africa and use reputable cloud and service providers that operate globally, your personal information may be stored or processed in countries other than your own, including outside South Africa, the United Kingdom, the European Economic Area, Australia, New Zealand and the United States.
8.2 Whenever we transfer personal information across borders, we take steps required by applicable laws to protect it - for example, using providers that are bound by appropriate contractual protections (such as standard contractual clauses), or that operate in countries recognised as providing an adequate level of protection, or where the transfer is necessary to provide our service to you or is made with your consent.
8.3 You can ask us for more information about these safeguards by contacting privacy@onwingman.com.
9. How long we keep your information
9.1 We keep personal information only for as long as we need it for the purposes in this Policy and to meet legal, tax and regulatory requirements.
9.2 Candidates. We generally keep your information for up to five years from our last meaningful interaction with you. At that point, we will ask whether you wish to remain on our database; if you do not confirm, we will delete or anonymise your information.
9.3 Applicants for roles at Wingman who are not successful: we keep your application for up to 12 months, unless you remain registered as a candidate or ask us to keep it for future roles.
9.4 Client and partner contacts. We keep your information for the duration of our relationship and for a reasonable period afterwards, as needed for our legitimate business and legal purposes.
9.5 We may keep certain information for longer where the law requires it, for example records needed for tax or to establish, exercise or defend legal claims.
10. How we protect your information
10.1 We take appropriate technical and organisational measures to protect personal information against loss, misuse and unauthorised access, disclosure or alteration. These include access controls, encryption of information in transit, and contractual protections with our service providers.
10.2 No system can be completely secure. We work to protect your information and to respond appropriately if a security breach occurs, including notifying you and the relevant regulator where the law requires.
11. Cookies and similar technologies
11.1 Our website and Platform use cookies and similar technologies. Cookies are small files placed on your device that help the site work and help us understand how it is used.
11.2 We use strictly necessary cookies (needed for the site to function and stay secure); analytics cookies (Google Analytics), to understand and improve how the site is used; and advertising cookies (Google Ads), to measure and support our advertising.
11.3 Where the law requires (for example in the United Kingdom and the European Economic Area), we ask for your consent before setting non-essential cookies, and you can withdraw your consent at any time. You can also control cookies through your browser settings and through Google’s opt-out tools for Google Analytics and Google Ads. Where the law requires, we honour recognised opt-out signals such as Global Privacy Control.
12. Your privacy rights
12.1 Depending on where you are, you have rights over your personal information, which may include the right to access it, to have it corrected or deleted, to object to or restrict its use, to data portability, to withdraw consent, to opt out of marketing, and to complain to a regulator. The country-specific sections below set out the rights that apply to you.
12.2 To exercise your rights, contact privacy@onwingman.com. We may need to verify your identity. We respond within the time the applicable law requires, and we do not charge unless the law allows.
13. Children
13.1 The Platform is intended for users aged 18 and over and is not directed at children. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected a child’s personal information without the required legal basis, we will delete it or take other appropriate steps.
14. Changes to this Policy
14.1 We may update this Policy from time to time. We will post the updated version here with a new effective date and, where changes are significant, take reasonable steps to bring them to your attention.
15. How to contact us and how to complain
15.1 You can contact us, including our Information Officer, at privacy@onwingman.com, or by writing to Wingman (Pty) Ltd, 222 Bowling Avenue, Woodmead, Johannesburg, 2191, South Africa.
15.2 If you have a concern, please contact us first so that we can try to resolve it. You also have the right to complain to the data-protection authority that applies to you, as set out in the country-specific sections below.
Country-specific sections
The following sections give additional information and rights depending on where you are. Where a country-specific section gives you more than the general sections above, that additional protection applies to you.
16. South Africa – Protection of Personal Information Act (POPIA)
16.1 We are the responsible party for your personal information. Our Information Officer can be contacted at privacy@onwingman.com.
16.2 Under POPIA you have the right to be notified that we collect your information; to access it; to ask us to correct or delete it; to object to processing on reasonable grounds; not to be subject, in certain circumstances, to a decision based solely on automated processing; not to receive unsolicited electronic direct marketing except as allowed by section 69; to complain to the Information Regulator; and to institute civil proceedings.
16.3 You may complain to the Information Regulator (South Africa): JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 (PO Box 31533, Braamfontein, 2017); telephone 010 023 5200; complaints: POPIAComplaints@inforegulator.org.za; general enquiries: enquiries@inforegulator.org.za.
16.4 Our PAIA Manual explains how you can request access to records we hold.
17. United Kingdom – UK GDPR and Data Protection Act 2018
17.1 Where the UK GDPR applies to our processing of your information, we rely on the lawful bases set out in section 4.
17.2 You have the right to access your information; to have it rectified or erased; to restrict or object to its use (including objecting to direct marketing and to processing based on our legitimate interests); to data portability; to withdraw consent; and rights in relation to automated decision-making.
17.3 If you are unhappy with how we handle your information, you have the right to complain to us at privacy@onwingman.com, and we will acknowledge and respond to your complaint. You also have the right to complain to the Information Commissioner’s Office (ICO): www.ico.org.uk; telephone 0303 123 1113; Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom.
18. United States – California and other state privacy laws
18.1 This section applies where a US state privacy law applies to our processing of your personal information. Some US privacy laws apply only to businesses that meet specific thresholds or carry out particular activities. Where a US privacy law does not apply, we may still choose to respond to reasonable privacy requests in line with this Policy, but this does not mean that we are subject to that law in every case.
18.2 In the past 12 months we have collected the following categories of personal information, from the sources in section 3, for the purposes in section 4, and disclosed them to the categories of recipient in section 7: identifiers; customer-records information; professional or employment-related information; education information; internet and other electronic activity; approximate geolocation; inferences; and sensitive personal information (racial or ethnic origin, and – where collected for a specific role – government identifiers, biometric information and criminal-history information).
18.3 We do not sell, and do not share for cross-context behavioural advertising, personal information, and have not done so in the past 12 months. We do not use or disclose sensitive personal information for purposes beyond those permitted by law.
18.4 Subject to the law of your state, you have the right to know about and access your personal information; to delete it; to correct it; to opt out of its sale or sharing (which we do not do); to limit the use of sensitive personal information; to opt out of certain automated decision-making or profiling; not to be discriminated against for exercising your rights; and to appeal a decision on your request. You may use an authorised agent, and we honour Global Privacy Control where the law requires. To exercise your rights, contact privacy@onwingman.com.
18.5 Background checks. Where we arrange a background check through a consumer reporting agency, we provide the disclosures and obtain the authorisations required by the Fair Credit Reporting Act, and follow its adverse-action process.
18.6 Biometric information (Illinois). Where we collect biometric information and a biometric privacy law applies, including the Illinois Biometric Information Privacy Act, we will provide any required notice, obtain any required consent, and follow applicable retention and deletion practices.
19. Australia – Privacy Act 1988 and Australian Privacy Principles
19.1 This section applies to individuals in Australia to the extent the Privacy Act applies to us. You have the right to access and correct your personal information, to opt out of direct marketing, and to complain.
19.2 As explained in section 8, your information may be disclosed to, and stored by, our service providers in countries outside Australia. Section 5 explains our use of automated processing and recommendations. Where practicable, the countries in which overseas recipients are likely to be located include South Africa, United Kingdom, the United States and countries where our cloud, communications and technology providers operate.
19.3 If you have a concern, please contact us first at privacy@onwingman.com. You may also complain to the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au; telephone 1300 363 992; GPO Box 5288, Sydney NSW 2001, Australia.
20. New Zealand – Privacy Act 2020
20.1 This section applies to individuals in New Zealand. You have the right to access and correct your personal information and to complain.
20.2 Where we collect your information from someone other than you (see section 3), we take reasonable steps to make you aware of it, as required by Information Privacy Principle 3A. Where we transfer your information overseas (see section 8), we take steps so that it remains protected.
20.3 If you have a concern, please contact us first at privacy@onwingman.com. You may also complain to the Office of the Privacy Commissioner: www.privacy.org.nz; telephone 0800 803 909; PO Box 10094, Wellington 6143, New Zealand.