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Privacy Policy

Your privacy and discretion are fundamental to our service. This policy outlines how we protect, collect, and use your information.

Last updated: December 2024

Overview

Wheels Up ("we," "our," or "us") is committed to protecting the privacy and confidentiality of our members. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use our exclusive matchmaking service.

Given the sensitive nature of our service and our high-net-worth clientele, we maintain the highest standards of data protection and discretion.

Information We Collect

Personal Information

  • • Full name, age, location, and contact information
  • • Professional details including company, title, and income verification
  • • Educational background and credentials
  • • Relationship preferences and lifestyle information
  • • Professional photographs and personal images

Financial Information

  • • Income verification and financial statements
  • • Net worth documentation
  • • Payment processing information (processed securely through Stripe)
  • • Tax and employment verification documents

Background Check Information

  • • Criminal background check results (CORI)
  • • Sex offender registry verification (SORI)
  • • Credit check information
  • • Employment and education verification
  • • Personal and professional references

Technical Information

  • • Device information and IP addresses
  • • Usage data and platform interactions
  • • Authentication logs and security events
  • • Communication metadata (not content)

How We Use Your Information

Primary Purposes

  • • Verify member eligibility and authenticity
  • • Conduct comprehensive background screening
  • • Create detailed member profiles
  • • Facilitate compatible matching algorithms
  • • Provide personalized relationship consulting
  • • Process membership payments securely

Service Enhancement

  • • Improve matching accuracy and quality
  • • Enhance platform security and fraud prevention
  • • Provide customer support and consultation
  • • Analyze service effectiveness and member satisfaction
  • • Ensure compliance with legal requirements
  • • Maintain audit trails for security purposes

Information Sharing and Disclosure

Strict Non-Disclosure

We DO NOT sell, rent, or trade your personal information to third parties. Your membership and personal details remain strictly confidential.

Limited Sharing

We may share limited information only in these specific circumstances:

  • • With potential matches - Only curated profile information you've approved
  • • Service providers - Background check agencies, payment processors (under strict NDAs)
  • • Legal compliance - When required by law, court order, or to protect rights and safety
  • • Business transfers - In the event of merger or acquisition (with continued privacy protection)

Data Security

Technical Safeguards

  • • End-to-end encryption for all data transmission
  • • AES-256 encryption for data at rest
  • • Multi-factor authentication requirements
  • • Regular security audits and penetration testing
  • • SOC 2 Type II compliant infrastructure
  • • Real-time threat monitoring and response

Administrative Controls

  • • Background-checked staff with security clearance
  • • Role-based access controls and audit logging
  • • Mandatory privacy training for all employees
  • • Strict data retention and disposal policies
  • • Regular compliance assessments
  • • Incident response and breach notification procedures

Your Privacy Rights

As a member, you have the following rights regarding your personal information:

  • Access: Request copies of your personal data
  • Correction: Update or correct inaccurate information
  • Deletion: Request deletion of your data (subject to legal requirements)
  • Portability: Receive your data in a structured format
  • Restriction: Limit how we process your information
  • Objection: Object to certain types of processing
  • Withdrawal: Withdraw consent at any time
  • Complaint: File complaints with supervisory authorities

Data Retention

Active Membership: We retain your information for the duration of your membership and up to 7 years after termination for legal and business purposes.

Background Check Data: Retained for legal compliance requirements, typically 7-10 years depending on jurisdiction.

Financial Records: Maintained for tax and audit purposes as required by law, typically 7 years.

Communication Logs: Security and audit logs retained for 3 years for fraud prevention and legal compliance.

Contact Us

For any privacy-related questions, concerns, or to exercise your rights, please contact our Privacy Officer:

Email: privacy@wheelsup.com

Phone: +1 (555) 123-WHEELS

Address: Wheels Up Privacy Office, [Confidential Address]

Response Time: Within 72 hours for urgent matters, 10 business days for standard requests

Policy Updates

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of any material changes via email and through our platform. Continued use of our services after notification constitutes acceptance of the updated policy.