Effective date: 13th Oct, 2022



  1. C.S GROUP (HK) LTD. which is a company duly incorporated in Hong Kong (hereinafter referred to as the “Company”), operates the app called WINGSFIT (hereinafter referred to as the “App”).
  2. This privacy policy (hereinafter referred to as the “Privacy Policy”) describes how the Company collects, uses, and disclosures the user’s personal data and how to manage the user’s privacy controls and rights when the user (hereinafter referred to as the “Client”) uses the App and the choices the Client has associated with that data. By using the App, the Client agrees to the collection and use of information in accordance with the Privacy Policy. The Privacy Policy is a legally binding agreement between the Client and the Company. By accessing and using the App, the Client acknowledges that the Client has read, understood, and agreed to be bound by the terms of the Privacy Policy.
  3. Please also read WINGSFIT Terms and Conditions at which sets out the terms governing the App. Unless otherwise defined in the Privacy Policy, the terms used in the Privacy Policy have the same meanings as in WINGSFIT Terms and Conditions.
  4. The Privacy Policy does not apply to third-party’s products or services or the practices of companies that the Company does not own or control, or to individuals that the Company does not employ or manage.


The Company collects information about the Client, including information that directly or indirectly identifies the Client, if the Client or the Client’s other members choose to share it with the Company. The Company collects information when the Client uses the App in a few different ways, including but not limited to tracking, completing, or uploading activities. There are also several opportunities for the Client to share information about himself/herself, the Client’s friends and the Client’s activities on or through the App.

  1. Account, profile, activity and use information

    While using the App, the Company may collect basic account information including but not limited to the Client’s name, email address, date of birth, gender, weight, phone number, address (state, province, city), ZIP/Postal code, photos, selfies, username and password that helps secure and provide the Client with access to the App. The Company may request access to the Client’s connected device in order to use the camera, microphone, or any other functions that assist the Client in taking photos or creating content for his/her profile.

    Profile, activity and use information are collected about the Client when the Client chooses to upload the content and activity (including date, time and geo-location information as well as the Client’s speed and pace and perceived exertion) or post, join a challenge, add the Client’s equipment usage, view others’ activities or otherwise use the App.

  2. Location information

    The Company collects and processes location information when the Client signs up and uses the App. The Company does not track the Client’s device location while the Client is not using the App, but in order to run and monitor the App, it is necessary for the Company to track the Client’s device location while the Client uses the App. If the Client would like to stop the device location tracking, the Client may do so at any time by adjusting the Client’s device settings.

  3. Content the Client shares

    The Company gathers information from the photos, posts, comments, kudos, ratings, reviews, and other content the Client shares on or through the App, including when the Client participates in the challenges and/or event on or through the App.

  4. Contacts Information

    The Client can choose to add his/her contacts’ information by connecting his/her contacts from the Client’s mobile device or social networking accounts to the App. If the Client chooses to share the Client’s contacts with the App, the Company will, in accordance with the Client’s instructions, access and store his/her contacts’ information in order to identify connections and help the Client connect with them. The company collects this information only with the Client’s explicit consent, and the Client may remove that consent at any time from the Client’s device privacy settings.

  5. Connected Devices and Apps Information

    The Company collects information from devices and apps the Client connects to the App. Such information can be synced to the App for certain purposes upon the Client’s explicit consent. For example, the Client may connect his/her smart watch to the App and information from these devices and apps will be passed along to the App.

  6. Health Information

    The Company may collect or infer health information. Certain health information may be inferred from sources such as heart rate or other measurements, including power, cadence, and weight or other indicators.

    Before the Client can upload health information to the App, the Client must give his/her explicit consent to the processing of that health information by the Company. The Client can withdraw the Client’s consent to the Company processing the Client’s health information at any time from the Client’s device privacy settings.

  7. Third-party accounts Information

    The Company allows the Client to sign up and log in to the App using accounts the Client creates with third-party products and services, such as Google (collectively referred to as, “Third-Party Accounts”). If the Client accesses the App with Third-Party Accounts, the Company will collect information that the Client has agreed to make available such as the Client’s name, email address, profile information and preferences and other information. This information is collected by the Third-Party Account provider and is provided to the Company under their privacy policies. The Client generally controls the information that the Company receives from these sources using the privacy controls in the Client’s Third-Party Account.

  8. Technical Information and Log Files

    The Company may also collect information from the Client’s browser, computer, or mobile device, which provides the Company with technical information when the Client accesses or uses the App. This technical information includes the Client’s device and network information, computer’s Internet Protocol address, browser type, browser version, the pages of the App that the Client visits, the time and date of the Client’s visit, the time spent on those, unique device identifiers and other diagnostic data, cookies, log files and analytics information.

  9. Tracking Data

    The Company may use third-party web analytics services such as those provided by Google Analytics. These service providers use cookies and other technologies to help the Company analyze how the Client interacts with the App. The information collected by the technology will be disclosed to or collected directly by these service providers. The Client can opt-out of having made his/her activity on the App available to Google Analytics by installing the Google Analytics opt-out browser add-on.

  10. Other Information

    The Company may, at any time, seek to obtain information about the Client from other sources. The Company may receive or affirmatively gather information about the Client from such sources and may combine it with the information that the Company already has for any purpose described throughout the Privacy Policy. The extent to which the Company may obtain information from such sources is governed by the terms of the Client’s relationship with that source.


In order to make the App available to the Client and/or to meet the legal obligation, the Company may need to collect and use certain information of the Client. If the Client does not provide the information that the Company requests, the Company may not be able to provide the Client with the requested products or services on or through the App. Any information the Company collects from the Client may be used for the following purposes:

  1. To provide and maintain the App

    The Company uses the information the Company collects and receives to provide and maintain the App, including providing the Client with the ability to:

    a. Participate in the challenges and events on or through the App.

    b. Record the Client’s activities and analyze the Client’s performance.

    c. Interact with other Clients.

    d. Manage the Client’s training.

    e. Visualize the Client’s activities.

  2. To customize the Client’s experience

    The Company uses the information the Company collects about the Client, the Client’s followers, and the Client’s activities to customize his/her experience. For example, the company may suggest the activities, challenges, or events that may interest the Client, athletes that the Client may want to follow, or new features that the Client may want to try.

  3. To protect the Client and the App

    The Company uses the information the Company collects to protect Clients, enforce the WINGSFIT Terms and Conditions and promote safety. The Company can find and remove content that violates the WINGSFIT Terms and Conditions such as hate speech or spam, as well as suspend or terminate accounts that share such content.

  4. To improve the App

    The Company also uses the information the Company collects to analyze, develop and improve the App. To do this, the Company may use third-party analytics providers to gain insights into how the App is used and to help the Company improve the App.

  5. To communicate with the Client

    The Company uses the information the Company collects to provide support in response to the Client’s requests and comments. The Company may also use the information the Company collects to market and promote the App, activities and events on or through the App, and other commercial products or services. This includes marketing and push communications, where the Client has not opted out of receiving such messages and notifications.

  6. To aggregate information

    The Company does not sell the Client’s personal information. The Company may aggregate and centralize the information the Client and others make available in connection with the App and post it publicly or share it with third parties for purposes of analytics, innovation, and to provide enhanced services on the App. Examples of the type of information the Company may aggregate include information about equipment, usage, demographics, routes and performance.

  7. To detect, prevent and address technical issues

    The Company may use the information the Company collects to detect, prevent and address technical issues.


The App is operated from Hong Kong. If the Client is located outside of Hong Kong and chooses to use the App or provide information to the Company, the Client acknowledges and understands that the Client’s information will be transferred, processed and stored in Hong Kong, as it is necessary to provide the App and perform the WINGSFIT Terms and Conditions. The data protection laws in Hong Kong may differ from those of the country in which the Client is located, and the Client’s personal information may be subject to access requests from governments, courts, or law enforcement in Hong Kong according to the laws of Hong Kong. Hong Kong privacy laws may not be as protective as those in the Client’s jurisdiction.


The Company may share the Client’s personal information in accordance with the Client’s preferences, as needed to run the Company’s business and provide the App, and where required for legal purposes, as set forth below.

  1. Service Providers

    The Company may share the Client’s personal information with third-parties who provide services to the Company such as supporting, improving, promoting and securing the App, or fulfilling orders. These service providers only have access to the information necessary to perform these limited functions on the Company’s behalf and are required to protect and secure the Client’s information. The Company may also engage service providers to collect information about the Client’s use of the App over time on the Company’s behalf, so that the Company or they may promote the Company or display information that may be relevant to the Client’s interests on the App or other websites or services.

  2. Publicly Available Information

    When the Client joins the Company’s community, the Client’s profile and activities are set to be viewable by everyone by default. The Client’s name and other profile information are viewable by other WINGSFIT members and the public and, subject to the Client’s privacy controls, additional information and content the Client shares may also be viewable. For example, the Client’s photos may be accessed by other WINGSFIT members and non-members or viewable on publicly accessible the Company’s pages or in search engine results. The Company provides a variety of tools to control the sharing of the Client’s information and encourage the WINGSFIT members to adjust their controls to align with their desired experience.

  3. Sharing Information and Activities

    As a social network, the Company shares the Client’s information with other WINGSFIT members and the public in accordance with the Client’s privacy controls. The Clients can change the visibility of the activities the Client uploads to the App. Also, the Client can tell the Company about important locations, such as the Client’s home or work address, by enabling a privacy in the Client’s settings. The Company will make private any portion of the Client’s activity that starts or ends in Client’s privacy. The Client can also share his/her activities with his/her contacts via text, email, or on social media applications like Facebook, Instagram, and Twitter. If the Client links his/her WINGSFIT account to other social networks and shares his/her activities, they will be viewable on such third-party platforms, including the Client’s location information. The Client should use caution when sharing information via third-parties and the Client should carefully review the privacy practices of such third-parties.

  4. Affiliates and Acquirers of the Company’s Business or Assets

    The Company may share the Client’s information with affiliates under common control with the Company, who are required to comply with the terms of the Privacy Policy with regard to the Client’s information. If the Company becomes involved in a business combination, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, the Company may share or transfer the Client’s information in connection with such transaction.

  5. Legal Requirements

    The Company may preserve and share the Client’s information with third-parties, including law enforcement, public or governmental agencies, or private litigants, within or outside the Client’s country of residence, if the Company determines that such disclosure is allowed by the law or reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory processes. The Company may also retain, preserve or disclose the Client’s information if the Company determines that this is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of the CALO Terms and Conditions or fraud or abuse of the Company or its members, or to protect its operations or its property or other legal rights, including by disclosure to the Company’s legal counsel and other consultants and third-parties in connection with actual or potential litigation.


The Company takes several measures to safeguard the collection, transmission and storage of the data the Company collects. The Company employs reasonable protections for the Client’s information that are appropriate to its sensitivity.

The security of the Client’s information is important to the Company, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While the Company strives to use commercially acceptable means to protect the Client’s information, the Company cannot guarantee its absolute security.

  1. Privacy Controls

    The Company offers several features and settings to help the Client manage his/her privacy and shares his/her activities. Most privacy controls are located on the Client’s privacy controls page, but some are specific to individual activities or athletes. The Company provides the Client the option to make the Client’s activities private.

  2. Adjust Notification and Email Preferences

    The Company offers various ways to manage the notifications the Client receives. The Client can choose to stop receiving certain emails and notifications by indicating his/her preference.

  3. Updating Account Information

    The Client may correct, amend or update profile or account information at any time by adjusting that information in the Client’s account settings.

  4. Deleting Information and Accounts and Downloading Data

    The Client can delete his/her account or download his/her data using the Company’s self-service tools. After the Client makes a deletion request, the Company permanently and irreversibly deletes the Client’s personal data from its systems, including backups. Once deleted, the Client’s data, including his/her account, activities and place on leaderboards cannot be reinstated. Following the Client’s deletion of his/her account, it may take up to a day to delete the Client’s personal information and system logs from the Company’s systems. Additionally, the Company may retain information where deletion requests are made to comply with the law and take other actions permitted by law.

    Note that content the Client has shared with others, such as photos, or that others have copied may also remain visible after the Client has deleted his/her account or deleted specific information from the Client’s own profile. The Client’s public profile may be displayed in search engine results until the search engine refreshes its cache.

    The Company also provides the Client the option to remove individual activities the Client has posted without deleting his/her account. Once removed, the activities may remain on the Company’s systems until the Client deletes his/her account.


The Company retains information as long as it is necessary to provide the App to the Client and others, subject to any legal obligations to further retain such information. Additionally, the Company may retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the WINGSFIT Terms and Conditions and take other actions permitted by law. The information the Company retains will be handled in accordance with the Privacy Policy. Information connected to the Client that is no longer necessary and relevant to provide the App may be de-identified or aggregated with other non-personal data to provide insights that are commercially valuable to the Company, such as statistics of the use of the App. This information will be de-associated with the Client’s name and other identifiers.


The App may contain links to other sites that are not operated by the Company. If the Client clicks on a third-party’s link, the Client will be directed to that third-party’s site. The Company strongly advises the Client to review the privacy policy of every site the Client visits. The Company has no control over and assumes no responsibility for the content, privacy policies or practices of any third-party sites or services.


The Company may update the Privacy Policy from time to time without notification. The Company will update the “effective date” at the top of the Privacy Policy. The Client is advised to review the Privacy Policy periodically for any changes. Changes to the Privacy Policy are effective when they are posted on this page and the Client agrees to be bound by such modifications or updates.


If the Client has any questions about the Privacy Policy, please contact the Company via email:

Company address: Unit 2210 of Tower B, Regent Centre, 63 Wo Yi Hop Road, Kwai Chung, N.T.,HK