The Wifi Company is a software as a service company based in the United States that enables it’s clients to gather guest intelligence and platforms to engage with guests that connect to WiFi networks that are owned and operated by those clients. The Wifi Company is committed to protecting the privacy of our users’ personal information. This Privacy Statement provides information explaining how The Wifi CompanyWiFi.com and related sites collects, uses, and shares information collected from our website, as well as the choices you have regarding our use of this information. This Privacy Policy covers the company The Wifi Company WiFi, LLC., its subsidiaries, and any products or trade names associated with the company. These are referred to as “The Wifi Company”, “TWC” “we,” “us,” and “our” throughout this policy. This Privacy Policy applies to our TWC tools and software products, including all TWC websites, apps, and online services that link to this Privacy Policy (collectively, “our Services”).

TO OPT-OUT
IF YOU DO NOT WANT US TO COLLECT ANY ADDITIONAL INFORMATION, CLOSE THIS BROWSER WINDOW, DISCONNECT FROM THE WIFI COMPANY POWERED NETWORK AND DISABLE ANY WIFI-ENABLED DEVICES IF YOU ARE IN OR NEAR A THE WIFI COMPANYPOWERED HOTSPOT VENUE. 

You agree that all transactions relating to our Services shall be deemed to have occurred in the United States, where we currently have all our personnel and operations. Your information collected through the Services may be stored and processed in the United States or any other country in which TWC or our subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer. If you are a resident of the EU or the State of California, you are protected under the GDPR or the CCPA (respectively.)

OUR LEGAL BASIS FOR USE OF YOUR INFORMATION

Under applicable law, we are considered the “data controller” of the personal data we collect through our website. We are a data processor of (1) personal data of end users provided directly to us by our clients and (2) personal data we process in the course of operating our clients’ websites or analyzing their email marketing campaigns. We are a data controller of all other personal data we obtain in the course of our relationship with our clients, including: (1) information you provide through your use of the WiFi, including automatically-collected information; and (2) any additional data provided by you directly to us or through our business partners. This means that we are responsible for deciding how to collect, use and disclose this data, subject to applicable law. Our contact information appears at the end of this Privacy Policy.

The laws of some jurisdictions such as the laws of the European Union require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing of your information. To the extent those laws apply, our legal grounds are as follows:

  • Contractual Commitments: We may use, share, or disclose information to honor our contractual commitments to you. For example, to comply with our Terms of Use, which you accept by accessing or otherwise using the WiFi or our website(s).

  • With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent. For example, when you registered and consented to our Enhanced Wi-Fi, you consented to our use of your information for marketing purposes.

  • Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for our Wi-Fi and Enhanced Wi-Fi, preventing fraud, and managing legal issues.

  • Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.

California Privacy Rights
This section applies to California, USA residents:

Information Notice

  • Categories of collected personal information

You can see all categories of collected personal information listed in the section What Information We Collect.

  • Sources from which the personal information is collected

You can find information about the sources of data in the section How Your Information is Collected by Us.

  • Business or commercial purpose for collecting or selling personal information

You can find all purposes of processing your personal information listed in the section How Your Information is Shared.

  • Categories of third parties with whom the business shares personal information

You can find all categories of recipients of personal information listed in the section How Your Information is Shared. The Wifi Company does not sell (as such term is defined in the California Consumer Privacy Act) your personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in this Policy.

Your Rights
You have the right to:

  • know what personal information is being collected about you;

  • know whether your personal information is sold or disclosed and to whom;

  • say no to the sale of personal information (right to opt out);

  • request deletion of your personal information; information will be deleted if no exception applies (including our right to defend our lawful interests);

  • access your personal information; specific information shall be provided in a portable and, to the extent technically feasible, in a readily usable format but not more than twice in a 12-month period;

  • equal service and price, even if you exercise your privacy rights.

Under California Civil Code § 1798.83, we are required to disclose to consumers the following information upon written request: (1) the categories of personal information that we have disclosed to third parties within the prior year, if that information was subsequently used for marketing purposes; and (2) the names and addresses of all such third parties to whom such personal information was disclosed.

Right To Opt Out Of Sale
If your personal information is subject to a sale you have the right to opt-out from that sale through a link to a website which will be given to you at the moment of collection of personal information. We will respect your decision to opt out for at least 12 months before asking you again to authorize the sale of your personal information.

Request Submission
You can submit your requests using contacts indicated below or using the CCPA form linked in this section. If you are a California resident under the age of 18, you may be permitted to request the removal of certain content that you have posted on our websites. You can also designate an authorized agent to exercise these rights on your behalf.

Links to Other Websites
This Privacy Statement only addresses TWC’s collection, use, and disclosure of your information through our website(s) and Services. The Wifi Company may contain links to other websites with privacy practices that differ from those of The Wifi Company WiFi. If you choose to click on a link and visit another website, please be aware that your information will be governed by that website’s privacy policy. For example, our website includes social media Features such as Facebook Share and other widgets. These Features are governed by the Privacy Policy of the company providing the feature or widget. We encourage you to carefully read and review the policies and practices of the websites you visit.

Definitions
We understand that Privacy Statements can often contain confusing terminology. To help you better understand our privacy practices, here is what we mean when we say:

  • Cookies: Cookies are small text files created by a web server that are delivered through a web browser and stored on your computer or device. Cookies are used to identify your computer or device and record your preferences and other data so that the website can personalize your visit(s). There are several types of cookies. For example, many websites use their own cookies, called “first-party cookies,” to make their websites run more smoothly by doing things like keeping track of items in your shopping cart. Some websites also provide space for “third-party cookies,” which are placed on your browser by companies different from the company that runs the website you are visiting and may be used to remember parts of your online activities in order to deliver personalized ads or analyze web traffic.

  • Personally Identifiable Information (PII): Information that directly identifies or reasonably can be used to figure out the identity of a user, such as your name, address, phone number, and email address. Personal information does not include information that has been made anonymous so that it does not identify a specific user.

  • Web Beacons: A small, transparent graphic image (also known as a tracking pixel) located on a web page or HTML email that is often used with a cookie. Web beacons are generally invisible because they are very small and the same color as the background of the Web page or email message.

  • WiFi Probe Requests: All WiFi-enabled devices send out requests that contain information about your device. A probe request is a special frame sent by your device requesting information from either a specific access point, specified by SSID, or all access points in the area, specified with the broadcast SSID. The information being requested in a probe includes the supported data rates, which are also included in the beacon frames typically broadcast from an access point. If you do not want information to be sent from your device, you must disable WiFi before entering an area with tracking capability.

 

 

The Wifi Company may collect information from you in several ways:

  1. If you call us, e-mail us or visit our website or website(s) powered by any of our platforms.

  2. If you visit our clients WiFi location powered by any of our platforms we may collect information on you and/or your device through WiFi Probe Requests, login forms or oAuth requests, surveys or questionnaires, by redirect from a captive portal system, or by comparing previous visits or logins.

  3. Automatically when you visit or interact with our website(s).

  4. Information that you’ve voluntarily shared or indirectly shared though supplying your e-mail, social or mobile phone information.

Information We Collect Automatically
We automatically collects information about your device when you visit a The Wifi Company powered Hotspot or website(s). For example, we may automatically collect information such as your device MAC address, dwell time, whether you are a new or returning guest, referring website(s), the login method you choose, the different areas of our website that you visit, and the date and time you accessed our website and your approximate location based on your IP address or geo-coordinates. The Wifi Company uses technologies, including cookies and web beacons, and presence analytics-enable equipment that listen to WiFi Probe Requests to collect this type of information. In addition, we collect information that is available via third-party social media companies based on information that you disclose upon connecting.

Cookies, Web Beacons, and Other Tracking Technologies
The Wifi Company may use, or may engage third-parties on our behalf to use, cookies, web beacons, and other tracking technologies to collect information about you when you interact with our website(s), email or visit a venue with presence analytics tracking capabilities. These technologies allows us to:

  • Supply analytical information to the location that you are visiting;

  • Create aggregated views of location trends and statistics;

  • Develop personalized programs, services, or content;

  • Customize the information or services that are of interest to you on our website;
    tailor our communications to you;

  • Determine whether an email has been opened and links within the email have been clicked;

  • Send customized marketing messages such as coupons, promotions, or announcements to you from the locations you’ve visited;

  • Determine if a marketing message has been read;

  • Determine is a voucher or coupon has been redeemed;

  • Create features such as “Frequently Asked Questions”

Advertising & Analytics Services
The Wifi Company also engages third party service providers to serve Advertisements on our behalf across the Internet and to provide analytics services. These third-party service providers may use cookies, web beacons, and other technologies to collect information about your use of our website(s) and Services. This information is used to analyze data, determine the popularity of specific content, and deliver advertising based on your interests.

We may use third-party web analytics services, such as those of Google Analytics. These service providers use cookies and other technologies described in this Privacy Policy to help us analyze how users use our website and the guest WiFi in The Wifi Company powered locations. The information collected by the technology will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on by clicking here.

Linking of MAC Address to Personally Identifiable Information.
You understand and agree that by supplying your e-mail address, mobile number or any other PII, you are permitting us to: a) store and access your Personally Identifiable Information; b) link your Personally Identifiable Information to the MAC address and your location, as offered by the device with which you access the Internet and/or our WiFi service; and, c) use your Personally Identifiable Information in such other ways which accord with the terms and conditions herein set forth.

 

 

 

The Wifi Company may disclose your information in the following contexts:

Our Clients
The Wifi Company shares your Personally Identifiable Information with its Clients (meaning, the provider of the Internet service at the location you’re at when connecting) or their affiliates to fulfill our contractual obligation to them. Our terms of use agreements restrict our client’s use of PII for the benefit of any third parties. If you believe this there is a violation of this, please contact us or the business where you used the WiFi service.

Our Client’s Request
At the request of a client, we may also make additional disclosures of information we hold for that client. As an example, your information may be shared with 3rd party systems such as a CRM, point of sale system or marketing platform. Any third-party systems are subject to their own privacy policies and are not in our control.

Consent or Legal Permission
The Wifi Company will only disclose your personal information to third parties with your consent. We may obtain your consent in writing or online through “click-through” agreements. You grant consent if you supply any personal information upon Connection or if it was received by a social platform that you’ve authorized to share your data.

Our Service Providers
The Wifi Company may share or store your personally identifiable information with other companies that perform services on our behalf (for example, our platforms run on network infrastructure owned by our service providers). These service providers are permitted to use the information only for the purpose provided to them and in a manner that is consistent with this Privacy Policy. We require our service providers to comply with industry standards around security, retention, and use of any personal information that we provide to them or that they collect on our behalf.

Legal Purposes
The Wifi Company may access, monitor, use, or disclose your personally identifiable information or communications with us to comply with the law (for example, to comply with a search warrant, subpoena, or court order); to respond to emergencies; to enforce an agreement with you; to protect our rights or property, or the rights or property of our agents, vendors, service providers, members, and customers; or in the case of a corporate sale, merger, dissolution, or acquisition.
Some of the information that The Wifi Company collects is non-personally identifiable that cannot be directly used to identify or reasonably used to identify an individual. Similarly, The Wifi Company may take steps to anonymize or aggregate personal information in order to create non-personally identifiable information. This Privacy Statement does not restrict the disclosure to third parties of non-personally identifiable information.

 

 

 

 

Security
The security of your information is important to The Wifi Company WiFi. Therefore, The Wifi Company follows generally accepted industry standards to protect the security and confidentiality of your information while it is under our control. We maintain physical, technical, and administrative safeguards to protect against the loss, misuse, and unauthorized access of your information. To the extent that The Wifi Company shares information with other companies performing services on our behalf, we may make sure that those companies have adequate security safeguards in place consistent with this Policy.

Access to the information held by any of our systems is limited to authorized personnel who have a legitimate need to know based on their job descriptions, for example, employees who provide technical support to clients, end users, or who service user accounts. In the case of third-party contractors who process information on our behalf, similar requirements are imposed. These third parties are contractually bound by confidentiality clauses, even when they leave. Where an individual employee no longer requires access, that individual’s credentials are revoked.

 

 

Opt-Out
If you do not want us to collect any additional information, close this browser window, disconnect from the The Wifi Company powered network and disable any WiFi-enabled devices if you’re in a The Wifi Company powered Hotspot.

Correspondence
If you wish to unsubscribe from e-mail communication from The Wifi Company WiFi, you may e-mail us at support@thewificompany.com. Additionally, most of our email distributions contain an “unsubscribe” link. If you have questions or comments about this Privacy Policy or the practices of The Wifi Company WiFi, you may contact us at support@thewificompany.com.

Managing Cookies
You can manage cookie settings by using tools available on most Internet browsers. Instructions for popular browsers are here:

Depending upon which web browser you use, you may be able to adjust your settings to reject or delete cookies. However, choosing to reject cookies may result in the loss of some functionality of our website(s).

Offices in Colorado & New Jersey

 (877) 949-9434

© 2020 The Wifi Company LLC.

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