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We at Cloud4Wi (“we”, “us”, “our”) respect your privacy. This privacy notice (“Privacy Notice”) explains who we are and how we collect, use and share personal information we receive from you in connection with our services (“Services”), which provide marketing and visitor analytics. If you have any questions, please don’t hesitate to contact us as set forth in the “Contacting Us” section at the bottom of this Privacy Notice.
This Privacy Notice does not cover any information collected by us through other means, such as through our websites, sales and marketing activities or otherwise in the course of operating the business.
Cloud4Wi is the Data Controller of your personal data. Cloud4Wi is a registered company of California.
The information that we may collect about you broadly falls into the following categories:
Information we collect automatically.
● Location Data
When you carry your device (with its Wi-Fi and/or Bluetooth function enabled) into one of our venues, the technology we use senses the following: the presence of your device, its signal strength, its manufacturer (Apple, Samsung, etc.), the geographic position and a unique identifier known as its Media Access Control (MAC) address. This combination of numbers and letters identifies a specific device to the surrounding Wi-Fi or Bluetooth networks. Because the MAC Address does not disclose the device owner’s real-world identity, that information is never collected. We promptly de-identify and de-personalize any MAC addresses we collect. General Visit Information is collected as your mobile device moves across different Locations that use our technology.
For clarity, this information is automatically collected if your device’s WiFi is enabled – even if you do not actually “connect” to the Location’s WiFi network.
● Activity information
Information you provide voluntarily.
● Registration Information
When you use the guest Wi-Fi services in one of our venues, registration is sometimes required. The “Registration Information” you may provide includes, for example, full name, telephone number, email address or demographic information (e.g. date of birth, gender, geographic area and preferences).
You understand and agree that by providing Registration Information to Us, you are permitting Us to: a) store and access your personal data; b) link your personal data to the MAC address and your location, as offered by your mobile device; and, c) use your Registration Information in such other ways which accord with the terms and conditions herein set forth.
● Information we collect from third party sources
If you Log-In to the WiFi network via a third-party service, such as Facebook Login or Google OpenID, we may access the information described in the third-party service’s request for authorization, such as your name, email address, gender, age, and home zip code. Please review your privacy settings with these third-party services to ensure you are sharing the information you wish to share.
General Visit Information : The General Visit Information is used to help Us to better understand how our customers behave. We do this by generating reports based on such aggregated data. We may also aggregate and combine your General Visit Information with the General Visit Information of many people across our network. We use the reports for a variety of purposes, such as to:
○ Improve customer service;
○ Improve operation of Our facilities;
○ Determine timing for promotions and sales;
○ Measure the effects of advertising and marketing;
○ Plan and execute marketing and advertising campaigns;
○ Set staffing levels;
○ Set store hours; and
○ Other business and operational purposes, such as financial and product planning and execution.
Please note, once you are Registered with the Our Services your General
Visit Information is combined with your Registration Information and
Activity Information as set forth in the “Registration Information and
Activity Information” section below. This information helps us to improve
your experience in case you opt-in to receive promotional communications,
by allowing sending you a personalized communication also based on your
visits. Such data may also be combined with Third Party Data and used for
research and analytics and/or to help serve advertising.
We do not combine Registration Information and Activity Information with General Visit Information previously collected from your mobile device.
Registration Information and Activity Information : As noted above, once you Register with the Our Services, we may combine and associate your Registration Information and Activity Information with your General Visit Information. All such information may be used by us for the following purposes:
○ So that we may provide you with more personalized advertising, offers, experiences and features;
○ Providing advertising we or they believe is more relevant and tailored to your interests;
○ Contacting you with special offers and incentives, where this is in accordance with your marketing preferences;
○ Analytics and market research purposes, such as understanding the shopping preference of you and large groups of people (for example, helping our partners understand which people like to go to a restaurant for diner after seeing a movie);
○ Fulfilling your requests;
○ Other business and operational purposes, such as financial and product planning and execution.
Other Uses : We also use your information to:
○ Help us internally operate and maintain the Our Services (such as, for the purposes of fixing malfunctions, testing our security systems, etc.).
○ Enhance, improve and further develop the Services (such as, creating new features or functions, refining the user experience, increasing the technical performance of our services, etc.).
○ Provide you with notices relate to your use of the Service (such as account notifications and legal notices).
We may also use your provided Personal Information to contact you regarding products, services, and offers when you opt-in to receive them. We allow you to opt-out from receiving promotional communications from us, as described in the “How you can opt-out” section below.
Except as described in this Policy, we will not disclose your Personal
Information to third parties without your consent. We may disclose Personal
Information to third parties in the following circumstances:
● To Service Providers: ● We may disclose Personal Information to third-party service providers (e.g., payment processing, data storage and processing facilities) that host our servers and databases and that provide other services to us. We limit the Personal Information provided to these service providers to that which is necessary for them to perform their functions, and we require them to agree to maintain technical and organizational measures necessary to ensure adequate protection and confidentiality of such Personal Information. We ensure, e.g. by contractual regulations, that these service providers process personal data in accordance with European data protection law to guarantee a high data protection level, even if personal data are transferred into a country, in which another data protection level is common and for which no adequacy decision of the Commission of the EU exists
● Upon Transfer of the Business: Information about users,
including Personal Information, may be disclosed and otherwise transferred
to an acquirer, successor, or assignee as part of any merger, acquisition,
debt financing, sale of Our company assets, or similar transaction, as well
as in the event of an insolvency, bankruptcy, or receivership in which
Personal Information is transferred to one or more third parties as one of
Our business assets.
● To Affiliated Companies: We may disclose Personal
Information and other information to our parent company and to other
corporate affiliates. These affiliated third-party companies may use and
disclose Personal Information and other information that we disclose to
them in accordance with their privacy policies and procedures.
● To Protect Our Interests: We also may disclose Personal Information and other information if we believe that doing so is legally required or is in Our interest to protect Our property or other legal rights (including, but not limited to, enforcement of agreements) or the rights or property of others, or to otherwise help protect the safety or security of the Services or other users of the guest Wi-Fi services.
Promotional communications opt-out
We offer you choices regarding the receipt of promotional communications when you access the guest Wi-Fi services. If you receive promotional communications from us or from our Customers, you may unsubscribe at any time by contacting us using the contact details provided under the “Contacting Us” heading below.
Once we receive your opt-out request, you will no longer receive communications for direct marketing purposes from us and/or from our customers.
Your “opt-out” will not affect the lawfulness of the processing based on the consent before the withdrawal.
For clarity, we may still collect and use (except for direct marketing purposes) your MAC Address. For your choices in this regard – please see the “Mobile Location Analytics Code of Conduct” section above).
Mobile Location Analytics Opt Out
We comply with the Mobile Location Analytics Code of Conduct . As provided for in the code, you may elect to opt out of associating information about your presence at a location with a device’s MAC Address (meaning General Visit Information as defined in this privacy notice) at: https://smart-places.org/. If you opt out, we will use your device’s MAC Address only to maintain the device’s opt-out status.
We acknowledge individuals have the right to access the personal information that we maintain about them. You also have the following data protection rights:
● The right to receive information about the data processing and a copy of the processed data,
● The right to demand the rectification of inaccurate data or the completion of incomplete data,
● The right to demand the erasure of personal data and, in case the personal data have been made public, the information towards other controllers about the request of erasure,
● The right to demand the restriction of the data processing (right to restriction of processing,
● The right to receive the personal data concerning the data subject in a structured, commonly used and machine-readable format and to request the transmittance of these data to another controller,
● The right to object the data processing in order to stop it,
● The right to withdraw a given consent at any time to stop a data processing that is based on your consent. The withdrawal will not affect the lawfulness of the processing based on the consent before the withdrawal
● The right to lodge a complaint with a supervisory authority if you consider the data processing to be an infringement of the GDPR.
If you wish to make use of any of the above mentioned rights you may contact us using the contact details provided under the “Contacting Us” heading below. If you provide us with sufficient information to identify you and verify your identity, we will use reasonable efforts to comply with your request without undue delay and at the latest within 30 days. For repeated or excessive requests, we reserve the right to charge you an administrative fee.
We retain your information for as long as you are a user of the guest Wi-Fi services. We also retain this information for 18 months after you are no longer a user or until it is no longer needed for the purposes for which it was collected. As far as such information is subject to any statutory data retention period exceeding afore-said storage period, We will store the data each concerned for the duration stipulated in the respective statutory provisions. In the latter case, the data will be stored in restricted form whereas further processing is allowed exclusively for the establishment, exercise or defense of legal claims, the protection of the rights of another person, or reasons of important public interest.
After this period, your personal data will be irreversibly destroyed. Any personal data held by us for marketing and service update notifications will be kept by us until such time that you notify us that you no longer wish to receive this information.
As of the date of this Policy, we store information in Ireland.
We may transfer your data from your respective country to other countries in connection with processing of data, fulfilling your requests and operating the services. If we collect your data in the EU, your data will not be transferred to a country or territory outside the EU.
We use third party provider who may process your personal data on Our behalf. We assessed the compliance and security measures implement by all of our providers and we signed Data Processing and Data Transfer agreements (where applicable) with them that comply with the GDPR.
We use appropriate administrative, organizational, technical, and physical
safeguards to protect the personal information we collect and process about
you. The measure we use are designed to provide a level of security
appropriate to the risk of processing your personal information and to help
ensure that your data is safe, secure, and only available to you and to
those you provided authorized access. Specific measures we use include
using secure socket layer protection (which you can look up on your
favorite search engine). We also take steps, like employing firewalls and
authentication, to safeguard your information and prevent unauthorized
access to it.
Mobile Location Detection Services information is transferred securely and then “hashed” before it is stored on virtual hosting infrastructures. Hashed data cannot be reverse-engineered by a third party to reveal a device’s MAC address.
However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so you should take care in deciding what information you send us in this way.
The guest Wi-Fi services may, from time to time, contain links to and from
the website of third parties. If you follow a link to any of these
websites, please note that these websites and any services that may be
accessible through them have their own privacy policies and that we do not
accept any responsibility or liability for these policies or for any
Personal Information that may be collected through these websites or
services. Please check these policies before you submit any personal data
to these websites or use these websites.
We do not knowingly collect information from anyone under the age of 16 unless we first obtain permission from that child’s parent or legal guardian. However, if despite our best efforts we learn that we have collected information from a child under the age of 16 on our Platform, we will delete that information as quickly as possible.
If you become aware that your child has provided us with personal information without your consent, please contact us using the contact details provided under the “Contacting Us” heading below.
We are dedicated to ensuring that its privacy practices are in compliance with the Principles and this Policy. Any employee that we determine is in violation of this Policy may be subject to disciplinary action up to, and including, termination of employment.
We encourage you to direct any questions, concerns or complaints regarding the collection and use of your personal information to Our data protection officer (contact information provided below). We will investigate and work expeditiously to resolve any complaints or disputes in accordance with the Principles and this Policy. If we do not provide a timely response to you, or you are not satisfied with the way we have handled your matter, please contact the appropriate independent dispute resolution service identified in the beginning of this Policy. The services the Privacy Shield BBB are provided to you at no cost.
We promise to do our best to remedy any problems arising out of the failure to comply with the Principles, including taking responsibility for a third party agent’s processing of personal information received under the Privacy Shield. If the third party agent does not process your personal information consistent with this Policy and the Principles, and We are responsible for the events giving rise to the damage you have incurred, then we remain liable to you under the Principles.
If you have any questions or comments about this Policy, please contact Us using the following contact information:
600 California Street, CA, 94108
You will automatically connect to Secure Wi-Fi going forward.
Our apologies - the secure network is currently only supported on Android and iOS devices at this time.