Privacy
Last Updated: July 15, 2015

This Privacy Policy (this “Policy“) relates to the practices of Cloud4Wi Inc. (“Cloud4Wi,” “we,” or “us“) regarding the services (“FOG”) we provide to companies (“Customers”). This Policy describes how Cloud4Wi handles the information of individuals who visit the venue(s) of our Customers (“you,” “your,” and “user“). This Policy together with our Terms of Use (“Terms”) applies to your access and use of the guest Wi-Fi services at one or more of our Customers venues.

1. SAFE HARBOR FRAMEWORKS AND CONSUMER COMPLAINT MECHANISMS

Cloud4Wi complies with the U.S. – E.U. Safe Harbor Framework and U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Cloud4Wi has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Cloud4Wi’s certification, please visit http://www.export.gov/safeharbor.

In compliance with the US-EU and US-Swiss Safe Harbor Principles, Cloud4Wi commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Cloud4Wi at privacy@cloud4wi.com.

Cloud4Wi has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. Please send any inquiries or complaints to us at privacy@cloud4wi.com.  If you do not receive timely acknowledgment of your complaint, or if Cloud4Wi does not satisfactorily address your complaint, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Cloud4Wi also complies with the Mobile Location Analytics Code of Conduct. This code was established as an industry-wide standard for protecting the privacy of consumers when dealing with their mobile device data obtained during visits to venues where our Customers are using our Platform. It also defines rules of engagement for technology companies like Cloud4Wi to inform consumers about location analysis and provide an easy way to opt-out. For more information about the use of location data collection and analytics and your choices, see http://www.smartstoreprivacy.com.

2. WHAT WE DO

Cloud4Wi offers a set of Services used by venue owners to analyze things that happen in and around their venues and to provide you with an enriched access to Wi-Fi hotspots at one or more of their venues.

In order to facilitate this process, we collect some information, including aggregate information. Aggregate information is information collected about a group of category of users, services, or devices that is not personally identifiable or from which individuals identifies are removed. We may use aggregate information to measure overall industry trends and we may provide aggregated information to our entire Customer base.

3. WHAT WE COLLECT

We collect different types of information during your visit to our Customer venues.

  • Mobile Location Detection Services
    When you walk with your device (with its Wi-Fi and/or Bluetooth function enabled) into one of our Customer venues, the technology we use senses the following: the presence of the 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 nor any personal data, that information is never collected. We promptly de-identify and de-personalize any MAC addresses we collect.

We do not collect or use data in adverse manner for the following purposes: employment eligibility, promotion or retention; credit eligibility; health care treatment eligibility; and insurance eligibility pricing or terms.

We collect and aggregate only anonymous data from your device into reports we prepare for our customers. These reports are used by our Customers for varied purposes, such as to improve venue layouts, determine timing for promotions and sales, measure the effects of advertising, and set staffing levels and venue hours.

  • Guest Wi-Fi Services
    When you use the guest Wi-Fi services in one of our Customer venues, registration is sometimes required. Registration information is sent to us, but the exact nature of the information categories requested is determined by our Customers when they create the user registration process. The personal information you may provide includes, for example, full name, address, telephone number, email address or demographic information (e.g. date of birth, gender, geographic area and preferences).

 

Personal information may include also the information from your social media account through which you access the guest Wi-Fi services (e.g. Facebook, Twitter, Linkedin, Google+, VKontakte). This information is taken from your social media access page and is subject to your privacy settings.

When you use the guest Wi-Fi services in one of our Customer venues, some information is collected automatically. This information includes, for example, the unique device identifiers known as MAC Address, device type and model, operating system, browser type and language, your browser’s Internet Protocol address, start and stop timestamps of your connections, amount of traffic, hotspot from which you are connected, and the logout reason type.

4. COOKIES

Cookies are data files placed on a device when it is used to access the guest Wi-Fi services (“Cookies”). We use temporary technical Cookies, which expire 24 hours after you access the splash portal (that is the registration page), to ensure that you access the same splash portal during the 24-hour time frame.

5. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

  • To enable you to use the guest Wi-Fi services;
  • To provide technical support and to respond to your inquiries;
  • To deliver customized content that may be interest of you;
  • To prevent fraud and potentially illegal activities and to enforce our Terms of Use;
  • To solicit your feedback to improve the guest Wi-Fi services and your experience using it;
  • To administer and improve the Services.

We may also use Personal Information you provide to contact you regarding products, services, and offers of ours and our Customers, when you opt-in to receive them. We allow you to opt-out from receiving promotional communications as described in the “Choices Regarding Promotional Communications” section below.

6. WHO WE SHARE YOUR INFORMATION WITH

Except as described in this Policy, we will not disclose your Personal Information that we collect on the Services to third parties without your consent. We may disclose Personal Information to third parties in the following circumstances:

  • To Venue Owners: We may disclose Personal Information to our Customers who operate and own the venue you visit and where you access the guest Wi-Fi services.
  • To Service Providers: We may disclose Personal Information to third-party service providers (e.g., payment processing and data storage and processing facilities) that assist us in our operations. We limit the Personal Information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such Personal Information.
  • To Business Transfers: 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 Cloud4Wi 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 Cloud4Wi 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 Cloud4Wi Interests: We also may disclose Personal Information and other information if it believes that doing so is legally required or is in Cloud4Wi interest to protect Cloud4Wi property or other legal rights (including, but not limited to, enforcement of agreements) or the rights or property of others, or otherwise to help protect the safety or security of the Services or other users of the guest Wi-Fi services.

7. WHERE WE STORES YOUR INFORMATION

As of the date of this policy, we store information in Ireland. We may add additional storage sites in the EU, Switzerland or US without notice. We may transfer your data from your own country to other countries in connection with storage and processing of data, fulfilling your requests and operating the FOG. Please note that each country has its own privacy and data security laws, some of which may be less stringent as compared to those of your own country.

8. HOW LONG WE RETAIN YOUR INFORMATION

We retain your information in its regular business records while you are a user of the guest Wi-Fi services. We also retain this information for 24 months after you are no longer a user or until it is no longer needed for the purposes for which it was collected.

9. SECURITY MEASURES WE USE

We take reasonable precautions to protect the safety and security of the information we collect and store. Once information is received, we generally encrypt it as it passes between our internal services, and to encrypt it when it is at rest. 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. Once a MAC Address is hashed, we will not attempt to re-identify the original MAC Address from that data. Hashed data cannot be reverse-engineered by a third party to reveal a device’s MAC address.

10. THIRD PARTY SITES

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.

11. CHOICES REGARDING PROMOTIONAL COMMUNICATIONS

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 sending an email to privacy@cloud4wi.com. Once we receive your opt-out request, you will no longer receive communications for direct marketing purposes.

12. PRIVACY POLICY FOR CHILDREN

We do not knowingly collect information from anyone under the age of 13 unless we first obtain permission from that child’s parent or legal guardian. If we learn that we have collected information from a child under the age of 13 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 at privacy@cloud4wi.com.

13. ACCESS TO YOUR INFORMATION

If you wish to access, correct, or delete the information about you, you may submit a request to privacy@cloud4wi.com. If you provide us with sufficient information to identify you and verify your identity, we will use reasonable efforts to comply with your request.

14. OPTING OUT OF MOBILE LOCATION DETECTION SERVICES AND OTHER USES

If you don’t want your device to be detected for Mobile Location Detection Services, you can opt out by submitting your MAC address here. We will remove any existing data about that MAC address and will collect no further data about that MAC address in the future. If you use an iOS 8 device, please note that you may have to opt-out repeatedly because the MAC address of iOS 8 devices changes periodically. Therefore, any prior opt out will be reset when the device’s MAC address changes.

You can also opt out of our sharing your data with third parties (aside from our Customers and as required for our operations), or from sending you notices or emails, by emailing us at privacy@cloud4wi.com. Our Customers may have their own opt-out provisions in their Privacy Policies, so please review them as well. Sending us your opt-out request will not opt you out of our Customer’s sharing or contact policy, or the Mobile Location Detection Services detection; you need to opt out of each service separately if you wish to do so.

15. AMENDMENTS TO THIS POLICY

From time to time, we may amend our Privacy Policy, to account for new features or for other reasons. When such changes occur, you will be able to view the new version of this Privacy Policy on our website. If we change this Policy in a manner that materially alters your rights or obligations under this Policy, we will use reasonable efforts to notify you of the change. For example, we could generate pop-up or similar notification when you access the Services for the first time after such material changes are made. Your use of the Platform after the effective date of the changes constitutes acceptance of the amended terms. We reserve the right to apply the amended terms to the information we have already collected, subject to any legal requirements. We suggest that you should review our Privacy Policy regularly to see if there have been any changes.

16. CONTACTS

If you have any questions or comments about this Policy, please contact Cloud4Wi using the following contact information:

Cloud4Wi Inc.
363 Clementina Street
San Francisco, CA 94103
United States of America

privacy@cloud4wi.com