DISCLAIMER

We are doing our best to help our customer with the content of the policies they need to produce. However, we cannot warranty the expressions and suggestions of the contents, as well as its accuracy.
This is a template is provided only as an example of a Privacy Policy. Use this only a possible reference tool and write your own policy.  Make sure to engage an attorney in the review of any privacy policy you develop for your particular service.


Guest WiFi Privacy Policy

We at [COMPANY NAME] (“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 Policy and the Terms of Use (“EULA”) (together the “Terms”), applies to your access and use of the guest Wi-Fi services in all of our venues.

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.

[Company Name] is the Data Controller of your personal data. [Company Name] is a registered company of [Jurisdiction]

What we collect and how we collect it

The information that we may collect about you broadly falls into the following categories:

Information we collect automatically.

Information you provide voluntarily.

How we use your information

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:

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:

Other Uses: We also use your information to:

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.

How we use cookies and similar technology

We may use cookies and similar tracking technology (collectively “Cookies”) to collect and use Activity Information about you (including to serve interest based advertising). For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

Who we share your information with

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:

How you can opt-out

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.

Data protection rights


We acknowledge individuals have the right to access the personal information that we maintain about them.  You also have the following data protection rights:

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.

How long we retain your information

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.

Where we store your 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.

How we keep your personal information secure

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.

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.

Privacy Policy for children

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.

Recourse, enforcement and liability

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.

Amendments to this policy

We may update this Privacy Notice from time to time. This Privacy Notice applies to information we collect while that notice is in effect. 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 review our Privacy Policy regularly to see if there have been any changes.

Contacting Us

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

[COMPANY]

[ADDRESS]

[DPO]

[dpo@company.com]