WIFI PRIVACY POLICY

IMPORTANT INFORMATION AND WHO WE ARE

The venue you are visiting (“Venue”) is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them.

Purple WiFi Limited is a processor of your personal data, acting on the instructions of the Venue and Purple and the Venue have a contractual arrangement which governs the processing.

INTRODUCTION

This policy (together with any end-user licence agreement provided on the splash page (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of the WiFi services (WiFi) accessed when you log in to the services on your mobile phone or WiFi-enabled device (Device).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The Services are not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

YOUR USE OF THE SERVICES

We are committed to protecting your personal data and respecting your privacy.

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data.

By using the WiFi, you consent to the processing of your personal data (including your device information, session details such as connection time and data usage, and (where applicable) any personal details you share as part of the log-in process, and (where applicable) your location data) as described in this Privacy Policy.

HOW YOU CAN WITHDRAW CONSENT

You may change your mind and withdraw consent (either by asking us to delete your data or unsubscribe you from marketing) at any time by contacting us at the above email address, but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

You have the right to make a complaint at any time to the relevant local regulator (e.g. the Information Commissioner’s Office in the UK) as regards data protection issues.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We will keep this privacy policy under review. It may change and if it does, these changes will be displayed upon your next login and you will be deemed to have accepted the changes by continuing to use the WiFi.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

THIRD PARTY LINKS

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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 data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you as follows:

1. Identity Data - for example, first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, or other information that the Venue requires you to provide.
2. Contact Data - email address and telephone numbers.
3. Device Data - includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, and the configured preferred language (locale).
4. Profile Data. : includes your username and password, your interests, preferences, feedback and survey responses.
5. Usage Data. includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise; and the connection times and data usage during your time using the WiFi.
6. Marketing and Communications Data. includes your preferences in receiving marketing from us and our third parties and your communication preferences.
7. Location Data - includes your device's current location disclosed by passive WiFi scanning or other means.

We explain these categories of data below.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature.

HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

1. Information you give us. This is information (including Identity, Contact and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Services, enter a competition, promotion or survey and when you report a problem with the Services. If you contact us, we will keep a record of that correspondence.
2. Information we collect about you and your device. Each time you visit one of Our Venues and use the Services we will automatically collect personal data including Device, Content and Usage Data.
3. Location Data. We may also use passive WiFi scanning to determine your device's current location. Some of our location-enabled Services require your personal data for the feature to work.

HOW YOUR PERSONAL DATA WILL BE USED

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

1. Where you have consented before the processing.
2. Where we need to perform a contract we are about to enter or have entered with you.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4. Where we need to comply with a legal or regulatory obligation.

Where applicable:

1. We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
2. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

PURPOSES FOR WHICH YOUR PERSONAL DATA MAY BE USED (this may depend on the specific Venue)

DISCLOSURES OF YOUR PERSONAL DATA

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table “Purposes for which we will use your personal data”:

1. Other companies in our Group and who may provide IT and system administration services.
2. External Third Parties such as:
3. Service providers acting as processors who provide other IT and system administration services
4. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
5. HM Revenue and Customs (and equivalent local regulators), other regulators and other authorities who require reporting of processing activities in certain circumstances
6. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the region in which you are located (e.g. Europe, APAC or Americas).

DATA SECURITY

All information you provide to us is stored on our secure servers.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

DATA RETENTION

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the Services for a period of 13 months then we will treat the account as expired and your personal data may be deleted.

YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You have the right to:

1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

1. if you want us to establish the data's accuracy;
2. where our use of the data is unlawful but you do not want us to erase it;
3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

1. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
2. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at the above address.

Glossary

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.