Last Updated: December 1, 2024
[COMPANY] (“Company”, “we,” “us,” or “our”) provides a Wi-Fi and marketing service ("Company WiFi Services"). This Privacy Policy (“Policy”) describes and governs only our information collection, use, and disclosure practices with respect to your use of the Company WiFi Services. When you access or otherwise use the Company WiFi Services, you also agree to the privacy practices of the provider of the services, Adentro, Inc.. The Adentro WiFi Network Privacy Policy can be accessed here.
Before you use or submit any information through or in connection with the Company WiFi Services, please carefully review this Policy. By registering for or otherwise using any part of the Company WiFi Services, you acknowledge that the Company will collect, use, and disclose your information as further outlined in this Policy.
We collect information about you in multiple ways, including when you provide information directly to us, automatically through your use of the Company WiFi Services, and information from third-party sources, as described below.
a. Information You Provide to Us Directly
We may collect information from you directly in various ways, such as when you:
b. Information Collected Automatically
We may collect information about you or your device automatically when you use the Company WiFi Services.
See Your Privacy Choices and Rights below for more information about your choices on this data collection.
c. Information Collected From Other Parties
We may collect information about you from other parties. For example, we may collect information about you from data enhancement providers and other parties.
We use your information for the following business purposes:
Data combination. Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy. We may use such combined information about you to create a profile about you and your interests. For example, we may combine your registration information with information that we collect automatically or from third parties to create a profile about your interests.
De-Identified/Aggregated Data. We may aggregate and/or de-identify information collected through the Company WiFi Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, and/or others. Adentro commits to maintain and use such data in a de-identified form and not attempt to re-identify the data.
We may disclose your information to other parties under the following circumstances:
Adentro: If you register for and log onto the Company WiFi Services at particular locations, you agree to also disclose your information to Adentro, and your data will be subject to the Adentro Wi-Fi Network Privacy Policy.
Affiliates: We may disclose information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with the Company. Our affiliates may use the information we disclose in a manner consistent with this Policy.
Vendors: We may disclose your information to employees, consultants, and other vendors who need access to such information to carry out work or perform services on our behalf, such as those who provide data storage, payment, technology support and services, customer service, analytics, fraud prevention, legal services, advertising and marketing services.
Business Partners: We may disclose information about you with business partners to provide you with a product or service you have requested. We may also disclose your information to business partners with whom we jointly offer products or services.
Safety and Protection of Company and Others: We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to (i) protect or defend the Adentro or other parties, including to defend or enforce this Policy, our Terms of Service, or any other contractual arrangement; and/or (ii) protect the rights, property or personal safety of Company, our agents and affiliates, our employees, users and/or the public.
Advertising and Analytics: We may disclose or make available some of your information to advertising and analytics partners to serve advertisements on our behalf across the internet and to provide analytics services. These entities may use cookies and tracking technologies to allow us to, among other things, track and analyze data, determine the popularity of certain content, deliver advertising and content targeted to your interests and better understand your online activity. For more information about how to manage having your web browsing information used for advertising purposes, please see the Analytics and Tailored Advertising section below.
Legal Requirements: We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.
Business Transfers: We may disclose certain information, in connection with or during negotiations or closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Other Disclosures with Consent or at Your Direction: We may disclose your information to nonaffiliated third parties based on your consent to do so.
We may use third-party analytics services in the Company WiFi Services. These vendors use various technologies (e.g. in the form of software development kits) to help us analyze how users use the Company WiFi Services.
We may also collect information about you for advertising purposes. For example, we may collect information about the types of Clients you visit and combine that with other information we collect about you, including information related to your use of the Company WiFi Services. We may combine this data to enable interest-based content or targeted advertising for Adentro services or the products and services of our Clients. We may also use information about you for other analytics and advertising purposes, such as to enhance data maintained by our Clients, and for analytics, attribution, and measurement purposes. You may opt out of this type of data processing and disclosure by visiting Adentro's Privacy Portal.
We offer you certain choices regarding the collection, use, and disclosure of information about you.
Marketing Emails: You can unsubscribe from marketing emails by following the directions in those emails. Note that you may continue to receive transaction-related emails. For example, we may also send you certain non-promotional communications regarding us and the Company WiFi Services, and you may not be able to opt out of those communications (e.g., communications regarding the Company WiFi Services or updates to this Policy).
Profile Information: You can submit a request to deactivate and delete your account for Company WiFi Services by visiting Adentro's Privacy Portal.
Analytics and Tailored Advertising: You can opt out of certain analytics and advertising processing of information about you by visiting Adentro's Privacy Portal.
Legal Bases for Processing: Adentro is considered the “data controller” of the “personal data” (as defined under applicable law) we handle under this Policy. The laws of certain jurisdictions (such as the European Economic Area, Brazil, UK) require us to tell you about the legal bases we rely on for processing. The legal bases we rely on are:
Rights to Information About You: Your local law may provide you certain rights with respect to your information. Depending on your jurisdiction, you may request that we:
You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.
Please note that certain information may be exempt from such requests under applicable law. For example, we may retain certain information for legal compliance and to secure the Company WiFi Services. We may need certain information in order to provide the Company WiFi Services to you; if you ask us to delete it, you may no longer be able to use the Company WiFi Services.
You also have the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
You may also have the right to opt out of sales of your personal information, or the processing of your personal information for targeted advertising. To opt out of targeted advertising, please visit Adentro's Privacy Portal.
If you would like information regarding your rights under applicable law or would like to exercise any of them, please visit Adentro's Privacy Portal, email us at privacy@adentro.com or contact us at (800) 807-WiFi (9434) . To protect your privacy and security, we take reasonable steps to verify your identity and requests before granting such requests. If we are unable to verify your identity, we may be unable to respond to your requests.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You may also have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our best to resolve your concern.
You may also have the right to opt out of sales of your “personal information” or “personal data” (as defined in applicable law), or the processing of such information for targeted advertising. To opt out of targeted advertising, please visit Adentro's Privacy Portal.
Regional Privacy Disclosures and Rights: Additional disclosures for residents of California, Colorado, and Nevada are set forth below in Regional Privacy Disclosures.
a. Residents of Nevada
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to unaffiliated parties. You can exercise this right by contacting us as described in the “Contact Us” section below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address.
b. Residents of California
Except as explicitly stated in this Policy, this section applies solely to California residents. Throughout this Policy, we discuss in detail the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we disclose it. Under the California Consumer Privacy Act (“CCPA”), we also have to provide you with (1) the “categories” of personal information and sensitive personal information we collect and disclose for business or commercial purposes (as “categories” are defined by the CCPA); (2) the categories of other parties to whom we (a) disclose such information for a business purpose, (b) “share” information for “cross-context behavioral advertising,” and/or (c) “sell” such information.
In the twelve months leading up to the effective date of this Policy, we have collected and disclosed the categories of personal information described in Section 1 for business or commercial purposes. The categories of personal information are identifiers, financial information (such as payment information), commercial or transactional information, internet or other electronic network activity information, geolocation data (such as derived from your device connecting to the Company WiFi Services), audio or video information (such as through CCTV in our store), other information about you that you may provide to us voluntarily, other information that may identify you, and inferences drawn from the information we collect.
When you access or otherwise connect with the Company WiFi Services, we also obtain location information about you, e.g. that your device is at our location. This type of geolocation is considered “sensitive personal information” under the CCPA.
We process the categories of personal information identified above for the purposes as described in more detail in Section 2 above.
We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Company WiFi Services; and (3) other parties.
We describe our information disclosure practices in more detail in Section 3 above.
i. “Sale” and “sharing” of personal information
The CCPA sets forth certain obligations for businesses that “sell” or “share” personal information. Where we refer to “sell” or “share” (or their variants) in quotes, we are referring to those terms as uniquely defined in the CCPA.
We may collect, combine, and disclose personal information about you to build out products and services and provide services for our Clients and other business partners. We do so to assist our Clients and other partners with marketing, advertising, analytics, measurement, and attribution. This may include creating audience segments, such as identifying an audience of consumers who may enjoy coffee. As part of the advertising services we offer, our Clients can also use our services to obtain analytics, attribution, and measurement data, such as understanding the efficacy of ads promoting Client products and services. We “sell” or “share” personal information as described in the chart above. If you or your authorized agent would like to opt out of our “sharing” or “sale” of your information for such purposes, you may do so by visiting Adentro's Privacy Portal. If you have a legally recognized browser-based opt out preference signal turned on via your device browser, we recognize the preference expressed by such signal in accordance with applicable law.
We do not knowingly “sell” or “share” the personal information of children under 16.
ii. Do-Not-Track Disclosure
We do not respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
iii. Retention of Personal Information About You
Please see the Retention of Personal Information section below.
iv. Other CCPA Rights
California residents can make requests about their personal information as described as set forth in Your Privacy Choices and Rights section above and also through our phone number at (800) 807-WiFi (9434) . The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA (e.g., to provide the Company WiFi Services to you).
v. Shine the Light
California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. To request such information, please contact privacy@adentro.com.
The Company WiFi Services are not designed for minors under 18, and our Terms of Service prohibit use by anyone under 18. If we discover that an individual under 18 has provided us with personal information, we will delete the personal information to the extent required by applicable law. We may, where permitted by law, retain certain information internally for purposes described in this Policy.
Company implements technical, administrative, and physical safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Therefore, we do not promise and cannot guarantee the security of your information or communications.
We store the information we collect as described in this Policy for as long as you use the Company WiFi Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Company WiFi Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
To determine the appropriate retention period for information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the information, certain risk factors, the purposes for which we process your information, and whether we can achieve those purposes through other means.
Your information may be stored and processed in the United States and other countries outside the United States that may have data protection laws that differ from the laws in your country, and data may be accessible to law enforcement and national security authorities under certain circumstances. By using the Company WiFi Services, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable countries in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside and/or are a citizen.
The Company WiFi Services may contain links to other websites/applications and other websites/applications may reference or link to our Company WiFi Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing information to third-party websites or applications is at your own risk.
We may change this Policy to reflect changes in the law, our information practices or the features of the Company WiFi Services. We will indicate the date of the most recent update in this Policy. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Company WiFi Services, you are confirming that you have read and understood the latest version of this Policy.
If you have any questions about our privacy practices or this Policy, or to exercise your rights as detailed in this Privacy Policy, visit Adentro's Privacy Portal or contact Adentro at privacy@adentro.com or at (800) 807-WiFi (9434) .