PRIVACY POLICY

Dear customer,

This User Privacy Notice (“Privacy Notice” or “Notice”) was last updated on 1st May 2018. This Privacy Notice may vary from time to time so please check it regularly.

This Notice describes the types of information collected, how that information is used and disclosed, and how you can access, modify, or delete your information.

Inkspotwifi Limited (company number SC 384468) whose registered office is at 3a Dublin Meuse, Edinburgh, EH36NW (“we”, “us” or “our”) is the ‘data controller’ for the personal data we collect. We are registered with the Information Commissioner’s Office with registration number ZA273646.

Wi-Fi

Inkspotwifi does not collect any information through its websites that can be connected to your person (name, address, phone number or e-mail), unless you voluntarily decide to provide it to us. (by registration or answering to questionnaires). Inkspotwifi is organising and storing the personal data provided by you (time of registration, chosen package) in order to operate the system. Inkspotwifi states that it is storing and documenting your data in order to complete your orders and to confirm your future requests. 

Some of our sites have Wi-Fi provided directly by us, and others are provided via third parties. You will also be offered the opportunity to subscribe to email marketing.

We are obliging ourselves, to handle the information collected by us according to the law. Upon transferring personal data to us, you agree to the registration and management of your personal data for purposes and period of time depending as essential by the nature of the service.

Inkspotwifi is exempt from liabilities deriving from damage due to unauthorised use, disclosure or loosing of user login name, password or certificate.

Through our Wi-Fi service, we may also collect data which shows how often, how long and from which one of our venues you are accessing the Wi-Fi services, which will include recording the address of your device that connects to the Wi-Fi network.

We use Wi-Fi within some of our venues that may communicate with your mobile device to identify its location if the device has Wi-Fi enabled and is properly configured. This will operate irrespective of whether or not you have subscribed to the Wi-Fi service. When this location information is analysed it will be aggregated to prevent any identification of individuals.

To opt out of the collection of your MAC or Internet Protocol (IP) address and location, turn off your device’s Bluetooth and Wi-Fi capabilities.

The address of your device will be stored for as long as it connects to the internet, and will be stored to allow you to reconnect at a later date.

The personal information gathered through Wi-Fi for Inkspotwifi’s legitimate business interests, to:

  1. Tailor our online services to you so the content you see is relevant to you. For example, we may request your date of birth, gender and some basic interests (such as ‘shopping’ and ‘dining’) so that we can provide you with content that we think you will be interested in – “profiling”; and

  2. Collect data obtained through our interaction with customers for research, analysis, testing, monitoring, risk management and administrative purposes including the optimisation of service delivery at our venues and to improve the customer experience.

The legal basis is also to form a contract with you to provide the Wi-Fi Service.

You may also be asked to consent to email marketing. You can withdraw this consent at any time.

Children

Children under the age of 13 are not permitted to use Wi-Fi networks. If you have reason to believe that a child under the age of 13 has provided personal information, please contact us and we will delete that information from our databases.

Protection of your information

We have in place administrative, technical and physical measures designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of the personal information that we hold. We place similar obligations on our third parties and risk assess their security based on the sensitivity of the personal data that they hold.

If we transfer your personal information outside of the EEA, it will continue to be subject to one or more appropriate safeguards set out in the law. These might be the use of model contracts in a form approved by regulators, or having our suppliers sign up to an independent privacy scheme approved by regulators (like the US ‘Privacy Shield’ scheme).

Your rights

Your duty to inform us of changes

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

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please email dataprotection@inkspotwifi.co.uk

    You will not have to pay a fee to access your personal information (or to exercise any of the other rights); however, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. You can also contact the Information Commissioner's Office via https://ico.org.uk/ for information, advice or to make a complaint.

  • What we may need from you

    We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

    For more information, please contact the data protection officer on dataprotection@inkspotwifi.co.uk

    Online Payments and Processors

    In case of online payment we are not storing and we don't see the card information (number of card and expiry date), because the transaction happens directly though a 3rd-party payment processor (WorldPay or PayPal).

    Changes to the privacy policy

    This Privacy Notice was last updated on 11 May 2018. If it is necessary for us to alter the terms of the Privacy Notice, we will post the revised Privacy Notice here. We encourage you to frequently review the Privacy Notice for the latest information on our privacy practices.

    How you can contact us

    If you have any questions about this Privacy Notice, please contact the Data Protection Officer at dataprotection@inkspotwifi.co.uk


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