Last updated: May 25, 2018
Information we collect about you
We collect certain information in the course of operations. In some instances, this information may include data that could be used to identify a particular individual, otherwise referred to as Personal Information. We collect the following Personal Information:
- Device identifying information, namely your MDN, IMEI, IMSI, ICCCID and IP address
- Location information
- User-submitted data when you contact us through a Service or directly about a matter
We also collect certain data that is not Personal Information. We collect the following non-Personal Information:
- When you use our apps we collect certain usage information (“Usage Data”). The Usage Data may consist, among other information, of the amount of data used, the name of a Wi-Fi hotspot (SSID), the status and duration of Wi-Fi session and whether your device is currently connected to a Wi-Fi hotspot. With respect to Wi-Fi use, we also collect certain diagnostic information related to a Wi-Fi connection, such as signal strength and the encoding rate. We also collect certain cellular data information, such as amount of cellular data used and cell tower information. Usage Data is not personally identifying. On the other hand, some Usage Data, either alone or when combined or linked with your Personal Information, may allow your identity to be discovered. In such cases, we treat the combined data as Personal Information.
How we use your Personal Information
We use your Personal Information to operate and best serve you. We use the aforementioned Personal Information as follows:
- Location information is used by our apps to identify potential Wi-Fi hotspots to connect to. We also collect anonymous and aggregated location information about where geographically devices are that use our websites.
- User-submitted information is used to respond to your requests, inquiries, comments or concerns.
How may we share your Personal Information
We will not share any Personal Information that we have collected from you except as described below:
- Information shared with service providers. We may engage third-party service providers, such as cloud-based providers to host our apps and Google Analytics to provide analytics on the websites, to work with us to administer and provide the Services. These third-party services providers have access to your Personal Information only for the purpose of performing services for us and are obligated not to disclose or use your Personal Information.
- Information disclosed as a part of business transaction. If we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your Personal Information may be disclosed or transferred to the third-party acquirer in connection with the transaction.
- Information disclosed to comply with legal requests. It is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about you to government or law enforcement officials or private parties if we have a good faith belief that such disclosure is necessary to (i) meet any applicable law, regulation, legal process or other legal obligation; (ii) detect, investigate and help prevent security, fraud or technical issues; (iii) to prevent or stop activity we consider to be illegal or unethical; and/or (iv) protect the rights, property or safety of SpotWiFi, our users, employees or others.
We may disclose Usage Data that is aggregated or de-identified in such a way such that it cannot be used to identify you.
We use the following categories of cookies on our websites:
- Performance. These cookies are used to collect anonymous information about how you use our websites. We use Google Analytics to collect this information for us which may include recording your use of our websites. By using our websites, you agree that we can place these types of cookies on your device.
- Functionality. These cookies are used to provide services or remember settings to enhance your visit. The information these cookies collect is anonymous and does not enable us to track your browsing activity on other websites. By using our websites, you agree that we can place these types of cookies on your device.
If you'd prefer to restrict, block or delete cookies from us and or any other website, you can use your browser to do this. Each browser is different, so check the 'Help' menu of your particular browser to learn how to change your cookie preferences. If you choose to disable all cookies, we cannot guarantee the performance of our websites and some features may not work as expected.
How we secure your Personal Information
We take steps, including through contracts, to ensure that Personal Information continues to be protected in a manner consistent with the standards of protection required under applicable law. We use various measures to protect the Personal Information. We regularly test our website, data centers, systems, and other assets for security vulnerabilities. We use commercially reasonable protection technology such as encryption, firewalls and other security procedures to help protect the accuracy and security of your Personal Information and to help prevent unauthorized access or improper use. However, given that no method of transmitting information over the Internet or storing information is completely secure, we cannot guarantee the absolute security of any information.
How long do we retain your Personal Information
We retain your Personal Information for as long as necessary to provide the Services and for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.
International Transfer of Personal Information
Links to other websites and services
Attn: Data Support
5796 Armada Drive, Suite 175
Carlsbad, California 92008