SpotWiFi Privacy Policy

We understand you value your privacy. This Privacy Policy identifies and describes the way SpotWiFi uses the information we collect about Customers and Users. All use of SpotWiFi products and services, as well as visits to our websites, are subject to this Privacy Policy.

The Information We Collect And How We Collect It

Information Collected

Personal Information that you provide through optional submissions to SpotWiFi (e.g. your account profile and email address, and communications with SpotWiFi). This personal information may be used to identify you, including, but not limited to, your home address and telephone number (where submitted voluntarily and not as a proxy for a service provider account username).
Service Usage information, such as your location and usage data, gathered from devices that have been registered to use the SpotWiFi Service, and the Websites. This information is stored in our databases and is associated with your user account. We describe this type of information collection in the "Service Usage" section of this document.

User-Submitted Information

We ask you for Personal Information (including, for example, your name) when you register with SpotWiFi. Throughout your use of the Websites and Services, you may voluntarily submit additional information and complete your user profile with information such as your mailing address, telephone number, and other demographic information. In addition, you may communicate with SpotWiFi and our community via social media, email, and other messages. This information is used to support you and personalize the Services for you. For example, we may use your personal information to provide you with services which are based upon your geographic location.

Service Usage

We track Service Usage to enable us to offer and improve the services for our users ("Usage Data"). This Usage Data is created when you use the Websites and when a device registered with the SpotWiFi Service attempts to log on to, or otherwise connect through the SpotWiFi Service to services such as a Wi-Fi hotspot. This Usage Data can consist of the name (SSID) of the Wi-Fi hotspot; location and identification of the hotspot; status and duration of the hotspot session; and whether a registered device is currently connected to an internet connection (presence information). This information is stored in our database and is associated with your registered user account. This information may be used to help improve site flow and usability, to discourage fraudulent use, and to make available the Services.

Accessing Information and Using Functions on Your Device

In order to provide the Services to you the SpotWiFi system utilizes certain information and functions available in your Device. The following is a description of this information and functions and how they are used by the system:

Information about Wi-Fi and Network Connections is used to automatically connect your device via the best available Wi-Fi connection to the Internet. For this purpose the system utilizes information about the status of the network connections, state of Wi-Fi radio, configured Wi-Fi networks, available networks and the current connection if any. The system utilizes full network access and the Internet only to communicate with the access control systems of possible Wi-Fi connections and the SpotWIFi server system about connections and analytics. It is for carrying out these functions that the SpotWiFi app needs permission for the following things: view Wi-Fi connections; view network connections; full network access and receive data from the internet.

Location information is used by the system to confirm identity of available Wi-Fi hotspots. Among other things this protects your device from possible spoof attempts by a Wi-Fi connection presenting itself as something it is not. Location may also be used to access information about cellular connections your device may be using and to collect information about geographic distribution of data usage. We always use the network based approximate location if it is available since it is more efficient than GPS. These are the functions for which SpotWiFi needs permission for accessing precise location and approximate location information.

System tools are used only to enable providing the Services to you. For example the system will turn on and off the Wi-Fi radio system, perform scans for Wi-Fi hotspots, configure networks and connect to hotspots using these tools. Some actions the system takes and messages the system presents to you depend on whether you are looking at the SpotWIFi user interface. For this reason only, the system needs to occasionally retrieve the list of running apps to see whether SpotWIFi is on the foreground. The system does not retrieve any information about running apps or usage of apps for any other purpose and does not store this information anywhere on the device or elsewhere. To provide the Services even after shutdown or reboot of the device the SpotWiFi background service is set to start at boot of the device. In order to manage the radio effectively and to receive messages form our server the system will modify the system settings to keep the Wi-Fi system, tablet or phone system form going to a "sleep" state. It is for the above-described functions only that SpotWiFi needs permission to use systems tools like connect and disconnect from Wi-Fi; retrieve running apps; run at startup; modify system settings; prevent tablet from sleeping and prevent phone from sleeping.

Access to storage is only used to save items used in providing the Services, for example images of icons and map pins used to represent hotspots on the map display. This is why SpotWiFi needs permission to modify or delete the contents of your USB storage and modify or delete the contents of your SD card.

Phone status and identity and account information is only used to identify your device for the purposes of providing the customized Services and to utilize Google Cloud Messaging to enable communication between SpotWIFi server and your device. These are the reasons SpotWiFi needs permission to read phone status and identify and find accounts on your device.

Children

Consistent with the federal Children's Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personally identifiable information from anyone under the age of 13 without requiring parental consent. Any person who provides their personal information to SpotWiFi represents that they are 13 years of age or older.

Information Sharing

SpotWiFi keeps your Service Information completely private and uses it only to operate the SpotWiFi Service. This means that your service provider data, such as usernames, passwords, and telephone numbers are never shared.

We may share Personal Information with our subsidiaries, affiliated companies, or other trusted businesses or persons for the purpose of performing a service on our behalf. We require that these parties agree to process such information based on our instructions, and in compliance with this Privacy Statement and any other appropriate confidentiality and security measures.

SpotWiFi may share aggregate information including, without limitation, usage data with third parties for marketing and other purposes. Aggregate information is not personally identifiable and is not linked to individual users. We do not otherwise share Personal Information about our users with third parties unless doing so is appropriate to carry out a user’s request, unless we reasonably believe that doing so is legally required, or is in our interest to protect our property or other legal rights or the rights or property of others.

Merger or Bankruptcy

If we file for bankruptcy or have our assets sold to or merge with another entity, information we receive from you is a SpotWiFi asset and may be transferred.

International

The Websites are hosted in the United States. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal information to the United States which does not have the same data protection laws as the EU, and that by providing your personal information you consent to: (i) the use of your personal information for the uses identified above in accordance with this Privacy Policy; and (ii) the transfer of your personal information to the United States as indicated above.

Security

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems. We use secure server software (SSL) and firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Websites or Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Websites and the Services. We may post a notice on the Websites if a security breach occurs. If this happens, you will need a web browser enabling you to view the Websites. We may also you send an email at the email address you have provided to us for these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive such free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us at support@spotwifi.com.

Updates

We may occasionally update this Privacy Statement. When we do, we will also revise the "Last update" on the Privacy Statement. We encourage you to periodically review this Privacy Statement to stay informed about how we are protecting the personal information we collect. Your continued use of the Services and Website constitutes your agreement to this Privacy Statement and any updates.

Last Update: 3/28/2013