Effective Date: 10 March 2020
1. Information we receive from or on behalf of our clients, such as the email addresses their customers supply when signing up for Wi-Fi or visiting our clients’ websites, as well as certain information collected in connection with the Wi-Fi routers; and
2. Information collected from visitors to riglobe’s own website, www.riglobe.com
1. PRIVACY INFORMATION RECEIVE FROM OR ON BEHALF OF OUR CLIENTS
In an expanding number of countries, we provide our clients (restaurants, stores, retails, school and other businesses) with wireless access point or routers that let them share their Internet connection with people around their location. Like all Wi-Fi access point or routers, ours receive the unique MAC address of nearby wireless devices, such as smartphones. We keep a record of these MAC addresses and the Wi-Fi access point or routers they are near, absent a legal constraint or an applicable opt-out. To sign up to use the Internet connection though a client’s Wi-Fi, a person must (1) submit basic contact information, such as an email address, and (2) agree to terms and privacy practices. (3) Using social media account to log in for access. The user may choose to enter additional information, such as their month and day of birth.
After a user signs, up, we associate their email address and other personal information with their device’s MAC address and with any location history we may previously have gathered (or later gather) for that device’s MAC address. Later, when the user’s device returns to this client location or enters the Wi-Fi range of another Riglobe access point or router (of any Riglobe client), we automatically recognize the device and record the visit in our record for that device, unless the user has opted out. We also may record information about whether and when the individual used the Internet, but Riglobe does not review or record the actual Wi-Fi traffic (such as the content of emails sent through the Wi-Fi or the URLs of web pages visited).
Online Analytics Platform:
Riglobe Enterprise clients may provide us with personal information (usually about their current and potential customers), such as customer contact or point-of-sale information. We also collect information from third-party sources (such as social networking platforms). We may enhance the data we receive from or on behalf of a particular client with data that we receive from other data sources or that we have inferred or modeled ourselves.
Uses of Information
We use the information described above (sometimes in combination with other information we obtain) for the following purposes: To help clients administer their Wi-Fi networks and contact lists. To help clients learn more about their current and prospective customers, and to assist them (or others) in identifying trends, inferences, affinities or patterns among customers or prospective customers (whether those customers are identified, de-identified or aggregated). To help clients with communications and marketing (such as content recommendations and optimization, ad targeting, and other promotional activities). To facilitate surveys and other business processes. To create aggregate or de-identified information, or to correlate likely identities over time and across platforms. For compliance with law, fraud prevention, risk mitigation, resolution of disputes, enforcement of legal terms, and similar purposes. To otherwise analyze, improve and provide products and services. For other purposes requested or authorized by our clients.
2. PRIVACY PRACTICES
We collect information, including when you provide information directly to us and when we passively collect information from you. Visitors to our website may submit contact information, such as their name, address, email address and phone number, as well as information required to make payments to us. They also may submit information about their business. Section 1 above describes the collection of various types of information from website visitors using automated technologies (such as cookies). On our website, we and our third-party providers may collect the same sorts of information, using the same sorts of automated technologies, for the same sorts of purposes, and with the same opt-out options.
Uses of Information
We use the information collected on our website (sometimes in combination with other information we obtain) for the following purposes:
To communicate with current and prospective clients, including for marketing and promotional purposes (for example, by using cookies and other technologies described above to target or retarget ads and offers to our own customers when they browse the internet)
To facilitate surveys and other business processes
To create aggregate or de-identified information
For compliance with law, fraud prevention, risk mitigation, and similar purposes
To otherwise analyze, improve and provide products and services.
Other purposes for which the individual provided it
3. ADDITIONAL INFORMATION ABOUT PRIVACY PRACTICES
Disclosures of Information
We disclose information as described below:
To Our Client. When we collect information for or on behalf of a client, we may share that information with that client.
Affiliates. We may share information with our affiliates.
To Agents & Contractors. We may share information with third parties that help us operate our business and provide our services, such as contractors that provide us with technology, services, data or content (e.g., a hosting / cabling provider).
For Legal Reasons. We may share information when we believe that doing so is appropriate to comply with the law; enforce or apply our agreements; or protect the rights, property, or safety of Riglobe, our clients, our employees, or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Changes in the Structure or Ownership of the Company or its Assets. We may transfer the information we hold in the event we sell or transfer all or a portion of our business or assets (such as in connection with a merger, acquisition, reorganization, dissolution or liquidation) or take steps in anticipation of such a transaction.
Aggregated or De-Identified Information. We may share aggregated or de-identified data without restriction.
At a Client’s Request. At the request of a client, we may also make additional disclosures of information we hold for that client.
Consent or Legal Permission. We may engage in additional sharing of information with the consent of the individual to whom it pertains or when otherwise permitted by law.
Opt-out and Privacy Rights
To opt out of our use of your device’s MAC address for marketing purposes, please email firstname.lastname@example.org. If you opt out, we also will refrain from using the list of locations where our Wi-Fi routers detect your device for marketing purposes. However, you will not be able to use most or all of riglobe clients’ Wi-Fi if you opt out. Alternatively, you may deactivate your device’s Wi-Fi, which will prevent our further collection of your device’s MAC address.
The law of your country you may give you additional rights to access, correct, update or delete certain personal information we hold about you. Your country may also give you additional rights to object to our processing of your personal information or to withdraw your consent to our processing of your information. You may contact us at email@example.com to make those requests or for help with the MAC address opt-out described above.
We may change this Statement from time to time. If we make significant changes in the way we treat your personal information, or to the Statement, we will provide you notice through the Services or by some other means, such as email. Your continued use of the Services after such notice constitutes your consent to the changes. We encourage you to periodically review the Statement for the latest information on our privacy practices.
If you have any questions about this Privacy Statement, please contact us a firstname.lastname@example.org.