This policy applies to all the websites We operate, Our use of emails and any other methods We use for collecting information. It covers what We collect and why, what We do with the information, what We won’t do with the information, and what rights you have.
Who We are
In this policy, whenever you see the words (‘We’, ‘Us’ or ‘Our’), it refers to Sugar WiFi, 318C King Georges Avenue Singapore 208563.
Information We collect
We will only ever collect the information We need – including data that will be useful to help improve Our services.
We may automatically collect and process the following data about you:
- any correspondence between you and Us, your responses to any surveys that We ask you to complete for research purposes, details of any transactions which you carry out through the Service, your browsing history and details of your use of the Service including (without limitation) location data, weblogs and other communication data and resources accessed by you (Additional Information);
- any information which We collect about the computer, tablet, mobile telephone, smart phone or other electronic device used to access the service (Device) including (where available) MAC address of any connected network interface, the unique device identifiers, operating system, browser types and telephone number (if applicable) of the Device (Device Information);
- any information which We collect about your actual location and relative signal strength, and data collected by Us for Wifi enabled Devices present at a location by means of relative signal strength from Wifi access points from which an X/Y coordinate is calculated (Location Information);
- any data collected by Us when Your device is used to access the Service including (without limitation) internet protocol addresses, internet service providers, browser types, language, viewed and exit pages and date and time stamps (Log Information);
- details of your visits to Our site including but not limited to, IP addresses (the location of the computer on the internet), pages accessed and files downloaded. This helps Us to determine how many people use Our sites, how many people visit on a regular basis, and how popular Our pages are. This is statistical data about Our users’ browsing actions and patterns, and does not identify any individual. It simply allows Us to monitor and improve Our service.
Personal information, such as name, postal address, phone number, email address, date of birth, gender and social media account details (such as Facebook, Twitter, Instagram, etc.) that you provide by registering and using Our Wifi services, filling in forms on Our web site and when you contact Us via telephone and includes information provided when you:
- subscribe to receive one of Our e-communications;
- enquire about a specific product or service;
- request information via telephone;
- request a call back;
- respond to a campaign;
- enter a competition or promotion;
- submit a question to Us or provide Us with feedback.
You are provided with an opportunity to opt out from receiving communications from Us or Our partners at the time that your details are submitted and on each occasion that you are contacted thereafter.
How We use the information We collect
If you have provided Sugar WiFi with personal data to access Wifi in a venue then We will use this data for the performance of the contract described in Our terms and conditions of service which you agreed to when accessing the service.
We may also process your personal data for Our legitimate business interests. “Legitimate Interests” means the interests of Our company in conducting and managing Our business and providing you with the best services and products in the most secure way. These interests include:
- To ensure that content from Our site is presented in the most effective manner for you and for your computer.
- To collate and aggregate anonymised information for consumer analysis and statistical reporting.
- To associate Submitted Information and/or Additional Information and/or Device Information and/or Location Information and/or Log Information to enable analysis by Us and the owner or sponsor of any venue at which You use the Service as to how people move around such venues – in such circumstances, the MAC address of your Device is masked to prevent linking data to other sources.
- To contact you regarding your opinions on Our products and services which may be used for research and analysis to help Us to improve or modify those products and services.
- To help Us identify you when you contact or visit Us.
- When dealing with your inquiries and requests.
- To help Us improve the quality, security and safety of Our products and services
- To carry out analysis and customer profiling.
- When you communicate with Us for customer service or other purposes (e.g., by emails, faxes, phone calls, tweets, etc.), We retain such information and our responses to you in the records of your account.
When We process your personal data for Our legitimate business interests We always ensure that We consider and balance any potential impact on you and your rights under data protection laws.
If you have any concerns about the processing described above, you have the right to object to this processing. For more information on your rights please see “Your Rights” section below.
Choice / opt-in and opt-out
Whenever the processing of your personal data requires your consent then you will be given the opportunity to opt-in or opt-out to having your contact details used as set out above, at the time your details are submitted.
For example, when you request product information, you can tell Us when you provide your details if you do not want to receive any other information from Us or Our partners, or you can let Us know how best to get in touch with you with information that may be of interest.
If you do not wish Us to use your data as set out above, please leave the relevant boxes, situated on the form which We used to collect your data, blank/unticked.
Please be aware that if you opt out of marketing communications received from one of our partners, and your information is also held by other partners, you may continue to receive information from these other partners until you inform them that you wish to opt out of marketing communications as well.
Sharing your information
Just like most other organisations, We work with third-party service providers which provide important functions to Us that allow Us to be easier, faster, and friendlier in the way We deliver Our services. We need to disclose user data to them from time to time, for any of the purposes set out above, so that the services can be performed.
We have listed below, those parties to whom We may disclose your personal data for the purposes set out in this policy:
- Our employees;
- the owners of the venues where you access Our wifi services;
- Virtual hosting infrastructure providers to host our servers and data, and to provide other services to Us.
- third party consultants, service providers or contractors when providing support and other services to Us;
- auditors or advisers assisting Us in Our business operations in any jurisdiction where we operate.
We may also disclose your personal information to third parties, if We are under a duty to disclose or share your personal data for legal or regulatory purposes, in relation to existing or future legal proceedings, for the prevention of fraud/loss or to protect the rights, property, safety of Our Group, Our customers or others.
Our standard policy is to store your personal Information on hosted services located in London for data collected in the EU and Africa, New York for data collected in North and South America and Singapore for data collected in Asia and Australasia. However, from time to time, We may allow individual customers to store your personal information on their own servers located within their own country when they are legally obligated to do so or when they request this. We may transfer the information to other offices and to other reputable third-party organisations as explained above – they may be situated inside or outside the European Economic Area, if this is the case We ensure that compliant safeguards are put in place and clearly communicated to you. We may also store information in paper files.
We have security protocols and policies in place to manage and record your data privacy and preferences correctly and that your data is stored securely to protect against its loss, misuse and alteration. Documentation can be supplied on request from Our Data Protection Officer using any of the contact methods listed below In Your rights.
Unfortunately, the transmission of data across the internet is not completely secure and whilst We do Our best to try to protect the security of your information We cannot ensure or guarantee that loss, misuse or alteration of data will not occur whilst data is being transferred.
We will keep your information only for as long as We need it to provide you with the services or information you have required, to administer your relationship with Us, to comply with the law, or to ensure We do not communicate with people that have asked Us not to. When We no longer need information, We will always dispose of it securely, using specialist companies if necessary to do this work for Us. If you are a user of Our Wifi services and you do not login to one of Our Wifi venues for more than 13 months, all personally identifiable data We store about you is deleted.
Under the data protection legislation, You have the right to request copies of your data, request rectification of your data, request erasure of your data, object to Us processing your data, the right to prevent your data being used for direct marketing, request Us to restrict the processing of your data and where Our systems allow, the right to access a copy of the information We hold about you (a subject access request) and the right to lodge a complaint with the relevant data protection authority. We will require proof of your identity before we are able to provide you with any personal information that we hold about you.
The following information provides more detail about some of these rights and how to exercise them:
- Right to make a Subject Access Request (“SAR”)
You have the right to view and request copies of your personal data that We hold about you. You are able to view or delete this information through Our portal, login details are emailed to you when you first register onto our wifi services. You may also request this information by contacting Us via one of the methods described below.
- Right to Rectification
You can request that we rectify inaccuracies and missing information in personal data held about you.
- Right to Object to Processing
You may have the right to object to Us processing your personal data and request that We stop processing it. You may do this by emailing Our Data Protection Officer (see below for details).
- Right to Request Erasure
You have the right to have your personal data erased where the data is no longer necessary for the purpose(s) for which it was originally collected/processed unless we have legitimate grounds or a legal right(s)/obligation(s) to store your personal data.
If you wish to exercise any of these rights please contact the Data Protection Officer in writing at 318C King Georges Avenue Singapore 208563 or by emailing firstname.lastname@example.org.