Effective Date: April 24, 2020
GO TO ZENREACH’S PRIVACY PORTAL FOR INFO ON HOW TO OPT OUT OF OUR ENHANCED WI-FI OR OUR USE OF YOUR MAC ADDRESS FOR MARKETING PURPOSES.
1. Information we receive in connection with our relationship with our clients, such as the email addresses their customers (“End Users”) supply when signing up for our Wi-Fi with enhanced marketing features (the “Enhanced Wi-Fi”) or visiting our clients’ websites, as well as certain information collected in connection with the Enhanced Wi-Fi routers; and
2. Information collected from visitors to Zenreach’s own website, zenreach.com.
1. Privacy Practices for Information We Receive in Connection with Our Relationship with Our Clients
In an expanding number of cities, we provide our clients (restaurants, stores and other businesses) with wireless routers that let them share their Internet connection with people around their location. Our clients’ End Users in the European Union and California can elect to just access the Internet via the client’s Wi-Fi, or they can voluntarily opt into the Enhanced Wi-Fi. For those who do not opt into the Enhanced Wi-Fi, we collect limited technical information that does not identify the End User and process such information to provide and troubleshoot Wi-Fi access. We retain such technical information collected for no more than thirty days. For those End Users who register for the Enhanced Wi-Fi, we receive and maintain the unique MAC address of your wireless device and the nearby Wi-Fi routers to provide you with the enhanced marketing features. To sign up for Enhanced Wi-Fi, an End User must (1) submit basic contact information, such as an email address or mobile phone number, and (2) agree to terms and acknowledge our privacy practices. The End User may choose to enter additional information, such as their month and day of birth.
After an End User signs up for Enhanced Wi-Fi, we associate their email address and other personal data with their device’s MAC address and any location history we may later gather for that device’s MAC address. Later, when the End User’s device returns to this client location or enters the Wi-Fi range of another Zenreach router (of any Zenreach client), we automatically recognize the device and record the visit in our record for that device, which enables us to provide you enhanced marketing features, such as coupons for businesses you already patronize. End Users may opt out of Enhanced Wi-Fi at any time, and End Users may also request that we delete their personal data at any time. Please see the sections below entitled, “Opt-Out and Privacy Rights” and “Your Legal Rights Under Local Laws” for more information. We also may record information about whether and when the End User registered for Enhanced Wi-Fi has used the Internet, but Zenreach 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).
In addition to the above, our clients may provide us with personal data (usually about their current and potential customers), such as customer contact or point-of-sale information. As permitted by applicable law, we may 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.
Cookies and Other Technologies:
If you are interested in more information about tailored browser advertising and how you can generally control certain cookies from being put on your device to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out Link, the Digital Advertising Alliance’s Consumer Opt-Out Link or the European Interactive Digital Advertising Alliance Opt-Out Link to opt out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that you will still receive advertising content even if you opt out of tailored advertising. Also, we do not control the four opt-out links above and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browser is configured to reject cookies when you visit an opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your opt-out may no longer be effective. Additional information is available on the websites accessible by the above links.
Uses of Information
We use the information described above (sometimes in combination with other information we obtain) for the following business and commercial purposes:
- To help clients administer their Wi-Fi networks and contact lists
- To help clients learn more about their current and prospective customers, and in accordance with local laws, to assist them (or others) in identifying trends, inferences, affinities or patterns among customers or prospective customers
- 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
- 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 for Information We Collect on Our Own Websites
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.
Job applicants on our site may submit their employment details and other information typically found in résumés. On a strictly voluntary basis, job applicants can also submit responses to certain demographic and life-history questions that we ask for equal employment compliance purposes.
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
- In the case of job applications, to evaluate candidates for possible employment or for related employment compliance purposes
- 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 Clients. When we collect information for or on behalf of a client, we may share certain information with that client to help our clients learn more about their current customers, and to assist them (or others) in identifying trends, inferences, affinities or patterns among customers (whether those customers are identified, de-identified or aggregated). We also share anonymized data (e.g. when coffee shops are the busiest) among our clients to assist them in communications and marketing activities (such as to provide content recommendations and optimization, ad targeting, and other promotional activities to you).
Affiliates. We may share information with our affiliates who provide services to us.
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 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 Zenreach, 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.
OUR LEGAL BASES FOR USE OF YOUR INFORMATION
The laws of some jurisdictions such as the laws of the European Union require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing of your information. To the extent those laws apply, our legal grounds are as follows:
- With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent. For example, when you registered and consented to our Enhanced Wi-Fi, you consented to our use of your information for marketing purposes.
- Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for our Wi-Fi and Enhanced Wi-Fi, preventing fraud, and managing legal issues.
- Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.
Opt-out and Privacy Rights
To opt out of the Enhanced Wi-Fi (and our use of your device’s MAC address for marketing purposes), please email firstname.lastname@example.org. Alternatively, you may deactivate your device’s Wi-Fi, which will prevent our further collection of your device’s MAC address.
Your Legal Rights Under Local Laws:
Residents of the European EU and European Economic Area Countries
Your local laws (e.g., laws of the E.U.) may permit you to request that we:
- provide access to and/or a copy of certain information we hold about you;
- prevent the processing of your information for direct-marketing purposes; (including any direct marketing processing based on profiling)
- update information which is out of date or incorrect;
- delete certain information that we are holding about you;
- restrict the way that we process and disclose certain of your information;
- transfer your information to a third-party provider of services; and
- revoke your consent for the processing of your information.
Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.
To exercise any of these rights, please contact us as described in the “Contacting Us” section below. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
Please see below for details on rights for California residents.
How long we keep information
We generally retain information for so long as it may be relevant to the purposes above and in compliance with applicable law. To dispose of any personal data, we may anonymize it, delete it or take other appropriate steps. Information may persist in copies made for backup and business continuity purposes for an additional period of time.
If you believe that any child under 13 has provided us with any personal information, we ask that the parent or guardian of that child contact us to ensure that such information is deleted from our files in accordance with applicable law. We also will honor similar requests from parents and guardians in jurisdictions where the age threshold provided by law is 16 or higher.
1 Letterman Dr Bldg C, Ste 3500
San Francisco CA, 94129.
Supplemental Privacy Notice for California Residents
Summary of Information We Collect
California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.
We or our service providers may collect the below categories of information for the following business purposes (as those terms are defined in applicable law):
- Providing the Services (e.g., enabling access to the Enhanced Wi-Fi, account servicing and maintenance, customer service and other communications with you, advertising and marketing, analytics, and communication about the Service);
- Our or our service provider’s operational purposes;
- Auditing consumer interactions on our site (e.g., measuring ad impressions);
- Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity, including protecting against unauthorized access/use of the Services, and preventing, detecting, and responding to breaches of terms and policies;
- Bug detection, error reporting, and activities to maintain the quality or safety of our Services (e.g. fixing the Services);
- Short-term, transient use, such as customizing content that we or our service providers display on the Services;
- Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
- Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third-party partners; and
- Other uses about which we notify you.
We may also use the personal information we collect for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.
In the past twelve months, Zenreach has collected the following categories of personal information about California consumers:
- Identifiers, such as an email address;
- Commercial information, such as transaction data we receive from your use of the Zenreach.com website;
- Location information, namely general location based on where you use the Services;
- Sensory information, such as audio recordings if you call our customer service; and
- Other information that identifies or can be reasonably associated with you (such as communications you send us).
We collect personal information from the following categories of sources:
- Your use of our services or automatically collected from you;
- Our Affiliates; and
- Third parties, such as our agents and/or service providers.
In the preceding twelve months, we have shared each of the categories of personal information identified above to the following categories of third parties for business purposes:
- Service providers; and
Our clients also receive personal information about End Users directly from the End Users or where End Users direct us to share their data.
If you are a California resident, you may have certain rights. California law may permit you to request that we:
- Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
- Provide access to and/or a copy of certain information we hold about you.
- Delete certain information we have about you.
You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.
If would like to exercise any of these rights, please submit a request at email@example.com or visit https://my.zenreach.com/privacy/request/zenreach/. You will be required to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us. Please note that we cannot honor requests with respect to personal information that we process on behalf of our clients as a service provider. For such data, please contact the restaurant, store, or other business for which you would like more information regarding your rights.
California residents may opt out of the “sale” of their personal information. Zenreach does not “sell” your personal information as we understand that term to be defined by the California Consumer Privacy Act and its implementing regulations.
California Shine the Light
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you would like to make such a request, please contact us at firstname.lastname@example.org.
California Do-Not-Track Disclosure
We do not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations and solutions.
Updated: April 24, 2020