29th March 2017

Privacy Policy

Your privacy is really important to WDSI, and we understand how important it is to you. Our aim is to be as clear and open as possible about what we do and why we do it. WDSI is committed to the privacy of all its customers.

This privacy policy relates to your use of a WiFi service which is operated by WDSI (the “service” or the "WiFi service") at Venue Owner’s venue locations from whose venues you have applied to access or accessed the WiFi service. This privacy policy explains how WDSI Limited ("WDSI" or “we”) use your personal information which may be collected when you use the WiFi service.

Please read this privacy policy carefully before using the WiFi service.

1. Your Personal Information

When you use the service, the following personal information will be collected (this is
not an exhaustive list):

• Your name;
• Your email address;
• Your mobile number;
• Your device details and MAC address;
• how you use the WiFi service (this may include the types of websites you visit, the apps you use and your amount of data usage);
• details about when and where you connect to the service including your venue location and the WiFi access point(s) where you are using the WiFi service. This data will be collected automatically by the wireless access point unless your phone/device is switched off or you have switched off WiFi on your phone/device; and
• your communications with us in connection with the WiFi service. (your "Personal Information") We will collect your Personal Information from you, from your use of the service and from social media providers if you register using a social media account.

2. Who we share your Personal Information with We may share some or all of your Personal Information with:

• The Venue Owner (see below for details of when, what information and how it will be used);
• Our service providers involved in providing the services to you;
• Law enforcement agencies, regulators, courts and public authorities;
• Emergency services;
• our marketing agents; and
• prospective or actual purchasers, sellers or partners and their advisers if we decide to sell, buy, merge or otherwise re-organise our business.

3. How we use your Personal Information

WDSI will use your Personal Information to provide the WiFi service to you and to help us develop our offers, products and services and the layout of our websites to ensure that our services are as useful and enjoyable as possible and to provide the best customer experience we can. In addition, we will use your Personal Information for the following purposes:

(a) Marketing

We may use your Personal Information to inform you by letter, phone, SMS, email or otherwise, about offers and products and services that we think may be of interest to you about us and Group Companies ("Group Companies" means WDSI Limited, our subsidiaries and any parent undertakings as defined in the Companies Act 2006). To opt out of WDSI marketing communications, please follow the opt out process in the marketing communication or email us at web@wdsiasia.com

(b) Customer care and correspondence

As part of our customer care procedures, we may follow-up, either by letter, phone, SMS, email or otherwise with customers who use the WiFi service. We may use your Personal Information to tell you about functionality changes to our websites, changes to our services or changes to our terms and conditions, to remind you about your customer benefits, to advise you regarding the use of our services and to respond to customer queries.

(c) Market research

From time to time, we may also use your Personal Information to contact you for market research purposes. We may contact you by letter, phone, SMS, email or otherwise. There is no obligation on you to take part in any research.

(d) Traffic Management and data analytics

Your Personal Information will also be used for traffic management purposes. We will also carry out research and analytics of use of our WiFi service to identify general consumer trends, to understand better customer, consumer and social behaviours and to improve our products and services. We may provide aggregated statistics about our sales, customers, traffic patterns to third parties but these statistics will not include any information that is likely to identify you as an individual.

(e) Law enforcement and protection of WDSI and its customers

We may also use your Personal Information to comply with applicable laws, regulations, court orders, government and law enforcement agencies’ requests, to operate our systems properly or to protect ourselves or our users and customers or to solve any disputes. We may also use your Personal Information for the prevention or detection of crime including fraud.

4. Cookies

Our authentication system sets a cookie at the beginning of each WiFi session to ensure that the user is authorised to access the WiFi service. A cookie is a small unique text file placed on your device when you visit a website which enables the website to identify your device whenever you visit that website. The cookies we use are session cookies which remain on your device until you close your browser when they automatically expire. You can refuse cookies by changing the relevant settings on your browser to prevent automatic acceptance and prompt you every time a cookie is sent to your device or to allow you to choose not to receive cookies at all. Some cookies are essential for us to provide you with the WiFi service and if you refuse them, you may not be able to use our WiFi service. If you carry on using the WiFi Service and do not change your browser settings we will assume that you consent to us using cookies as described above. Websites that you visit using the WiFi service may deploy cookies. WDSI has no control over that deployment. You should read the privacy and cookie policies of the sites which you visit when using the WiFi service for details about the cookies used by them.

5. How long we retain your Personal Information

We will retain your personal information as required for our business purposes and in accordance with our legal and regulatory obligations. Data relating to your access to the WiFi service will be kept for at least a year to comply with our legal obligations.

6. How the Venue Owner uses your Personal Information

If we obtain your consent to do so, WDSI will share with the Venue Owner the following information that you provide or (if you register using a social media account) that is collected from the social media provider to register to use the WiFi service:
• your name;
• your email address;
• your mobile number;
• any other information you have provided to us to register for the WiFi Service.
(collectively your "registration data").
The Venue Owner may use your registration data for internal analytics and marketing purposes. The Venue Owner may share registration data with the Venue Owner's group companies, affiliates and service providers for these purposes. Please note that WDSI is not responsible for the Venue Owner's use of your Personal Information and if you have any queries in relation to the Venue Owner's use of your personal information, please contact the Venue Owner.

7. Your Right of Access to Your Personal Information

If you want, you can always access your personal information. Just make a written request to our Disclosures team at the address below clearly identifying yourself and the information you require. We may charge you £10 to cover the cost of processing your request and supplying your information to you. We will ask you to provide identification to ensure we do not disclose your information to the wrong people. If you tell us that we hold any inaccurate information about you we will correct it at no charge to you.

Please write with your full name, address and telephone number to Support Team, WDSI Limited, 354 Omega Court, Cemetery Road, Sheffield, S11 8FT

8. Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on our website at www.wdsigroup.com.

By continuing to use our services you acknowledge and agree WDSi to make those changes.