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 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 NRVE router (of any NRVE 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 EU Law” 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 NRVE 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 purposes:
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:
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 NRVE, 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:
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 Law:
Your local laws (e.g., laws of the E.U.) may permit you to request that we:
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.
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.
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.
California Privacy Rights
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 using the information provided below.
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. We also will honor similar requests from parents and guardians in jurisdictions where the age threshold provided by law is 16 or higher.