Last updated: May 01, 2017
- Information we receive from or on behalf of our clients, such as the email addresses their customers supply when signing up for WiFi or visiting our clients’ websites, as well as certain information collected in connection with the WiFi routers; and
- Information collected from visitors to GoGoGuest’s own website, GoGoGuest.com.
1. PRIVACY PRACTICES FOR INFORMATION WE RECEIVE FROM OR ON BEHALF OF OUR CLIENTS
In an expanding number of cities, we provide our clients (coffee shops, pubs, bars, craft brew pubs, restaurants, stores and other businesses) with a platform that integrate with their wireless routers that let them share their Internet connection with people around their location. Like all WiFi routers, ours receive the unique MAC address of nearby wireless devices, such as smartphones. We keep a record of these MAC addresses and the WiFi 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 WiFi, a person must (1) submit basic contact information, such as an email address, and (2) agree to terms and privacy practices. The user may choose to make a purchase using our platform while in our client’s venue or enter additional information, such as their credit card information and billing address.
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 WiFi range of another GoGoGuest router (of any GoGoGuest 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 GoGoGuest does not review or record the actual WiFi traffic (such as the content of emails sent through the WiFi or the URLs of web pages visited). A user’s purchases are recorded in the account and purchase history to help validate transactions and charges between our client and a user.
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.In addition to the above, our 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 InformationWe use the information described above (sometimes in combination with other information we obtain) for the following purposes:To help clients administer their WiFi networks and contact listsTo 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 processesTo create aggregate or de-identified information, or to correlate likely identities over time and across platformsFor compliance with law, fraud prevention, risk mitigation, resolution of disputes, enforcement of legal terms, and similar purposesTo otherwise analyze, improve and provide products and servicesFor 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 servicesIn 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 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 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 GoGoGuest, 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 support@GoGoGuest.com. If you opt out, we also will refrain from using the list of locations where our WiFi routers detect your device for marketing purposes. However, you will not be able to use most or all of GoGoGuest clients’ WiFi if you opt out. Alternatively, you may deactivate your device’s WiFi, 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 support@GoGoGuest.com to make those requests or for help with the MAC address opt-out described above.
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.
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 higher.