Privacy Policy

Last updated: September 14, 2018

Protecting your privacy is really important to us. With this in mind, we’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive through our Services.

OVERVIEW

GoGoGuest (“GoGoGuest“, “we” or “us“) respect your privacy. This privacy notice (“Notice“) explains who we are, how we collect, use and share information that identifies you (directly or indirectly) (“Personal Information”), and how you can exercise your privacy rights.

This Privacy Policy covers GoGoGuest’s handling of two categories of information:

  1. Information we collect and receive from or on behalf of our Clients and their Users, such as the email addresses their Subscribers supply when signing up for WiFi or visiting our Clients’ websites, social sites, as well as certain information collected in connection with the WiFi routers and other digital touch points our Client chooses to integrate with their GoGoGuest Services; and
  2. Information collected from visitors to GoGoGuest’s own website, GoGoGuest.com and sub-domains and in connection with our events, recruitment, sales and marketing activities.

a. About Us.

GoGoGuest is a company headquartered in San Francisco, CA. We provide consumer intelligence and customer marketing software products and services that allow our Clients to capture customer data through digital touch points in their physical store and online store, build and send out marketing messages to their Subscribers. Through our application, our Clients can also store information about and track the engagement of their Subscribers.  You can find out more about us and our products here.

b. Key Terms.

In this Notice, the terms below have the meanings defined below:

i. “Clients” means the entity we have contracted with to provide the Services, which if you are a User, generally refers to the entity of which you are an employee, contractor, member or other participant.

ii. “Subscribers” means any individual: 1) whose information is stored or collected by our Users on or via the Services; and/or 2) to whom Users send emails to or otherwise engage or communicate with via the Services.

iii. “Services” means the GoGoGuest business WiFi service management, customer data and insights, email marketing software, products, applications, tools, and/or related services.

iv. “User” means any individual who has registered to use and access the Services under the Client account and who directly builds, sends, collaborates on and/or reviews emails or forms through the Services.

vi. “Website” means any website we own and operate (such as www.gogoguest.com and any sub-domains).

2. GOGOGUEST CLIENTS AND USERS

This section applies to Personal Information we collect and process when you engage with us as a User of the Service. If you are not yet a User, Section 4 (applicable to visitors to our Websites) may be more applicable to you and your data.  In this Section, “you” or “your’ refer to Users.

a. Information We Process.

i. Information You Provide To Us. You may provide Personal Information to us through the Services – for example, when you sign up for a GoGoGuest  account to access the Services, consult with our customer success or support teams, send us an email or communicate with us in any other way. We will usually let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information. The information you provide to us, may include:

1. Registration Information. You need a GoGoGuest account to use the Services as a User. When you register for an account, we ask you to provide contact information such your name, email address, telephone number, job title, and organization name.

2. Billing Information. If you purchase our Services, you may also need to provide us with payment and billing information such as your credit card details and billing address. We will also maintain a record of your purchases, transactional information, your Services history and usage, and any communications and responses.

ii. Information Collected Automatically. When you use the Services, we automatically collect certain information about your device and use of the Services. We may use cookies and other tracking technologies to collect some of this information.

1. Device Information. We collect information from your device and applications you use to access our Services,  such as your IP address, device attributes (for example: hardware model, operating system, web browser version, as well as unique device identifiers and characteristics), connection information (for example, name of your mobile operator or Internet Service Provider, browser type, language and time zone, and mobile phone number); and device locations (for example, internet protocol (IP) addresses and Wi-Fi information).

2. Log data. Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services, such as images.

3. Information relating to your use of the Services. We collect usage data about whenever you interact with our Services,  which may include the dates and times you access the Services, page views, which activities and features are used of our Services, crash logs, storage configuration settings, and technical data relating to the device(s) you are using to access and use the Services and the performance of the Services in doing so.

iii. Information We Obtain From Third Party Sources. We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records and provide Services that may be of interest to you. This Personal Information may include (for example), information such as your name, employer, job title, email address, phone numbers, and other company, contact, and/or employment information.

b. Why We Process Your Information.

We process your Personal Information for our legitimate interests, which include:

i. To Provide the Services. We process your Personal Information to provide the Services as follows: i) to identify who you are, including both for identification and authentication purposes; ii) to enable you to login and access your account; iii) to respond to your inquiries; iv) to provide you with customer support; v) to send you information as part of the Services; and vi) to provide you with information about your account, including renewals and changes in Services or your account status.

ii. To Market To You. To contact you  with marketing and promotional information (in accordance with your marketing preferences) about products and services that we offer, to provide advertising to you on third party sites (based on your browsing activities on the Website), and to send you information regarding us, and/or our partners. You can can opt-out of receiving marketing communications from us at any time by unsubscribing from our Services. Marketing data purchased from third parties may be combined with information we already have about you and may be used to create more tailored advertising and products.

iii. To Customize Services to You. To help us deliver a better and more personalized experience (for example, it enables us to tailor our Services according to your interests); and to build a profile about you so as to help direct you to other relevant features and Services we offer and help you in using our Services, by making recommendations for you to optimize use of our Services.

iv. To Improve Our Services. To create new Services, features, content or make recommendations; improve our Services for you and all Users; and to fix bugs and troubleshoot product functionality.

v. For Business Analytics. To infer your geographic location based on your IP address; to track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our Services; and to conduct internal business analysis based on meta-data about usage, feature adoption and forecasting.

vi. To Prevent Abuse/Illegal Activities. To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud.

vii. For Legal Records. To identify who you are, including both identification and authentication purposes; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us (including for billing and collection); and to respond to legal requests or prevent fraud. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

c. How We Share Your Information.

In the following limited situations, we may disclose information that we collect or that you provide to us:

i. to our contractors, service providers and other third parties who provide data processing services to us and with whom the sharing of your Personal Information is necessary to undertake the work e.g. to process billing, to analyze data, host data, to provide customer support and to deliver online and offline marketing communications about us and/or our Partners that we think will interest you.

ii. as required by law, such as to comply with any court order, subpoena or other law or legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a governmental or regulatory request.

iii. to enforce our rights arising from any contracts entered into between you and us and for billing and collection.

iv. to a buyer or other successor in the event of a merger, sale or transfer of some or all of GoGoGuest’s assets.

d. Cookies And Tracking Technologies.

We (and our partners and vendors) use various tracking technologies (such as cookies and similar technologies like pixels and web beacons) to collect and store information when you use the Services.  For example, cookies allow us to collect information such as your IP address, browser, email client type and other similar details. We use this information to measure the performance of our application and to provide analytics information and enhance the effectiveness of our Services. We use page tags (also known as web beacons) in the emails we send to our Users. This means when you receive and engage with marketing messages we send to you, web beacons track certain behavior such as whether the email sent to you was delivered and opened. Links within these emails are tracked to show individual recipient’s clicks.

e. Children.

i. Our Services are not intended for and may not be used by minors. “Minors” are individuals under the age of 13 (of under a higher age if permitted by the laws of their residence).  We do not knowingly collect Personal Information from Minors or allow them to register. If it comes to our attention that we have collected personal data from a Minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.

ii. Clients and their Users are responsible for ensuring that their emails and data collection practices comply fully with applicable children’s data privacy protection legislation, such as the United States’ Children’s Online Privacy Protection Act (“COPPA”), including where relevant by obtaining parental consent prior to the collection of Personal Information. We rely upon our Clients to disclose whether or not their use is subject to COPPA.

f. Data Retention.

i. We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a Service you have requested or to comply with applicable legal, tax or accounting requirements).

ii. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise Personal Information. If this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

iii. We will retain information we process on behalf of our Clients as a data processor for as long as needed to provide Services to our Clients (unless deletion is requested at an earlier time by the Client) and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

3. GOGOGUEST CLIENTS’ SUBSCRIBERS 

This section applies to Personal Information we collect and process about our Client’s Subscribers as a data controller when providing the Services. In this Section “you” or “your” refers to a Subscriber.

IMPORTANT NOTE:  Our Services are intended for use by our Clients who control the content of any Personal Information uploaded to the Services, the content of emails sent, forms built, and information provided at the point of data collection. Therefore, most of the time we collect and process Personal Information about our Clients’ Subscribers, as a processor on behalf of our Clients (the controller). GoGoGuest is not responsible for the privacy or security practices of our Clients, which may differ from those described in this Notice. We require our Clients to comply with all applicable laws and regulations and to provide Subscribers with notice of the collection of data as outlined in this Notice. To understand how Clients will use your Personal Information, you will need to directly contact the Client who sent you the email or whose online form you filled out.

a. Information We Collect.

In an expanding number of cities, we provide our Clients (coffee shops, pubs, bars, craft brew pubs, restaurants, retail stores, pop up retailers and other businesses) with a platform that integrate with their wireless routers that let them share their Internet connection with people around their location.

The GoGoGuest platform receives the unique MAC address of nearby wireless devices, such as smartphones. We keep a record of these MAC addresses associated with our client’s wireless router, 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 preferences, 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 managed router (of the same 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.

In some cases, we may operate a portion of our client’s website or social site, such as when we manage an email list sign-up form for them (in addition to or instead of the WiFi-based signup form). On our clients’ websites, and in the signup and login pages for our WiFi, we and our third-party service providers, including Google Analytics, may use cookies, web beacons, and other automated technologies to collect information about the computers or other devices used to access the WiFi. As described further below, we may collect and analyze information such as browser type, ISP, operating system, access time, IP address, device type, unique device identifiers, and the web pages from which visitors arrive at the website.Cookies and Other Technologies: We and our third-party service providers may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the products and services we provide. We or our third-party service providers also may use certain of these technologies in emails to end users, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. You can choose to accept or decline certain cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline certain cookies if you prefer. If you disable cookies, you may be prevented from accessing or taking full advantage of the WiFi or our clients’ websites.

b. Information We Process.

i. Information We Receive About Subscribers from Client.   A Client may provide Personal Information about you to us through the Services in connection with their use of the Services– for example, when a User imports and/or collects email addresses and other Personal Information about their Subscribers.

ii. Information Collected Automatically. When you interact with the Services (for example receive or open an email sent through the Services), we automatically collect certain information about your device and interaction with any content provided to you through the Services. We may use cookies and other tracking technologies to collect some of this information. The information we automatically collect through the Services may include:

1. Device Information. We collect information from your device and applications you use to view emails sent via our Services,  such as your IP address, device attributes (for example: hardware model, operating system, web browser version, as well as unique device identifiers and characteristics), connection information (for example, name of your mobile operator or Internet Service Provider, browser type, language and time zone, and mobile phone number); and device locations (for example, internet protocol (IP) addresses and Wi-Fi information).

2. Email Engagement Data. Emails sent by or on behalf of our Users through the Services include page tags (also known as web beacons) that allow the sender to collect information about who opened those emails. Additionally, your engagement with any links in emails sent using the Services (for example, when you click a link) is reported to the User.

b. Why We Process Your Information.

We process your Personal Information for our legitimate interests, which include:

i. In Connection With Support Queries. To respond to an enquiry which you may submit to us. For example, our customer support team may use your email address to communicate with you if you have contacted us about an email you received, but we will not send marketing to you unless you have otherwise opted-in to marketing.

ii. To Improve Our Product & Ensure Functionality.

1. To ensure the full functionality of the Service. We collect information using cookies about your interaction with an email sent to you through the Services. These cookies are used to ensure that the full functionality of our Services is operational; to ensure that the Service experience works well across all possible devices; and to fix bugs and troubleshoot product functionality.

2. To track behaviour at the aggregate/anonymous level to identify and understand trends in the various interactions with our Services (for example, by inferring geographic location to produce aggregated data around Subscriber location trends as they relate to open rates). This data will be aggregated and anonymized so we can examine patterns in terms of Subscribers’ preferences as they relate to email engagement. We collect and use all this data for our (and our Client’s) legitimate interests, like providing our Clients with metrics around probability of engagement related to email sending times, locations, content and also to help our Customers understand industry trends in marketing.

iii. To Prevent Abuse/Illegal Activities. To screen for and prevent undesirable, abusive, and/or illegal activity. We use your IP address and a GoGoGuest auto-generated Subscriber ID for abuse monitoring purposes (so we can identify a Client who abused the Services by sending spam email or sent an email in any other manner contrary to our usage policies and/or to facilitate a User in complying with their own legal obligations). We also have automated systems that screen content for phishing activities, spam, and fraud.

iv. For Legal Records. To enforce our agreements where applicable (for example we keep a record of the number of emails sent to individual Subscribers for to bill for Services used by our Clients). To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

c. How We Share Your Information.

In the following limited situations, we may disclose Subscriber information to someone other than the Client or their User:

i. to our contractors, service providers and other third parties who provide data processing services to us and with whom the sharing of your Personal Information is necessary to undertake the work e.g. to process billing,  to analyze data, host data, deliver content and to provide customer support and other business related functions.

ii. to comply with any court order, law or legal process, including responding to a governmental or regulatory request.

iii. to Affiliates of our corporate group for customer support, technical operations, and account management purposes.

iv. to a buyer or other successor in the event of a merger, sale or transfer of some or all of GoGoGuest’s assets.

d. Data Retention.

i. We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to prevent abuse or illegal activities, retain our legal records, or to comply with other applicable legal, tax or accounting requirements).

ii. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise Personal Information. If this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

iii. We will retain information we process (as a data processor) on behalf of our Clients for as long as needed to provide Services to our Clients (unless deletion is requested at an earlier time by the Client) and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

iv. To have any Personal Information that is retained by us on behalf of the Client deleted, please contact the Client (the controller of that data).

4. GOGOGUEST WEBSITE VISITORS

This Section applies to Personal Information that we collect and process through our Websites (for example when you visit our website and sign up for our marketing lists or apply for a job at GoGoGuest) and in the usual course of our business, such as in connection with our events, sales and marketing activities.

a. Information We Process.

i. Information You Provide To Us. Certain parts of our Websites  may ask you to voluntarily provide Personal Information (such as your name, contact details and company name). For example, when registering for an account, expressing an interest in obtaining additional information about GoGoGuest or our Services, subscribing to marketing, applying for a job, or otherwise contacting us. We may also collect Personal Information, such as your contact and professional background details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.

ii. Information Collected Automatically. When you visit our Websites, like most website owners, we may also collect certain information automatically from your device, such as your device type, browser type, broad geographic location (e.g. country or city-level location), the referring website, what pages your device visited, and the time that your device visited our Website. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.  We (including our service providers) may use cookies, pixel tags and other similar tracking technologies to collect this information.

iii. Information We Obtain From Third Party Sources.  We may receive Personal Information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide Services that may be of interest to you. This Personal Information may include (for example), information such as your name, employer, job title, email address, phone numbers, and other company, contact, and/or employment information.

b. Why We Process Your Information.

i. To Provide You With Information You Have Requested. To respond to your requests or provide you with information requested by you, including where you apply for a job at GoGoGuest or request information about our products or Services.

ii. To Market To You. To contact you  with marketing and promotional information (in accordance with your marketing preferences) about products and services that we or our Affiliates offer, to provide advertising to you on third party sites (based on your browsing activities on the Website), and to send you information regarding us, our Partners. You can opt-out of receiving marketing communications from us at any time). Marketing data purchased from third parties may be combined with information we already have about you and may be used to create more tailored advertising and products.

iii. For Business Analytics. To infer your geographic location based on your IP address; to track behavior at the aggregate/anonymous level to identify and understand trends in usage and the various interactions with our Websites and marketing content; determining the effectiveness of our marketing; and to conduct internal business analysis based on meta-data about usage, feature adoption and forecasting to improve our Websites and Services.

iv. For Website Optimization. To administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, and statistical purposes; to understand how our Website is used and to improve our Website to ensure that content is presented in the most effective manner for you and your computer; and as a part of our efforts to keep our Website safe and secure.

v. For Legal Records. To comply with and enforce applicable legal requirements, agreements and policies.

c. How We Share Your Information.

In the following limited situations, we may disclose information that we collect or that you provide to us:

i. to our contractors, service providers and other third parties who provide data processing services to us and with whom the sharing of your Personal Information is necessary to undertake the work e.g. to process billing, analyze data, host data, provide customer support, and to deliver online and offline marketing communications about us and/or our Partners that we think will interest you.

ii. as required by law, such as to comply with any court order, subpoena or other law or legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a governmental or regulatory request.

iii. to enforce our rights arising from any contracts entered into between you and us and for billing and collection.

iv. to Affiliates of our corporate group for customer support, marketing, technical operations, and account management purposes.

v. to a buyer or other successor in the event of a merger, sale or transfer of some or all of GoGoGuest assets.

d. Data Retention.

i. We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with information you have requested or to comply with applicable legal, tax or accounting requirements).

ii. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

5. GENERAL INFORMATION

Further Information for Subscribers:  As described in our Privacy Policy, for much of the Personal Information we collect and process about you through the Services, we act as a processor on behalf of our Clients. In such cases, if you want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by GoGoGuest as a processor on behalf of our Clients, you should contact the relevant Client that has contracted with GoGoGuest for use of the Services, and refer to their separate privacy policies. If you are having difficulties finding this Client, you can contact us through our support team and we will try our best to help you.

a. Third-Party Websites And Apps.

This Notice only applies to the GoGoGuest Website and Services. We are not responsible for the privacy practices or disclosures of third parties that use or access the GoGoGuest Website or Services. In addition, the Website or Service may contain links to third-party websites and apps. Any access to and use of such linked websites or apps is not governed by our Privacy Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties.

b. How Do We Keep Your Personal Information Secure?

i. We use appropriate technical and organizational security measures to protect any Personal Information we process against unauthorized access, disclosure, alteration, and destruction.

ii. Unfortunately, nobody is truly and completely safe from hackers. Although we do our best to protect your Personal Information, we cannot guarantee security, no Internet transmission can ever be guaranteed 100% secure, and so we encourage you to take care when disclosing Personal Information online and to use readily available tools, such as Internet firewalls, secure e-mail and similar technologies to protect yourself online.

c. International Data Transfers.

i. The Website and the Services are provided, supported, and hosted in the United States. If you are using the Website or Services from outside the United States, be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your Personal Information, in the United States and other countries. These countries may have data protection laws that are different to the laws of your country.

ii. However, we have taken appropriate measures to require that your Personal Information will remain protected in accordance with this Privacy Policy and have implemented appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Notice. We have implemented similar safeguards with our third party service providers and partners. Further details can be provided upon request.

d. Changes To This Privacy Notice.

We may revise this Privacy Policy from time to time in response to changing legal, technical or business developments. The most current version of this Privacy Policy will govern our use of your Personal Information. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

e. Opt-out and Privacy Rights.

To opt out of our use of your device’s MAC address and email address for marketing purposes, simply unsubscribe from our Client’s marketing campaigns. If you opt out, a Client will refrain from sending marketing campaigns associated with the location that you granted permission to when you joined that Client’s WiFi service for marketing purposes. However, if you granted  our Client permission to send  marketing campaigns by joining our Client’s WiFi service in more than one location, your device’s MAC address and email address will continue to be associated with the location unless you opt-out. Alternatively, you may deactivate your device’s WiFi, which will prevent our further collection of your device’s MAC address.

For information about opt-out options relating to data collected using cookies and other automated technologies (e.g., for analytics and advertising), please review the hyperlinks in the “Information Collected” part of Section 1 of this Privacy Policy, above.

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.

f. 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.

g. Contact Us.

Thanks for taking the time to learn about our privacy notice. We hope it was clear and reassuring.

To execute a Data Protection Agreement (often referred to as a “Data Processing Agreement or “DPA”), please submit a request to support via this Contact Us form.

For general data privacy questions related to the GoGoGuest Services, please email Support@gogoguest.com.