Last Updated: February 12, 2024

Adentro, Inc. (“Adentro”, “we,” “us,” or “our”) operates a Wi-Fi and marketing service (the “WiFi Services”).  Our Clients use our services to help operate their in-store Wi-Fi networks and to understand and communicate with their customers.

This Privacy Policy only applies to Adentro’s processing of your personal information when it operates the WiFi Services as a separate, independent controller or other similar term.

This Privacy Policy does not address our Clients’ own privacy practices.

NOTICE AT COLLECTION

At or before the time of collection, California residents may have a right to receive notice of our practices, including the categories of personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details as it relates to personal information that is subject to this Policy by clicking on the links below.

1. UPDATES TO THIS PRIVACY POLICY
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE PERSONAL INFORMATION
4. HOW WE DISCLOSE PERSONAL INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
7. RETENTION OF PERSONAL INFORMATION
8. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
9. SUPPLEMENTAL NOTICE FOR EU/UK GDPR
10. CHILDREN’S INFORMATION
11. THIRD-PARTY WEBSITES/APPLICATIONS
12. CONTACT US

1. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in our sole discretion.
If we do, we’ll let you know by posting the updated Privacy Policy on our website and/or may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we obtain automatically when you use the WiFi Services, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

• Wi-Fi Registration. We may collect personal information in connection with your Wi-Fi registration at a Client location such as your name, email address, birthdate, and the Client location you are registering at.
• Your Communications with Us. We may collect personal information, such as your name, email address, or phone number when you contact us.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the WiFi Services.

• • Automatic Collection of Personal Information.
    • Device and Usage Information.  We may collect certain information automatically when you use the WiFi Services, such as your Internet protocol (IP) address, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, operating system, Internet service provider, and information regarding the location of certain routers through which your device has connected to the WiFi Services. We may also track how frequently you access or use the WiFi Services and the various locations where you use the WiFi Services.
    • Location Information. When you access or use the WiFi Services, we may collect precise location information that is inferred based on your proximity to certain routers through which your device has connected to the WiFi (e.g., through your device MAC address). If you do not want to send such information, you can disable the functionality that allows you to connect to wifi on your device or not register for the WiFi Services. See your device manufacturer’s instructions for further details.
    • Cookie Policy (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of the WiFi Services.
      • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
      • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the WiFi Services that collects information about engagement on the WiFi Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

C. Personal Information Collected from Third-Party Sources

We may collect personal information from third parties. These third parties include, but are not limited to, data brokers, security and fraud detection services, and other commercially available sources. We may combine such personal information with the personal information collect from you.

3. HOW WE USE PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide the WiFi Services, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the WiFi Services

We use your personal information to fulfill our contract with you and provide the WiFi Services, such as:

• • Managing your information;
  • Providing access to certain areas, functionalities, and features of the WiFi Services;
  • Answering requests for support; and
  • Communicating with you.

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

• Creating a profile about you including, but not limited to, (1) combining your registration information with personal information that we collect automatically or from third parties and (2) creating a profile of the various locations where you use the WiFi Services;
• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in the WiFi Services;
• Improving, upgrading, or enhancing the WiFi Services;
• Carrying out analytics;
• Developing new products and services;
• Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
• Debugging to identify and repair errors with the WiFi Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the WiFi Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide the WiFi Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the WiFi Services

The categories of third parties with whom we may share your personal information are described below.

• • • Clients You Share or Interact with Using the WiFi Services. As mentioned above, Clients use the WiFi Services to help operate their in-store WiFi networks and to understand and communicate with their customers.

      By using the WiFi Services at a Client location, you acknowledge that you are directing Adentro to disclose any personal information Adentro collects about you in connection with that Client interaction with the Client. This includes, but is not limited to, your WiFi registration information and any personal information that Adentro has collected about you from third-party sources.
      Once your personal information is shared with the Client, it will also be subject to the Client’s privacy policy or other similar document. We are not responsible for the Client’s processing of your personal information.

    • Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of the WiFi Services. This includes service providers and vendors that provide us with analytics, marketing services, IT support, hosting, customer service, and related services.
    • Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
    • Affiliates.We may share your personal information with our corporate affiliates.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the WiFi Services, and you will not be able to opt out of those communications (e.g., communications regarding the WiFi Services or updates to this Privacy Policy).
• “Do Not Track.”Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies.You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the WiFi Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Confirm Whether We Are Processing Your Personal Information (the right to know);
• Request Access to and Portability of Personal Information about you, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine-readable format (the “right of data portability”);
• Request Correction of your personal information where it is inaccurate or incomplete;
• Request Deletion of your personal information;
• Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws);
• Request Restriction of or Object to our Processing of your personal information; and
• Withdraw your Consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

To protect your privacy, we will take steps to reasonably verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

• EEA Data Protection Authorities (DPAs)
• Swiss Federal Data Protection and Information Commissioner (FDPIC)
• UK Information Commissioner’s Office (ICO)

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use the WiFi Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the WiFi Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents supplements our Privacy Policy and only applies to our processing of personal information that is subject to this Privacy Policy and the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”).

The CCPA provides California residents with the right to know what categories of personal information Adentro has collected about them, whether Adentro disclosed that personal information for a business purpose (e.g., to a service provider), whether Adentro “sold” that personal information, and whether Adentro “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using and disclosing personal information are set forth in “Personal Information We Collect”, “How We Use Personal Information”, and “How We Disclose Personal Information” above, respectively. We will retain personal information in accordance with the time periods set forth in “Retention of Personal Information.”

Additional Privacy Rights for California Residents

Disclosure Regarding “Sales” of Personal Information under the CCPA. In the preceding twelve months, Adentro has not “sold” any personal information (as defined by the CCPA) collected via the WiFi Services, nor does Adentro have actual knowledge of any “sale” of such personal information of minors under 16 years of age.

Disclosure Regarding Cross-Context Behavioral Advertising under the CCPA. In the preceding twelve months, Adentro has not “shared” any personal information collected via the WiFi Services for “cross-context behavioral advertising” (as such terms are defined in the CCPA), nor does Adentro have actual knowledge of any “sharing” of such personal information of minors under 16 years of age for “cross-context behavioral advertising”.

Disclosure Regarding Opt-Out Preference Signals. Adentro does not “sell” personal information collected via the WiFi Services or “share” personal information collected via the WiFi Services for “cross-context behavioral advertising” so it does not respond to opt-out preference signals.

Disclosure Regarding Sensitive Personal Information. Adentro only uses and discloses sensitive personal information for the following purposes:

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services. For clarity, this may include Adentro sending you marketing materials.
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at Adentro and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Adentro, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Adentro.
• For purposes that do not infer characteristics about individuals.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

9. SUPPLEMENTAL NOTICE FOR EU/UK GDPR

This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK GDPR.

Adentro’s processing of your personal information may be supported by one or more of the following legal bases:

• Performance of a Contract. Adentro may need to process your personal information to perform our contract with you.
• Legitimate Interest. Adentro may process your personal information to further our legitimate interests, but only where our interests are not overridden by your interests or fundamental rights and freedoms.
• Consent. In some cases, Adentro may also rely on your consent to process your personal information.
• Compliance with our Legal Obligations. Adentro may process your personal information to comply with our legal obligations.

10. CHILDREN’S INFORMATION

The Services are not directed to children under 16 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

11. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

12. CONTACT US

Adentro is the controller of the personal information we process under this Privacy Policy.

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, visit us at https://my.zenreach.com/privacy/request/zenreach or contact us at:

Adentro, Inc.
1 Letterman Drive
Building C, Suite 3500
San Francisco, CA 94129

[email protected]

(800) 807-WiFi (9434)