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Privacy Policy

Zenreach is now operating as Adentro.

Effective Date: January 13, 2021

GO TO ZENREACH’S  PRIVACY PORTAL FOR INFO ON HOW TO OPT OUT OF OUR ENHANCED WI-FI OR OUR USE OF YOUR MAC ADDRESS FOR MARKETING PURPOSES.

This is the Privacy Policy of Zenreach, Inc. (“Zenreach,” “we,” “us,” or “our”), doing business as Adentro. We give our clients tools to manage their own Wi-Fi service and to understand and communicate with their customers. This Privacy Policy covers Zenreach’s handling of two categories of information:

1. Information we receive in connection with our relationship with our clients, such as the email addresses their customers (“End Users”) supply when signing up for our Wi-Fi with enhanced marketing features (the “Enhanced Wi-Fi”) or visiting our clients’ websites, as well as certain information collected in connection with the Enhanced Wi-Fi routers; and

2. Information collected from visitors to Zenreach’s own website, zenreach.com.

Each of those two categories has its own section below. Following those sections is a third section containing general information about our privacy practices, as well as your opt-out options and details about exercising your rights. This Privacy Policy does not address our clients’ own privacy practices.

1. Privacy Practices for Information We Receive in Connection with Our Relationship with Our Clients

Information Collected

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 and California 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 Zenreach router (of any Zenreach 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 Local Laws” 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 Zenreach 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 some cases, we may operate a portion of our client’s website, such as when we manage an email list sign-up form for them (in addition to or instead of the Wi-Fi-based signup form). On our clients’ websites, and in the signup and login pages for our Enhanced Wi-Fi, 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 Enhanced Wi-Fi. 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. We act as a data processor for personal data we access when we operate a portion of our clients’ websites.

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:

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 Enhanced Wi-Fi or our clients’ websites.

Online Analytics:

We may use third-party web analytics services, such as those of Google Analytics. These service providers use cookies and other technologies described in this Privacy Policy to help us analyze how users use our website and the Enhanced Wi-Fi. The information collected by the technology will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on by clicking here.

Tailored Advertising:

Third parties such as Facebook may also use cookies, web beacons or other tracking technologies on your computer or device to collect information about your access to or use of our client’s website or Enhanced Wi-Fi, or elsewhere on the Internet, to (i) inform, optimize, and serve marketing content based on your access to or use of a website or the Enhanced Wi-Fi and (ii) report how our marketing content impressions, other uses of marketing services, and interactions with these marketing impressions and marketing services are related to visits to our establishment(s), access to, or use of websites or the Enhanced Wi-Fi. We may also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored marketing to you through our clients’ websites or Enhanced Wi-Fi, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Enhanced Wi-Fi. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider in hashed, non-human readable form.

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 business and commercial purposes:

2. Privacy Practices for Information We Collect on Our Own Websites

Information Collected

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 Zenreach, 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.

Direct Collection by Third Parties. In some cases, we may arrange for a third party to collect information directly from individuals, such as if we help a client install embedded content or tools on their website or app (or when we do this on our own website), such as embedded videos, embedded social network buttons or automated advertising technology. These third parties may collect information directly (for example, when they record a user’s “Like” of something). Such providers’ handling of the information is subject to their own privacy policies, terms and practices and is not covered by this Privacy Policy.

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

Under applicable law, we are considered the “data controller” of the personal data we collect through our website. We are a data processor of (1) personal data of end users provided directly to us by our clients and (2) personal data we process in the course of operating our clients’ websites or analyzing their email marketing campaigns. We are a data controller of all other personal data we obtain in the course of our relationship with our clients, including: (1) information you provide through your use of the Enhanced Wi-Fi, including automatically-collected information; and (2) point-of-sale data provided by you directly to us or through our business partners. This means that we are responsible for deciding how to collect, use and disclose this data, subject to applicable law. We operate our services out of North America, including both the United States and Canada. Our contact information appears at the end of this Privacy Policy.

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 support@adentro.com. Alternatively, you may deactivate your device’s Wi-Fi, 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.

Your Legal Rights Under Local Laws:

Residents of the European EU and European Economic Area Countries

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.

California Residents

Please see below for details on rights for California residents.

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.

Children’s Privacy

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 in accordance with applicable law. We also will honor similar requests from parents and guardians in jurisdictions where the age threshold provided by law is 16 or higher.

Updates to this Privacy Policy

We may modify this Privacy Policy from time to time as our business practices and legal requirements evolve. In the event this Privacy Policy is modified, we will provide notice of the change by posting the updated Privacy Policy to zenreach.com, and we will include the effective date of the update.

Contacting us

If you have any questions about this Privacy Policy or our privacy practices, please contact our Privacy Officer at support@adentro.com. You also may write to our Privacy Officer at:

Zenreach, Inc.
1 Letterman Dr Bldg C, Ste 3500
San Francisco CA, 94129.

Supplemental Privacy Notice for California Residents

This Supplemental Privacy Notice supplements the information in our Privacy Policy, and except as provided herein, applies solely to California residents. It applies to personal information we collect on or through the Enhanced Wi-Fi and website (collectively, the “Services”) and through other means (such as information collected offline, in person, and over the telephone). It does not apply to personal information we collect from our employees and job applicants in their capacity as employees and job applicants. It also does not apply to personal information we process as a service provider to our clients. It also does not apply to personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.

Summary of Information We Collect 

California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.  

We or our service providers may collect the below categories of information for the following business purposes (as those terms are defined in applicable law):

We may also use the personal information we collect for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

In the past twelve months, Zenreach has collected the following categories of personal information about California consumers:

We collect personal information from the following categories of sources:

In the preceding twelve months, we have shared each of the categories of personal information identified above to the following categories of third parties for business purposes:

Our clients also receive personal information about End Users directly from the End Users or where End Users direct us to share their data.

Rights

If you are a California resident, you may have certain rights. California law may permit you to request that we:

You may have the right to receive information about the financial incentives that we offer to you. Please review the California Notice of Financial Incentives for more information. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services. 

If would like to exercise any of these rights, please submit a request at privacy@adentro.com or visit https://my.zenreach.com/privacy/request/zenreach/. You will be required to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us. Please note that we cannot honor requests with respect to personal information that we process on behalf of our clients as a service provider. For such data, please contact the restaurant, store, or other business for which you would like more information regarding your rights.

California residents may opt out of the “sale” of their personal information. Zenreach does not “sell” your personal information as we understand that term to be defined by the California Consumer Privacy Act and its implementing regulations.

California Notice of Financial Incentives

End Users may receive certain rewards or incentives, such as coupons and other discounts, when they direct us to share their information with our clients. You can opt into the rewards or incentives by directing us to share your information with our clients. Your participation is completely voluntary, and you have a right to withdraw your consent at any time. If you decide you don’t want to participate, you can opt out through our Privacy Portal.

Rewards or incentives vary based on the client. The monetary value of the reward or incentive is a reasonable approximation of the monetary value of the personal information you direct us to share with our clients. We have arrived at this estimate based on consideration of multiple factors, including the following: (1) revenue generated by Zenreach in sharing information with our clients at your direction; (2) expenses incurred by Zenreach in operating Zenreach, including expenses for collecting and retaining personal information and expenses incurred for offering a financial incentive; and (3) our reasonable assessment of profit we may generate as a result of Zenreach sharing information with our clients at your direction.

California Shine the Light

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 at support@adentro.com. 

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.

Updated: January 13, 2021