Guaranteed Return on your Ad Spend
Call: (800) 807-WiFi (9434)
Email: [email protected]
Support: [email protected]
© 2024 – Adentro Inc
Adentro Wi-Fi Network Privacy Policy
Last Updated: December 1, 2024
Adentro, Inc. (“Adentro”, “we,” “us,” or “our”) operates a Wi-Fi and marketing service and software that facilitates access to our Wi-Fi and marketing service (collectively, the “WiFi Services”). Our customers (“Clients”) use our services to help operate their in-store Wi-Fi networks and to understand and communicate with their customers. This Privacy Policy (“Policy”) describes and governs only our information collection, use, and disclosure practices with respect to your use of the WiFi Services including any software you download or otherwise use to access our services. Without limitation then, it does not apply to (1) information we process as a data processor or service provider on behalf of our Clients; (2) information we process from your access and use of our website (adentro.com), which are governed by the Adentro Website Privacy Policy; and (3) information practices of our Clients, including their handling of information collected from or about you through the WiFi Services, which are subject to our Client’s own privacy policies.
Before you use or submit any information through or in connection with the WiFi Services, please carefully review this Policy. By registering for or otherwise using any part of the WiFi Services, you acknowledge that Adentro will collect, use, and disclose your information as further outlined in this Policy.
Table of Contents
We collect information about you in multiple ways, including when you provide information directly to us, automatically through your use of the WiFi Services, and information from third-party sources, as described below.
We may collect information from you directly in various ways, such as when you:
The information you provide us with directly may include, without limitation, account registration information such as your name, email address, and birth month and day.
We may collect information about you or your device automatically when you use the WiFi Services.
Device/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 your device connects with or otherwise accesses the WiFi Services.
Location Information. When you access, use, or otherwise connect to the WiFi Services, we may collect location information that is inferred based on your proximity to certain routers through which your device has connected to the Wi-Fi (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 Wi-Fi on your device, not register for the WiFi Services, or if you have previously registered for the WiFi Services, terminate your registration to the WiFi Services. See your device manufacturer’s instructions for further details.
See Your Privacy Choices and Rights below for more information about your choices on this data collection.
We may collect information about you from other parties. These other parties include, but are not limited to, publicly available data sources, data brokers, partners, security and fraud detection services, and other commercially available sources.
We use your information for the following business purposes:
Data combination. Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy. We may use such combined information about you to create a profile about you and your interests. For example, we may combine your registration information with information that we collect automatically or from third parties to create a profile about your interests.
De-Identified/Aggregated Data. We may aggregate and/or de-identify information collected through the WiFi Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, and/or others. Adentro commits to maintain and use such data in a de-identified form and not attempt to re-identify the data.
We may disclose your information to other parties under the following circumstances:
Clients: If you register for and log onto the WiFi Services at particular locations, you agree to also disclose your information to the relevant Client and to the Client’s relevant privacy policy. Information disclosed may include information about your usage of the WiFi Services as well as other information Adentro has collected about you. Adentro does not control how Clients process information about you, so please consult the Client’s privacy policy to learn more about how they process your information.
Affiliates: We may disclose information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Adentro. Our affiliates may use the information we disclose in a manner consistent with this Policy.
Vendors: We may disclose your information to employees, consultants, and other vendors who need access to such information to carry out work or perform services on our behalf, such as those who provide data storage, payment, technology support and services, customer service, analytics, fraud prevention, legal services, advertising and marketing services.
Business Partners. We may disclose information about you with business partners to provide you with a product or service you have requested. We may also disclose your information to business partners with whom we jointly offer products or services.
Safety and Protection of Adentro and Others: We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to (i) protect or defend the Adentro or other parties, including to defend or enforce this Policy, our Terms of Service, or any other contractual arrangement; and/or (ii) protect the rights, property or personal safety of Adentro, our agents and affiliates, our employees, users and/or the public.
Advertising and Analytics: We may disclose or make available some of your information to advertising and analytics partners to serve advertisements on our behalf across the internet and to provide analytics services. These entities may use cookies and tracking technologies to allow us to, among other things, track and analyze data, determine the popularity of certain content, deliver advertising and content targeted to your interests and better understand your online activity. For more information about how to manage having your web browsing information used for advertising purposes, please see the Analytics and Tailored Advertising section below.
Legal Requirements: We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.
Business Transfers: We may disclose certain information, in connection with or during negotiations or closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Other Disclosures with Consent or at Your Direction. We may disclose your information to nonaffiliated third parties based on your consent to do so.
We may use third-party analytics services in the WiFi Services. These vendors use various technologies (e.g. in the form of software development kits) to help us analyze how users use the WiFi Services.
We may also collect information about you for advertising purposes. For example, we may collect information about the types of Clients you visit and combine that with other information we collect about you, including information related to your use of the WiFi Services. We may combine this data to enable interest-based content or targeted advertising for Adentro services or the products and services of our Clients. We may also use information about you for other analytics and advertising purposes, such as to enhance data maintained by our Clients, and for analytics, attribution, and measurement purposes. You may opt out of this type of data processing and disclosure by visiting our Privacy Portal.
We offer you certain choices regarding the collection, use, and disclosure of information about you.
Marketing Emails: You can unsubscribe from marketing emails by following the directions in those emails. Note that you may continue to receive transaction-related emails. For example, we may also send you certain non-promotional communications regarding us and the WiFi Services, and you may not be able to opt out of those communications (e.g., communications regarding the WiFi Services or updates to this Policy).
Profile Information: You can submit a request to deactivate and delete your account for WiFi Services by visiting our Privacy Portal.
Analytics and Tailored Advertising. You can opt out of certain analytics and advertising processing of information about you by visiting our Privacy Portal.
Legal Bases for Processing: Adentro is considered the “data controller” of the “personal data” (as defined under applicable law) we handle under this Policy. The laws of certain jurisdictions (such as the European Economic Area, Brazil, UK) require us to tell you about the legal bases we rely on for processing. The legal bases we rely on are:
Rights to Information About You: Your local law may provide you certain rights with respect to your information. Depending on your jurisdiction, you may request that we:
You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.
Please note that certain information may be exempt from such requests under applicable law. For example, we may retain certain information for legal compliance and to secure the WiFi Services. We may need certain information in order to provide the WiFi Services to you; if you ask us to delete it, you may no longer be able to use the WiFi Services.
You also have the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
You may also have the right to opt out of sales of your personal information, or the processing of your personal information for targeted advertising. To opt out of targeted advertising, please visit Privacy Portal.
If you would like information regarding your rights under applicable law or would like to exercise any of them, please visit our Privacy Portal, email us at [email protected] or contact us at 1 (800) 807-WiFi (9434). To protect your privacy and security, we take reasonable steps to verify your identity and requests before granting such requests. If we are unable to verify your identity, we may be unable to respond to your requests.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You may also 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 best to resolve your concern.
You may also have the right to opt out of sales of your “personal information” or “personal data” (as defined in applicable law), or the processing of such information for targeted advertising. To opt out of targeted advertising, please visit Privacy Portal.
Regional Privacy Disclosures and Rights: Additional disclosures for residents of California, Colorado, and Nevada are set forth below in Regional Privacy Disclosures.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to unaffiliated parties. You can exercise this right by contacting us as described in the “Contact Us” section below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address.
Except as explicitly stated in this Policy, this section applies solely to California residents. Throughout this Policy, we discuss in detail the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we disclose it. Under the California Consumer Privacy Act (“CCPA”), we also have to provide you with (1) the “categories” of personal information and sensitive personal information we collect and disclose for business or commercial purposes (as “categories” are defined by the CCPA); (2) the categories of other parties to whom we (a) disclose such information for a business purpose, (b) “share” information for “cross-context behavioral advertising,” and/or (c) “sell” such information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. We “share” information to provide more relevant and tailored advertising to you. Our use of third-party analytics services and online advertising services may result in the sharing of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” under the CCPA. Please see the following chart for the rest of this information, which is also described throughout this Policy:
As described in this Policy, we collect geolocation information based on your use of the WiFi Services at Client locations. Such information is considered “sensitive personal information” under the CCPA.
We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the WiFi Services; and (3) other parties such as unaffiliated parties.
The CCPA sets forth certain obligations for businesses that “sell” or “share” personal information. Where we refer to “sell” or “share” (or their variants) in quotes, we are referring to those terms as uniquely defined in the CCPA.
We may collect, combine, and disclose personal information about you to build out products and services and provide services for our Clients and other business partners. We do so to assist our Clients and other partners with marketing, advertising, analytics, measurement, and attribution. This may include creating audience segments, such as identifying an audience of consumers who may enjoy coffee. As part of the advertising services we offer, our Clients can also use our services to obtain analytics, attribution, and measurement data, such as understanding the efficacy of ads promoting Client products and services. We “sell” or “share” personal information as described in the chart above. If you or your authorized agent would like to opt out of our “sharing” or “sale” of your information for such purposes, you may do so by visiting our Privacy Portal. If you have a legally recognized browser-based opt out preference signal turned on via your device browser, we recognize the preference expressed by such signal in accordance with applicable law. We do not knowingly “sell” or “share” the personal information of children under 16.
We do not respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
Please see the Retention of Personal Information section below.
California residents can make requests about their personal information as described as set forth in Your Privacy Choices and Rights section above and also through our toll-free number at (800) 807-WiFi (9434). The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA (e.g., to provide the WiFi Services to you).
California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. To request such information, please contact [email protected].
The Colorado Privacy Act requires Adentro to provide additional information on how we process “personal data,” as that term is defined by the Colorado Privacy Act. Please see the chart above to see those additional details.
The WiFi Services are not designed for minors under 18, and our Terms of Service prohibit use by anyone under 18. If we discover that an individual under 18 has provided us with personal information, we will delete the personal information to the extent required by applicable law. We may, where permitted by law, retain certain information internally for purposes described in this Policy.
Adentro implements technical, administrative, and physical safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Therefore, we do not promise and cannot guarantee the security of your information or communications.
We store the information we collect as described in this 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 information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the information, certain risk factors, the purposes for which we process your information, and whether we can achieve those purposes through other means.
Our services are global and your information may be stored and processed in the United States and other countries outside the United States that may have data protection laws that differ from the laws in your country, and data may be accessible to law enforcement and national security authorities under certain circumstances. By using the WiFi Services, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable countries in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside and/or are a citizen.
The WiFi Services may contain links to other websites/applications and other websites/applications may reference or link to our WiFi 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 information to third-party websites or applications is at your own risk.
We may change this Policy to reflect changes in the law, our information practices or the features of the WiFi Services. We will indicate the date of the most recent update in this Policy. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the WiFi Services, you are confirming that you have read and understood the latest version of this Policy.
If you have any questions about our privacy practices or this Policy, or to exercise your rights as detailed in this Privacy Policy, visit our Privacy Portal or contact us at:
Adentro, Inc.
1 Letterman Drive
Building C, Suite 3500
San Francisco, CA 94129
(800) 807-WiFi (9434)
Call: (800) 807-WiFi (9434)
Email: [email protected]
Support: [email protected]
© 2024 – Adentro Inc