The following principles are complied with when processing personal data:
The lawful basis of processing of data will always be determined prior to any data being processed. The laws for processing personal data under the GDPR are as follows:
CloseComms processes personal data under one, or more, of the following Lawful Bases:
When you download and use our apps, you will be asked to give permission for Location-based Services. We automatically collect certain information connected to your Wi-Fi enabled device:
Information we collect when you join the Wi-Fi or use the app:
If your phone or other Internet-connected device is equipped with Global Positioning System (GPS), we may obtain, access, or use such GPS information for the provision of our Services. We collect your geolocation data from your device only after you explicitly give your permission for us to do this through the prompts appearing in the App.
If connecting via the Android or iOS app, we do not need your telephone number and email address. Therefore, we do not collect your phone number or email address, unless you optionally, and explicitly, provide it when if you leave store feedback within the app. If, however, you are connecting with an alternative device (e.g. laptop) then we do ask you for these details.
Information we collect about your Location:
CloseComms may make interactive features such as games available through the App, which may include public leaderboards. To be added to such a leaderboard with your game score you may choose to go public and provide us with information such as a pseudonym, an online identifier, or your name. Your public information includes said pseudonym or name and metadata provided with it. CloseComms may disseminate this information, meaning it will be visible to other users. When you share information or content like your pseudonym or name, you should think carefully about what you are making public.
Information you may choose to provide directly through the app:
CloseComms’ website can be found at https://closecomms.com (“Website”). If you come to our Website, we use Google Analytics to aid us in providing you with information and in continuing to improve upon the provision and maintenance of such Services.
You may also use our contact information on the Website to contact us through a medium on your side (telephone, email, or postal service) and provide us with any information you wish to share through the medium of your choosing.
You can enjoy additional benefits in the App by optionally signing-in via social media platform integrations. If you choose to do so, we collect the following additional information according to the social media platform you choose to sign-in with:
You can withdraw your consent for sharing this information at any time by signing-out of the App. We never post to, or comment in your social media account.
We will retain your information for as long as is necessary to provide you with Services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain and use your information to make promotional offers to you as described, unless you have opted out of receiving such communications.
Data is stored on servers in accordance with local regulations. All personally identifiable information is deleted from our servers after 13 months. The data that we collect from you may be transferred to, and stored at, a destination outside the USA. It may also be processed by staff operating outside the USA who work for us or for one of our suppliers.
Our Application and Services, as well as our Website, are not designed to attract individuals under the age of 13. We do not collect or store any personal information, even in aggregate, about children under the age of 13. If we discover we have received any information from a child under the age of 13 in violation of this policy, we will delete that information immediately. If you believe that CloseComms has any information from or about anyone under the age of 13, please contact us at the contact points specified below.
We will use your information
Your information is aggregated and shared with our Business Partners. We do not provide any personally identifiable information to any other third parties for any reason, except as outlined below in 7.2.
We do so to provide insights about customer behaviors based on the collection of GPS and Wi-Fi location. Your information is analyzed and processed to create anonymous aggregate reports before sharing. For example, reports are created to detail how many people visited a store, and the gender percentage, if such information is available. This information is used to improve the experience of the Services.
We share the following non-aggregated data with our business partners:]
We share information collected through our Apps (Section A), information you provide directly through our Apps (Section B), and information collected from social media platforms (Section D) with our hosting vendor/s and our infrastructure support vendor/s. At present they are:
In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction.
With regard to geolocation, you may at any time opt out from further allowing CloseComms to access location data by adjusting your permissions in your mobile device. With regard to push notifications, you may at any time opt out from further allowing CloseComms Lab to send you push notifications by adjusting your permissions in your mobile device.
You may stop using the Service at any time by discontinuing the App and uninstalling it.
We maintain safeguards designed to protect the information that we collect about you against accidental or unauthorized access or disclosure. However, protecting your information is a shared responsibility. We protect your personal information according to industry standard. We cannot control how third parties choose to use your personal information. You can protect your information by notifying us immediately of any suspicious activity.
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
Individuals (‘Data Subjects’) have the right to obtain:
How do individuals (‘Data Subjects’) submit requests for their information?
The information CloseComms Ltd hold is available upon request by contacting firstname.lastname@example.org.
Individuals can also request their data is updated and/or deleted at any time, unless CloseComms Ltd needs to retain it for legitimate business or legal purposes, by submitting a request to this email address.
CloseComms Ltd may ask the individual to verify their identity before their request is actioned.
CloseComms Ltd has the right to ask the individual for enough information to judge whether the person making the request is the individual to whom the personal data relates. This is to avoid personal data about one individual being sent to another, accidentally or as a result of deception.
CloseComms Ltd has the right to ask for information that is reasonably needed to find the personal data covered by the request. If no personal information about the individual is held, they will be informed.
If data processing is outsourced, subject access requests may be sent to the third party to respond.
CloseComms Ltd will refer to the Company’s GDPR Data Register to locate all the information held on the individual and liaise with the CloseComms Ltd Departments and/or Third Parties concerned in order to collate all the information.
Information will be provided within at least one month of receiving the request. Where requests are complex or numerous, CloseComms Ltd has the right to extend the deadline for providing the information to three months. However, a response to the request explaining why the extension is necessary, will be sent within one month.
Data Access Requests that are manifestly unfounded or excessive can be refused or a charge be made. If a request is refused, the individual will be informed as to why and advised that they have the right to complain to the ICO and to a judicial remedy. The refusal will be made without undue delay and at the latest, within one month.
Information will be provided free of charge.
If you have any questions regarding this Policy, or are required to contact by the terms of this Policy, or if there are any privacy-related errors you wish to correct, please contact us by any of the following methods:
IMPORTANT - READ CAREFULLY: THIS AGREEMENT ("AGREEMENT") IS A BINDING CONTRACT BETWEEN YOU ("YOU") AND: CLOSE COMMS LIMITED ("US") , who are the developer and supplier of the Wi-Fi App ("APP") and the operator of the guest Wi-Fi service in participating locations ("SERVICE"). The App is part of the Service, therefore references to the Service herein also relate to the App.
THIS AGREEMENT GOVERNS YOUR USE OF THE SERVICE AND YOUR DOWNLOAD AND USE OF THE APP and the content and information provided in the App.
Purpose. The purpose of the Service is to allow you to use the guest Wi-Fi provided in participating locations via the App which you are invited to download when you access the Service through a browser on your mobile device. Your access to the App and the guest Wi-Fi service is anonymous until you optionally choose to sign-in to the app using social media credentials.
Mobile and Email Communications. YOU AGREE THAT UNLESS YOU OPT OUT WE MAY SEND MARKETING MESSAGES TO YOU FROM US OR ON BEHALF OF PARTICIPATING LOCATIONS, AS WELL AS NOTIFICATIONS (IF YOU HAVE ENABLED YOUR DEVICE TO RECEIVE NOTIFICATIONS FROM THE APP) REGARDING YOUR USE OF THE APP. You have the opportunity to easily opt out of receiving such notifications at any time by adjusting the permissions in your device Settings. Additionally, if you have logged into the App via a social media platform in which you have allowed us to receive your email address from that platform, then you further agree to receiving marketing emails from us from time to time regarding your use of the App. We will only send such emails to people who have the App installed. You can easily opt out of such email communication by changing your privacy settings in the App.
You can enjoy additional benefits in the app by optionally signing-in via social media. If you choose to do so, we collect the following additional information according to the social platform you choose to sign-in with:
We grant you a personal, limited, non-exclusive, revocable, non-transferable license, without the right to sublicense, to electronically access and use the Service solely for the purposes set out in the above section. The Service includes any software, programs, documentation, tools, internet-based services, components and any updates (including software maintenance, service information, help content, bug fixes or maintenance releases) thereto provided to you for use with the Service.
While we want you to enjoy the Service, you may not, nor may you permit any third party to do any of the following: (a) access or attempt to access our systems, programs or data that are not made available for public use; (b) copy, reproduce, republish, upload, post, transmit, resell or distribute in any way material from us; (c) permit any third party to use and benefit from the Site via a rental, lease, timesharing, service bureau or other arrangement; (iv) transfer any rights granted to you under this Agreement; (d) work around any of the technical limitations of the Service, use any tool to enable features or functionalities that are otherwise disabled in the Service, or decompile, disassemble or otherwise reverse engineer the Service, except to the extent that such restriction is expressly permitted by law; (e) perform or attempt to perform any actions that would interfere with the proper working of the Service, prevent access to or use of the Service by our other users, or impose an unreasonable or disproportionately large load on our infrastructure; or (f) otherwise use the Service except as expressly allowed under this section.
We use service providers to provide you with many aspects of the Service. Those service providers are express third party beneficiaries of the protections afforded to us that are set out in this Agreement.
We may terminate this Agreement for any reason or no reason at any time upon notice to you. Without limiting the foregoing, we may also suspend your access to the Service if you (a) have violated the terms of this Agreement, (b) pose an unacceptable fraud risk to us, or (c) provide any false, incomplete, inaccurate, or misleading information or otherwise engage in fraudulent or illegal conduct.
We may, in our sole and absolute discretion without liability to you or any third party, terminate your use of the Service for any reason, including without limitation inactivity or violation of this Agreement or other policies we may establish from time to time. We will not be liable to you for compensation, reimbursement, or damages in connection with your use of the Service.
You may terminate this Agreement at any time by uninstalling the App on your mobile device.
You acknowledge that you may need to install future software updates to continue to use the App.
The Service and associated software are licensed and not sold to you. The Service and associated software are protected by copyright, trade secret and other intellectual property laws. You acknowledge and agree that we or our service providers own or have the legal right to the title, copyright and other worldwide Intellectual Property Rights in the Service and all copies thereof.
Unless otherwise noted, all materials in the App are protected as the copyrights, trade dress, trademarks and/or other intellectual properties owned, licensed or used by us and used with permission. The logos are registered trademarks and service marks owned and registered by usi and used with permission. All rights not expressly granted are reserved. This Agreement does not grant you any rights to the trademarks or service marks appearing in the App. You may choose to or we may invite you to submit comments or ideas about the Service, including without limitation about how to improve the Service or our products ("Ideas").
By submitting any Idea, you agree that your disclosure is gratuitous, unsolicited and without restriction and will not place us or any of our service providers under any fiduciary or other obligation, and that we are free to use the Idea without any additional compensation to you, and/or to disclose the Idea on a non-confidential basis or otherwise to anyone. You further acknowledge that, by acceptance of your submission, that we and our service providers do not waive any rights to use similar or related ideas previously known to us or our service providers or developed by their employees, or obtained from sources other than you.
You will indemnify, defend and hold us and our service providers (and our respective employees, directors, agents, affiliates and representatives) harmless from and against any and all claims, costs, losses, damages, judgments, tax assessments, penalties, interest, and expenses (including without limitation reasonable attorneys' fees) arising out of any claim, action, audit, investigation, inquiry, or other proceeding instituted by a person or entity that arises out of or relates to: (a) any actual or alleged breach of your representations, warranties, or obligations set forth in this Agreement; (b) your wrongful or improper use of the App; (c) your violation of any third-party right, including without limitation any right of privacy, publicity rights or Intellectual Property Rights; (d) your violation of any law, rule or regulation of the United States of America or any other country; and (e) any other party's access and/or use of the App with any log-in credentials you have used in the App.
You represent and warrant that: (a) you are eligible to register and use the App and have the right, power, and ability to enter into and perform under this Agreement; (b) you will not use the App, directly or indirectly, for any fraudulent undertaking or in any manner so as to interfere with the use of the Service.
The Service is provided on an "AS IS" and "AS AVAILABLE" basis. Use of the Service is at your own risk. To the maximum extent permitted by Applicable law, THE SERVICE IS PROVIDED WITHOUT WARRANTIES OF ANY KIND, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, or non-infringement. No advice or information, whether oral or written, obtained by you from us or through the Service will create any warranty not expressly stated herein. Without limiting the foregoing, we and our service providers (and their respective subsidiaries, affiliates, members, shareholders, directors, officers, employees and agents) do not warrant that the content is accurate, reliable or correct; that the Service will meet your requirements; that the Service will be available at any particular time or location, uninterrupted or secure; that any defects or errors will be corrected; or that the Service is free of viruses or other harmful components. Any content downloaded or otherwise obtained through the use of the Service is downloaded at your own risk and you will be solely responsible for any damage to your property or loss of data that results from such download. We do not warrant, endorse, guarantee, or assume responsibility for any product or service advertised or offered by a restaurant location or other third party through the App or any hyperlinked website or service, or featured in any banner or other advertising, and we will not be a party to or in any way monitor any transaction between you and third-party providers of products or services.
YOUR EXCLUSIVE REMEDY WITH RESPECT TO ANY DISPUTE RELATING TO OR IN CONNECTION WITH YOUR USE OF THE SITES OR BREACH OF THIS AGREEMENT IS TO DISCONTINUE YOUR USE OF THE SERVICE AND UNINSTALL THE APP. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WE, OUR SERVICE PROVIDERS AND ANY OTHER PARTY (WHETHER OR NOT INVOLVED IN CREATING, PRODUCING, MAINTAINING OR DELIVERING THE SERVICE) AND THE SUBSIDIARIES, AFFILIATES, MEMBERS, SHAREHOLDERS, DIRECTORS, OFFICERS, EMPLOYEES AND AGENTS OF EACH PARTY, EXCLUDE ALL LIABILITY AND RESPONSIBILITY FOR ANY AMOUNT OR KIND OF LOSS OR DAMAGE THAT MAY RESULT TO YOU OR A THIRD PARTY (INCLUDING WITHOUT LIMITATION, ANY DIRECT, INDIRECT, CONSEQUENTIAL, RELIANCE OR PUNITIVE LOSS OR DAMAGE OR ANY LOSS OF INCOME, PROFITS, GOODWILL, DATA, CONTRACTS, USE OF MONEY, OR LOSS OR DAMAGE ARISING FROM OR CONNECTED IN ANY WAY TO BUSINESS INTERRUPTION AND WHETHER IN TORT (INCLUDING WITHOUT LIMITATION NEGLIGENCE), CONTRACT OR OTHERWISE) IN CONNECTION WITH THE SERVICE IN ANY WAY OR IN CONNECTION WITH THE USE, INABILITY TO USE, OR THE RESULTS OF USE OF THE SERVICE, INCLUDING WITHOUT LIMITATION ACTIONS OR ACTIVITIES RESULTING FROM USE OF RESOURCES PRESENTED IN THE APP, ANY WEBSITES LINKED TO OR REFERENCED FROM THE APP, OR THE MATERIAL ON SUCH WEBSITES, OR USE OF ANY SUBMISSION, INCLUDING BUT NOT LIMITED TO LOSS OR DAMAGE DUE TO VIRUSES THAT MAY AFFECT YOUR MOBILE DEVICE, COMPUTER EQUIPMENT, SOFTWARE, DATA OR OTHER PROPERTY ON ACCOUNT OF YOUR ACCESS TO, USE OF, OR BROWSING THE APP OR YOUR DOWNLOADING OF ANY MATERIAL FROM ANY WEBSITE LINKED TO OR REFERENCED FROM THE APP.
UNDER NO CIRCUMSTANCES WILL WE OR OUR SERVICE PROVIDERS BE RESPONSIBLE FOR ANY DAMAGE, LOSS OR INJURY RESULTING FROM HACKING, TAMPERING OR OTHER UNAUTHORIZED ACCESS OR USE OF THE APP OR THE INFORMATION CONTAINED THEREIN. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WE AND OUR SERVICE PROVIDERS (AND OUR AND THEIR RESPECTIVE SUBSIDIARIES, AFFILIATES, MEMBERS, SHAREHOLDERS, DIRECTORS, OFFICERS, EMPLOYEES AND AGENTS) ASSUME NO LIABILITY OR RESPONSIBILITY FOR ANY (I) ERRORS, MISTAKES, OR INACCURACIES OF CONTENT; (II) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO OR USE OF THE APP; (III) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION STORED THEREIN; (IV) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM THE APP; (V) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE THAT MAY BE TRANSMITTED TO OR THROUGH THE APP BY ANY THIRD PARTY; (VI) ANY ERRORS OR OMISSIONS IN ANY CONTENT OR FOR ANY LOSS OR DAMAGE INCURRED AS A RESULT OF THE USE OF ANY CONTENT POSTED, EMAILED, TRANSMITTED, OR OTHERWISE MADE AVAILABLE THROUGH THE APP; AND/OR (VII) USER CONTENT OR THE DEFAMATORY, OFFENSIVE, OR ILLEGAL CONDUCT OF ANY THIRD PARTY.
TO THE EXTENT ANY OF THE FOREGOING LIMITATIONS ARE FOUND TO BE UNENFORCEABLE TO YOU IN YOUR JURISDICTION, THIS SECTION 13 SHOULD BE CONSTRUED SO AS TO EFFECTUATE THE INTENT OF ITS PROVISIONS TO THE MAXIMUM EXTENT PERMISSIBLE.
The Service is controlled and operated from and in the United States of America and the United Kingdom. We make no representations that the App is appropriate or available for use in other locations outside of the United States of America, Canada and the United Kingdom. Those who access or use the Service from other jurisdictions do so at their own volition and are entirely responsible for compliance with all applicable local laws and regulations, including but not limited to export and import regulations. You may not use the Service if you are a resident of a country embargoed by the United States of America, or are a person or entity with whom such transactions are blocked or denied by the United States government.