Skyfii Privacy Policy

Date of Last Revision: June 2016

1. Summary

Skyfii Limited (ACN 009 264 699) and its subsidiaries such as Skyfii Group Pty Ltd (ACN 165 152 241) (‘Skyfii’, ‘us’ or ‘we’) recognise and value the importance of protecting the privacy of our customers and end-users.

This Privacy Policy is a simple, plain English summary of:

  • how and why we collect, hold, use and disclose your personal information;
  • the nature of our business, customers and services;
  • our approach to advertising, marketing and security; and
  • how you can contact us to access or correct your personal information, make a complaint or ask a question.

2. Introduction

Skyfii supplies a range of products and services to our business customers (our ‘Providers’), who are the ultimate providers of Wi-Fi services to you (the ‘Service’) on their respective premises.  Our Providers use the products and services we supply to help them analyse the behaviour of visitors to their premises.  In most cases, our Providers choose to operate the platform needed to supply the Service entirely on their own, however in certain limited circumstances we may operate it on their behalf.

When we supply products and services to our Providers (including our facilitation of your receipt of the Service) we collect personal information both on their behalf and on our own behalf.  The provision of the Service to you by the Provider is governed by that Provider’s terms of use and privacy policy.  Our involvement (including facilitating the provision of the Service and the collection of personal information) is governed by our ‘Terms of Use’, which are available at http://www.skyfii.io/user-terms.  By registering for and using the Service you are indicating your acceptance of both our Terms of Use and this Privacy Policy, as well as the terms of use and privacy policy of our Provider.  If you do not agree to all of these documents, you must not use the Service.

This Privacy Policy is broken into a number of sections and includes information on how we manage personal information as well as answers to commonly asked questions.

3. What is personal information?

Definitions of ‘personal information’ differ around the world.  In Australia, the collection, storage, use and disclosure of ‘personal information’ is regulated by the Privacy Act 1988 (Cth) (the “Act”).  The Act defines ‘personal information’ as:

…information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable

The definition of ‘personal information’ is therefore extremely broad, but good examples would include your full name and your address.

Schedule 1 of the Act also sets out thirteen Australian Privacy Principles (the ‘APPs’) which comprehensively cover the protection of personal information.  You can feel confident that we will always collect, hold, use and disclose your personal information in accordance with the Act, the APPs and this Privacy Policy.

4. Why do we need to collect your personal information?

The products and services supplied by Skyfii support the collection and analysis of several different data sources, but each of our Providers may use our products and services in a different way.  It is important that you carefully consider how our Providers will use and handle your personal information, as set out in their respective terms of use and privacy policy.  Skyfii facilitates the Provider providing internet connectivity at their premises.  Skyfii is able to facilitate our Providers providing the Service to you because both Skyfii and our Providers collect certain information about your use of the Service and behaviour at their premises, for example concerning how, where and for how long you use the Service while at their premises.  You can think of this as a ‘fair exchange’, where the Provider provides (and we facilitate the provision of) the Service to you in exchange for your provision of certain information about your activities and receipt of certain content.  Our data analysis enables our Providers to better understand how you and other customers engage with their businesses and premises.  Ultimately, this enables our Providers to make their service offering to you more compelling and interesting.

While it is possible for you to interact with us under a pseudonym in some cases, it is still necessary for us to collect certain personal information from you.  We will not collect more than we reasonably need to facilitate the provision of the Service to you and to supply our products and services to our business Providers.  Our Providers will also have their own terms and conditions and privacy policy which will be made available to you when you register for the Service.

5. How do we collect your personal information?

We collect your personal information in two ways as set out in this section. Firstly, you may be asked to provide us with certain personal information when you register as a user of the Service. At that time, we (or our Providers) will notify you that your personal information is being collected via a collection statement.  We (or our Provider) will also collect personal information about you while you receive and use the Service, for example your browsing history while you are at the premises of the relevant Provider.  In most cases, you will not know that we (or our Provider) are collecting this second tier of personal information as it occurs automatically in the background.

When you register to use the Service, the kinds of personal information we collect will depend on our relationship with the relevant Provider.  In most cases, we will collect or infer the following information on registration (or if you contact us directly):

  • your full name and prefix (e.g. Mr or Mrs)
  • your mobile number
  • your email address, so that we can authenticate you electronically and administer your account
  • your date of birth
  • your gender
  • your social network contact and publicly available details
  • your employer
  • your country or state of residence

In most cases, we will also collect (either directly or through our Provider) the following information in respect of your use of the Service:

  • the time, date and location of registration
  • the duration and frequency of your use of the Service and visits to our Providers’ premises
  • the approximate location of your device while at our Providers’ premises
  • your browsing history while using the Service
  • demographic information such as age and gender
  • general information from (and a unique identifier for) your browsing device, such as the Media Access Control (MAC) address

You may not be able to register to use the Service if you do not provide us with a minimum of personal information, which is usually your email address.  Because the information you provide us is linked to the device you use to access the Service, you should not let anyone else use your device while connected to the Service.

We will never collect “sensitive” information about you.  Sensitive information includes certain kinds of information about you, such as your political opinions or your racial or ethnic origin.

6. How do we use your personal information?

Registration allows a single wireless device to conveniently log in to the Service wherever it is provided.  This might include registering for the Service at one of our Providers’ premises before subsequently using the Service at the premises of a different Provider.  Our Providers may share your personal information between themselves for this and other purposes, and we may facilitate this process.

We use your personal information to facilitate the provision of the Service to you and to supply products and services to our Providers, as well as our general operational, technical and administrative purposes.  The products and services we supply to our Providers may include the marketing services discussed below, as well as data analysis about your activities on their premises (for example, your location and device browsing history).  We may share the personal information we collect with any of our Providers, regardless of which specific Provider you first received the Service from.

7. Advertising and marketing

As mentioned above, you can think of the provision of the Service by our Providers as a fair exchange for certain things you provide or agree to receive.  One of those ‘exchanges’ is our use of advertising and marketing content, similar to that which you may have seen elsewhere (for example ad-funded video content). By registering for and using the Service you are agreeing to Skyfii or any Provider sending advertising and direct marketing material to you, and providing associated interactive functionality, that we or any Provider consider may be of interest to you.

You may opt-out of the provision of some direct marking materials by using the functional unsubscribe option or by contacting us.  In other cases, it is an inherent part of the Service you are receiving and it is not operationally possible to opt-out of any advertising displayed as part of your access to the Service (e.g., advertising displayed upon WiFi login).

8. How do we disclose your personal information?

Generally, we will disclose your personal information to our Providers in connection with our supply of products and services to them, as well as to facilitate their provision of the Service to you.  We may also facilitate the sharing of your personal information between our Providers.

Skyfii is part of a group of companies and we may (in rare circumstances) also transfer your personal information between the different Skyfii entities, however we will do so in accordance with all applicable laws including the Act and the APPs.  Information on the different Skyfii entities comprising the group can be found on our website.

Either Skyfii or our Providers may also disclose your personal information where it is reasonable to do so or we are authorised or required to do so by applicable law.  For example, we might disclose your personal information confidentially to a third party contractor that is contracted to provide services to us.  In very rare circumstances we also might transfer your personal information overseas (for example as part of our disaster recovery policies in respect of our data centres), however we will not do this as a matter of course.

9. Which Skyfii company is responsible for your personal information?

Skyfii is committed to complying with all privacy laws in each jurisdiction in which it operates.

In almost all cases, your personal information will be collected, held, use and disclosed by Skyfii Group Pty Ltd.  If you register or receive the Service overseas, your personal information will be likely to be provided to Skyfii Group Pty Ltd in Australia.  If this changes, we will take reasonable steps to bring this to your attention.

10. Security

We are committed to protecting your personal information by taking all reasonable steps to prevent the personal information we hold about you from misuse, interference or loss, and from unauthorised access, modification or disclosure.  Our security measures meet the highest industry standards and you can feel confident in our processes.  These include access control procedures, network firewalls, encryption and physical security.

Your personal information will be encrypted and where practicable will also be anonymised and aggregated.

11. Quality of your personal information

We will take reasonable steps to ensure that the personal information we hold, use and disclose is accurate, up to date and complete.  However, we will not take any administrative steps to verify the accuracy or completeness of the information you provide to us (or a third party such as our Providers provide to us) at the time of collection (for example, if you make a mistake when typing in your details or choose to use a pseudonym).

If you suspect or believe that the personal information we have is not accurate, complete or up to date, please contact us at the details below and we will respond to your request within a reasonable period.  When responding, we will take reasonable steps to correct that information and to ensure that it remains accurate, complete and up to date in the future.  If for some reason we are unable to correct your personal information, we will provide you with our reasons in writing and your further options for complaint.  We will not ordinarily charge you for requesting the correction of your personal information.

12. Access to your personal information

You are entitled to access the personal information we hold about you, on request, subject to a limited number of exceptions.  If for some reason we are unable to provide you with access to your personal information, we will provide you with our reasons in writing as well as your further options for complaint.  If we did not collect your personal information directly from you, it will ordinarily be more practical for us to pass your access request on to the relevant third party (e.g. our Provider).

You may make an access request via the contact details below and we will respond to your request within a reasonable period.  Ordinarily, we will require you to attend our office to access your personal information in secure circumstances, however we will give reasonable consideration to any other access procedure you may suggest in writing where it is practicable to do so (in whole or in part).  We will not ordinarily charge you for gaining access to your personal information.

13. How long will we keep your personal information?

We retain personal information after we have used the personal information for the purposes for which we collected or received it.  The duration that we keep your personal information for will be influenced by the nature of that information and as required by our Providers.  Unless otherwise required by our Providers, we will begin to delete most of your personal information around three years after collection as this is the average life of most devices which use the Service.  When no longer required, Skyfii will use its best endeavours to ensure that all such information will be destroyed in a secure manner and in a reasonable timeframe.

14. How to contact us

If you would like to contact us, including to ask a question or make a complaint, we may be reached at the details below:

A:

Privacy Compliance
Skyfii Group Pty Ltd
Level 1
34-36 Oxford Street
Darlinghurst
SYDNEY NSW 2010
AUSTRALIA

E:

privacy@skyfii.io

T:

+61 2 8188 1188

We may modify or amend the provisions of this Privacy Policy from time to time.  We will take reasonable steps to bring any such modifications or amendments to your attention.

You can also find out more about the way we manage the personal information we hold by contacting us via our website athttp://www.skyfii.io.