Skyfii Privacy Policy

Date of Last Revision: November 2017

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. Our Privacy Policy is based on Australian Law. where the collection, storage, use and disclosure of ‘personal information’ is regulated by the Privacy Act 1988 (Cth) (the “Act”) the Australian Privacy Principles (the ‘APPs’) set out in schedule 1 of the Act.

This Privacy Policy is a simple, plain English summary and statement 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’), to assist them as the ultimate providers of Wi-Fi services to you (the ‘Service’) on their respective premises.  Our Providers also 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 here.  More information is available about our products and services and us via our website at http://www.skyfii.io (“website”)

By registering for and using the Service you are agreeing to both our Terms of Use and this Privacy Policy and the terms of use and privacy policy of our Provider.  Please read these documents carefully. 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 your personal information as well as answers to commonly asked questions.

3           What is personal information?

When used in this Privacy Policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include, but is not limited to, your name address, telephone number and email address. The information that we and our Providers usually collect is set out in paragraph 5. If the information we collect personally identifies you or you are reasonably identifiable from it, the information will be considered to be personal information.

4           Why do we need to collect your personal information?

Skyfii collects personal information and other information to facilitate 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 the collection of information about your activities and your receipt of 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. The products and services supplied by Skyfii support the collection and analysis of several different data sources and each of our Providers may use different products and services.  Our Providers may also have their own terms and conditions and privacy policies which will be made available to you when you register for the Service. 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.

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 Providers.

5           How do we collect your personal information?

We collect your personal information in three main ways:

  1. you may be asked to provide us with certain personal information when you register as a user of the Service at which time you will be asked to acknowledge that you have read and accepted our Terms of Use and this Privacy Policy and /or our Providers respective terms of use and privacy policy.
  2. 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. Other trusted partners may also collect non-identifiable data about you via cookies when you visit specific websites.
  • via our website or directly when businesses, advertiser and potential partners contact us about our products and services

When you register to use the Service, the kinds of personal information we collect or infer will depend on the service and products we provide to the relevant Provider.  Different Providers may request different information from you on registration and at other times when you use the Service. In most cases, we will collect some or all of 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 postcode
  • your country or state of residence

In most cases, we will also collect (either directly or through our Provider) or infer 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 their own purposes as set out in this Privacy Policy and or their respective privacy policies, and we may facilitate this process.

We use your personal information to facilitate the provision of the Service to you from our Providers and to supply products and services to our Providers, as well as for our general operational, technical and administrative purposes.  We generally have no direct relationship with the users of the Service whose personal information we process. 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, from time to time, process your personal information to put it in a form from which your identity is not reasonably ascertainable (“De-identified information”). We use such De-identified information for analytic purposes, and may disclose that information to others for our business purposes including enhancing our products and services. De–identified information falls outside the scope of the Act.

7           Use of Cookies

“Cookies” also known as HTTP cookies, web cookies of browser cookies) are simply small pieces of data, which are stored as text files on your mobile device browsers, whenever you visit certain websites. Their typical purpose is to help sites remember particular actions you may have done there in the past. For example, cookies may track when you have logged into a site, visited certain pages or clicked certain buttons or links. We, the Providers and our trusted third–party partners may use cookies to:

  • remember when you have opened a mobile App or visited a website
  • remember your user preferences, searches and favourites
  • target more relevant advertising to you.

 

Although we, our providers or third -party partners may use cookies to gather information to improve your user experience, this information is not personally identifiable.  We do not use cookies to store any personal information, such as name, address or contact details.

Despite this, if you do wish to disable or remove cookies, please see the “Help” section of your browser or mobile device. Each browser or device handles the management of cookies differently, so you will need to refer to your appropriate “Help” documentation.

8           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 the provision 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 consenting 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 or all of direct marking materials by using the functional unsubscribe option or by contacting us.  Some advertising (which may not be direct) 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).

9           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 regardless of which specific Provider you first received the Service from.

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 the disaster recovery processes in respect of our data centre), however we will not do this as a matter of course.

10        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 and held by Skyfii Group Pty Ltd in Australia.  If this changes, we will take reasonable steps to bring this to your attention.

11        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.

12        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.

13        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 information is incorrect we will update it or delete it unless we have to keep that information for a legitimate business or legal purposes.  We may reject requests that are unusually repetitive, require disproportionate technical effort, risk the privacy of others or it would be extremely impracticable (for instance requests residing on backup systems).

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 your request relates to your personal information that we did not collect 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.  We will ask you to verify your identity, so we can act on your request. Ordinarily, we will require you to attend our office to do so and 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 unless it would require disproportionate effort.

14        How long will we keep your personal information?

We retain 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 our contractual arrangements with our Providers.  Unless otherwise required by our Providers or you, 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 or de-identified in a reasonable timeframe.

15        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.

For more information about privacy issues in Australia and protecting your privacy, visit the Australian Federal Privacy Commissioners’ website www.privacy.gov.au