Skyfii Privacy Policy for End Users & Website Visitors

Last Updated: May 3, 2019

INTRODUCTION

This privacy policy relates to personal information collected and/or processed by Skyfii Group Pty Ltd (ACN 165 152 241) and its affiliates (‘Skyfii’, ‘us’ or ‘we’).

Skyfii is committed to protecting your privacy. The purpose of this privacy policy is to help you understand what personal information we collect and why, and what we do with it. We have prepared this privacy policy with due regard to the data protection laws in the countries in which we collect and process personal information, including the EU General Data Protection Regulation (EU Regulation 2016/679). Our policy is to comply not only to the letter of the law, but also to the spirit of the law.

Skyfii provides products and services utilising the Skyfii platform (our “Platform”) to our business customers (our “Customers”). Customers use the Platform with their WiFi network to provide guest WiFi services to individuals who visit their premises, venues and locations (“Venues”). The Platform enables Customers to generate visitor location analytics, collect information from visitors to their Venues (including personal information) and to interact with them.

This privacy policy applies to individuals who visit Venues and whose data is collected by our Platform and also to individuals visiting our website or contacting us through the website or our online channels (“you” and “your”).

When you visit our website or contact us using our online channels (such as through our social media accounts) we collect your personal information as a controller. For more information please see the section of this policy below on Website Visitors.

When we collect your personal information because you have visited a Venue, our Customer is the data controller and we are collecting your personal information as their data processor. For more information about our role as a processor, please see the section of this policy below on End User Processing.

SKYFII WEBSITE VISITORS

Personal information we collect

When you visit our website or contact us using our online channels

When you contact us using the information on our website or through one of our social channels (including LinkedIn, Twitter and Facebook) we collect the information you provide to us. This typically includes your name, job title, employer business address, business email and any additional information you include in your message.

If you sign up to receive our latest product and company updates, we collect your email address.

When you visit our website, we may collect limited personal information automatically through the use of cookies and web beacons. For more details on cookies and web beacons, please refer to the section on cookies immediately below. We may also automatically collect information including the IP address of your organisation or ISP, your browser family, operating system family and version, your country and continent and your web page viewing path including page response times and download times. This information does not include personal information and is used only help us improve the performance of our website and to troubleshoot problems.

Cookies & social media links

When you visit our website

Skyfii uses cookies and web beacons on our website and web beacons in some emails we send. Cookies are small text files and web beacons are small graphic images. They are downloaded to your device when you visit a website or receive certain emails unless you have set your browser to stop them.

We use cookies to remember your preferences, display content that is more relevant to you and improve your overall experience on our site. We use web beacons to track the actions of individuals (such as email recipients) and measure the success of our marketing campaigns and response rates.

To learn more about cookies and web beacons, and what you can do to block them, please view our Cookie Policy.

Our website includes social media sharing buttons and links to enable you to share our content through your preferred social media site from one of our web pages. These features may collect your IP address and the page you are visiting on our website and may set a cookie on your device.

When you use one of these buttons or links, you are sharing information to another website or service (such as LinkedIn, Twitter or Facebook) and this privacy policy will no longer apply. Please read the privacy notices provided by the particular social media website you are sharing through before posting any personal information using these links.

How we use your personal information

Collected when you visit our website or contact us using our online channels

We use the personal information you provide to us to respond to your enquiry and, if you have agreed to us doing so, we use it to subscribe you to our product and company updates. You can unsubscribe from our updates and associated communications at any time by contacting us at privacy@skyfii.io or by using the ‘unsubscribe’ link in our emails.

We use cookies and web beacons as set out above. For information on how to block cookies, please see our Cookies Policy.

Basis for using your personal information

We use your personal information to communicate with you because it is in our legitimate interests to reply to enquiries made by individuals through our website, by email or through our social channels. Also, to send you our product and company updates where you have consented to us doing so.

You can object to, or withdraw your consent for, Skyfii using your personal information in these ways. You can do so by unsubscribing to our product and company updates using the link provided in our emails or by contacting us at privacy@skyfii.io.

We only use cookies and web beacons with your consent. Unless you decline them, you consent to our use of cookies and web beacons by closing or dismissing the cookie banner displayed when you visit our site. You can manage your cookie preferences through your web browser settings, as set out in our Cookie Policy. You can also contact us at privacy@skyfii.io if you have any questions about the use of cookies on our website.

How long we keep your personal information

We will retain your personal information for as long as it necessary for the purpose of our relationship or until you object to us processing it or withdraw your consent.

Sharing your personal information

Sharing your information with our affiliates

We may share your personal information with our affiliates for operational, administration and management purposes. Affiliates with whom we share your personal information may only process it in line with this privacy policy. All Skyfii affiliates are subject to the same security measures and policies when processing personal information.

Employees and independent contractors working for Skyfii only have access to your personal information if it is strictly necessary to allow them to perform their duties and, in all cases, they are bound by obligations of confidentiality.

Sharing your information with our service providers and suppliers

We may use service providers, such as SaaS productivity and collaboration applications, to process your personal information. Where this applies, we enter in to written processing contracts with these service providers imposing data protection terms to the standard required by data protection law.

Other sharing

It is possible that we may be required to share your personal information where mandated or permitted by law or with valid legal processes, such as in response to a court order or with government or law enforcement agencies; when we consider disclosure to be necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal purpose; and in the context of organisational restructuring.

International transfers of your personal information

Skyfii is an Australian organisation with operations in multiple countries. When you contact us using the information on our website or through one of our social channels your personal information is likely to be stored in or accessed from Australia and other countries.

SKYFII END USER PROCESSING

Personal information we collect

When you visit a Customer Venue

When you visit a Venue, our Platform passively collects information from your devices(s) if the WiFi functionality is switched-on. This information includes the Media Access Control (MAC) address which is a unique identifier for your device, although in certain cases both Android and iOS randomise the WiFi MAC. Randomised MAC addresses cannot be used as a unique identifier for your device.

We collect MAC information even if you do not connect to the Venue WiFi. Using the information from your device, we log details about your visit including the duration and frequency of your visits and your location and movements whilst at the venue. From the MAC address we can recognise the manufacturer of your device. Neither Skyfii nor our Customers can identify you using this information.

We collect this information on behalf of the Customer and use it to provide them with visitor analytics through our Platform. These analytics include:

  • Foot traffic: Measuring unique visitor counts and identifying peak visitor times
  • Visitor flow: Visualising the most travelled paths and popular destinations at a Venue
  • Dwell time: Understanding how visitors spend their time at a Venue
  • Heat mapping: Viewing visitor movement and density at a venue

Our analytics help Customers to improve the visitor experience at their Venue. Although the information we collect from your device does not include information we or the Customer can use to identify you, we do understand that you might not want to be included in visitor location analytics.

You can opt-out of visitor location analytics at any time through our online self-service portal located at: https://profile.skyfii.com. If you opt-out entirely from data collection, the MAC addresses associated with your email will not be monitored for analytics purposes in the future, at any Venue.

Personal information we collect

When you register for WiFi at a Customer Venue

When you register for guest WiFi at a Venue, our platform will directly collect information from you at the time of registration. Our Customers may also actively collect additional information after you register through questionnaires and surveys. Our Customer determines the information, including personal information, that we ask you for directly and we always collect this information on their behalf.

The information collected from you directly commonly includes your:

  • Full name and prefix (e.g. Mr, Mrs, etc.)
  • Mobile number
  • Email address
  • Date of birth
  • Gender
  • Age
  • Postcode
  • Country or state of residence

If you register using a social network identity you will be asked what information, including personal information, you wish to share with us, and we will collect this information directly from the social network.

We also collect information about you passively and by inference. This commonly includes:

  • Your browsing device fingerprint, including the MAC address, as set out above.
  • The time, date and location of registration
  • The duration and frequency of your use of the WiFi service and visits to Venues
  • The approximate location of your device while at Venues
  • Your browsing history while using the using the Venue WiFi
  • Your engagement with the Customer’s social media posts and other social activity
  • Demographic information such as age and gender (if not provided at registration)
  • Your interests and likes

Cookies & Web Beacons

When you register for WiFi at a Customer Venue

Skyfii may download third party cookies and web beacons to your browsing device when you register for WiFi at a Venue and if you give your consent to do so. Cookies are small text files and Web Beacons are small graphic images.

Cookies and web beacons enable our advertising partners to passively track your web browsing activities, gather information about your demographics and interests and to serve targeted advertisements to you. Cookies and web Beacons may recognise you across multiple devices and will track your browsing activities even when you are not at a Venue.

If you consent to cookies and web Beacons you can change your mind and withdraw consent at any time by opting out of cooking and pixel tracking at https://profile.skyfii.com.

You can also learn more about online behavioural advertising and set your preferences at the following links:

Sharing your personal information

Sharing your information with our affiliates

We may share your personal information with our affiliates for operational, administration and management purposes as permitted by our data processor agreement with our Customers.

Affiliates with whom we share your personal information may only process it in line with this privacy statement. All Skyfii affiliates are subject to the same security measures and policies when processing personal information.

Employees and independent contractors working for Skyfii only have access to your personal information if it is strictly necessary to allow them to perform their duties and, in all cases, they are bound by obligations of confidentiality.

Sharing your information with Customers

Our Customers sometimes share your personal information with third parties, including their other data processors. We often help facilitate this by allowing third parties to have access to your personal information within or from our Platform at a Customer’s request. Common examples of this include where:

  • The administration of our Platform has been outsourced by a Customer to another supplier (such as one of our reseller partners) and we have provided the that supplier with admin access to the Customer’s account via the Platform.
  • Personal information is transferred automatically from our Platform to another processing system used by the Customer such as a CRM, using the API we provide to Customers to integrate our Platform with other systems.

When we facilitate the transfer of information in this manner your personal information is being transferred by our Customer.

Sharing your information with our service providers and suppliers

We use service providers to help us process your personal information on the Customer’s behalf. We are authorised to use these service providers as sub-processors in our data processing agreement with the Customer. In all cases we enter into written processing contracts with our service providers imposing data protection terms to the standard required by law.

Other sharing

It is possible that we may be required to share your personal information where required or permitted by law or with valid legal processes, such as in response to a court order or with government or law enforcement agencies; when we consider disclosure to be necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal purpose; and in the context of organisational restructuring.

International transfers of your personal information

Skyfii is an Australian organisation with operations in multiple countries. Whilst we will always store your personal information in your local region, it may be accessed or processed in Australia and other countries globally for purposes including Customer support and reporting.

We are permitted by Customers to process personal information about individuals in the European Economic Area (“EEA”) outside of the EEA as set out in our data processing agreement which includes ‘Standard Contractual Clauses’ approved by the European Commission.

Standard Contractual Clauses safeguard the rights and freedoms of individuals in the EEA when their personal information is transferred to and processed in countries outside the EEA.

How long we keep your information

We retain your personal information for as long as determined by the Customer on whose behalf we collected it.

If a Customer deletes your data from our Platform because you longer wish to be a registered user of their WiFi service or to receive communications from them facilitated by our Platform, we will no longer hold it. If a Customer ceases to use our products and services, we will destroy your personal information in a secure manner or anonymise it within a reasonable timeframe.

If you don’t register for the WiFi service at a Venue but we collect general information and the unique MAC address for your browsing device, we retain this information for as long as you continue to visit a Venue with the device. We will anonymise the MAC address and make it impossible to recognise if we don’t detect it at a Venue for 13 months.

PROTECTING YOUR INFORMATION

We use variety of security measures including resilient technical controls and robust organisational policies and procedures to protect your personal information.  These measures include security monitoring, restricted access to personal information at multiple levels and enforced by technical controls, encryption of data in transit and at rest, secure software development processes and ongoing third-party security testing.

YOUR RIGHTS

You have legal rights in relation to your personal information.

Skyfii as data controller

If we have collected your personal information because you visited our website or contacted us through the site or our social media channels, then we will facilitate your rights directly because we are the controller of your personal information.

Where Skyfii is the controller of your personal information, we extend the rights available to individuals in the EEA to all data subjects whose data we process irrespective of their location. These are as follows:

  • You have the right of access to your personal information and can request copies of it from the controller and information about their processing of it.
  • If the personal information the controller holds about you is incorrect or incomplete, you can ask it to rectify or add to it.
  • If the controller is using your personal information with your consent, your can withdraw your consent at any time.
  • Where the controller is using your data because it is in its legitimate interests to do so, you can object to it using it this way.
  • Where the controller is using your personal information for direct marketing, including profiling for direct marketing purposes, you can object to it doing so.
  • In some circumstances, you can restrict the controller from processing your data, request a machine-readable copy of your personal information to transfer to another service provider and compel the controller to erase your personal information.

You also have the right to lodge a complaint with a supervisory authority in an EU member state if you believe the we are infringing EU data protection laws. You can lodge a complaint with the supervisory authority in your EU member state of residence, the member state in which you work or the member state in which the alleged infringement took place.

You can find the contact details for your national data protection authorities in the EU at this link.

Skyfii as data processor

If we have collected your personal information on behalf of a Customer when you have visited a Venue, your rights are facilitated by the Customer because they are the controller of your personal information.

The rights available to you depend on the laws of the country in which you are located or in which the controller is established and processes your personal information. You should contact the data controller to exercise your rights. If you are unsure who the data controller is you can contact us at privacy@skyfii.io and ask for the controller’s contact details.

In some cases, you can exercise some of your rights using our self-service portal at https://profile.skyfii.com.

CONTACTING 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:

Attention: Privacy Officer
Level 2, 100 William Street
Woolloomooloo
Sydney, NSW 2011
Australia
Email: privacy@skyfii.io
Tel: +61 2 8188 1188

UPDATES TO THIS PRIVACY POLICY

We may update this privacy policy from time to time in response to changes in applicable laws and regulations, to our processing practices and to services we offer.

When changes are made, we will update the ‘Last Updated’ date at the top of this page. Please review this privacy policy periodically to check for updates.