SuperFi LLC Privacy Policy

This is the Privacy Policy of SuperFi LLC. (“SuperFi”). We give our clients tools to manage their own Wi-Fi service and to understand and communicate with their customers. This Privacy Policy covers SuperFi’s handling of two categories of information:

  1. Information we receive from or on behalf of our clients, such as the email addresses their customers supply when signing up for Wi-Fi or visiting our clients’ websites, as well as certain information collected in connection with the Wi-Fi routers; and
  2. Information collected from visitors to SuperFi’s own website, GetSuperFi.com.

Each of those two categories has it’s own section below. Following those sections is a third section containing general information about our privacy practices, as well as your opt-out options and details about exercising your rights. This Privacy Policy does not address our clients’ own privacy practices.

  1. PRIVACY PRACTICES FOR INFORMATION WE RECEIVE FROM OR ON BEHALF OF OUR CLIENTS

Information Collected

In an expanding number of cities, we provide our clients (restaurants, stores and other businesses) with wireless routers that let them share their Internet connection with people around their location. Like all Wi-Fi routers, ours receive the unique MAC address of nearby wireless devices, such as smartphones. We keep a record of these MAC addresses and the Wi-Fi routers they are near, absent a legal constraint or an applicable opt-out. To sign up to use the Internet connection though a client’s Wi-Fi, a person must (1) submit basic contact information, such as an email address, and or (2) agree to terms and privacy practices.

After a user signs up, we associate their email address and other personal information with their device’s MAC address and with any location history we may previously have gathered (or later gather) for that device’s MAC address. Later, when the user’s device returns to this client location or enters the Wi-Fi range of another SuperFi router (of any SuperFi client), we automatically recognize the device and record the visit in our record for that device, unless the user has opted out. We also may record information about whether and when the individual used the Internet, but SuperFi does not review or record the actual Wi-Fi traffic (such as the content of emails sent through the Wi-Fi or the URLs of web pages visited).

In some cases, we may operate a portion of our client’s website, such as when we manage an email list sign-up form for them (in addition to or instead of the Wi-Fi-based signup form). On our clients’ websites, and in the signup and login pages for our Wi-Fi, we and our third-party service providers, including Google Analytics, may use cookies, web beacons, and other automated technologies to collect information about the computers or other devices used to access the Wi-Fi. As described further below, we may collect and analyze information such as browser type, ISP, operating system, access time, IP address, device type, unique device identifiers, and the web pages from which visitors arrive at the website. Cookies and Other Technologies: We and our third-party service providers may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the products and services we provide. We or our third-party service providers also may use certain of these technologies in emails to end users, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. You can choose to accept or decline certain cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline certain cookies if you prefer. If you disable cookies, you may be prevented from accessing or taking full advantage of the Wi-Fi or our clients’ websites.

Online Analytics:

We may use third-party web analytics services, such as those of Google Analytics. These service providers use cookies and other technologies described in this Privacy Policy to help us analyze how users use our website and Wi-Fi. The information collected by the technology will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on by clicking here.

Tailored Advertising:

Third parties may also use cookies or other tracking technologies on your computer other device to collect information about your access to or use of our client’s website or Wi-Fi to (i) inform, optimize, and serve marketing content based on your access to or use of a website or Wi-Fi and (ii) report how our marketing content impressions, other uses of marketing services, and interactions with these marketing impressions and marketing services are related to visits to our establishment(s), access to, or use of websites or Wi-Fi. We may also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored marketing to you through our clients’ websites or Wi-Fi, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Wi-Fi. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider in hashed, non-human readable form.

If you are interested in more information about tailored browser advertising and how you can generally control certain cookies from being put on your device to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out Link, the Digital Advertising Alliance’s Consumer Opt-Out Link or the European Interactive Digital Advertising Alliance Opt-Out Link to opt out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that you will still receive advertising content even if you opt out of tailored advertising. Also, we do not control the four opt-out links above and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browser is configured to reject cookies when you visit an opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your opt-out may no longer be effective. Additional information is available on the websites accessible by the above links. In addition to the above, our clients may provide us with personal information (usually about their current and potential customers), such as customer contact or point-of-sale information. We also collect information from third-party sources (such as social networking platforms). We may enhance the data we receive from or on behalf of a particular client with data that we receive from other data sources or that we have inferred or modeled ourselves. Uses of Information we use the information described above (sometimes in combination with other information we obtain) for the following purposes: To help clients administer their Wi-Fi networks and contact lists. To help clients learn more about their current and prospective customers, and to assist them (or others) in identifying trends, inferences, affinities or patterns among customers or prospective customers (whether those customers are identified, de-identified or aggregated) To help clients with communications and marketing (such as content recommendations and optimization, ad targeting, and other promotional activities) To facilitate surveys and other business processes To create aggregate or de-identified information, or to correlate likely identities over time and across platforms For compliance with law, fraud prevention, risk mitigation, resolution of disputes, enforcement of legal terms, and similar purposes To otherwise analyze, improve and provide products and services For other purposes requested or authorized by our clients

  1. PRIVACY PRACTICES FOR INFORMATION WE COLLECT ON OUR OWN WEBSITES

Information Collected

We collect information, including when you provide information directly to us and when we passively collect information from you.

Visitors to our website may submit contact information, such as their name, address, email address and phone number, as well as information required to make payments to us. They also may submit information about their business.

Job applicants on our site may submit their employment details and other information typically found in résumés. On a strictly voluntary basis, job applicants can also submit responses to certain demographic and life-history questions that we ask for equal employment compliance purposes.

Section 1 above describes the collection of various types of information from website visitors using automated technologies (such as cookies). On our website, we and our third-party providers may collect the same sorts of information, using the same sorts of automated technologies, for the same sorts of purposes, and with the same opt-out options.

Uses of Information

We use the information collected on our website (sometimes in combination with other information we obtain) for the following purposes:

To communicate with current and prospective clients, including for marketing and promotional purposes (for example, by using cookies and other technologies described above to target or retarget ads and offers to our own customers when they browse the internet)

To facilitate surveys and other business processes

To create aggregate or de-identified information

For compliance with law, fraud prevention, risk mitigation, and similar purposes

To otherwise analyze, improve and provide products and services in the case of job applications, to evaluate candidates for possible employment or for related employment compliance purposes

Other purposes for which the individual provided it

  1. ADDITIONAL INFORMATION ABOUT PRIVACY PRACTICES

Disclosures of Information

We disclose information as described below:

To Our Client. When we collect information for or on behalf of a client, we may share that information with that client.

Affiliates. We may share information with our affiliates.

To Agents & Contractors. We may share information with third parties that help us operate our business and provide our services, such as contractors that provide us with technology, services, data or content (e.g., a hosting provider). For example, to receive more details about the individuals whose contact information we receive, we may share the information with FullContact, which handles the information pursuant to its privacy policy (www.fullcontact.com/privacy) and terms (www.fullcontact.com/terms).

For Legal Reasons. We may share information when we believe that doing so is appropriate to comply with the law; enforce or apply our agreements; or protect the rights, property, or safety of SuperFi, our clients, our employees, or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Changes in the Structure or Ownership of the Company or its Assets. We may transfer the information we hold in the event we sell or transfer all or a portion of our business or assets (such as in connection with a merger, acquisition, reorganization, dissolution or liquidation) or take steps in anticipation of such a transaction.

Direct Collection by Third Parties. In some cases, we may arrange for a third party to collect information directly from individuals, such as if we help a client install embedded content or tools on their website or app (or when we do this on our own website), such as embedded videos, embedded social network buttons or automated advertising technology. These third parties may collect information directly (for example, when they record a user’s “Like” of something). Such providers’ handling of the information is subject to their own privacy policies, terms and practices and is not covered by this Privacy Policy.

Aggregated or De-identified Information. We may share aggregated or de-identified data without restriction.

At a Client’s Request. At the request of a client, we may also make additional disclosures of information we hold for that client.

Consent or Legal Permission. We may engage in additional sharing of information with the consent of the individual to whom it pertains or when otherwise permitted by law.

Opt-out and Privacy Rights

To opt out of our use of your device’s MAC address for marketing purposes, please email support@SuperFi.org. If you opt out, we also will refrain from using the list of locations where our Wi-Fi routers detect your device for marketing purposes. However, you will not be able to use most or all of SuperFi clients’ Wi-Fi if you opt out. Alternatively, you may deactivate your device’s Wi-Fi, which will prevent our further collection of your device’s MAC address.

The law of your country may give you additional rights to access, correct, update or delete certain personal information we hold about you. Your country may also give you additional rights to object to our processing of your personal information or to withdraw your consent to our processing of your information. You may contact us at support@SuperFi.org to make those requests or for help with the MAC address opt-out described above.

Children’s Privacy

If you believe that any child under 13 has provided us with any personal information, we ask that the parent or guardian of that child contact us to ensure that such information is deleted from our files. We also will honor similar requests from parents and guardians in jurisdictions where the age threshold provided by law is higher.

Updates to this Privacy Policy

We may modify this Privacy Policy from time to time as our business practices and legal requirements evolve.  In the event this Privacy Policy is modified, we will provide notice of the change by posting the updated Privacy Policy to GetSuperFi.com, and we will include the effective date of the update.

Contacting us

If you have any questions about this Privacy Policy or our privacy practices, please contact our Privacy Officer at support@SuperFi.org

You also may write to our Privacy Officer at:

 

SuperFi LLC
1225 West Beaver St
Jacksonville, FL 32204