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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:

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

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.

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

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.

PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

Cookies, Cont.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

– “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number.  We refer to this information as “Order Information.”

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).  Additionally, we use this Order Information to:

Communicate with you;

Screen our orders for potential risk or fraud; and

When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

We use Device Information and cookies to deploy retargeting ads through Visto, AdRoll, Facebook, Twitter, Bing, Google AdWords, ReTargeter, Instagram, Perfect Audience, Site Scout, Exact Drive, and Criteo.

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above.  For example, we use WordPress to power our online store–you can read more about how WordPress uses your Personal Information here:  https://wordpress.org/about/privacy/.  We also use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

We use Personal Information and cookies to deploy retargeting ads through Visto, AdRoll, Facebook, Twitter, Bing, Google AdWords, ReTargeter, Instagram, Perfect Audience, Site Scout, Exact Drive, and Criteo.

BEHAVIOURAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by visiting the following URLs and following the instructions included therein:

Article describing how to opt out from various services used: https://www.howtogeek.com/341487/how-to-opt-out-of-targeted-ads-around-the-web/

General targeted advertising services opt out: http://optout.networkadvertising.org

FACEBOOK – https://www.facebook.com/settings/?tab=ads

GOOGLE – https://www.google.com/settings/ads/anonymous

BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:  http://optout.aboutads.info/.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above.  Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

DATA RETENTION

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons

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

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 Robly, which handles the information pursuant to its privacy policy (https://support.robly.com/privacy-policy/) and terms (https://support.robly.com/robly-terms-of-service-2/).

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@GetSuperFi.com. 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@GetSuperFi.com 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@GetSuperFi.com

You also may write to our Privacy Officer at:

SuperFi LLC
25 N. Market St.
Jacksonville, FL 32202