What do we mean by “Personal Information”?
We support a wide interpretation of what constitutes personal information, which we define as data that relates to any natural person such as an employee or business client, including but not limited to names, addresses, birthdates and billing records. With respect to our clients and when the context so requires, personal information also includes traffic data, location data, IP addresses and internet usage data.
What Personal Information do we collect?
Due to the nature of our services and products, we may collect the following Personal Information subject to notice or consent where relevant:
1. Contact Information, meaning information that allows us to identify or contact you. This information includes name, address, telephone number, e-mail address, user names and passwords, birthdates, gender, language preferences, delivery details, as well as other contact information which is collected directly from you.
2. Account Information, meaning information you provide to us to set up our services such as bank account information, billing address, and information you provide us when you enter competitions or when you contact us inquiring about our products and services.
3. Service Information, meaning information necessary for us to provide services to you, such as the model and service number of your router, Wi-Fi hardware, software versions and IP/MAC address.
4. General Usage Information, meaning information generated when you use our products and services, for instance, when you use our networks to access the internet or use our website.
5. Other Personal Information, meaning information we may obtain, in accordance with applicable law, from publicly available sources or from credit check agencies.
For what purposes do we use Personal Information?
We collect information about you due to the nature of our services and products. It is important for us to ensure that our products and services are simple, personal and reliable. We are constantly looking for ways to improve our services and products and to match them as much as possible to your personal needs. We may therefore collect personal information for the following purposes, subject to notice or consent where relevant:
1.To provide our products and services. We use Contact, Account and Service Information for setting up and maintaining our products and services, for our administrative processes and to administer offers and competitions. These activities include provisioning, technical support, hardware and software upgrades, billing, collection of payments and credit checking.
2.To enhance our products and services. We may rely on general usage information to identify improvement areas. We may conduct market research to improve our existing services and develop new products according to the needs of our clients.
3.To present new products and services. We may communicate with you about upcoming features in our products and services or promotions that might interest you. Please refer to Section “How can you opt-in and opt-out?” where we explain how you can update your marketing preferences.
4.To enable the purchase of goods and services from our Commerce Partners. From time to time, we may present you with special offers while using our products and services enabling you to purchase goods and services from our partners, such as advertisers, promoters, application providers or app stores (all referred to herein as “Commerce Partners”). Should you decide to take advantage of such offers or engage in a transaction, we may collect and communicate your relevant Personal Information to Commerce Partners sponsoring the promotions or transactions. The information will be collected and disclosed by smarthotspots Ireland, only upon your affirmative response to such offers. In addition to fulfilling your request, Commerce Partners may also use Personal Information to send you other information in which you might be interested. The use of Personal Information by Commerce Partners will be governed by their respective privacy policies, which you should refer to in the event that you have any queries regarding how our Commerce Partners might use your Personal Information.
5.To manage our performance. We may use personal information when asking for feedback in respect of the performance of our products and services, our customer care service and our maintenance and operations. Where allowed by applicable law, we may use information related to your use and access to our products and services for purposes of traffic management, customer enquiries and prevention or detection of fraud. Where allowed by applicable law, we may also monitor and record our communications with you, including e-mails and phone conversations, for training purposes, quality assurance and to record details about the products and services you order from us.
6.To meet our legal obligations. We may be required by law to disclose personal information in compliance with the terms of a valid legal process or where required to do so by law enforcement agencies. These disclosures may be made without your consent and knowledge, and without notice, in compliance with the terms of a valid legal process. We reserve the right to challenge the access to personal information by authorities.
7.Other uses. We may use anonymous and aggregated information to develop reports and analyses about what types of internet traffic and/or internet protocols are used, for research and for other legitimate business purposes.
To whom may we disclose Personal Information?
smarthotspots Ltd. is committed to protecting personal information. For the performance of our products and services, we may disclose, in compliance with applicable law and subject to prior notice or consent where relevant, personal information to third parties as described below
1. Smarthotspots Employees. We
limit the number of our employees who have access to your personal
information to a select group of specially authorised employees. Access
is granted to these employees for the proper performance of their duties
on a need to know basis.
2. Commerce Partners. When
you elect to participate in a special offer or engage in a transaction
presented by us but provided by our Commerce Partners, we may disclose
Personal Information to such Commerce Partners where relevant. For more
details please refer to Section “For what purposes do we use Personal
3. Purchaser of our business.
If another company acquires smarthotspots Ltd. or acquires assets of
smarthotspots Ltd. that comprise or include your personal information,
that company will possess the personal information collected by
smarthotspots Ltd. and it will assume the rights and obligations
regarding your Personal Information as described in this Policy.
4. Other third parties. Where allowed by applicable law, we may also share Personal Information with third parties we trust where the disclosure is necessary for the performance of our products and services (e.g. customer care) and with third party vendors specifically engaged by smarthotspots Ltd. to provide products or services to us, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified products or services to us. Where allowed by applicable law, we may also share personal information with credit check agencies or debt collection agencies. There may be instances where we may be required by law to disclose personal information to authorities or other third parties.
How do we protect Personal Information?
We work very hard to protect your privacy and have taken key steps in protecting it. We have formally appointed individuals who are responsible for the security of our network, supporting infrastructure and our information systems. We have implemented solutions to protect personal information, which consist of a variety of both technical and policy-based solutions which vary depending on the applicable service or product offered or provided to you. These solutions may include, but are not limited to, password protection, encryption, firewalls, anti-virus, intrusion detection, anomaly detection and access controls for our employees.
How long do we keep Personal Information?
We must keep personal information for no longer than is necessary for us to fulfil the purposes for which the personal information was collected unless we are specifically required to keep your personal information longer by applicable law.
How can you opt-in and opt-out?
You can change your email, postal or telephone marketing preferences at any time by calling our customer service on 01-5290136 or through the ‘Contact Us’ page on our website. You will be given an opportunity to opt out each time we send a marketing communication to you electronically. Your marketing consent to electronic marketing will remain valid for a further 12 months after receipt of an email or SMS from us unless you opt-out of receiving electronic marketing communications from us.
What about cookies?
What are your rights?
You have a right to have incomplete, incorrect, inappropriate or outdated personal information deleted or updated. If you believe any of the details we hold about you are incomplete, incorrect, inappropriate or outdated, let us know and we will make the necessary corrections or deletions within the applicable legal time frames. You have a right to know what personal information we hold about you. Where permitted by applicable law we may apply a small charge that will cover the cost of the administration involved in providing such information to you. You also have a right to request that we stop processing your personal information for direct marketing purposes. If you no longer want to receive direct marketing information or telephone sales calls from us, please contact our Customer Service. You can contact Customer Service through the ‘Contact Us’ page on our website. Please be aware that when you opt-out or request us to stop processing your personal information there may be instances where we may not be able to continue to provide you with our products or services.
How can you contact us about this Policy?