Privacy Policy

Wipanto, also referred as “Spotbox” in some locations, is a platform that automatically collects, organize and treats information shared by WiFi users when connecting to Wipanto’s public networks. We give our clients tools to manage their own Wi-Fi service and to understand and communicate with their customers. This Privacy Policy covers Wipanto’s handling of two categories of information:

  1. Information we collect, such, but not only, as the email addresses our clients’ customers supply when signing up for Wi-Fi or visiting our clients' websites, as well as certain information collected about the Wi-Fi routers; and

  2. Information collected from visitors to Wipanto’s own website, wipanto.com.

Each of those two categories has its 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.

Wipanto has developed a marketing platform that collects, organize and treats information shared by WiFi users when connecting to Wipanto’s public networks. The information is automatically collected by devices (routers) and, by using its own algorithm, has the main goal to understand and optimize information, maximizing results in the marketing channel; Wipanto’s technology allows to analyze customer preferences. It helps businesses to grow by understanding how clients behave online and by allowing specific actions to be taken to improve the customer experience, gain frequent customers, improve online reviews, grow clients’ data base, among others based on users’ behaviors. You can know more about the automated decisions/profiling further in this document.

The success of Wipanto depends directly on the ability to satisfy all parts, specially its clients (businesses that have installed Wipanto’s devices) and subscribers (users contained in the databases that gave at the time of registration, the consent order to receive advertising campaigns). With this intention, Wipanto defined a set of principles that aim to safeguard the best interests of all parties:

- We believe that Marketing should always create a positive experience for users. We developed a system with the ultimate goal of delivering the right message to the most receptive user, aiming to increase campaigns performance, the shopping/consumer experience and enlarging subscribers’ lifecycle.

- The security of our Clients, Subscribers and Partners is a cornerstone at Wipanto. A trustful relationship must be built between, Clients, Wipanto, Users and other external parties. Clients must accomplish industry standards and Wipanto’s rules, regarding advertising material. The widespread advertising must be accurate and truthful. The information provided by the clients in their marketing campaigns must be credible and true by fulfilling all applicable laws.

- The widespread publicity should be clear and transparent, easily identifying which service is being advertised. The violation of applicable law is the (solo) responsibility of the Client.

- On the other hand, Wipanto’s data collection is made through the “opt-in” method and grants explicit consent of the subscribers to receive third party advertising campaigns. Databases are in complete accordance with the applicable legislation in each case (International, European and National laws), thus guaranteeing that subscribers are protected from potential damage associated with the activity of some types of marketing, such as phishing, virus, trojans, scams or other types of malware.

 

1. Information Collected by Wipanto


We provide our clients wireless devices (routers) that can be plugged to the existing internet router, allowing them to share their Internet connection with people around their store. 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 through a client's Wi-Fi, a person must (1) submit basic contact information or connect through a login on its social media account, and (2) agree these terms and privacy practices. The user may need to enter additional information, such as their date of birth, gender or other.

When using the social media buttons to login, we may collect information associated to the user’s social media account chosen such as (1) name, (2) email address, (3) phone number, (4) birthday date, (5) gender, (6) location.

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 Wipanto router (of any Wipanto 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 Wipanto 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 and our third-party service providers, including Google Analytics and others, 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.

You can read more about who will have access to your data on section 3. “Additional Information About Privacy Practices”.

Online Analytics

We may use third-party web analytics services. These service providers use cookies and other technologies described in this Privacy Policy to help us analyze users’ preferences. The information collected by the technology will be disclosed to or collected directly by these service providers.

 

Tailored Advertising

Third parties may also use cookies or other tracking technologies on your computer or other device you are using to collect information about your access 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) 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.

 

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:

  1. To help clients administer their Wi-Fi networks and contact lists

  2. 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)

  3. To help clients with communications and marketing (such as content recommendations and optimization, ad targeting, and other promotional activities)

  4. To facilitate surveys and other business processes

  5. To create aggregate or de-identified information, or to correlate likely identities over time and across platforms

  6. For compliance with law, fraud prevention, risk mitigation, resolution of disputes, enforcement of legal terms, and similar purposes

  7. To otherwise analyze, improve and provide products and services

  8. For other purposes requested or authorized by our clients.

Automated Decisions and Profiling

 

We use your data to improve our clients’ communications. Based on the information collected, you may receive automated communications based on (1) your birthday, (2) your visit frequency, (3) your age, (4) your gender, (5) your location or others.

 

2. Information collected on our own Websites


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 CV’s. 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.

 

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:

  1. 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)

  2. To facilitate surveys and other business processes

  3. To create aggregate or de-identified information

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

  5. To otherwise analyze, improve and provide products and services

  6. In the case of job applications, to evaluate candidates for possible employment or for related employment compliance purposes

  7. Other purposes for which the individual provided it

 

3. Additional Information About Privacy Practices


Disclosures of Information

 

We disclose information as described below:

  1. To Our Client

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

  2. Affiliates

    1. We may share information with our affiliates.

  3. To Agents & Contractors

    1. 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).

  4. For Legal Reasons

    1. 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 Wipanto, our clients, our employees, or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.

  5. Changes in the Structure or Ownership of the Company or its Assets

    1. 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.

  6. Direct Collection by Third Parties

    1. 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.

  7. Aggregated or De-identified Information

    1. We may share aggregated or de-identified data without restriction.

  8. At a Client's Request

    1. At the request of a client, we may also make additional disclosures of information we hold for that client.

  9. Consent or Legal Permission

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

 

As described above, your data may be shared with third parties (our clients, affiliates, agents and contractors), however when this situation occurs, we have previously taken into consideration all security measures and legal aspects (per example, by written contracts) to ensure that your data is kept safe and used only by terms we’ve established.

Data Storage

Your data may be stored for as long as this service is active, but you will always have the right to access, correct or delete your personal data.

 

Access Your Data, Your Rights, Opt-out and Privacy Rights

You can access, correct, oppose, delete, limit or transfer all your personal data. To request any of this, please email support@wipanto.com. If you feel your rights have not been secured, you can contact the competent authority for Data Protection in your country.

To opt out of our use of your device's MAC address for marketing purposes, please email support@wipanto.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 Wipanto 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.

For information about opt-out options relating to data collected using cookies and other automated technologies (e.g., for analytics and advertising), please review the "Information Collected" part of Section 1 of this Privacy Policy, above.

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@wipanto.com to make those requests or for help with the MAC address opt-out described above.

Children's Privacy

 

If you believe that any minor under 16 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 might be 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 wipanto.com, and we will include the effective date of the update.

Contacting us

turnU Lda. is the owner and manager of the platform named “Wipanto” (also referred as “Spotbox” in some locations); is present at Rua do Campo Alegre, N. º 796, 4º Dto Traseiras, 4150-171 Porto, Portugal.

If you have any questions about this Privacy Policy or our privacy practices, please contact us at info @ wipanto.com. You also may write to our Office at:

turnU, Lda

Rua do Campo Alegre, N.º 796, 4º Dto Traseiras, 4150-171 Porto

Portugal

© 2020 by turnU