Cloud4WI (“C4WI”, “We”, “us”, or “our”) is a privacy-first technology development company that specializes in offering users (“Users” or “You”) a seamless, secure WiFi access and unleash innovative location-aware experiences, while driving business outcomes – without any additional workload for IT staff. We believe in creating immersive mobile-first environments where people can connect with the brands they love. This is facilitated through a combination of technology solutions that have user privacy at its core without compromising the user experience. We care about the security and privacy of the personal data that is entrusted to us during user testing.
It is C4WI’s policy to respect your privacy while you use our demo product experiences and mobile apps, which we own and operate. Any information that we do receive is by fair and lawful means.
If you are not a test user of one of our customers/potential customers you should not install this app and/or use the demo experience.
A Special Notice About Children
Users Under 16 Years of Age
Children are not eligible to use this app/service unsupervised, and we ask that children do not submit any personal information to us. If you are under the age of 16, you may only use the Services in conjunction with, and under the supervision of your parents or guardians.
Users Under 13 Years of Age
Children under the age of 13 are not eligible to use the app/service. Only parents or legal guardians can submit personal information to us about a child.
If we learn we have collected Personal Information from a User under the age of 13 without parental consent, we will delete that information as quickly as possible.
Owner & Data Controller
Cloud4Wi Inc. is a company established at 68 Jay Street, New York, NY 11201, United States of America, which has appointed Cloud4Wi Srl, with registered address at Via Filippo Corridoni 117/D, 56125 Pisa, Italy, as its representative in the European Union for the purposes of the General Data Protection Regulation which is acting as a data controller as regards to the personal data processed while using the app.
How to Contact Us
For customer support, please open a ticket at support.cloud4wi.com using your Service account.
How We Collect Your Information
We will collect the information directly form the users when they download and install the app or user the service.
Which Information We Collect About You
We may collect the following information from you:
a) Device Information: Advertising identifiers for Android mobile devices, IP Address.
b) Contact data: Name, surname, email address;
c) Usage Data: Usage Data such as browser type, session duration, operating system, system language, device model, device motion parameters, first launch, app opens and updates, download, and installation confirmation.
d) Location Data: Proximity to a specific Point of Interest
How We Use Your Data
a) Device Identifiers: We collect this information to optimize our app and services and to help with troubleshooting. (Legitimate interest)
b) Usage Data: Troubleshooting and improving our app and services. (legitimate interest)
d) Contact data: To identify the users for troubleshooting purposes as well as to respond to your queries (contractual obligation)
d) Location data: Your device`s location data is collected via mobile apps only if you have consented to location data sharing with the app and specifically with Cloud4Wi, and in general by locating the networks where users connect to WiFi services managed via the C4WI product; location data is collected and processed for the purposes of analytics (e.g. city flows, traffic patterns, visits to POIs) and contextual-messaging (i.e. reaching out a user when in a specific location with a message contextual to the location and time). As Location data we intend in general data that allows to pinpoint an individual at a certain point in time in the range of a point of interest.
C4WI does not use algorithms or profiling to make any decision that would significantly affect you.
How We Disclose Personal Data
We may disclose personal data to third parties in the following circumstances:
a) Our entities within the C4WI group of companies.
b) Service Providers: We may share Personal Data with some of our service providers such as Amazon, subject to contract terms that limit their use of Personal Data. We may have service providers that provide services on our behalf, such as media attribution, identity verification services, website hosting, data analysis, marketing services, information technology, and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only to perform services on our behalf and will always comply with legal requirements. We require such service providers to contractually commit to protecting the security and confidentiality of the Personal Data they process on our behalf. our service providers are located in the European Union
e) Compliance & Harm Prevention: We share Personal Data as we believe necessary:
(i) to comply with applicable laws such as GDPR, CCPA, and others;
(ii) to enforce our contractual rights;
(iii) to protect the our and your rights, privacy, safety, and property ; and
(iv) to respond to a request from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
Some of the service providers mentioned above may be located abroad and, in this case, we adopt additional safeguards to guarantee an adequate level of protection for your personal data.
Transfer of Your Information
In accordance with the GDPR, when we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that we use specific controls approved by the European Commission which give personal data the same protection it has in Europe.
How We Protect Your Information
To ensure that your personal information is secure, we communicate our privacy and security guidelines to all employees and business partners and strictly follow precautionary measures regarding privacy within the company.
We strive to protect your personal information through physical, technical, and organizational measures aimed at reducing the risks of loss, misuse, unauthorized access, disclosure, and improper alteration of this data.
We make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical technical or managerial safeguards. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on our Site or through other forms of communication.
How Long We Retain Your Information
Unless you request us to delete your data, the data you have provided to us will be deleted 1 year after your last interaction with the application or since you have uninstalled the application.
If you wish to have more detailed information about our retention times, please contact us at firstname.lastname@example.org.
California Privacy Rights
This section applies only to California residents. The California Consumer Privacy Act (CCPA) is a data protection law that ensures you have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
- Right of Access: you have the right to request that we disclose what Personal Information we have collected, used, and disclosed about you in the past 12 months.
- Right of Deletion: you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
- Right to Non-Discrimination: You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.
You also have the right to opt out of the sale of personal information. In the preceding 12 months, we have not disclosed your personal information to any third party in a manner that would be considered a sale under the CCPA.
For more details on the personal information collected in the preceding 12 months, see our sections above How We Collect Your Information and Which Information We Collect About You. We collect this information for business and commercial purposes as described above in the How We Use Your Data section. Information about which categories of third parties we share this information with is described above in How We Disclose Personal Data.
a) California consumers can make a request related to the above-noted rights by emailing us at email@example.com.
Your Rights Under the GDPR (If You Are a Data Subject in the European Union)
Under the law, you are granted six fundamental rights when data about you is being processed. We will ensure to reach out without undue delay (no more than 30 days) when you submit a request related to exercising your data subject rights. Although uncommon, when applicable for official or legal reasons we may be unable to address the specific request you make related to your rights.
Also, if a request is manifestly unfounded or excessive, in particular, because of its repetitive character, we may either:
- charge a reasonable fee considering the administrative costs of providing the information or communication or taking the action requested; or
- refuse to act on the request.
In this scenario will we inform you of the reasons we believe your request is manifestly unfounded or excessive character of the request.
As a data subject, you have the right to:
a) The right to request confirmation of whether C4WI process Personal Data relating to you and if so, to request a copy of that Personal Data;
b) The right to request that C4WI rectifies or updates your Personal Data that is inaccurate, incomplete, or outdated;
c) The right to request that C4WI erase your Personal Data in certain circumstances provided by law;
d) The right to request that C4WI restrict the use of your Personal Data);
e) The right to request that we export your Personal Data that we hold to another company, where technically feasible;
Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or:
- In some cases, you may also have the right to object to the processing of your Personal Data.
- To exercise your data protection rights please contact our DPO at firstname.lastname@example.org.
- To delete or export all your personal data visit the webpage https://mydata.cloud4wi.com/ and enter the email address provided during the use of the Apps or Services
We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may have the right under applicable laws to consult with the data protection authority in your country.