Surefi Guest Wifi Privacy Notice

This Wifi Privacy Policy (“Wifi Privacy Policy”) applies to individuals who use the wireless connection to the Internet or “Wifi” provided by Surefi (the “Service”).

The property or business (“Property”) providing you the Service is using Surefi LLC (“Surefi”) to provide Wifi to you, its tenants, and other visitors. Surefi wants you to know how we collect, use, share and protect information gathered when you use the Service.

By using the Service, you agree to the terms at http://www.surefi.com/tos, (“Terms”) and this Privacy Policy, which is incorporated into those Terms and forms an agreement between you and Surefi on behalf of itself and its affiliates (collectively, “Surefi”, “we”, “us” and similar).

This Wifi Privacy Policy describes our privacy practices for individuals using the Service, such as users of Guest Wifi service provided by businesses or venues (each a “Property”), users that pay per use basis, or businesses who use Surefi’s services to provide wireless networks for their individual business purposes. This Wifi Privacy Policy only applies to the use of the Surefi Service. If you access Wifi or the through any other service provider, then its privacy policy and other terms apply to your use of such service.

This Wifi Privacy Policy explains:

  • what information we collect;

  • how we use that information;

  • who we might share information with;

  • your options regarding the collection, use, and distribution of the information;

  • how you can opt in or out of Surefi promotional e-mail;

  • how you can review or change the information;

  • the kind of security procedures we use to protect the information; and

  • how we make changes to this Wifi Privacy Policy.

What kinds of information do we collect?

Surefi collects a limited amount of personally identifiable information and general usage information that may be aggregated across many users and Properties.

Personally Identifiable Information/Personal Data: Personally Identifiable Information (“PII”) is information that can be used on its own to directly identify or contact an individual. Personal Data means any information relating to a living and identifiable natural person, including PII. In addition to PII, Personal Data may include identifiers such as a name, an identification number, email address, telephone number, physical address, or other information that can reasonably identify a data subject.

We may gather certain Personal Data when you sign on or connect to the Service with your devices. For example, we may ask for your email address or other forms of electronic messaging address, i.e., SMS/text address, mobile push notification or social media connection (“Contact Info”). If you make a purchase from us or a Property, your address and payment information will also be collected, provided, however, we will not store your payment information. Our system may remember some of your Contact Info the next time you visit a Property using Surefi or one of our other Services. This information is used to deliver the Services and other benefits directly to you. While some information we collect is Personal Data, much of it is not. When you submit any PII to us, Surefi: (a) will use the information for the purposes described at the time you submit it; and (b) we may use your Contact Info to provide information, special offers, and VIP opportunities to you as described in this Wifi Privacy Policy and the Terms on behalf of the Property where you used the Service.

GENERAL INFORMATION: We may record information about your usage of the Service to analyze and improve the Service, help Properties serve their customers, and to automate your logins on the same device for future visits to any Properties using our Service. This data is stored and aggregated and may be used to deliver better service to you and merchants in your local area. The information gathered from users may include:

  • Utilization – e.g., # of users of the Service by location and access point

  • Session data – e.g., time, length, and frequency of sessions

  • Type of device– e.g., Dell, iPhone, Samsung, Kindle, Chromebook

  • Browser data – e.g., browser version, IP address

  • Location data – e.g. location where a device receives a signal from an access point

  • Use of promotion services – e.g., offers and coupons claimed or used, unique device identifier (UDID), mobile equipment identifier (MEID) for your mobile device, or MAC address (collectively, “DID”)

  • Web sites and pages visited – e.g., Surefi.com, facebook.com, google.com

We reserve the right to monitor, intercept and disclose any transmissions over or using our network and to provide user information, or use records, and other related information under certain limited circumstances (for example, in response to lawful process, orders, subpoenas, or warrants, or to protect our rights, users or property.

How is this Information Used?

  • To comply with applicable law:

  • protect against, identify and prevent fraud, other crime, claims and other liabilities;

  • comply with legal obligations and our policies;

  • establish, exercise or defend a legal claim; and

  • monitor and report compliance issues.

We may disclose some PII in limited circumstances.

We consider the PII contained provided by our users to be confidential. We may sometimes disclose PII to our affiliates or others who work for us, such as service providers and vendors, to provide the Service.

Who do we share Personal Data with?

We may share information we collect with our partners, which include the Property and other Surefi customers, as well as Surefi subsidiaries and affiliates. Surefi may use this information to offer you products and services that we determine may be of interest to you. Surefi does not own the Property but does provide marketing services on behalf of the Property and its other customers. Such services may include web pages, email messages, social media paid and organic messaging, and promotional messages. Surefi may add customers, subsidiaries, and affiliates at any time. Personal Data will only be directly shared with Properties where you have visited.

Service Providers: We may share information with parties that provide support services to us (such as a vendor or wireless infrastructure provider), or that help us market our products and services. These companies may need information about your use of the Service to provide their services to us.

Other Entities (for marketing): We may share information with vendors, business partners, and other organizations that are not directly related to Surefi. These companies and organizations may use the information we share to offer you special offers and opportunities. You will always have the opportunity to opt-out.

Sharing Aggregate Information with Third Parties: We may share aggregate information (information that does not directly identify an individual) with third parties for lawful purposes.

Legal Requirements: We may disclose your information when we believe disclosure is appropriate to comply with the law; to enforce or ensure compliance with the Surefi terms of use, apply applicable terms and conditions and other agreements; or to protect the rights, property or safety of our company, our customers or others.

How this Information is Protected: We maintain administrative, technical, and physical safeguards to protect your information. We store all information gathered through your use of the Wifi Service within a database accessible only to Surefi and its specifically authorized contractors and vendors. However, as effective as our security measures may be, no security system is always completely effective. Therefore we cannot guarantee the complete security of our database, nor can we guarantee that the information you supply won't be intercepted while being transmitted to us over the Internet. When online with any Wifi service, it is important to remember that Wifi is not an inherently secure technology and that wireless communications can be intercepted.

How can you opt in or out of receiving Surefi promotional messages or distribution of information?

As you sign on to the Surfi Wifi Service we may ask for your email address. We may use the e-mail address you provide when you sign in to validate your device by sending you an authentication email. We may also send you service messages and promotional messages regarding products or services you might be interested in based on the Property networks you access. If you do not want to subscribe to the user list for any particular Property, you can not check or uncheck the box for subscription when you sign it. If you later wish to unsubscribe from a Property’s list, any promotional email we send you will provide instructions for how to opt out of receiving additional messages from that Property’s list. If you sign in to the Service again, you might receive an additional message, which again will provide another opportunity to opt out. If you wish to modify your information, the opt-out process will allow you to do that. You may also contact us to request changes at the address below. You must verify your identity before any such requests are addressed. Please note that Properties may send you messages directly, not via the Service. You must opt out of those messages following the Property’s direct unsubscribe procedures.

Your California Privacy Rights: As described above, from time to time, we make your PII available to third parties. If you do not want us to share your PII with other companies or organizations, you may request opt-out of this information sharing by making a request at the following email address: legal@surefi.com. This notice is designed to comply with California's "Shine the Light" law, but the opt-out option is available to all of our users.

Changes to this Wifi Privacy Policy

We may change the Wifi Privacy Policy from time to time. If we change this policy at some point in the future, we’ll post the changes here, and by continuing to use the Service after we post any changes, you accept and agree to this privacy policy, as modified.

Information About Children

The Service is not directed to children under the age of 13, and Surefi does not knowingly collect personally identifiable information from anyone under the age of 18 using the Service unless expressly specified. Children should always get permission from a parent or legal guardian before sending any information about themselves (such as their names, e-mail addresses, zip codes, and telephone numbers as well as Personal Data) over the Internet to us or anyone else.

How Do You Contact Surefi?

Questions regarding this privacy policy or requests should be directed to Surefi by email to Info@surefi.com or by mailing:

Surefi

317 Commercial St NE,

Albuquerque NM, 87102

Phone: (650) 449-8555

E-mail: legal@Surefi.com

Last Updated: April 17, 2019