PRIVACY POLICY



This Privacy Policy (this "Policy") relates to the privacy practices of HOTSPOTSYSTEM, a product of Hotspot System Ltd. (“HOTSPOTSYSTEM" and "we") regarding the system (“System”) we provide to companies (“Hotspot Operators"). This Policy describes how HOTSPOTSYSTEM handles the information of individuals who visit the venues where our Hotspot Operators are using our System ("you" and "your"). To understand how our Hotspot Operators handle your data, you should review their privacy policies to determine their practices.



What we do


HOTSPOTSYSTEM provides businesses with a hotspot management system that enhances Guest Wi-Fi access at venues. When our Hotspot Operators request us to provide the service for them, we collect information on their behalf.


What we collect


Submitted Information


The information you provide when you register an account or login, such as details provided on a form or social media account. Information is taken from your social media access page and is subject to your privacy settings. We do not store or process payment information, such as credit card numbers on our servers. Any payment transactions is processed and stored by External Data Processors, described below.


Additional Information


When you use the guest Wi-Fi services provided by our Hotspot Operators at venues, some information is collected automatically. This information includes, for example, the unique device identifiers known as MAC Address, device type and model, operating system, browser type and language, your browser's Internet Protocol address, start and stop timestamps of your connections, amount of traffic, hotspot from which you are connected, and the logout reason type.


Since HOTSPOTSYSTEM collects this data on its Hotspot Operator's behalf, the purpose(s) for collection vary between Hotspot Operators. Therefore, you should consult the Hotspot Operator's privacy policies directly to understand what your data is being used for.


Cookies


We use Cookies like a website would; to enable us to distinguish you from other users.


External Data Processors


We may transfer your personal information to 3rd party companies (Data Processors) in case you are using online payments. Payment information, such as credit card numbers are  submitted on a 3rd party external server only so we don’t and cannot store these data on our servers. Based the availability and chosen processor, they can be the following processors:


Adyen B.V.

Simon Carmiggeltstraat 6-50, 1011 DJ in Amsterdam, the Netherlands

Contact information: https://www.adyen.com/contact


PayPal (Europe) S.à r.l. et Cie, S.C.A.

22-24 Boulevard Royal, L-2449 Luxembourg

Contact information: https://www.paypal.com/eu/selfhelp/contact/email/privacy


How your data is used and who we share your information with


Generally, we use your information to provide services to you and our Hotspot Operators  to maintain and operate our business. Our Hotspot Operators  as third party data controllers, have access to most of the information we collect on their behalf. Their use of information is governed by their privacy policies and practices, and our Hotspot Operators may direct us to share information we collect on their behalf with third parties. Your data may be used to by the Hotspot Operators to understand how you use a particular venue, to communicate with you or to offer you relevant goods and services. To understand what our Hotspot Operators do with the information they receive from us or collect directly, please consult their privacy policies directly.



Where we store your data


Data is stored on our own secure servers in Hungary in accordance with local regulations. We may add additional storage sites in the EU without notice.



How long we store your data


We retain your data for 24 months after you do not login in to any venue, managed by us or until it is no longer needed for the compatible purposes for which it was collected. Compatible purposes include those that reasonably serve Hotspot Operator relations, compliance and legal considerations, auditing, security and fraud prevention, preserving or defending HOTSPOTSYSTEM’s legal rights, or other purposes consistent with the expectations of a reasonable person given the context of the collection. When data reaches the end of the retention period, it is deleted automatically on a monthly basis.


Security measures we use


We take reasonable and appropriate precautions to protect the safety and security of the information we collect and store.


Accessing your own data


You can access and amend the data we hold on you at any time by visiting your Customer Portal or you may submit a request to privacy@hotspotsupport.com.  If you provide us with sufficient information to identify you and verify your identity, we will use reasonable efforts to comply with your request.