Article 1 – General
If the user wants to log in to the free WiFi network, the user must first give SpotOn Wifi access to the data of his Facebook account, Google+ account or the user must enter his e-mail address.
If a user is 14 years old or younger, he/she must have permission from his/her parents or guardian before using SpotOn Wifi's free Wi-Fi network.
SpotOn Wifi is responsible. SpotOn Wifi is a trade name of Spot Marketing Solutions BV, located in Groningen at Hoge der A 12, (Chamber of Commerce number 65394178).
The free internet is offered to you by the owner of the hotspot (hereinafter referred to as Hotspot Owner), who is also responsible.
Article 2 – Collection and use of personal data
SpotOn Wifi stores the user's personal data when he logs in to the free WiFi network. In order to enable proper use of the service and to be able to offer the service to consumers free of charge, certain data about you is collected while using the service and this is also shared with third parties.
SpotOn Wifi processes the following personal data of the user in a profile: data when logged in with, for example, Facebook, Google+, Twitter, Instagram (social media account, name, age, place of residence, e-mail address, telephone number, interests, likes and followed pages ), chosen login method, device data (operating system, browser data, language, MAC address, IP address, IDFA and AAID), location data, time of logging in to the WiFi network, the duration of WiFi use and future use and the data you send via our website. SpotOn Wifi does not store any information about which websites the user visits.
With the explicit permission of the user, SpotOn Wifi uses the user's personal data for marketing purposes such as:
Displaying websites in a correct and personalized way.
To map statistics about user behaviour.
To allow users to provide feedback about Hotspot Owner.
To better understand your needs (whether or not via cookies), in order to improve better services and SpotOn Wifi and to be able to offer a better implementation of SpotOn Wifi website(s), security and software.
To handle requests, requests, complaints submitted via the website or via other means of communication.
To simplify future login attempts.
To get a picture of the movements of all customers of Hotspot Owner in its business space(s).
Comply with legal (tax) retention obligations and other legal and regulatory obligations.
Safeguard and protect our business and to identify and help minimize or prevent fraud, unauthorized activity, claims and other liabilities.
With the explicit permission of the user, SpotOn Wifi uses the personal data of the user to inform him specifically about special offers and promotions of SpotOn Wifi, for example by means of a newsletter, SMS or Facebook notification. The newsletter contains a link that allows the user to unsubscribe directly from the newsletter.
Article 3 – Transfer to third parties
SpotOn Wifi will not sell the user's personal data to third parties and will only make it available to third parties that are directly involved in performing the service to the user. Employees of SpotOn Wifi, Hotspot Owner and third parties engaged by them are obliged to respect the confidentiality of personal data.
The user gives explicit permission to make the personal data referred to in Article 2.2 and 2.3 available to Hotspot Owner. Hotspot Owner uses this data to map the user's visit to his company Hotspot Owner. The Hotspot Owner has the option to make an export of all data. In addition, this personal data is used to inform the user about special offers and promotions.
SpotOn Wifi does not provide advertisers with information about identifiable individuals, but may provide advertisers with data that SpotOn Wifi has collected through your data and other data held by SpotOn Wifi regarding gender, age groups and other demographic analysis. SpotOn Wifi may use such information to help advertisers and sponsors reach their target audiences. SpotOn Wifi may use your data to enable SpotOn Wifi or sponsors and/or advertisers to appropriately tailor an advertisement or promotion.
SpotOn Wifi may transfer and store the information SpotOn Wifi collects about you to countries other than the country in which the information was originally collected, including the United States and other destinations outside the European Economic Area ("EEA"), in accordance with the applicable law.
Article 4 – Cookies
SpotOn Wifi uses so-called cookies. Cookies are small text files that are placed on the user's computer and read by a browser.
The user can set his browser in such a way that no cookies are received during visits to the website.
Article 5 – Social media
To log in to the free WiFi network, there are buttons for various social media channels on the login screen. These buttons are realized by a code that is supplied by the relevant social media channel. This code places, among other things, a cookie.
The privacy statements of the relevant social media channel (which can change regularly) state how these websites handle the user's personal data.
Article 6 – Change/deletion of personal data
User has the right to view, correct, supplement, delete and protect his personal data, in accordance with the provisions of the relevant privacy rules.
The user has access to his own profile via the personal access code and password and can always view the personal data. User has the right to change the personal data and/or have it removed.
SpotOn Wifi will send the requested information within 4 weeks, whereby SpotOn Wifi may first ask for proof of identity.
Article 7 – Retention period
SpotOn Wifi stores the personal data for a maximum period of 24 months, counting from the last time the user logged in to the free WiFi network.
SpotOn Wifi is entitled to keep the personal data for longer than the period referred to in the previous paragraph, if this is done on the basis of a statutory regulation.
Article 8 – Security
SpotOn Wifi will handle the personal data with the utmost care. When the user logs in, the following security techniques are used: Firewall, SSL, VLANs, WPA/WPA2-PSK, TKIP/AES. The personal data will be protected at all times and treated as confidential.
Article 9 – Liability
Article 10 – Outside the EU
For technical and operational reasons, it may be necessary for data to be transferred (to servers of) SpotOn Wifi affiliates and/or advertisers in the United States or other countries outside of Europe. Because the regulations in the field of privacy protection may not offer the same protection as in the EU, the user hereby agrees, insofar as necessary, that the data can be transferred to countries outside Europe. Should SpotOn Wifi switch to this at any time, the user will always be informed about this first.
Article 11 – Suspicion of abuse
SpotOn Wifi reserves the right to take both proactive and corrective action in the event of suspected abuse. This means that SpotOn Wifi in this case has the right to store and store all information from and about users as possible evidence of misuse. SpotOn Wifi also has the right, in case of a sufficiently substantiated suspicion of abuse, to request further information about the user from third parties. With sufficient evidence, SpotOn Wifi can take appropriate measures, including exclusion from our website or services and/or reporting it to the police.
Article 13 – Complaints