Effective Date: October 30, 2017
1. Information we receive from or on behalf of our clients, such as the email addresses their customers supply when signing up for Wi-Fi or visiting our clients' websites, as well as certain information collected in connection with the Wi-Fi routers; and
2. Information collected from visitors to Zenreach's own website, zenreach.com.
In an expanding number of cities, we provide our clients (restaurants, stores and other businesses) with wireless routers that let them share their Internet connection with people around their location. 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 though a client's Wi-Fi, a person must (1) submit basic contact information, such as an email address or mobile phone number, and (2) agree to terms and privacy practices. The user may choose to enter additional information, such as their month and day of birth.
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 Zenreach router (of any Zenreach client), we automatically recognize the device and record the visit in our record for that device, unless the user has opted out (as described in detail below). We also may record information about whether and when the individual used the Internet, but Zenreach 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 addition to the above, 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.
Cookies and Other Technologies:
If you are interested in more information about tailored browser advertising and how you can generally control certain cookies from being put on your device to deliver tailored advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out Link, the Digital Advertising Alliance's Consumer Opt-Out Link or the European Interactive Digital Advertising Alliance Opt-Out Link to opt out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that you will still receive advertising content even if you opt out of tailored advertising. Also, we do not control the four opt-out links above and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browser is configured to reject cookies when you visit an opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your opt-out may no longer be effective. Additional information is available on the websites accessible by the above links.
Uses of Information
We use the information described above (sometimes in combination with other information we obtain) for the following purposes:
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 résumés. 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.
Section 1 above describes the collection of various types of information from website visitors using automated technologies (such as cookies). 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:
Disclosures of Information
We disclose information as described below:
To Our Clients. When we collect information for or on behalf of a client, we may share that information with that client and with other clients to help our 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). We also share such data among our clients to assist them in communications and marketing activities (such as to provide content recommendations and optimization, ad targeting, and other promotional activities to you).
Affiliates. We may share information with our affiliates.
For Legal Reasons. 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 Zenreach, our clients, our employees, or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Changes in the Structure or Ownership of the Company or its Assets. 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.
Aggregated or De-identified Information. We may share aggregated or de-identified data without restriction.
At a Client's Request. At the request of a client, we may also make additional disclosures of information we hold for that client.
Consent or Legal Permission. We may engage in additional sharing of information with the consent of the individual to whom it pertains or when otherwise permitted by law.
Opt-out and Privacy Rights
To opt out of our use of your device's MAC address for marketing purposes, please email email@example.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 Zenreach 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.
The law of your country you 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 firstname.lastname@example.org to make those requests or for help with the MAC address opt-out described above.
California Do-Not-Track Disclosure
We do not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations and solutions.
California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you would like to make such a request, please contact us using the information provided below.
If you believe that any child under 13 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 is higher.
1 Letterman Dr Bldg C, Ste 3500
San Francisco CA, 94129.
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