Effective as of November 5 2015
When you log in to use the Services through one of your Social Networking Accounts, such account will automatically provide us with, or authorize us to access, some personal information about you (collectively, the “Personal Information”). Such Personal Information may include your first and last name, username, profile pictures, unique identifiers and access tokens, e-mail address, and phone numbers. We do not collect any Personal Information from you when you use the Services or the Website unless you provide us with the Personal Information voluntarily or authorize us to access it.
Certain features and functionalities of the Services are based on your location. In order to provide these features and functionalities after you sign in to the Services at a Venue, we may automatically collect geolocational information from your Device or wireless carrier and/or certain third-party service providers. Such information is collectively called the “Geolocational Information.” Collection of such Geolocational Information occurs only when the Services are running on your Device.
In addition to the Personal Information and the Geolocational Information, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:
From You. Additional information about yourself that you voluntarily provide to us, such as hobbies, personal interests, household income range, number of children, gender, product and service preferences, and other information that does not identify you personally.
From Your Activity. Information that we automatically collect when you use the Services or the Website, including, without limitation:
When you visit the Website, we may collect your IP address, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, sections of the Website visited, etc.
When you use the Services, we may manage networks that collect your browsing activity occurring via the Services (collectively, the “Browsing Data”). In those circumstances we may have access to Browsing Data but we do not collect, share, or store Browsing data and we will use our good-faith, reasonable efforts to contractually prohibit the Venues from doing the same.
When you use the Services, we may collect the Venue in which you have authenticated, offers from us and our promotional partners that you have accepted or rejected, and similar information.
When you use the Services, we may collect information regarding the total data transferred or consumed, time logged in, and similar information.
About Your Device. We may collect information about your Device, including universally unique ID (“UUID”), MAC address, operating system and version (e.g., iOS, Android or Windows), carrier and country location, hardware and processor information (storage, chip speed, camera resolution, NFC enabled, and network type (WiFi, 2G, 3G, 4G).
From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or Mobile Device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Website and/or the Services. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or Mobile Device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Website or the Services may not function properly.
We use the Personal Information, the Geolocational Information, and the Other Information to provide and improve the Website and the Services; solicit your feedback; inform you about our products and services and those of our third-party marketing partners (without using Browsing Data, as described above); and administer our rewards, contests, sweepstakes, competitions, and promotional programs. Also, we may share Personal Information, Geolocational Information, and/or Other Information as described below.
In order to provide the Services, we may share your Personal Information, Geolocational Information, and Other Information with the applicable Venue. We do not, and will not, knowingly provide Browsing Data to the Venue or any such Venue’s internet service provider if we have access to it, although Venues and such Venue’s internet service provider may independently gain access to such Browsing Data. As mentioned above, we will use our good-faith, reasonable efforts to contractually prohibit the Venues from accessing, using, or sharing your Browsing Data, but in no instances shall we be responsible for any Venue’s or any Venue’s internet service provider’s use of Browsing Data.
In order to administer our rewards, contests, sweepstakes, competitions, and promotional programs, we may share your Personal Information, Geolocational Information, and Other Information (excluding the Browsing Data as described above) with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
We may from time to time share Personal Information, Geolocational Information, and/or Other Information (excluding the Browsing Data as described above) with other companies who may provide you information about the products and services they offer. However, to the extent required by law, you will be given the opportunity to opt-out of such sharing.
In an ongoing effort to better understand our users and our Website and Services, we might analyze the Other Information and the Geolocational Information in aggregate form in order to operate, maintain, manage, and improve the Services and/or the Website. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, Venues and business partners. We may also disclose aggregated user statistics in order to describe our products, the Website, and Services to current and prospective business partners and to other third parties for other lawful purposes.
We may employ other companies and individuals to perform functions on our behalf. Examples may include providing network services, information technology support and customer service. These other companies will have access to the Personal Information, the Geolocational Information, and the Other Information only as necessary to perform their functions and to the extent permitted by law.
With your permission, third-party applications or services may access your Personal Information. We use standard OAuth (open authorization) to enable you to give permission to share your Personal Information with other websites and services, such as Facebook and Twitter (e.g., when you agree to a pop-up requesting you to allow another application to access your account information). We also use OAuth to allow us to share information about you that is stored by us without sharing your security credentials.
We may share some or all of your Personal Information, Geolocational Information, and Other Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Personal Information, Geolocational Information, and Other Information may be part of the transferred assets.
To the extent permitted by law, we may also disclose Personal Information, Geolocational Information, and Other Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of SmartWiFi.ae or others.
We take commercially reasonable steps to protect the Personal Information, the Geolocational Information, and the Other Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
The Website and the Services are operated in the United Arab Emirates. If you are located outside of the United Arab Emirates, please be aware that any information you provide to us will be transferred to the United Arab Emirates. By using the Website or the Services and/or providing us with any information, you consent to this transfer.
Gold & Diamond Park, Building 4
Dubai, United Arab Emirates