Protecting your personal data is a top priority for us. This Privacy notice (hereinafter referred to as “Notice”) is intended to provide you with information about who we are, what personal data we collect and for what purpose, how and for how long we process it and your rights regarding data. This information applies to any user of our services (hereinafter referred to as the “User” or “you”).
1. Who we are
Data Controller is the company which is responsible for the operation of the location where you access the Internet, whose details and logo appear on your registration [hereinafter referred to as “Operator” or “Location”]. Zoottle acts as a Processor, on behalf of the Operator, and processes your information in accordance with the Operator’s instructions, who has access to them and maintains them either in the Zoottle application or in information systems controlled by the Operator.
Zoottle acts as a Data Controller only for your login information, keeping this information in order to provide you with WiFi connection service at any point or area covered, without having to repeat the registration process.
2. Personal data we collect
2.1 Data collected through log-in
Regardless of how you log in, Zoottle always logs your device’s MAC Address to recognize the device on future logins so you don’t have to repeat the entire registration process.
2.1.1 Facebook login
Every time you connect to the WiFi service via Facebook login, the Operator collects and stores the information posted on your Facebook profile. This information includes:
- Your public profile
- Your e-mail
- Your date of birth
- Your Homecountry / Hometown
- Your gender
2.1.2 Twitter login
Every time you connect to the WiFi service via Twitter login, we collect your Twitter profile information, including the email address your Twitter account is connected to, and we can read tweets from your timeline.
2.1.3 E-mail login
When you choose to sign in by entering your email, we validate collect and store this information.
2.1.4 Password login
When you choose to sign in by entering the password provided by the Operator for the use of the service, we will not ask for any other personal information.
2.2 Data we collect during the use of our services
2.2.1. Data We Collect Automatically
When you login via Facebook, we receive and store information about the number of your Facebook logins and check-ins (if applicable) at the Operator ’s Location.
2.2.2. Data You Give Us
When you use our services, you may be asked about your Operator experience or service evaluation. If you choose to answer these questions, we will process your feedback and keep it with the other information collected from you.
Why do we process your data?
a. Provision of services based on contract
If it is necessary for the provision of the service, we will use your contact information to inform you about service and use issues.
b.Communication for service promotion, news and consent-based surveys
If you provide your consent to receive email about marketing, company news, and surveys by selecting the relevant field, the Operator will use the data collected to inform you, send you offers and advertisements, and market research inquiries in relation to its services or products.
If you choose to respond to inquiries – questions about your Operator experience, the information and comments you submit will be directly received by the Operator who will process them to address any complaints and take action to improve its services. In this context, the Operator may contact you to obtain more information about your experience and the evaluation of its services.
c. Consent-based profiling
If you provide your consent to receive personalized offers, the Operator will create your profile based on all information we collect either during your registration process or when using our services (see above Personal Data We Collect). Your profile will be taken into consideration in order to:
- select the ads that are shown to you while browsing the internet (during use of the wifi access service and after)
- shape the commercial communication and / or the offers we will send you to match your preferences.
d. Statistical analysis
The data collected during the registration process and the use of our services will be used for statistical analysis and for the export of anonymous demographics that concern all Service Users from the Operator’s Location.
e. Our Legal Obligations
We will process your personal data to the extent necessary to fulfill our legal obligations, in particular to respond to requests from competent authorities or reporting bodies, provided that they are submitted in accordance with the applicable provisions.
f. Pursuit of a legitimate interest
We will process your personal data to the extent necessary for the purposes of the legitimate interests pursued by us or by a third party, for example for the establishment, exercise or defence of legal claims.
4. Who receives and processes your personal data
Access to your information may only be provided to authorized employees or external partners acting on our behalf by providing IT services for recording and storing your data and / or customer service and / or sending updates, promotional messages or carrying out market research.
Zoottle acts as a Processor for the purposes outlined above, and as a Controller to allow you to access your services faster on your next logins.
5. How long do we keep your data?
We will keep your data for three (3) years since the last time you used the login service. Your data will then be deleted unless you give your consent for processing. In any case, you have the right to request the interruption of communication for advertising purposes and / or the deletion of your information at any time.
6. Your rights
The Operator ensures your rights to the processing of your personal data and facilitates their exercise.
You are entitled:
- To request access to your personal data and in particular, you can get information about what data we process, the purposes for processing, the categories of recipients to whom the personal data have been disclosed and the scheduled storage period.
- To request rectification of your personal data if it is inaccurate or incomplete..
- To request the erasure of your personal data unless the processing of such data is necessary for exercising the right the rights of the Operator or third parties, for compliance with a legal obligation, for reasons of public interest or for reasons of defendin our legitimate rights before judicial or other authorities .
- To request the restriction of processing of your personal data for specific purposes only.
- To withdraw at any time your consent to the processing of your personal data for advertising purposes by informing us to the contact details of the Operator available on its website. In this case, we will stop processing them by us for these purposes without affecting the lawfulness of any processing based on consent before its withdrawal.
- If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the Hellenic Data Protection Authority.(dpa.gr)
Operator / Location: The contact details are available at the Operator ‘s website
Zoottle IKE (EUROPE)
Leoforos Andrea Syggrou 3, 11743, Athens, Greece
tel: (+30) 210 9245773
Zoottle Inc (USA)
49 Freemont St. Lexington, MA02421, USA
If this Privacy Notice is amended, we will immediately publish the amendments to our site. These amendments will take effect thirty (30) days from the date of their publication, unless otherwise specified in the amended provisions. During this time, there will be a relevant labeling every time you use our services.
Last Update: May 21st , 2018