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Boingo Wireless<sup>®</sup>, Inc.
Privacy Policy
<p>Effective date: 06/01/2020</p>
<p>Boingo Wireless, Inc.
and its subsidiaries and affiliates (“Boingo,” “we,” “us,” and “our”) are concerned about the privacy and security of your information.
We want to make your experience with the Boingo<sup>®</sup> service as enjoyable and rewarding as possible, and also allow you to feel secure that your privacy interests are being respected.
This Privacy Policy covers how we treat Personal Data that we gather when you are accessing or using our Site or Services.
“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations.
This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
By visiting or using the Site or Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.
Any capitalized terms used herein without definition shall have the meaning given to them in Boingo’s Terms of Use (which is hereby incorporated into this Privacy Policy).
</p>
<p>If you have a disability, you may access this Privacy Policy in an alternative format by contacting privacy@boingo.com.</p>
<p>If you reside in the European Union, you agree to our EU privacy policy which can be found here.
</p>
<br>
<strong>
Categories of Personal Data We Collect
</strong>
<p>The following details the categories of Personal Data that we collect and have collected over the past twelve (12) months:</p>
<p>
<strong>PROFILE OR CONTACT DATA</strong>
</p>
<p>Examples of Personal Data We Collect:</p>
<ul>
<li>First and last name</li>
<li>Email</li>
<li>Phone number</li>
<li>Unique indentifiers such as passwords</li>
<li>Account name</li>
<li>Boingo Account #</li>
</ul>
<p>Categories of Third Parties With Whom We Share this Personal Data</p>
<ul>
<li>Service Providers</li>
<li>Advertising Partners</li>
<li>Business Partners</li>
<li>Parties You Authorize, Access or Authenticate</li>
</ul>
<p>
<strong>PAYMENT DATA</strong>
</p>
<p>Examples of Personal Data We Collect:</p>
<ul>
<li>Payment card type</li>
<li>Last 4 digits of payment card</li>
<li>Billing address, phone number, and email</li>
</ul>
<p>Categories of Third Parties With Whom We Share this Personal Data</p>
<ul>
<li>Service Providers (specifically our payment processing partner, currently [Chase PaymenTech and Paypal])</li>
</ul>
<p>
<strong>COMMERCIAL DATA</strong>
</p>
<p>Examples of Personal Data We Collect:</p>
<ul>
<li>Purchase history</li>
<li>Consumer profiles</li>
</ul>
<p>Categories of Third Parties With Whom We Share this Personal Data</p>
<ul>
<li>Service Providers</li>
<li>Advertising Partners</li>
<li>Business Partners</li>
<li>Parties You Authorize, Access or Authenticate</li>
</ul>
<p>
<strong>DEVICE/IP DATA</strong>
</p>
<p>Examples of Personal Data We Collect:</p>
<ul>
<li>IP address</li>
<li>Device ID</li>
<li>Domain server</li>
<li>Type of device/operating system/browser used to access the Services</li>
<li>Media Access Controller address</li>
</ul>
<p>Categories of Third Parties With Whom We Share this Personal Data</p>
<ul>
<li>Service Providers</li>
<li>Advertising Partners</li>
<li>Business Partners</li>
<li>Parties You Authorize, Access or Authenticate</li>
</ul>
<p>
<strong>WEB ANALYTICS</strong>
</p>
<p>Examples of Personal Data We Collect:</p>
<ul>
<li>Web page interactions</li>
<li>Referring webpage/source through which you accessed the Services</li>
<li>Non-identifiable request IDs</li>
<li>Statistics associated with the interaction between device or browser and the Services</li>
</ul>
<p>Categories of Third Parties With Whom We Share this Personal Data</p>
<ul>
<li>Service Providers</li>
<li>Advertising Partners</li>
<li>Business Partners</li>
<li>Parties You Authorize, Access or Authenticate</li>
</ul>
<p>
<strong>SOCIAL NETWORK DATA</strong>
</p>
<p>Examples of Personal Data We Collect:</p>
<ul>
<li>Email</li>
<li>Phone number</li>
<li>User name</li>
<li>IP address</li>
<li>Device ID</li>
</ul>
<p>Categories of Third Parties With Whom We Share this Personal Data</p>
<ul>
<li>Service Providers</li>
<li>Advertising Partners</li>
<li>Business Partners</li>
<li>Parties You Authorize, Access or Authenticate</li>
</ul>
<p>
<strong>PROFESSIONAL OR EMPLOYMENT-RELATED DATA</strong>
</p>
<p>Examples of Personal Data We Collect:</p>
<ul>
<li>Resume</li>
<li>Job title</li>
<li>Job history</li>
<li>Performance evaluations</li>
</ul>
<p>Categories of Third Parties With Whom We Share this Personal Data</p>
<ul>
<li>Service Providers</li>
<li>Advertising Partners</li>
<li>Business Partners</li>
<li>Parties You Authorize, Access or Authenticate</li>
</ul>
<p>
<strong>GEOLOCATION DATA</strong>
</p>
<p>Examples of Personal Data We Collect:</p>
<ul>
<li>IP-address-based location information</li>
<li>GPS data</li>
<li>Movements</li>
</ul>
<p>Categories of Third Parties With Whom We Share this Personal Data</p>
<ul>
<li>Service Providers</li>
<li>Advertising Partners</li>
<li>Business Partners</li>
<li>Parties You Authorize, Access or Authenticate</li>
</ul>
<p>
<strong>SENSORY DATA</strong>
</p>
<p>Examples of Personal Data We Collect:</p>
<ul>
<li>Photos, videos or recordings of your environment</li>
</ul>
<p>Categories of Third Parties With Whom We Share this Personal Data</p>
<ul>
<li>Service Providers</li>
<li>Advertising Partners</li>
<li>Business Partners</li>
<li>Parties You Authorize, Access or Authenticate</li>
</ul>
<p>
<strong>INFERENCES DRAWN FROM OTHER PERSONAL DATA COLLECTED</strong>
</p>
<p>Examples of Personal Data We Collect:</p>
<ul>
<li>Profiles reflecting user attributes</li>
<li>Profiles reflecting user behavior</li>
</ul>
<p>Categories of Third Parties With Whom We Share this Personal Data</p>
<ul>
<li>Service Providers</li>
<li>Advertising Partners</li>
<li>Business Partners</li>
<li>Parties You Authorize, Access or Authenticate</li>
</ul>
<p>
<strong>OTHER IDENTIFYING INFORMATION THAT YOU VOLUNTARILY CHOOSE TO PROVIDE</strong>
</p>
<p>Examples of Personal Data We Collect:</p>
<ul>
<li>Identifying information in emails or letters you send us</li>
</ul>
<p>Categories of Third Parties With Whom We Share this Personal Data</p>
<ul>
<li>Service Providers</li>
<li>Advertising Partners</li>
<li>Business Partners</li>
<li>Parties You Authorize, Access or Authenticate</li>
</ul>
<br>
<strong>Categories of Sources of Personal Data</strong>
<p>We collect Personal Data about you from the following categories of sources:</p>
<p>
<strong>You</strong>
</p>
<ul>
<li>when you provide such information directly to us, and</li>
<li>when Personal Data about you is automatically collected in connection with your use of our Services</li>
</ul>
<p>
<strong>Third parties, when they provide us with Personal Data about you (“Third Parties”).</strong> Third Parties that share your Personal Data with us include:</p>
<ul>
<li>Service providers.
For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.</li>
<li>Social networks connected to the services.
If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.</li>
<li>Advertising partners.
We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our Site, applications, products, services, advertisements or communications.</li>
</ul>
<br>
<strong>Optional Information</strong>
<br>
<p>Like any business interested in attracting and offering the highest quality of service to customers, Boingo gathers voluntary demographic information about our customers.
These questions seek to gain insight on such things as how an individual became aware of our service, their gender, occupation and travel preferences and practices.
In addition, customer comments and inquiries are collected and stored for each customer that submits them.
This information is collected and stored with the customer’s individual Boingo account information.</p>
<p>Boingo occasionally conducts user surveys to better target our service offering to existing as well as new customers.
We sometimes share aggregated demographic information in these surveys with various business partners.
Participation in our customer surveys is voluntary.</p>
<p>Boingo has and may institute referral programs or similar programs, such as the “Tell a Friend” program.
Boingo’s “Tell a Friend” program allows customers to receive credit for each individual (a “Referral”) that, as a result of their recommendation, also becomes a customer.
For a customer to receive a free month of service under this program, (1) the Referral must become a subscriber to Boingo Unlimited and remain a subscriber of Boingo Unlimited for more than 31 days.
(2) the Referral cannot be an existing Boingo customer.
and (3) the Referral cannot have been previously submitted to the “Tell a Friend” program by another person.
Existing customers provide the e-mail address of the Referral, and Boingo may send an e-mail message to the Referral from the referring customer’s e-mail address informing them of the Boingo service.</p>
<br>
<strong>Geographic Location Information</strong>
<p>When you use Boingo’s services on a mobile device (such as your laptop or a smart phone), Boingo may collect and/or track certain geographic location information that is derived from your usage of the Boingo service such as usage patterns, travel patterns, Web site page views, traffic patterns and information about your geographic location.
Boingo may use this tracking and location information for statistical, analytical or business-related purposes to improve our products, offerings and services and to manage our networks and systems more efficiently.</p>
<br>
<strong>Information Collected Automatically</strong>
<p>To keep track of traffic on their servers, Web sites often store a small data file on your hard disk and/or device when you visit them.
This file is commonly referred to as a “cookie.” For detailed information on the cookies we collect, please visit our Cookie Policy.
A cookie file can contain user specific information, such as User ID, or it can be used to maintain a connection with you during your visit (so that you can visit pages of a site without retyping the same information over and over).
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “cookies”) to track customer traffic patterns, to maintain a connection during your visit with us, to track your preferences, and to diagnose problems on our server and administer our site.
The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, that we may share with a data provider solely in hashed, non-human readable form.
Cookies enable you to enter all parts of the Site, and are used to save your User ID on the login page (we encrypt the User ID for added security).
In addition, cookie files help us assist you with questions about site navigation, functionality or performance.
Partners also may use their own “cookies.” We may supplement the information we collect from you with information received from third parties, including third parties that have placed their own cookies on your device(s).</p>
<p>IF YOU DO NOT WISH TO HAVE WEB COOKIES PLACED ON YOUR COMPUTER, YOU SHOULD SET YOUR BROWSER TO REFUSE WEB COOKIES, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THIS SITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES.
IF YOU REFUSE WEB COOKIES, YOU ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.</p>
<p>To explore what cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu.
To find out more information about cookies, including information about how to manage and delete cookies, please visit http://www.allaboutcookies.org/.</p>
<strong>Information about Interest-Based Advertisements: </strong>
<br>
<p>We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services.
These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”).
Information for Internet-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties.
Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services.
To accomplish this, we or our service providers may deliver cookies, including a file (known as a “web beacon”) from an ad network to you through the Services.
Web beacons allow websites to track users who have visited that page or to access certain cookies.
Web beacons also allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers and enable ad networks to serve targeted advertisements to you when you visit other websites.
Web beacons allow ad networks to view, edit or set their own cookies on your browser, just as if you had requested a web page from their site.</p>
<p>Boingo may use web beacons in the following ways:</p>
<ul>
<li>Boingo may use web beacons within our Web sites in order to track customers signing up at one of our hotspot locations.</li>
<li>Boingo may use web beacons within our Web sites in order to fulfill sponsored access campaigns or other promotions.</li>
<li>Boingo may use web beacons to measure where customers leave the signup process in order to improve customer experience.</li>
<li>Boingo may use web beacons to track customers that come through our Web sites from advertisements or search engines.</li>
<li>Boingo may use web beacons to serve ads to customers after they leave our Web sites.</li>
</ul>
<p>Boingo also records the MAC (Media Access Controller) address, IDFA, ADID and device identifier numbers from the network card in or used with your computer or other device to enable Boingo to accurately perform our billing functions and in the ordinary course of business.</p>
<p>We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising.
Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties.
To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices.</p>
<strong>Information Collected from Other Websites and Do Not Track Policy</strong>
<br>
<p>Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services.
Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites.
Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.</p>
<br>
<strong>How We Use Your Personal Data</strong>
<p>We process Personal Data to operate, improve, understand and personalize our Services.
We use Personal Data for the following purposes:</p>
<ul>
<li>To meet or fulfill the reason you provided the information to us.</li>
<li>To communicate with you about the Services, including Service announcements, updates or offers.</li>
<li>To provide support and assistance for the Services.</li>
<li>To create and manage your Account or other user profiles.</li>
<li>To personalize website content and communications based on your preferences, including targeted offers and ads served through the Services.</li>
<li>To process orders or other transactions.</li>
<li>To respond to user inquiries and fulfill user requests.</li>
<li>To improve and develop the Services, including testing, research, analysis and product development.</li>
<li>To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.</li>
<li>To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.</li>
<li>To respond to law enforcement requests, for national security reasons and as may be required by applicable law, court order, or other governmental regulations.</li>
<li>For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).</li>
</ul>
<p>We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.</p>
<br>
<strong>Our Commercial or Business Purposes for Collecting Personal Data </strong>
<p>We disclose your Personal Data to service providers and other parties for the following business purposes:</p>
<ul>
<li>Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.</li>
<li>Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.</li>
<li>Debugging to identify and repair errors that impair existing intended functionality.</li>
<li>Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.</li>
<li>Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.</li>
<li>Undertaking internal research for technological development and demonstration.</li>
<li>To respond to law enforcement requests, for national security reasons and as may be required by applicable law, court order, or other governmental regulations.</li>
<li>Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, was manufactured for us, or control.</li>
</ul>
<p>Subject to the terms of this Privacy Policy, we may disclose information to our employees, contractors, affiliates, distributors, dealers, vendors, partners and suppliers who process information on our behalf, participate with us in the provision or operation of our site or provide you with services.</p>
<p>We may email you about products and services that we believe may be of interest to you if you’ve provided us the means to do so.
Also, we may receive a confirmation when you open an email from us, which helps us improve our Services.
If you wish to opt-out of receiving marketing materials from us, please follow the instructions at the bottom of each email for opting out or send a request via email to privacy@boingo.com.
Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.</p>
<p>We allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers.
For example, we might use the fact you are located in San Francisco to show you ads or offers for San Francisco businesses, but we will not tell such businesses who you are.
</p>
<p>Advertisers may serve ads that appear on our sites or services, which may contain a feature allowing you to input your email address.
If you choose to input your email address in connection with these ads, you understand that we will transmit your email address to the applicable third party advertiser.
this Privacy Policy does not apply to such advertisers’ collection and use practices, so please review their privacy policies before providing your email address in this manner.</p>
<br>
<strong>How We Share Your Personal Data</strong>
<p>We disclose your Personal Data to the categories of service providers and other parties listed in this section.
Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data.
For more information, please refer to the state-specific sections below.</p>
<strong>SERVICE PROVIDERS</strong>
<p>These parties help us provide the Services or perform business functions on our behalf.
They include:</p>
<ul>
<li>Payment processors</li>
<li>Ad networks</li>
<li>Security and fraud prevention consultants</li>
<li>Hosting and other technology and communications providers</li>
<li>Analytics providers</li>
<li>Staff augmentation and contract personnel</li>
</ul>
<strong>BUSINESS PARTNERS</strong>
<p>These parties partner with us in offering various services.
They include:</p>
<ul>
<li>Businesses that you have a relationship with</li>
<li>Companies that we partner with to offer joint promotional offers or opportunities</li>
</ul>
<strong>PARTIES YOU AUTHORIZE, ACCESS OR AUTHENTICATE</strong>
<p>These parties include:</p>
<ul>
<li>Social media services (if you intentionally interact with them through your use of the Services)</li>
<li>Third-party business partners who you access through the Services</li>
<li>Other parties authorized by you</li>
</ul>
<br>
<strong>Legal Obligations</strong>
<p>We may share any Personal Data that we collect with third parties in conjunction with any of the legal requirements or obligations set forth in the “How We Use Your Personal Data” section above.</p>
<br>
<strong>Business Transfers</strong>
<p>All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.</p>
<br>
<strong>Data that is Not Personal Data</strong>
<p>When Boingo collects usage information (such as the numbers and frequency of visitors to the Site), we generally use this data in aggregate form.
For example, this aggregate data tells us how often users use parts of the Services, so that we can make the Services appealing to as many users as possible.
We may also provide this aggregate information to our partners.
our partners may use such information to understand how often and in what ways people use our Services, so that they too, can provide you with an optimal experience.
As between you and Boingo, you own the information that you provide to Boingo under this Privacy Policy, and may request its deletion at any time.</p>
<br>
<strong>Correcting and Updating Your Information</strong>
As a Boingo customer, you are in full control of the information that we maintain to service you.
You can change your information at any time and as often as necessary via our self-care application which can be accessed at: https://my.boingo.com.
You can also request that the data be changed or deleted (requests for deletion of certain information may require closing the account) by calling the following numbers:
<br>
From North America: 1-800-880-4117
<br>
From the UK: Local 0-203-450-6554
<br>
Free Phone (charges by mobile provider will vary) 0-800-032-6793
<br>
US-based carriers +1-800-880-4117
<br>
From Japan: Softbank Telecom 0061-010-800-8804-1170
<br>
KDD 001-010-800-8804-1170
<br>
NTT 0033-010-800-8804-1170
<br>
US-based carriers +1-800-8804-1170
<br>
From India: +1-1310-405-8806
<br>
<p>From outside of North America, UK, Japan and India: 00-800-2646-4646
Information about a customer may be withheld or exempted from deletion if this is required by law, is part of a fraud investigation or is required for accounting and audit purposes.</p>
<p>Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties.
If you are a California resident and would like a copy of this notice, please submit a written request to: privacy@boingo.com.</p>
<br>
<strong>Opt-out Policy</strong>
<p>If you have provided us with a means of contacting you, we may use such means to communicate with you.
For example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Services.</p>
<p>Boingo automatically opts customers in to providing Boingo with information, as well as a separate opportunity to opt-in to certain location-tracking services, or receiving communications from us and our partners.</p>
<p>At any time, customers can contact Boingo to opt-out of any of our promotions, programs, location-tracking services or contests via the following link: https://selfcare.boingohotspot.net/unsubscribe.
Alternatively, customers can opt not to provide certain information when enrolling for the Boingo service or when participating in some programs and surveys, although choosing not to provide certain information may hinder our ability to complete your registration process.</p>
<p>Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.</p>
<br>
<strong>Personal Data of Children</strong>
<p>We do not knowingly collect or solicit Personal Data from children under the age of 16.
In the event that we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible.
If you believe that we might have any information from or about a child under 16, please contact us at privacy@boingo.com.</p>
<br>
<strong>Security Measures</strong>
<p>Your account information is protected by a unique User Identification and password that is issued to you.
Your User Identification and password should be kept confidential because it is the key to accessing the information held by Boingo about you.
If your computer or other device is accessible to or by others, please log out of the Boingo site before you leave it.
Security is also provided through your web browser, which supports 40, 56 or a 128-bit version of encryption with the SSL (Secure Sockets Layer) security protocol.</p>
<p>Boingo has instituted internal safeguards to reduce the likelihood of accidental disclosures and unintended access of your information (although it is impossible to eliminate this possibility completely).
In general, all employees, contractors and other companies engaged by Boingo are contractually required, through signed, internal non-disclosure agreements, to keep your Personal Data confidential and not to use it in any way other than what is necessary to perform their work for Boingo.
Violations of these policies can result in termination in the case of employees, the severing of contractual obligations in the case of contractors and other companies, and in civil and criminal penalties if warranted and applicable by law.</p>
<p>While Boingo uses reasonable measures to protect the security of your information, no security measures are foolproof, and Boingo does not guarantee that your information will remain confidential.</p>
<p>The Services may contain links to other sites.
We are not responsible for the privacy policies and/or practices on other sites.
When following a link to another site you should read that site’s privacy policy.</p>
<p>We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services.
In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal or contractual obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.
We may further retain information in an anonymous or aggregated form where that information would not identify you personally.</p>
<br>
<strong>Security of Third Party Networks</strong>
<p>Because of the global nature of our services, there are some places where you cannot access the Boingo Wi-Fi Network.
In these places, you may (1) manually search for available third party networks and, if required to do so, assent to Terms of Service or other click-through agreements.
or (2) connect to other people’s Wi-Fi networks automatically by using the Boingo Wi-Finder tool if you opt-in to use this feature.
Please see our FAQs for more information about these options: http://www.boingo.com/faq/wifinder.</p>
<p>Third parties are under no obligation to comply with this Privacy Policy with respect to information that you provide directly to those third parties or that those third parties collect for themselves.
We do not control the third-party sites that may be accessible through this Site or Boingo’s services.
Thus, this Privacy Policy does not apply to information provided to third-party sites or gathered by the third parties that operate them.
Before visiting a third-party site, whether by means of Boingo Wi-Finder, manually searching for an available third party network or otherwise, and before providing any information to any third party, you should inform yourself of the privacy policies and practices (if any) of the third party, and should take those steps necessary to your discretion, to protect your privacy.</p>
<br>
<strong>Affiliated Businesses and Third Party Websites</strong>
<p>In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through the Services (either alone or jointly with us).
You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Data with that affiliated business only to the extent that it is related to such transaction or service.
One such service may include the ability for you to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third party account.
We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.</p>
<strong>California Resident Rights</strong>
<p>If you are a California resident, you have the rights outlined in this section.
Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict.
If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@boingo.com.</p>
<strong>Access</strong>
<p>If the CCPA applies to you, you have the right to request certain information about our collection and use of your Personal Data over the past twelve (12) months.
We will provide you with the following information:</p>
<ul>
<li>The categories of Personal Data that we have collected about you</li>
<li>The categories of sources from which that Personal Data was collected</li>
<li>The business or commercial purpose for collecting or selling your Personal Data</li>
<li>The categories of third parties with whom we have shared your Personal Data</li>
<li>The specific pieces of Personal Data that we have collected about you</li>
</ul>
<p>If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.</p>
<strong>Deletion</strong>
<p>You have the right to request that we delete the Personal Data that we have collected from you.
Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested.
If your deletion request is subject to one of these exceptions, we may deny your deletion request.</p>
<strong>Exercising Your Rights</strong>
<p>To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it.
Each request that meets both of these criteria (as determined by Boingo in its sole discretion) will be considered a “Valid Request.” We may choose to not respond to requests that do not meet these criteria.
We will only use Personal Data provided in a Valid Request to verify you and complete your request.
You do not need an account to submit a Valid Request.</p>
<p>We will work to respond to your Valid Request within forty five (45) days of receipt.
We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded.
If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.</p>
<p>You may submit a Valid Request using the following methods:</p>
<ul>
<li>Call us at: +1-800-880-4117</li>
<li>Email us at: privacy@boingo.com</li>
</ul>
<strong>Sales of Personal Data</strong>
<p>In this section, we use the term ‘sell’ as it is defined in the CCPA.
We sell your Personal Data, subject to your right to opt-out of these sales.</p>
<p>As described in our Cookie Policyv, we have incorporated cookies from certain third parties into our Services.
These cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device.
Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit.
Under the CCPA, sharing your data through third party cookies for online advertising may be considered a “sale” of information.</p>
<p>You have the right to opt-out of the sale of your Personal Data.
You can opt-out using the following methods:</p>
<ul>
<li>Email us at: privacy@boingo.com</li>
</ul>
<p>Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.</p>
<p>To our knowledge, we do not sell the Personal Data of minors under 16 years of age.</p>
<strong>We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA</strong>
<p>We will not discriminate against you for exercising your rights under the CCPA.
We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.
However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.</p>
<br>
<strong>Nevada Resident Rights</strong>
<p>If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data.
You can exercise this right by contacting us at privacy@boingo.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.
Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.</p>
<br>
<strong>Privacy Policy Changes</strong>
<p>Boingo reserves the right, in its sole discretion, to revise, amend, or modify this Privacy Policy at any time, and in any manner without notice, but we will alert you to changes by placing a notice on the Site, by sending you an email, and/or by some other means.
Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you shall be responsible for reviewing and becoming familiar with any such modifications.
Your use of the Services following such notification constitutes your acceptance of the terms and conditions of this Privacy Policy as modified.
Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.</p>
<br>
<strong>Additional Information</strong>
<p>Boingo reserves the right to change this policy at any time.
By using our Services, you are acknowledging and accepting all terms and conditions outlined in this Privacy Policy.</p>
<p>If you have any questions regarding this policy statement, please do not hesitate to contact us at:</p>
<ul>
<li>Call us at: +1-800-880-4117</li>
<li>Email us at: privacy@boingo.com</li>
</ul>
<p>This privacy and security pledge is part of our contract with you.
Thank you for choosing Boingo Wireless, Inc.</p>
<p>We use cookies to help provide a great user experience.
By using Boingo.com, you accept our Cookie Policy.
(If you’re a fan of snickerdoodles, our cookie policy also includes a great recipe.)</p>
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