Sky WiFi - Privacy and Cookie policy

Who we are and how to get in touch

We are The Cloud Networks Limited and “Sky WiFi” is our trading name. Our company number is 05141256 and our registered address is Grant Way, Isleworth, Middlesex, TW7 5QD. We are a wholly owned subsidiary of Sky UK Limited.

We have appointed a data protection officer whom you can reach by email via dp.department@sky.uk or by sending your query to the address above, marked for the attention of “Data Protection Officer – Sky WiFi” if you need to contact us regarding this Privacy Notice.

Your rights

We are legally required to let you know about the rights you may have with respect to your personal data:

• You have the right to request from us access to, or rectification or erasure of, the personal data we hold about you.
• You have the right to request us to restrict the processing of the personal data we hold about you.
• You have the right to object to us processing personal data relating to you.
• Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.
• You have the right to obtain certain personal data from us in a format that can be transferred electronically to a third party (also called “data portability”).

If you wish to exercise any of these rights, please get in touch with us as described above. Whether we can comply with your request will depend on the circumstances but we will keep you informed of the actions that we take throughout this process.

We take our data protection responsibilities seriously and make every effort to protect your personal data but should you wish to make a complaint about how we use your personal data you can notify us by email to wificomplaints@sky.uk or by writing to us at The Cloud Networks Limited, First floor, 4 Victoria Square, Victoria Street, St. Albans, Hertfordshire, AL1 3TF.

We will try to resolve your complaint in accordance with Sky’s Customer Complaints Code of Practice and you can find details of the steps we will take including when we aim to respond by here. If you are not satisfied with our response then please let us know and we will take the further steps detailed in the aforementioned link.

If you are still unhappy then you should contact the Information Commissioner’s Office via their website or the Irish Data Protection Commissioner via their website for more information about your rights.

This part of our Privacy Notice covers the personal data we process when you use your Sky WiFi Roaming account to roam across WiFi hotspots and access WiFi services provided by either Sky or one of its partners.

How and why we process personal data

In this section, we explain what personal data we process, the purposes for which we use it and the legal grounds for doing so.

Controllership and types of personal data we may hold about you

Sky WiFi Roaming

When you create a Sky WiFi Roaming account, we act as the data controller for the personal data that you provide to us in setting up and using your account, namely:

• “Account Information” (such as your name, date of birth, gender, postal address, mobile phone number, email address, your device(s) MAC address which is a unique identifier linked to your device);
• “Usage Information” (such as the time and hotspot location where you used Sky WiFi Roaming and other service-related data including your IP address and information about your device); and
• “Administrative Information” (such as personal data you have provided to us, for example in correspondence with you or when you exercise your rights or provide Sky WiFi feedback).

When you use your Sky WiFi Roaming account to connect to a WiFi service provided one of Sky’s partners, once you have accepted the partner’s WiFi Service Terms and Conditions and acknowledged the partner’s Privacy Notice we will share your Account Information and Usage Information (relating to your use of the WiFi Service at that hotspot location) so that the partner can operate and provide its WiFi Service to you.

When the partner receives your personal data, it acts as an independent data controller of it. You can find out more about how our partners process your data in the Privacy Notice which is displayed to you prior to you confirming that you wish to use the partner’s WiFi Service. A copy will also be available for you to review via the WiFi Services Preference Centre (which can be accessed here) once you have agreed to use the partner’s WiFi Service using your Sky WiFi Roaming account.

If you use your Sky WiFi Roaming account to access a partner’s WiFi Service and you return to that hotspot or visit other WiFi hotspots operated by that partner, you will be automatically recognised as having accepted the partner’s WiFi Service Terms and Conditions and provided with access to the WiFi service unless you have removed the device you used previously from your Sky WiFi Roaming account or your account has been marked as dormant because you have not used it for 12 months.

Purposes and legal bases

We are legally required to tell you the purposes for which we use your personal data and the legal bases we rely on in doing so. The primary purpose for which we use and share personal data is to provide Sky WiFi Roaming to you, which includes managing your relationship with us and your activity across our network. We have to process this personal data in order to perform our obligations under the Sky WiFi Roaming Terms and Conditions. If you do not provide this data, then we will not be able to provide Sky WiFi Roaming to you.

In addition to the main purpose described above, we may also use personal data for the following purposes and in reliance on the following legal bases:

• We may monitor and improve Sky WiFi Roaming (e.g. by sending you surveys to obtain feedback about your use of Sky WiFi Roaming and the different WiFi services you access using your Sky WiFi Roaming account) and we may also generate anonymous statistics. This is in our legitimate interest as we want to ensure that Sky WiFi Roaming functions properly and keeps up with technological, social or legal changes that may affect it.
• We may also need to use your personal data or pass it to others: so we can meet legal or regulatory requirements; to protect or enforce our rights or the rights of any third party; in the detection and prevention of fraud and other crimes; and for the purpose of protecting national security. We do this primarily to comply with applicable laws. However, where no laws require such sharing, we rely on our or the applicable third party’s legitimate interest in enforcing our/their rights or in the detection and prevention of fraud and other crimes.
• We may pass your personal data to anyone who takes over our business for them to use for the purposes set out in this Privacy Notice. We would do this on the basis of our and their legitimate interest in ensuring the continued operation of Sky WiFi Roaming (or a related successor service) and would provide notice of any such change as required.

If you do not wish to receive surveys from us, Sky WiFi will not send you survey emails if you have selected the “No, thank you” option in the section of the WiFi Services Preference Centre titled “Sky WiFi Communications”. A link to the WiFi Services Preference Centre is available [here] and may be accessed once you have created a Sky WiFi Roaming account.

We do not currently process personal data in the context of automated decision-making or profiling that would produce legal or other significant effects for you. If that changes at any time in the future, we will notify you beforehand as required.

How and with whom we share personal data

In this section, we explain with whom we share personal data as well how the same is shared.

As explained in the section entitled “How and why we process personal data”, we may share:

• Your Account Information with partners whose WiFi services you choose to connect to using your Sky WiFi Roaming account.
• Your personal data with third party suppliers who act as our data processors and only in accordance with our instructions to help provide Sky WiFi Roaming to you. Examples of the types of suppliers we may use include: IT and network services suppliers, software suppliers (including software as a service and managed service suppliers), analytics and service improvement suppliers, outsourced personnel, and business support service suppliers.
• Your personal data with anyone who takes over our business or with anyone as required by law or in order to protect or enforce our rights or the rights of any third party or in order to detect and prevent fraud and other crimes. You will be informed of the identity of such recipients subject to applicable law, if and when such sharing takes place.

Where we provide personal data to partners or third party suppliers for the purposes described above, we require that appropriate security measures are in place. Details of third party suppliers that we currently use are available here and does not currently involve a transfer of personal data to countries outside of the European Economic Area, but should this change we will notify you beforehand as required.

How long we keep personal data

In this section, we explain how long we keep your personal data for or, where we cannot give you an absolute time period, the factors we use to determine the retention period. We keep your personal data for the following periods, after which we delete it.

• We keep your Account Information for up to 1 year after the account that you use for Sky WiFi Roaming is marked as dormant (this will happen automatically if you do not use your account for 12 months) or it is deactivated because you have asked us to.
• For all active Sky WiFi Roaming accounts we delete Usage Information and Administrative Information relating to them on a 3 year rolling basis.

We may alter the periods listed above if the legal basis for keeping the personal data changes.

From time to time, and subject always to applicable law, instead of deleting personal data, where required for business reasons we may anonymise it or put it beyond use. If we do this and any personal data is retained in backups, we will delete personal data that is required to be deleted before any data is restored from such backups.

This section covers the cookies which may be placed on your device to help provide Sky WiFi Roaming to you and personal data we may use to deliver and help personalise the advertisements you see whilst you use Sky WiFi Roaming.

How and why we process personal data

Controllership and types of personal data we may hold about you

When you access the websites we host (such as Sky WiFi’s homepage and the landing pages that are presented when you use Sky WiFi Roaming), we (and third parties that provide elements of these pages on our behalf such as advertising) use cookies and other similar technologies to collect certain Usage Information (as described in Part 2 of this Privacy Notice) and combine it with certain Account Information for the purposes described below.

The use of cookies and other similar technologies is commonplace on the internet and important to support the provision of basic online services to you. The term “cookie” refers to one or more small pieces of information or text files which are stored on or provided by your computer or device when you access online information and may be placed either by the website owner (“First Party Cookies”) or by third parties that have an agreement with the website owner to place cookies when you visit that website (“Third Party Cookies”).

Your browser or device sends First Party Cookies every time you visit a website primarily so that the website (and related pages) can recognise your computer or device and tailor what you see on the screen – often these cookies are essential to make the service work otherwise they will help improve your overall browsing experience. Third Party Cookies are commonly placed to enable advertisers to display advertisements and monitor sites that you visit to tailor and personalise the advertisements that are displayed to you. Other similar technologies such as pixel tags, locally stored objects and device fingerprinting work in a similar manner.

When you create a Sky WiFi Roaming account we serve a Cookie Notice to notify you that we use data collected via cookies and other similar technologies for the purposes described in this Privacy Notice. By continuing to use our websites and Sky WiFi Roaming you agree to our use of cookies as described in this notice however if you do not wish to receive tailored advertising we have provided information below (and at appropriate stages of the Sky WiFi Roaming user journey) on how you can prevent your personal data being collected for this purpose. You can also find out more about how cookies work including how to manage them at http://www.aboutcookies.org.uk/cookies.

Sky WiFi is the data controller of personal data collected via the cookies which are used to provide Sky WiFi Roaming and to deliver and help personalise advertisements you see whilst using the service. To the extent that we share this data with partners to enable them to provide their WiFi service to you or with advertising partners that provide tailored advertising to you when you are not using Sky WiFi Roaming and the recipients act as independent data controllers when they receive your data.

You can find out more about the purposes for which the owners of Third Party Cookies use and process your personal data in their Privacy Notices. We have provided a list of the advertising partners we use via the link available in the “How and with whom we share personal data” section of this Part of the Privacy Notice below.

Purposes and legal bases

The primary purpose for which we use and share personal data in this context is to provide Sky WiFi Roaming to you. The First Party Cookies that we use for this purpose are essential and because they help us to:

• recognise your computer or device and its location on the network (i.e. whether you are in a hotspot that Sky WiFi is the service provider of or a hotspot where our partners provide the WiFi Service);
• keep you logged in during your use of Sky WiFi Roaming (otherwise you would might have to log in repeatedly on every website you visit) and position information on your device’s screen so that you can see the website and use its functionality accordingly; and
• create sessions (and assign tokens and ids for that purpose) and record Usage Information in relation to your session.

We also use other First Party Cookies for purposes that may not be considered essential but are otherwise important because they help us to improve your overall browsing experience by:

• providing the session and related text in the appropriate language;
• remembering settings and preferences that you have made (including marketing preferences); and
• remembering the number of times you been shown a particular image or advertisement.

Cookies and other similar technologies also help us keep track of what websites, information and links are popular and which ones don't get used so much, to help us keep our information on our websites relevant and up to date, identify trends of how people navigate the same and when and where 'error messages' may originate. This information is grouped together and analysed on an anonymous basis not for the purpose of attributing this information or profiling individuals that use Sky WiFi Roaming.

We use Third Parties cookies to deliver and help personalise the advertisements you see when you use Sky WiFi Roaming. This includes advertisements on our websites as well as advertisements on other websites you visit, apps you use and other media you see. To support this we carry out analyses to help ensure that the advertisements are effective (for example, that the number of times you see the same ad is limited) and delivered to the right audiences (for example, Sky WiFi users above a particular age). It is in our legitimate interest to use personal data this way because our provision of Sky WiFi Roaming relies in part on the revenue we receive from doing so. Notwithstanding this, please note that Third Party Cookies will only be placed on your computer or device when you use Sky WiFi Roaming if the following conditions have been satisfied:

• You have accepted the Sky WiFi Roaming Terms and Conditions;

• You are either 18 years of age or older; and

• You have provided consent to receive tailored advertising.

If you have taken some other action to prevent cookies from being stored on your computer or device (such as setting a cookie that overrides all other cookies or prevents them from being placed) then even if the above conditions have been satisfied the Third Party Cookies will not be placed.

As mentioned previously in this notice if you do not wish to receive tailored advertising when you use Sky WiFi Roaming then you can prevent Third Party Cookies being placed by opting out from receiving tailored advertising in the “Advertising Choices” section of the Sky WiFi Roaming user journey. If you do not opt out of receiving tailored advertising at that stage (or conversely you did opt out but later decide to opt in) you can change your preference in the “Advertising Choices” section of the WiFi Service Preference Centre to stop new Third Party Cookies being placed but you will also need to delete any existing Third Parties Cookies that have been placed previously.

Virtually all modern browsers allow you to see what cookies are stored on your computer or device, and to clear them either individually or collectively. You can see a list of the steps that you need to take to delete or remove cookies at http://www.aboutcookies.org.uk/managing-cookies but note that removing all cookies may impact your browsing experience when using Sky WiFi Roaming. For this reason we recommend that you remove only Third Party Cookies provided by our advertising partners so we have provided a link with the names of our current advertising partners in the “How and with whom we share personal data” section of this part of the Privacy Notice for information.

How and with whom we share personal data

As explained in the section entitled “How and why we process personal data”, we may share:

• Your Usage Information combined with some of your Account Information with our advertising partners listed here so that they can deliver or personalise the advertisements you see. None of our current advertising partners transfer personal data outside of the European Economic Area but in the event this changes, we will provide you with further information on the safeguards we apply for such transfer; and
• Your personal data with anyone who takes over our business or with anyone as required by law or in order to protect or enforce our rights or the rights of any third party or in order to detect and prevent fraud and other crimes. You will be informed of the identity of such recipients subject to applicable law, if and when such sharing takes place.

How long we keep personal data

We keep your personal data in this context for the same timeframes, and subject to any terms therein, that are listed in the second Part of this Privacy Notice.

This section covers the personal data we process when Sky WiFi is the service provider of the WiFi service at a hotspot and which you may access either using your Sky WiFi Roaming account or your social media account (where we have enabled Social Log-In Roaming – explained in more detail below - at hotspots which Sky WiFi is the service provider of).

It will be clear that Sky WiFi is the service provider at a hotspot because your device will be connected to a network usually described as “_The Cloud” and you will not be prompted to accept any partner terms and conditions for use of the WiFi service. Further after completing the user journey for the WiFi service (including accepting the Sky WiFi Roaming Terms and Conditions and acknowledging this Privacy Notice) you will be presented with a Sky WiFi branded landing page (as opposed to a partner branded landing page).

If you have any queries about who provides the WiFi service at a particular hotspot you should refer to the Frequently Asked Questions section of our website for more information or otherwise contact wifiuser@sky.uk for further assistance.

How and why we process personal data

Controllership and types of personal data we may hold about you

We have described in Part 2 of this Privacy Notice the Account Information we collect when you create a Sky WiFi Roaming account to access Sky WiFi Roaming and the basis on which it is held by Sky WiFi. From time to time we may provide alternative ways for you to access and roam across hotspots which Sky WiFi is the service provider of including by enabling you to log-in in via a third party social networking service using your social media account (“Social Log-In Roaming”).

If you do not have a Sky WiFi Roaming account and access our WiFi Service via Social Log-In Roaming, prior to receiving access you will be notified by the third party social networking service during the user journey that certain information from your public profile will be shared with us so that we can provide our WiFi service to you. For details of the information included in your public profile (and how you may limit this) you should refer to the data sharing policy of the third party social networking service that you use to access our WiFi service.

The third party social networking service is the data controller of personal data it shares with us and we act as an independent data controller of the data we receive. This information constitutes Account Information and we use it for the primary purpose of providing our WiFi service to you, including generally managing your relationship with us and your activity across our network, and otherwise for the performance of our obligations to you under the Sky WiFi Roaming Terms and Conditions and applicable law.

In addition to the Account Information described above Sky WiFi also collects personal data relating to how you use our WiFi Service, including your IP address (this is a number that identifies a specific network device on the internet and is needed for your devices to communicate with web pages) and other technical details about your device(s) and usage of the WiFi Service (e.g., how much data you used during a given session). Such personal data forms part of your Usage Information. To the extent that you provide us with it, Sky WiFi may also collect Administrative Information about you.

In respect of your Account Information, Usage Information and Administrative Information Sky WiFi is a data controller of this information and uses it for the purposes described in the “Purposes and legal bases” section of this Part of the Privacy Notice below.

Purposes and legal bases

The primary purpose for which we use personal data in this context is to deliver, operate, support and monitor the WiFi service that we provide to you in accordance with our obligations under the Sky WiFi Roaming Terms and Conditions and applicable law. This includes securing the WiFi service against threats such as malicious traffic, resolving any service issues and providing support to you.

In addition to the primary purpose described above:

• We may monitor and improve the WiFi service to understand and improve how it is provided and used. For example, we use Usage Information to analyse whether the hotspots at which we provide a particular WiFi service are providing appropriate coverage during peak times. This is in our legitimate interest as we want to ensure that the WiFi service functions properly and keeps up with technological, social or legal changes that may affect it;
• Where we provide the WiFi service on behalf of the owner of a hotspot, we may provide the owner with access to insights and analysis about the use of the WiFi service (e.g. user presence such as footfall counting, number of returning users, etc. and/or location features such as heatmaps and user device movements) at their venues. This is in our legitimate interest because the provision of the WiFi service to you relies on the revenue Sky WiFi receives from hotspots owners;
• We may also need to use your personal data or pass it to others so we can meet our legal or regulatory requirements; to protect or enforce our rights or the rights of any third party (including to guard against and stop use of the WiFi service contrary to the Sky WiFi Roaming Terms and Conditions); in the detection and prevention of fraud and other crimes; and for the purpose of protecting national security. We do this primarily to comply with applicable laws. However, where no laws require such sharing, we rely on our or the applicable third party’s legitimate interest in enforcing our/their rights or in the detection and prevention of fraud and other crimes;
• We may pass your personal data to third party suppliers that support Sky WiFi with the provision of the WiFi service to you or any person who takes over our business for them to use for the purposes set out in this Privacy Notice. We do this on the basis of our and their legitimate interest in ensuring a continued operation of the relevant WiFi Service (or a related successor service); Details of third party suppliers that Sky WiFi currently use are available here.
• We may share certain personal data about you with hotspot owners where you have provided consent to receive direct marketing from the relevant owners about news, events and offers relating to their products and services. We have provided more detail on how Sky WiFi provides this information and how you can prevent this below for your information.

As mentioned above we may provide hotspot owners with access to insights and analysis about the use of the WiFi service at hotspots where Sky WiFi is the service provider of the WiFi service. To provide these services we process the MAC address of your device together with certain Usage Information. This information is then grouped together with personal data Sky WiFi has collected from other users of the WiFi service and presented to hotspot owners on an anonymised basis so that they can analyse it and understand how users use the WiFi service at their hotspot.

None of your personal data is visible to hotspot owners (including where we provide access to real time user device movement within the hotspots) in this context because when your device connects to the WiFi service Sky WiFi anonymises it using a method of “hashing and salting” and then deletes your MAC address. Sky WiFi further anonymises the hashed information by applying a new salt value to the hashed information at regular intervals.

We appreciate that you may prefer for information about your device’s movement at a hotspot to not be provided to a hotspot owner and if so then please can let us know by emailing wifiuser@sky.uk and we will take steps to ensure such information is not provided.

With respect to the sharing of your personal data with any hotspot owners that ask to receive your data to send you direct marketing about news, events and offers relating to their products and services Sky WiFi will only send the personal data that the hotspot owner has requested for this purpose if you have provided express consent to receive direct marketing from the hotspot owner when using the service at that hotspot.

If you select “No, Thank You” to receiving direct marketing from a particular hotspot owner during the user journey Sky WiFi will not share any of your personal data or your preference data with the hotspot owner so if you have previously subscribed to receive direct marketing from that hotspot owner via another service (e.g. when buying goods or services from that hotspot owner) you will need to notify the owner directly that you no longer wish to receive direct marketing from them.

You can review any marketing preferences (together with the hotspot owner’s Privacy Notice) and change them in the “Partner Marketing” section of the WiFi Services Preference Centre which can be accessed here should you wish to. If during the user journey you decide that you would like to receive direct marketing from the hotspot owner but subsequently change your mind when you alter your preference via the WiFi Services Preference Centre Sky WiFi will notify the hotspot owner of your decision. In respect of your preference data the hotspot owner will be the data controller of it and Sky WiFi processes it on behalf of the hotspot and in accordance with its instructions.

We do not currently process personal data you provide when you use the WiFi service for the purpose of automated decision-making or profiling that would produce legal or other significant effects for you. If that changes at any time in the future, we will notify you beforehand as required.

How and with whom we share personal data

As explained in the section of this Part of the Privacy Notice entitled “How and why we process personal data”, we may share your personal data with:

• suppliers that support Sky WiFi with the provision of the WiFi Service to you;

• anyone who takes over our business to ensure the continued operation of this WiFi Service to you;

• with any person we may be required to meet our legal or regulatory requirements or to otherwise protect or enforce our rights (or the rights of any third party);

• hotspot owners that Sky WiFi provides the WiFi Service at where you consent to Sky WiFi sharing your data that owner for the purposes of receiving direct marketing from them.

In respect of any sharing that is connected to Sky WiFi needing to meet its legal or regulatory requirements, subject to applicable law, we will inform you of the identity of such recipients, if and when such sharing takes place. Further in that context we may also need to share relevant personal data hotspot owners for the same purpose.

How long we keep personal data

We keep your personal data in this context for the same timeframes, and subject to any terms therein, that are listed in the second part of this Privacy Notice.