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:
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suppliers that support Sky WiFi with the provision of the WiFi Service to you;
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anyone who takes over our business to ensure the continued operation of this WiFi Service to you;
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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);
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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.