This part of our privacy notice covers the personal data we process to enable you to roam across particular hotspots and access different WiFi services using your Sky WiFi Roaming account.
How and why we process personal data
In this section, we explain what personal data we process, the purposes for which we use them and the legal grounds for doing so.
Controllership and types of personal data we may hold about you
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, age, 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, duration and venue where you used Sky WiFi Roaming as well as other service-related data collected via cookies and related technologies), 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 then use your Sky WiFi Roaming account to connect to a particular WiFi Service, we share your Account Information with the provider of the WiFi Service, primarily so that the provider is able to operate its WiFi Services. The provider will, when it receives the personal data, act as an independent data controller in respect of it and you can find out more about how it processes that personal data in the provider's privacy notice. Where Sky WiFi provides the WiFi Services, this information is provided further below in part 4.
The provider's identity, terms and conditions for use of the WiFi Service and privacy notice will be available via the Landing Page that is displayed to you when you use the Sky WiFi Roaming to access the particular WiFi Service and also via the Sky WiFi marketing preferences section in the Preference Centre.
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 generally managing your relationship with us and the activity across our systems. We have to process this personal data in order to perform our obligations in 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 the Sky WiFi Roaming Service 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. Notwithstanding this you can choose not to receive surveys from us by selecting the "No, thank you" option in the section of the Sky WiFi Roaming Preference Centre titled "Sky WiFi Communications" which you can access from the Account Settings.
• 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 a continued operation of Sky WiFi Roaming (or a related successor service).
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 in the context of Sky WiFi Roaming as well how such sharing is done.
As explained in the section entitled "How and why we process personal data", we may share:
• Your Account Information with the providers of the particular WiFi Services you choose to connect to using your Sky WiFi Roaming account. Such sharing is done using appropriate security measures and does not currently involve a transfer of personal data to countries outside of the EEA.
•Your personal data with suppliers who act as our data processors and only in accordance with our instructions. We use a number of suppliers which fall into the following categories: IT and network services suppliers (for example, Morar Consulting Limited, an email survey supplier which we use to send you surveys to obtain feedback about your use of the Sky WiFi Roaming Service and the different WiFi Services you access using your Sky WiFi Roaming account), software suppliers (including software as a service and managed service suppliers), analytics and service improvement suppliers, outsourced personnel, and business support service suppliers. Where we provide personal data to these suppliers, we require that appropriate security measures are in place. Our use of suppliers does not currently involve a transfer of personal data to countries outside of the EEA. You can choose If you do not wish to receive email
• 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
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 2 years after your Sky WiFi Roaming account is marked as dormant or once you tell us to close your Sky WiFi Roaming account. Your Sky WiFi Roaming account is automatically marked as dormant if we you do not use it for more than 2 years.
• We delete Usage Information relating to your Sky WiFi Roaming account on a 3 year rolling basis.
• We delete Administrative Information relating to your Sky WiFi Roaming account on a 3 year rolling basis.
The periods listed above may be shorter where the legal basis for keeping the personal data no longer applies.
Instead of deleting personal data, we may anonymise it or put it beyond use which means that, subject to applicable laws, we ensure that where personal data is retained in backups, we delete it before any data is restored from such backups.