Wi-Free Limited (“Wi-Free”, “We,” “Us,” and/ or “Our”) is concerned about the privacy and security of your information which is governed by this privacy policy (“Privacy Policy”). We want to make your experience with Wi-Free as enjoyable and rewarding as possible, and also allow you to feel secure that your privacy interests are being respected.

Collection of Information

Required Information

Wi-Free collects certain information that is necessary to fully service your User Account. As a customer, you will be asked to provide Information that is needed in order to create your User Account and fulfil our service commitment to you such as your name, address, phone number, e-mail address and billing information. We treat this personal information that you provide to us as highly confidential. Wi-Free may use this Information for editorial and feedback purposes, marketing and promotional purposes, for statistical analysis and for product development. Your personal information, however, will never be sold to any company nor will it be shared with third parties, unless specifically stated otherwise by You or in special circumstances.

Optional Information

Like any business interested in attracting and offering the highest quality of service to customers, Wi-Free gathers voluntary demographic information about our customers. These questions seek to gain insight on such things as how an individual became aware of our Services, 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 Wi-Free User Account information. This information is kept completely private and confidential except as disclosed in the ‘Use and Disclosure of Information’ section below.

Wi-Free 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 that offer complimentary offerings to Our Services. This information is summarized, and information about specific individuals is never shared with any third party. Participation in our customer surveys is voluntary.

Wi-Free may offer incentive or other promotional offers or programs to customers, Partners and other visitors to the Wi-Free site www.wi-free.com (the “Site”), the general public and individuals identified through direct mail lists. These offerings are promoted on Our Site, advertisements and press releases. At a minimum, required information includes name and e-mail address; in some cases, the customer must answer mandatory survey questions about other personal data or enter a program code. The information gathered in the entry form is used to verify the customer's identity, to send the customer an e-mail notification that their entry has been received, and to contact winners and/or prize recipients. Because the rules and terms of each promotional program can vary, all information about each promotional program is clearly posted on Our Site during the event. All such programs are conducted in accordance with the laws of Gibraltar.

Geographic Location Information

When You use Our Services, including when doing so through a mobile device (such as a laptop, tablet or a smart phone), We may collect and/or track certain geographic location information that is derived from your usage of the Wi-Free Service such as usage patterns, travel patterns, Site views, traffic patterns and information about your geographic location. Wi-Free may use this tracking and location information for statistical purposes to improve our products and Services and to manage our networks and systems more efficiently.

Cookies and Web Beacons

To keep track of Web sites often store a small data file on your hard disk when you visit them. This file is commonly referred to as a “cookie.” 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). Wi-Free uses 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. 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.” 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 OFFUNCTIONALITY.

We do not control the use of third parties’ cookies and expressly disclaim responsibility for information collected through them.

Web sites may contain an electronic file called a “web beacon” that allows a website to track users who have visited that page or to access certain cookies. Wi-Free may use web beacons in the following ways:

(a) within our Web sites in order to track customers signing up at one of our hotspot locations.

(b) within our Web sites in order to fulfil sponsored access campaigns or other promotions.

(c) to measure where customers leave the signup process in order to improve customer experience.

(d) to track customers that come through our Site from advertisements or search engines.

(e) to serve ads to customers after they leave our Site.

Use and Disclosure of Information

Except as described herein, Wi-Free will not divulge any of your personal information, contact, financial, bill history, or geographic location to any other organization unless (1) you give Wi-Free explicit and specific, prior permission (for example, if you opt-in to a sponsorship offer from one of our Partners), (2) the disclosure is required by law or by legal process authorized by a court of competent jurisdiction, (3) Wi-Free suspects fraud by a customer involving Wi-Free, in which case Wi-Free may investigate and report any evidence, including personal information, to law enforcement officials and to the courts in the course of seeking remedies at law and equity, and/or (4) you make an inquiry, request or complaint that requires follow-up and we share your information with others to satisfy your inquiry.

Subject to the terms of this Privacy Policy, we may disclose information to our employees, contractors, Partners, affiliates, distributors, dealers, vendors and suppliers who process information on our behalf, participate with Us in the provision or operation of our Site or provide You with Services.

We reserve the right to transfer all information in our possession to a successor entity in the event of a merger, acquisition, reorganisation, or other sale of all or a portion of our assets or business. Other than to the extent ordered by a court, the use and disclosure of all transferred information will be subject to this Privacy Policy or to a new privacy policy if you are given notice of that new privacy policy and you affirmatively opt-in to accept it. Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor entity.

We may email you about products and services that we believe may be of interest to you. 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.

In instances where Wi-Free and a third party jointly promote the Wi-Free Services, Wi-Free may provide that third party certain information, such as name and e-mail address, for the sole purpose of allowing Wi-Free and the third party to evaluate the promotion.

Wi-Free may contact customers or Site visitors regarding account status and changes to this privacy policy and any other policies or agreements relevant to Site visitors. Wi-Free may use your information to disclose summary information to strategic and business partners. This is obtained by combining data from many individuals with the name and other identifiers removed. Wi-Free also may create aggregate reports on user demographics and traffic patterns. This information may be used to negotiate with service providers who complement the Wi-Free service or assist us in our efforts to expand our customer base.

Wi-Free opposes the e-mailing of any junk mail, and does not sell customer information to e-mail lists or telemarketers. If any of our partner sites engage in such practices, for any reason, Wi-Free will immediately investigate, and if appropriate, discontinue services with such parties. If you receive junk e-mail that mentions Wi-Free or its services, please send details to us at CONTACT US and we will investigate promptly.

Correcting and Updating Your Information

As a Wi-Free customer, you are always fully in 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://secure.wi-free.com/account/profile/. 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:

• United Kingdom: +44 20 7617 7767
• United States: +1 718 569 7778
• Australia: +61 390 187 355
• Hong Kong: +852 8199 9677
• Chile: +56 45 708 825

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.

Opt-out Policy

Wi-Free automatically opts customers in to providing Wi-Free with information, as well as a separate opportunity to opt-in to certain location-tracking services, or receiving communications from us and our partners.

At any time, customers can contact Wi-Free to opt out of any of our promotions, programs, location-tracking services or contests via the following link http://www.wi-free.com/contacts.html. Alternatively, customers can opt not to provide certain information when enrolling for the Wi-Free 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.

Commitment to the Privacy of Your Family

We do not knowingly collect information from children under the age of 13. If we determine that we have collected personally identifiable information on children, we will promptly delete it from our system. We recommend that children who are 13-17 years old receive permission from a parent before gaining access to the Wi-Free service or sending information to Wi-Free or anyone else online.

Security Measures

Your account information is protected by a unique User Account login name and password that is issued to you. Your login name and password should be kept confidential because it is the key to accessing the information held by Wi-Free about you. If your computer or other device is accessible to or by others, please log out of the Site before you leave it. Security is also provided through your web browser.Wi-Free 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). All employees, contractors and other companies engaged by Wi-Free are contractually required, through signed, internal non-disclosure agreements, to keep your Personal Information confidential and not to use it in any way other than what is necessary to perform their work for Wi-Free. 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.

While Wi-Free uses reasonable and proportionate measures to protect the security of your information, no security measures are 100% guaranteed, and Wi-Free does not guarantee that your information will remain confidential.

Security of Third Party Networks

Because of the global nature of our Services, there are some places where you cannot access the Wi-Free Services. In these places, you may manually search for available third party networks and, if required to do so, assent to terms of service or other click-through agreements. Please see our FAQ’s http://www.wi-free.com/faq.html for more information about your options: http://www.wi-free.com/faq.html

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 Wi-Free’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 Wi-Free, 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.

Privacy Policy Changes

Because of changes in technology and the growth and development of our business, or for other business reasons, we may need to modify this Privacy Policy from time to time. We will alert you by email if this Privacy Policy is revised (if you have given us your email address), and we will post a copy of the new policy with its effective date on this Site. It is therefore important that you register with us and notify us if you change your email address. If you do not provide us with a current email address, you should regularly review this policy to ensure that you are informed of any changes as soon as they occur.

Additional Information

This Privacy Policy is effective as of the date hereof. Wi-Free reserves the right to change this Privacy Policy at any time. By using the Wi-Free Service, you are acknowledging and accepting all terms and conditions outlined in this Privacy Policy.

If you have any questions regarding this Privacy Policy, please e-mail us at: info@wi-free.com

If this Privacy Policy is translated into another language the English language version will prevail in the event of any conflict between the translation and the English language version.

Terms and expression not expressly defined herein shall bear the meaning attributed thereto under the Terms.

*Last updated 15th November 2012