Privacy Notice

Sky WiFi Privacy Notice

This privacy notice informs you about the way we, Sky WiFi, use your personal data. To make it easier to read, we have split it into four parts: In the first part (“General Information”), you can find out more about who we are, how you can get in touch and what rights you may have in relation to your personal data. The second part covers the personal data we process when you use your Sky WiFi Roaming account to roam across particular WiFi hotspots (“Sky WiFi Roaming”) and access WiFi services provided by our partners or us (“WiFi Services”) and the third part covers the personal data we use in delivering and helping to personalise the adverts you see (“Advertising”). The fourth part covers the personal data we use where, in addition to Sky WiFi Roaming, Sky WiFi is the service provider of the WiFi Service at the relevant hotspot. In each of these parts, we explain how and why we use your personal data, including with whom we share it and how long we keep it.

Part 1: General Information

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 plc.

We have appointed a data protection officer whom you can reach via dp@sky.uk or by sending your query to the address above, marked for the attention of “Data Protection Officer – Sky WiFi”.

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 your right can be exercised depends on the circumstances and so if you exercise your rights we will check whether such exercise is valid and will keep you informed throughout this process.

Finally, you can also submit a complaint to the Information Commissioner’s Office if you are unhappy with how we process personal data relating to you. The Information Commissioner’s Office’s contact details are available via www.ico.org.uk

Part 2: Sky WiFi Roaming

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 those 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 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.

Part 3: Advertising

This section covers the personal data we use in delivering and helping to personalise the advertisements you see.

How and why we process personal data

Controllership and types of personal data we may hold about you

When you access the webpages we host or the apps we publish (such as Sky WiFi’s homepage, the landing pages that are presented when you use your Sky WiFi Roaming account to access a particular WiFi service or the Sky WiFi Finder app), we collect personal data (such as your IP address and information about your device’s characteristics and capabilities) which forms part of the Usage Information we hold about you. We collect this Usage Information primarily via cookies and related technologies and we act as an independent data controller in relation to it. Where we share this personal data with others, they will also act as independent data controllers.

The term “cookie” refers to one or more small pieces of information stored on or provided by your computer or device when you access online information. Your browser or device sends these cookies back to us every time you visit our pages, or it sends the cookies to another webpage that recognises the cookie, so each page can recognise you and can then, for example, tailor what you see on the screen. Other technologies which are sometimes called pixel tags, locally stored objects and device fingerprinting work in a similar manner.

We combine this Usage Information with some of your Account Information (such as your device’s MAC address) for the purposes described below.

Purposes and legal bases

The primary purpose for which we use and share personal data in this context is to deliver and help personalise the advertisements you see. This includes advertisements on our websites and apps as well as advertisements on other websites you visit, apps you use or media you see (such as on TV or online). It is in our legitimate interest to use personal data in this way as our provision of Sky WiFi Roaming relies in part on the revenue we receive in delivering and helping to personalise advertisements.

In addition to the main purpose described above, we also carry out analyses relating to how we deliver and help personalise the advertisements you see. This is in our legitimate interest as we want to ensure that the advertisements that are delivered to you 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).

However, please note that it is optional for you to provide personal data in this context so if you would like us to stop using your personal data as described in this part of the privacy notice, please untick the box in the “Advertising Choices” section of the Preference Centre. You can access this from Account Settings. You can also manage cookies by disabling them or switching them off via the settings tool in your browser. Please note that doing so may impact your browsing experience when using the WiFi Services.

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 third party advertisers so that they can deliver or personalise the advertisements you see. We have listed these third parties below:
- Acxiom Ltd;
- Liveramp (an Acxiom Limited Company);
- Blis Media Limited;
- Google Ireland Limited;

None of the above partners transfer personal data outside of the European Union but in the event that such sharing does occur in the future, we will provide you with further information on the safeguards we apply for such transfer.

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.

Part 4: WiFi Service Provision

This section covers the personal data we use to provide you with WiFi Services where you have chosen to access them using your Sky WiFi Roaming Account.

How and why we process personal data

Controllership and types of personal data we may hold about you

When you access any WiFi Service for which we are identified as being the provider, we collect personal data relating to how you use that 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.

In addition to the Usage Information described above, we use the Account Information that forms part of your Sky WiFi Roaming account (see the second part of this notice) in the context of providing the WiFi Services to you. We act as the data controller for the Account Information and the Usage Information in this context.

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 Services. This includes securing the WiFi Services against threats such as malicious traffic, resolving any service issues and providing support to you. 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 the WiFi Service 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 venues at which we provide a particular WiFi Service are adequately covered with WiFi hotspots 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.
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 Services 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 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 the relevant WiFi Service(s) (or a related successor service).
Certain owners of venues where Sky WiFi provides the WiFi Service may wish to receive your personal data so that they can send you direct marketing about news, events and offers relating to their products and services. In such cases when you visit the relevant venue and access the WiFi Service using your Sky WiFi Roaming Account we will ask you whether you would like to receive direct marketing from the owner of the venue in accordance with the owner’s privacy policy and consent to us sharing relevant personal data (i.e. your first and last name, email address and the date and time that you gave consent) with the owner for that purpose. It is optional for you to provide your personal data in this context and so if you click “No, thank you” when asked none of your personal data (including the fact that you have said “No, thank you” to receiving direct marketing) will be shared with the owner of that venue but this will mean that if you have already subscribed to receive direct marketing from the owner via a different service then you will need to notify the owner directly that you do not wish to receive direct marketing from them. You may review and change any direct marketing preferences you have made in the “Venue Partner Marketing” section of the Sky WiFi Preference Centre which you can access from Account Settings.

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 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. Further if you consent to us sharing your data with the owner of a hotspot for the purposes of receiving direct marketing from them we may also share relevant personal data with the owner of the hotspot for that 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.