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.
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”.
We are legally required to let you know about the rights you may have with respect to your personal data:
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
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.
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:
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 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.
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:
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.
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.
This section covers the personal data we use in delivering and helping to personalise the advertisements you see.
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.
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.
As explained in the section entitled “How and why we process personal data”, we may share:
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.
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 use to provide you with WiFi Services where you have chosen to access them using your Sky WiFi Roaming Account.
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 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
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.
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.