GDPR Commitment | Cucumber Tony Splash WiFi

This Privacy Policy applies to Cucumber Tony's WiFi Marketing tools, splash pages and platform (collectively, the "Services"), cucumberwifi.io and other Cucumber Tony websites (collectively, the "Websites") and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Cucumber Tony. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Cucumber Tony's business.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Cucumber Tony platform ("Third Party Services"), or any other third party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the "Customer Agreement"), including the processing of personal data (collectively, "Customer Data"). The organization (e.g., the business or location) that entered into the Customer Agreement ("Customer") controls their instance of the Services and any associated Customer Data that may be collected by way of the Splash Pages. If you have any questions about specific Service settings and privacy practices, please contact the Customer whose splash pages you use. You can check for contact information of your Dashboard owner(s) and administrator(s) via the splash pages directly.

Information We Collect And Receive

Cucumber Tony may collect and receive Customer Data and other information and data ("Other Information") in a variety of ways:

Customer Data. Customers or individuals granted access to the Internet by a Customer ("Authorized Users") routinely login and submit Customer Data to Cucumber Tony when using the Services. This includes social profiles etc.

Other Information. Cucumber Tony also collects, generates and/or receives Other Information:

Dashboard and Account Information. To create or update a Dashboard account, you or your Customer (e.g., your employer) supply Cucumber Tony with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Cucumber Tony (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.

Usage Information

Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.

Device information. Cucumber Tony collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and MAC addresses. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.

Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. For example, we know the address of the business from where you access the Services or an IP address received from your browser or device to determine approximate location.

Cookie Information. Cucumber Tony uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie Policy.

Networking Data. Cucumber Tony collects data from devices running the Cucumber Tony firmware. Networking data includes information like data transferred, client mac addresses and signal strength. This data is cached for 30 days in a data storage facility located within the EU. We use this data to improve the quality of service.

WiFi Analytics. Cucumber Tony may collect WiFi analytics and environmental data from various sources. This data is not used for location analytics, user tracking. This data is used, like the networking data, to improve network performance. Client identifiers are encrypted with a random salt unique to the Customer that gets refreshed every 30 days. Data is expired after 30 days automatically.

Additional Information Provided to Cucumber Tony. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Cucumber Tony.

Where Is My Data?

Customer and User data is primarily stored in Google Cloud platform in their European data centres. Data is encrypted at rest. Data including Email addresses is processed (but not stored) in the US since that's where Google's Cloud Functions run. Backups of the data are encrypted and stored in the EU.

How We Use Information

Customer Data will be used by Cucumber Tony to build User Profiles for the Customer to understand usage patterns at their businesses. For example, Cucumber Tony will use Customer MAC addresses to identify individuals and link them to their social accounts.

Cucumber Tony will use User Emails to send automated email campaigns for the Customer.

Cucumber Tony will use User phone numbers to send automated SMS messages on behalf of the Customer.

Cucumber Tony will use twitter @handles to send automated Twitter messages on behalf of the Customer.

To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User's request.

Networking Data and Analytics Data is used for network performance enhancements and troubleshooting.

As required by applicable law, legal process or regulation.

To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.

To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Cucumber Tony. These are marketing messages so you can control whether you receive them.

For billing, account management and other administrative matters. Cucumber Tony may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.

To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Cucumber Tony may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as "Personal Data."

Data Retention

Cucumber Tony will retain Customer Data in accordance with a Customer's instructions, including any applicable terms in the Customer Agreement and Customer's use of Services functionality, and as required by applicable law. Cucumber Tony may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Cucumber Tony to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

For example, we retain access logs for 12 months as required by law in certain countries.

How We Share And Disclose Information

This section describes how Cucumber Tony may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Cucumber Tony does not control how they or any other third parties choose to share or disclose Information.

Customer's Instructions. Cucumber Tony will solely share and disclose Customer Data in accordance with a Customer's instructions, including any applicable terms in the Customer Agreement and Customer's use of Services functionality, and in compliance with applicable law and legal process.

Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors we use to support delivery of our Services is set forth at Cucumber Tony Subprocessors.

During a Change to Cucumber Tony's Business. If Cucumber Tony engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Cucumber Tony's assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.

To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. Please see the Data Request Policy to understand how Cucumber Tony responds to requests to disclose data from government agencies and other sources.

To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Cucumber Tony or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

With Consent. Cucumber Tony may share Other Information with third parties when we have consent to do so.

Security

Cucumber Tony takes security of data very seriously. Cucumber Tony works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, Cucumber Tony cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.

Age Limitations

To the extent prohibited by applicable law, Cucumber Tony does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will takes steps to delete such information.

Changes To This Privacy Policy

Cucumber Tony may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Cucumber Tony will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

Data Protection Officer

To communicate with our Data Protection Officer, please email [email protected]

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the "controller" and "processor" of information. In general, Customer is the controller of Customer Data. In general, Cucumber Tony is the processor of Customer Data and the controller of Other Information. Cucumber Tony trading as Cucumber Tony Inc is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use WiFi Hotspots Services.

Your Rights

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Customer for additional access and assistance. Please check https://ct-networks.io for Customer contact information.

To the extent that Cucumber Tony's processing of your Personal Data is subject to the General Data Protection Regulation, Cucumber Tony relies on its legitimate interests, described above, to process your data. Cucumber Tony may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Cucumber Tony's use of your Personal Data for this purpose at any time.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Cucumber Tony's use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority:

Contacting Cucumber Tony

Please also feel free to contact Cucumber Tony if you have any questions about this Privacy Policy or Cucumber Tony's practices, or if you are seeking to exercise any of your statutory rights. You may contact us at [email protected] or at our mailing address below:

Cucumber Tony @ 101 Finsbury Pavement, London EC2Y 9AU

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Effective: February 2018