We recognize that privacy is important. This Privacy Policy applies to your use of this wireless Wi-Fi Service (the “Service”) offered by Surge Social (the “Company”). We have prepared this Privacy Policy to describe the manner in which we collect, use, disclose and otherwise manage personal information in connection with the Service.

Information We Collect and How We Use It

The term “personal information” means information about an identifiable individual, including name, address, email address, phone number and other information relating to an individual.

We may collect personal information when you:

  • Sign up and use the Services;
  • Connect to the Internet using the Services;
  • Sign up to receive newsletters and other promotional communications; or
  • Contact us with a comment, question or complaint.

Wi-Fi Service: In order to use the Service, you may be asked to register by connecting your social media profile from one of the following 3rd party websites: Facebook, Twitter, LinkedIn, or other social media networks. If you do so, we will collect your name, email address, city, gender and other information disclosed to you at the time you connect through the social media networks. Alternatively, you may also be asked to register by providing your name, email address, city, gender, country, year of birth, and phone number. Your registration information is used to provide you access to and otherwise administer the Wi-Fi Service, including the provision of tailored advertisements and other offers from us or our marketing partners while you are connected to the Service. We may collect log information about how and when you use our Service, such as your MAC address, social activity, location of device, advertising performance, and coupon redemption.

Newsletters, Text Messages and Promotional Materials: When you register to use the Service, you may also sign up to receive our email newsletter, SMS text messages and other communications. When you subscribe to our newsletter, SMS text messages or other communications, we will use your email address or phone number to send you information about our product and service offerings or those of our marketing partners. You may remove yourself from our newsletter list by clicking the “unsubscribe” link that appears at the bottom of each of our e-mails. If you have signed up to receive SMS text messages, you may unsubscribe by following the opt-out instructions provided in your SMS messages.

Contests, Sweepstakes and Promotions: When you enter a contest, sweepstakes or participate in a promotion, we may collect your name, address, phone number, email address, location, and other information you provide. We use this information to administer your participation in the contest, sweepstakes or promotion. At the time you enter the contest, sweepstakes or promotion, we may obtain your consent to send you future promotional communications. If a contest, sweepstakes or promotion is jointly sponsored by us and one or more sponsors, your personal information may be shared with such sponsors, as specified at the time of collection of your personal information. We do not control the use, disclosure or security of your personal information by other sponsors, and recommend you review their respective privacy notices or statements.

Surveys and Customer Research: From time to time, we may offer you the opportunity to participate in one of our surveys or other customer research. We use this information to help us understand our customers and to enhance our product and service offerings and promotions.

Contact Us: When you send email or other communications to us, we may use and retain those communications in order to process your inquiries, respond to your requests and improve the Wi-Fi Services.

Disclosure of Personal Information

We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out herein.

Service Provider Arrangements: We may transfer (or otherwise make available) your personal information to our affiliates and other third parties who assist us with providing the Services. For example, we may use service providers to host our website and send advertisements or other marketing communications on our behalf. Your personal information may be maintained and processed by our affiliates and other third party service providers in the US, Canada, or other jurisdictions. Our service providers are given only the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own purposes. For additional information about our third-party service providers, contact us as set out below.

Sale of Business: We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Surge Social LLC or as part of a corporate reorganization or stock sale or other change in corporate control.

Legal: We, our affiliates and other service providers, may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by applicable US or other law. We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims, as part of the administration of our loss prevention program, or as otherwise permitted by law.

Technology Information

When you access the Services, our servers automatically log certain information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, MAC address, location (such as GPS signals sent by a mobile device) or information that can be used to approximate your location (such as a cell ID), browser type, browser language, connection history, and the date and time of your request.

Cookies: We may use a technology called “cookies”. A cookie is a tiny element of data that websites can send to your browser, which may then be stored on your device so we can recognize you when you return. We use cookies to improve the quality of our Service, including for storing user preferences, improving ad selection, and tracking user trends. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from us, you may not be able to take advantage of all of the features of our Services.

Advertising: We and other third parties (such as ad networks, data exchanges, and other service providers) may also use cookies and similar technologies to provide you with advertisements and promotions when you use our Services. The information collected by these third parties may be used to tailor ads you see both on our Services and on third-party websites. You can choose not to receive tailored advertising from listed ad networks, data exchanges, and other service providers using this online tool. You can opt out of Google’s specific use of cookies for these purposes by visiting Google’s Ads Preferences Manager. If you opt out of receiving tailored advertising from a third party, including Google, you may still see ads about us, but those ads will not be customized by the companies that you opt-out of.

Third party links: When you use our services, you may be presented with links to websites that we do not own or operate. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

We may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our content and services.

Information Security

We have implemented reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. Unfortunately, no collection or transmission of information over the Internet or other publicly accessible communications networks can be guaranteed to be 100% secure, and therefore, we cannot ensure or warrant the security of any such information.

Data Integrity

We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Accessing and Updating Personal Information

You have the right to access, update, and delete your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and deletion your personal information by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

Retention of Information

We may keep a record of your personal information, correspondence or comments in a file specific to you. We will utilize, disclose or retain your personal information for as long as necessary to fulfill the purposes for which that personal information we collected as permitted or required by law.

Changes to this Privacy Policy

This Privacy Policy may be updated periodically to reflect changes to our personal information practices. The revised Privacy Policy will be presented when you sign-in to use the Services. We strongly encourage you to please refer to this Privacy Policy often for the latest information about our personal information practices.

Questions

Any questions about this Privacy Policy should be addressed to surgesocial.com/contact.

Last modified: Sept 17, 2018