(Date of last version May 2018)
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Identity: FON WIRELESS LIMITED (hereinafter ‘Fon’). Included on the Registrar of Companies for England and Wales under number 5661131.
Address: 25 Farringdon Street (EC4A 4AB) – London (UK).
Telephone number for customers in Spain: +34 912917600
Data Protection Officer (DPO): Picón & Asociados Abogados.
DPO contact: email@example.com – Telephone number for customers in Spain: +34 914575614.
2. Registration Data
When you sign up for the Fon Service, we will ask you for certain personal information, such as your username, password, email address, date of birth, gender, postal code, country, etc. We may also ask you for further information, such as your mobile phone number and mobile phone company (hereinafter ‘Data’).
3. Storing your Data
Fon is responsible for processing the data you provide and fully complies with current legislation regarding personal data protection, as well as with confidentiality obligations relating to the work it carries out. Fon also complies with all complementary regulations and other applicable legislation.
4. The purpose of processing your Data
Fon processes the personal data you provide it with in order to:
(a) Manage relations with its customers, as well as the provision, billing and collection of payment for its services. Providing Data for this purpose is compulsory and necessary to enter into a contract with Fon.
(b) Send out advertising material relating to our products and services, except where you express your wish to not receive such material, this being done by any reasonable means. Using the information provided, we are able to create sales profiles with the aim of offering you products and services that match your interests. Authorisation to process your Data for this purpose is optional and if you opt out of this, the only consequence will be that you will not receive information about our products and services.
(c) Meet data retention obligations for electronic communications. In accordance with current legislation, providing data for this purpose is compulsory.
(d) Improve our customer care support service, as well as keep in contact with our customers.
(e) Improve your Fon Service experience, optimising the way we provide our services and products.
(f) Provide other customers with the approximate location of a Fon Spot so that all our customers may use the Fon Service.
5. Duration of Data processing
Data provided for the purpose of managing customer relations, as well as for the billing and collection of payment for our services will be stored for the entire duration of the contract. Once said relation has ended, where appropriate, your Data may be stored for the period of time stipulated in applicable legislation and until the prescription period relating to liability resulting from the contract has ended.
Data provided for the purpose of sending out information on our products and services will be stored indefinitely or until you express your wish for us to delete it.
Data necessary to comply with the obligation to store data generated or processed within the context of electronic communications services in Spain will be stored for a period of twelve months from the date on which the communication took place. In other countries where the Fon Group operates, in the case of regulations existing in this regard, said Data will be stored for the time stipulated by sector-specific regulations in each country.
6. Entitlement to process Data
The legal basis for processing your Data is the performance of the Internet access service contract, as detailed in the Service Use Conditions, in accordance with the terms and conditions found here.
Providing information on our products and services is based on the legitimate interest of the business, allowing us to offer customers other products and services and thus achieve customer loyalty. Such legitimate grounds are provided for in applicable legislation (the General Data Protection Regulation), which expressly allows personal data to be processed for direct marketing purposes. Nevertheless, we remind you that you are entitled to object to your Data being processed for this purpose, doing this in any of the ways provided for in this clause.
The basis for storing Data relating to electronic communications in Spain is compliance with the legal obligation laid out in Law 25/2007 of the 18th October regarding the storing of data relating to electronic communications and public communications networks. In other countries where the Fon Group operates, in the event of this aspect being regulated, its legal basis will come from sector-specific regulations in each country.
7. Parties your Data will be provided to
Your Data will be given to the following:
(a) Relevant public authorities, as specified by law and for the purposes provided for in current legislation.
(b) Online processing companies used for payment and collection.
(c) Other companies within our Group, amongst which are: Fon Technology S.L, Fon Labs S.L., etc. The purpose of providing these companies with your Data is to centralise our work and comply with internal administrative procedures, including the processing of our customers’ personal Data.
(d) Given the international scope of Fon services, Data will be transferred to various collaborating entities and joint agents within the telecommunications sector or partners, within and outside the EU where the Fon Service is offered, even if you are a customer of said collaborating entity. Said transfers will be necessary for:
- The performance of a contract between the data subject and the controller or for the implementation of pre-contractual measures taken at the data subject’s request;
- The conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person.
If said Data were not transferred, it would not be possible to fulfil the main purpose of the Fon Service in the various geographical areas were Fon operates. These transfers are expressly provided for in Article 49.1 of the General Data Protection Regulation for the purpose mentioned. Furthermore, in certain circumstances, the country in question will ensure a suitable level of protection or the entity will adhere to the Privacy Shield for transfers between the USA and EU.
Entities which collaborate with the Fon Service are published on the Fon website.
Moreover, it should be noted that the purpose for which these collaborating entities process your Data is limited solely and exclusively to the provision of the Fon Service. If these collaborating entities do not have access to your Data, neither they nor Fon will be able to guarantee access to the Fon Service in accordance with the conditions specified in your contract.
8. Payment Data
When you purchase a Fon Pass or make other purchases through the Fon Service, your credit card, SMS or PayPal information and other financial data that we need to process your payment are collected and stored by third-party payment processing companies, i.e. this information is not processed by Fon. We may also collect some limited information, such as your postal code and details of your transaction history related to the Fon Service. These third parties generally provide us with some limited information relating to you, as well as your card type, expiration date and last four digits. The use of your Data by our billing service provider will be governed by its privacy policies, which you must accept when registering on said payment process systems.
9. Information regarding the location of Fon Spots will be made public.
While the Contract is in place, Fon will publish information relating to the Fon Spot location and address of all Fon Spots. This is necessary so that other Fon customers are able to access the Fon Network.
You accept and agree that Fon needs to share the address of your access point to enable other Fon customers to find it. Please contact us through our customer care support service if you wish to edit the location information to make it less specific – for example, by removing the flat number from an address or giving a street number range (8 – 14 Main Street) rather than a precise number, thus providing an approximate location.
These approximate addresses will be visible on Fon maps and directories of nearby access points. We will not publicly associate your name with your address and access point and we will not make your name or specific address available to third parties. We cannot guarantee that third parties will not be able to deduce your precise address.
10. Access and security for global Fon Spots
Recognising the global nature of the Internet, you agree to comply with all local laws regarding online conduct and acceptable content. Fon Spots in different countries may be subject to different local laws and we may be required to store data in order to comply with these laws.
Specifically, you agree to comply with all applicable laws regarding the transmission of technical data exported from your home country, the country in which you reside or any country in which you are located when using the services.
Access, Data and information relating to such access through each Fon Spot will be governed by the laws of the country where the Fon Spot is located.
Fon has adopted the technical measures necessary to maintain the security level required, in accordance with the nature of the personal Data processed and the circumstances of this processing, with the aim of avoiding (as far as possible and always using the latest technology) its alteration, loss, processing or unauthorised access.
11. Accessing third-party websites
If you disclose your personal information to other companies, your information will be dealt with according to their privacy practices.
You understand that by using any of the Fon Services you agree to do this at your sole risk and that Fon will not be liable to you or any other person for third-party services in the event of their content, services or products being deemed offensive, indecent or objectionable, regardless of whether they contain explicit language, and that the results of any search or entering of a particular URL may automatically and unintentionally generate links or references to objectionable material.
You acknowledge and agree that Fon is not responsible for examining or evaluating the content, accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect of such third-party content or websites.
Moreover, third-party services and content which may be accessed as they appear on the software or are linked to the software, are not available in all languages or in all countries. Fon in no way guarantees that such services and content are appropriate or available for use in any particular location.
When accessing such services or content, you do so at your own initiative and are responsible for respecting all applicable laws, including but not limited to applicable local laws.
Fon and its licensors or partners reserve the right to change, suspend, withdraw or disable access to any of the services at any time without prior notice.
In no event will Fon be liable for the removal or withdrawal of access to such services.
This clause will remain applicable following termination of this Contract.
12. Rights relating to your Data
You are entitled to obtain confirmation of whether we are processing personal Data belonging to you. Fon customers have the right to access their Data, as well as request that any incorrect information be rectified or, where appropriate, request their information be deleted when it is no longer needed for the purpose for which it was provided, amongst other reasons.
In accordance with the conditions found in the General Data Protection Regulation, data subjects, i.e. Fon customers, may request that the processing of their Data or Data relating to their portability be limited, in which case we will only store said data for exercising or defending rights within the context of complaints.
In certain circumstances and for reasons relating to their specific situation, data subjects may object to their Data being processed. If you have granted permission for your Data to be used for a specific purpose, you may withdraw such permission at any time, without this affecting the legality of data processing carried out prior to said withdrawal. In such cases, we will cease to process your Data or, where appropriate, we will cease to process it for the specific purpose in question, except in the case of compelling legitimate grounds or for exercising and defending rights within the context of complaints.
All the rights referred to may be exercised by getting in touch with us using the contact information included at the beginning of this policy.
If your rights are infringed or if you have been unable to properly exercise them, in Spain you may submit a complaint to the Spanish Data Protection Agency (contact information available on www.agpd.es). In other countries, you may do this by getting in touch with the relevant authority for data protection. You may also obtain more information on your rights by getting in touch with said organisations.
When providing data relating to third parties, you are responsible for informing them beforehand of everything stipulated in Article 14 of the General Data Protection Regulation, in accordance with the conditions laid out therein.
Fon’s goal is to respect your privacy to the best of its ability. Please contact us at firstname.lastname@example.org with any suggestions you have for improving this Policy.