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PRIVACY POLICY




PRIVACY POLICY STATEMENT

This is our privacy policy from 25th February 2021 in accordance with the Data
Protection Act 2018 and the UK GDPR (the “Act” or “GDPR”)  . Again, this sets
out how we will treat both you and your personal data,  but reflects changes to
your rights and our obligations introduced as a result of the GDPR. During the
course of our activities, Wifinity Limited of Unit 1 Kingsmill Business Park,
Chapel Mill Road, Kingston Upon Thames, Surrey, KT1 3GZ (we), will collect,
store and process data about users of our website at www.wifinity.co.uk and our
Wi-Fi services to you (you).


ABOUT THIS POLICY

 1. The personal data (personal data or information) that we hold about you,
    which may be held on paper or on a computer or other media, is subject to
    certain legal safeguards specified in the GDPR and other regulations.
 2. This policy sets out the basis on which we will process any personal data we
    collect from you, or that is provided to us by you or from other sources.


COOKIES

Where you have consented to our use of cookies, cookies will be used to
distinguish you from other users of our website. This helps us to provide you
with a good experience when you browse our website and also allows us to improve
our website. For detailed information on the cookies we use and the purposes for
which we use them see our Cookie Policy.


WHAT INFORMATION WE MAY HOLD ABOUT YOU

 1. Information you give us. This is information about you that you give us by
    registering to use our WiFi service including filling in forms, completing a
    survey on our website at www.wifinity.co.uk (our website) or by
    corresponding with us by phone, e-mail or otherwise. It is the information
    you provide when you register with us and when you report a problem with our
    website or services. The information you give us and we hold about you may
    include your name, address, age, phone number, email address, billing
    details, subscription history as well as device identifiers and usage
    (applications and browsing history).
 2. Information we collect about you. With regard to each of your visits to our
    website we will collect the following information:

a. Technical information, including the Internet protocol (IP) address used to
connect your computer to the Internet, your login information, browser type and
version, time zone setting, browser plug-in types and versions, operating system
and platform.

b. Information about your visit, including the full Uniform Resource Locators
(URL), clickstream to, through and from our website (including date and time),
products you viewed or searched for, page response times, download errors,
length of visits to certain pages, page interaction information (such as
scrolling, clicks, and mouse-overs), methods used to browse away from the page,
and any phone number used to call our customer service number.

c. Information we receive from other sources. This is information we receive
about you if you use any of the other services we provide. In this case we will
have asked for your consent when we collected that personal data if we intended
to share that personal data internally and combine it with data collected on our
website. We will also have told you for what purpose we will share and combine
your personal data. We work closely with third parties (including, for example,
business partners, sub-contractors in technical, payment and delivery services,
advertising networks, analytics providers, search information providers, credit
reference agencies). We will notify you when we receive information about you
from them and the purposes for which we intend to use that information.




WHAT WE MAY USE THIS INFORMATION FOR

1. Where we need to use your information to perform a contract with you or to
fulfil a request originated by you.

2. Where you have given your consent for us using your information

3. When using your information is in our legitimate business interests (provided
these interests are balanced against your rights

4. Where we need to process your personal data to comply with legal obligations
to which we are subject


WE MAY CONTACT YOU

 1. To provide you with information about other goods and services we offer that
    are similar to those that you have already purchased or enquired about.
 2. To provide you, or permit selected third parties to provide you, with
    information about goods or services we feel may interest you. If you are an
    existing customer, we will only contact you by electronic means (e-mail or
    SMS) with information about goods and services similar to those which were
    the subject of a previous sale or negotiations of a sale to you. If you are
    a new customer, and where we permit selected third parties to use your
    personal data, we (or they) will contact you by electronic means only if you
    have consented to this by opting in to receive such information
 3. To notify you about changes to our services and/or.
 4. To ensure that content from our website is presented in the most effective
    manner for you and for your computer.

Information we collect about you. We will use this information:

 1. To administer our website and for internal operations, including
    troubleshooting, data analysis, testing, research, statistical and survey
    purposes
 2. To improve our website to ensure that content is presented in the most
    effective manner for you and for your computer
 3. To allow you to participate in interactive features of our service, when you
    choose to do so.
 4. As part of our efforts to keep our website safe and secure
 5. To measure or understand the effectiveness of advertising we serve to you
    and others, and to deliver relevant advertising to you; and/or
 6. Where you have agreed to this, to make suggestions and recommendations to
    you and other users of our website about goods or services that may interest
    you or them.

Information we receive from other sources. We will combine this information with
information you give to us and information we collect about you. We will use
this information and the combined information for the purposes set out above
(depending on the types of information we receive).


LAWFULNESS OF PROCESSING

 1. In the course of our business, we may collect and process personal data and
    are, for that purpose, a controller of the data. This may include data we
    receive directly from you (for example, by completing forms or by
    corresponding with us by mail, phone, email or otherwise) and data we
    receive from other sources (including, for example, business partners,
    sub-contractors in technical, payment and delivery services, credit
    reference agencies and others).
 2. The GDPR is not intended to prevent the processing of personal data, but to
    ensure that it is done lawfully and without adversely affecting your rights
    as the data subject
 3. We will only process personal data as specifically permitted by the GDPR. We
    will usually obtain your consent to process your personal data unless one of
    the exemptions within the GDPR permits processing without your consent.
 4. For the purposes of processing your personal data we will usually rely on
    one of the following conditions:
 5. Where you have given your consent to the processing your personal data for
    one or more specific purposes and/or
 6. Processing is necessary for the performance of a contract to which you are a
    party or in order to take steps you requested prior to entering into a
    contract with us (for example, a contract for our WiFi services).


PRINCIPLES RELATING TO THE PROCESSING OF PERSONAL DATA

 1. We will process all personal data fairly and in a transparent manner. In
    particular personal data will be collected for specified, explicit and
    legitimate purposes and not further processed in a manner that is
    incompatible with those purposes. All personal data shall be:

a. Adequate, relevant and limited to what is necessary in relation to the
purposes for which the personal data is processed.

b. Accurate and, where necessary, kept up to date; every reasonable step will be
taken to ensure that personal data which is inaccurate, having regard to the
purposes for which it is processed, is erased or rectified without delay.

c. Kept in a form which permits the identification of you as a data subject for
no longer than is necessary for the purposes for which the personal data is
processed and

d. Processed in a manner that ensures appropriate security of the personal data,
including protection against unauthorised or unlawful processing and against
accidental loss, destruction or damage, using appropriate technical or
organisational measures.


CONSENT TO PROCESS PERSONAL DATA

 1. We shall usually seek your consent to process personal data using clear and
    plain language. You will have the right to withdraw your consent at any
    time.
 2. We will only process and hold your personal data as long as is necessary to
    provide our services (for example, for the duration of the contract through
    which we provide our WiFi services to you).
 3. Where we are providing our Wifi services to you, withdrawing your consent
    for us to process you personal data may prevent us from providing our
    services to you. If you still wish to withdraw your consent, you must
    provide us with any necessary notice to end our provision of services to you
    as set out in our agreement with you.


YOUR RIGHT OF ACCESS

The GDPR gives you the right to access copies of the information held about you.
Your right of access can be exercised in accordance with the GDPR. The first
copy of the personal data held about you will be provided free of charge but any
subsequent copy will be subject to a reasonable fee based on the administrative
costs of providing this information to you.


THE RIGHT TO CORRECT OR ERASE PERSONAL DATA AND RESTRICTION OF PROCESSING

 1. You have the right to ensure that we correct the records of any personal
    data held about you which is inaccurate. You also have the right to ensure
    that we complete any incomplete personal data held about you.
 2. You have the right to ensure that we erase your personal data (the right to
    be forgotten).
 3. In certain circumstances, such as where you have contested the accuracy of
    personal data, you have the right to restrict our processing of your
    personal data.
 4. Where any rectification or erasure of personal data or restriction of
    processing has taken place we shall communicate any rectification to you or
    erasure or restriction of processing to each recipient to whom the personal
    data has been disclosed, unless this proves impossible or involves
    disproportionate effort. We shall, if you request, inform you about those
    recipients.


YOUR RIGHT TO REQUEST AN ELECTRONIC COPY OF YOUR PERSONAL DATA

Where you request personal data you have the right to be provided with a
structured, commonly used and machine-readable copy and have the right, in
certain circumstances, to ensure that we transmit that personal data to another
controller without hindrance.


AUTOMATED INDIVIDUAL DECISION-MAKING

We do not envisage that any automated decision-making or profiling will be
carried out. Profiling means any form of automated processing of personal data
consisting of the use of personal data to evaluate certain personal aspects
relating to a natural person, in particular to analyse or predict aspects
concerning that natural person’s performance at work, economic situation,
health, personal preferences, interests, reliability, behaviour, location or
movements


RIGHT TO OBJECT TO DIRECT MARKETING

You have the right to object to processing for direct marketing purposes. We
will always obtain your prior consent before we carry out any direct marketing.


DATA STORAGE AND DATA SECURITY

 1. We will take appropriate security measures against unlawful or unauthorised
    processing of personal data, and against the accidental loss of, or damage
    to, personal data and shall implement appropriate technical and
    organisational measures to ensure a level of security appropriate to the
    risk. Any payment transactions will be encrypted. Where we have given you
    (or where you have chosen) a password which enables you to access our
    services or certain parts of our website, you are responsible for keeping
    this password confidential. We ask you not to share a password with anyone.
 2. We will put in place procedures and policies to maintain the security of all
    personal data from the point of collection to the point of destruction.
    Personal data will only be transferred to a third party to process that
    personal data on our behalf if that third party agrees to comply with those
    procedures and policies, or if that third party puts in place adequate
    security measures. By default only personal data which is necessary for each
    specific purpose of the processing shall be processed.
 3. All information you provide to us is stored on our secure servers or with
    trusted third parties. Some of these third parties are based outside the
    European Economic Area (the “EEA“).  If we do transfer your information
    outside the EEA we will take appropriate steps to protect that information
    which include one of the following: (i) transferring to third parties in
    jurisdictions that the EU Commission has determined offers adequate
    protection for your information’ (and information relating to Adequacy
    Decisions made by the European Commission are available; (ii) entering into
    an agreement with the third party, which includes clauses that the EU
    Commission has determined offers adequate protection for your information;
    or (iii) transferring to third parties that have agreed to comply with
    schemes approved by the European Commission to protect your information.
 4. Unfortunately, the transmission of information via the internet is not
    completely secure. Although we will do our best to protect your personal
    data, as described in this policy, we cannot guarantee the security of your
    data transmitted to our website; any transmission is at your own risk.


RETENTION OF RECORDS

We shall only hold your personal data in our records for as long as is required
to provide our services to you. Unless we have notice from you that you wish us
to terminate our services to you, we shall erase all of our records of your
personal data within twenty four months from the last ascertainable point that
you accessed our services.


RIGHT TO COMPLAIN TO THE SUPERVISORY AUTHORITY

You have the right to lodge a complaint about the way your personal data has
been processed with the Information Commissioner’s Office at any time.


DISCLOSURE AND SHARING OF PERSONAL INFORMATION

 1. We may share personal data we hold with any member of our group, which means
    our subsidiaries, our ultimate holding company and its subsidiaries, as
    defined in section 1159 of the UK Companies Act 2006.
 2. We may also disclose personal data we hold to third parties in circumstances
    such as the following:

a. In the event that we sell or buy any business or assets, in which case we may
disclose personal data we hold to the prospective seller or buyer of such
business or assets

b. If we sell all of our assets or substantially all of our assets are acquired
by a third party, in which case personal data we hold will be one of the
transferred assets

c. To provide to business partners, suppliers and sub-contractors for the
performance of any contract we enter into with you. Any of these third parties
will be required to provide you with a notice that they are processing your
personal data if they do so

d. Where you have provided consent for us to do so, to analytics and search
engine providers that assist us in the improvement and optimisation of our
website

e. Where you have provided consent for us to do so, to credit reference agencies
for the purpose of assessing your credit score where this is a condition of us
entering into a contract with you and

f. If we are under a duty to disclose or share your personal data in order to
comply with any legal obligation, or in order to enforce or apply any contract
with you or other agreements; or to protect our rights, property, or safety of
our employees, customers, or others. This includes exchanging information with
other companies and organisations for the purposes of fraud protection and
credit risk reduction.


NOTIFICATION OF A PERSONAL DATA BREACH

 1. We shall, without undue delay, and where feasible, not later than 72 hours
    after having become aware of a personal data breach, notify the personal
    data breach to the Information Commissioner’s Office, unless the personal
    data breach is unlikely to result in a risk to your rights and freedoms.
 2. Where the personal data breach is likely to result in a high risk to your
    rights and freedoms we shall communicate the personal data breach to you
    without delay.


CONTACT

Questions, comments and requests regarding this policy are welcomed and should
be addressed to data@wifinity.co.uk.


OTHER WEBSITES

Our website may have links to other websites. This policy only applies to this
website and not those of other websites. You should, therefore, read the privacy
policies of the other websites when you are using those websites.


CHANGES TO THIS POLICY

We reserve the right to change this policy at any time. Where appropriate, we
will provide you with notice of those changes by post or email


TRUSTED BY…




AWARD-WINNING WIFI.


AWARD-WINNING WIFI.

2018 ISPAS WINNER

Best Project or Partnership. For our fantastic Good Connections programme.

2019 MEGABUYTE EMERGING STARS WINNER

Best Performing Company. For incredible sales performance and growth.

1000 COMPANIES TO INSPIRE BRITAIN

2018 London Stock Exchange shortlist.

SURREY SUPER GROWTH AWARDS

2019 Finalist. For our outstanding sales growth.

2018 ISPAS WINNER

Best Project or Partnership. For our fantastic Good Connections programme.

2019 MEGABUYTE EMERGING STARS WINNER

Best Performing Company. For incredible sales performance and growth.

1000 COMPANIES TO INSPIRE BRITAIN

2018 London Stock Exchange shortlist.

SURREY SUPER GROWTH AWARDS

2019 Finalist. For our outstanding sales growth.





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SUPPORT

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Note: This profile prompts automatically to screen-readers.
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Accessibility StatementCompliance status

We firmly believe that the internet should be available and accessible to anyone
and are committed to providing a website that is accessible to the broadest
possible audience, regardless of ability.

To fulfill this, we aim to adhere as strictly as possible to the World Wide Web
Consortium’s (W3C) Web Content Accessibility Guidelines 2.1 (WCAG 2.1) at the AA
level. These guidelines explain how to make web content accessible to people
with a wide array of disabilities. Complying with those guidelines helps us
ensure that the website is accessible to blind people, people with motor
impairments, visual impairment, cognitive disabilities, and more.

This website utilizes various technologies that are meant to make it as
accessible as possible at all times. We utilize an accessibility interface that
allows persons with specific disabilities to adjust the website’s UI (user
interface) and design it to their personal needs.

Additionally, the website utilizes an AI-based application that runs in the
background and optimizes its accessibility level constantly. This application
remediates the website’s HTML, adapts its functionality and behavior for
screen-readers used by blind users, and for keyboard functions used by
individuals with motor impairments.

If you wish to contact the website’s owner please use the website's form

Screen-reader and keyboard navigation

Our website implements the ARIA attributes (Accessible Rich Internet
Applications) technique, alongside various behavioral changes, to ensure blind
users visiting with screen-readers can read, comprehend, and enjoy the website’s
functions. As soon as a user with a screen-reader enters your site, they
immediately receive a prompt to enter the Screen-Reader Profile so they can
browse and operate your site effectively. Here’s how our website covers some of
the most important screen-reader requirements:

 1. Screen-reader optimization: we run a process that learns the website’s
    components from top to bottom, to ensure ongoing compliance even when
    updating the website. In this process, we provide screen-readers with
    meaningful data using the ARIA set of attributes. For example, we provide
    accurate form labels; descriptions for actionable icons (social media icons,
    search icons, cart icons, etc.); validation guidance for form inputs;
    element roles such as buttons, menus, modal dialogues (popups), and others. 
    
    Additionally, the background process scans all of the website’s images. It
    provides an accurate and meaningful image-object-recognition-based
    description as an ALT (alternate text) tag for images that are not
    described. It will also extract texts embedded within the image using an OCR
    (optical character recognition) technology. To turn on screen-reader
    adjustments at any time, users need only to press the Alt+1 keyboard
    combination. Screen-reader users also get automatic announcements to turn
    the Screen-reader mode on as soon as they enter the website.
    
    These adjustments are compatible with popular screen readers such as JAWS,
    NVDA, VoiceOver, and TalkBack.
    
    
 2. Keyboard navigation optimization: The background process also adjusts the
    website’s HTML and adds various behaviors using JavaScript code to make the
    website operable by the keyboard. This includes the ability to navigate the
    website using the Tab and Shift+Tab keys, operate dropdowns with the arrow
    keys, close them with Esc, trigger buttons and links using the Enter key,
    navigate between radio and checkbox elements using the arrow keys, and fill
    them in with the Spacebar or Enter key.
    
    Additionally, keyboard users will find content-skip menus available at any
    time by clicking Alt+2, or as the first element of the site while navigating
    with the keyboard. The background process also handles triggered popups by
    moving the keyboard focus towards them as soon as they appear, not allowing
    the focus to drift outside.
    
    Users can also use shortcuts such as “M” (menus), “H” (headings), “F”
    (forms), “B” (buttons), and “G” (graphics) to jump to specific elements.

Disability profiles supported on our website
 * Epilepsy Safe Profile: this profile enables people with epilepsy to safely
   use the website by eliminating the risk of seizures resulting from flashing
   or blinking animations and risky color combinations.
 * Vision Impaired Profile: this profile adjusts the website so that it is
   accessible to the majority of visual impairments such as Degrading Eyesight,
   Tunnel Vision, Cataract, Glaucoma, and others.
 * Cognitive Disability Profile: this profile provides various assistive
   features to help users with cognitive disabilities such as Autism, Dyslexia,
   CVA, and others, to focus on the essential elements more easily.
 * ADHD Friendly Profile: this profile significantly reduces distractions and
   noise to help people with ADHD, and Neurodevelopmental disorders browse,
   read, and focus on the essential elements more easily.
 * Blind Users Profile (Screen-readers): this profile adjusts the website to be
   compatible with screen-readers such as JAWS, NVDA, VoiceOver, and TalkBack. A
   screen-reader is installed on the blind user’s computer, and this site is
   compatible with it.
 * Keyboard Navigation Profile (Motor-Impaired): this profile enables
   motor-impaired persons to operate the website using the keyboard Tab,
   Shift+Tab, and the Enter keys. Users can also use shortcuts such as “M”
   (menus), “H” (headings), “F” (forms), “B” (buttons), and “G” (graphics) to
   jump to specific elements.

Additional UI, design, and readability adjustments
 1. Font adjustments – users can increase and decrease its size, change its
    family (type), adjust the spacing, alignment, line height, and more.
 2. Color adjustments – users can select various color contrast profiles such as
    light, dark, inverted, and monochrome. Additionally, users can swap color
    schemes of titles, texts, and backgrounds with over seven different coloring
    options.
 3. Animations – epileptic users can stop all running animations with the click
    of a button. Animations controlled by the interface include videos, GIFs,
    and CSS flashing transitions.
 4. Content highlighting – users can choose to emphasize essential elements such
    as links and titles. They can also choose to highlight focused or hovered
    elements only.
 5. Audio muting – users with hearing devices may experience headaches or other
    issues due to automatic audio playing. This option lets users mute the
    entire website instantly.
 6. Cognitive disorders – we utilize a search engine linked to Wikipedia and
    Wiktionary, allowing people with cognitive disorders to decipher meanings of
    phrases, initials, slang, and others.
 7. Additional functions – we allow users to change cursor color and size, use a
    printing mode, enable a virtual keyboard, and many other functions.

Assistive technology and browser compatibility

We aim to support as many browsers and assistive technologies as possible, so
our users can choose the best fitting tools for them, with as few limitations as
possible. Therefore, we have worked very hard to be able to support all major
systems that comprise over 95% of the user market share, including Google
Chrome, Mozilla Firefox, Apple Safari, Opera and Microsoft Edge, JAWS, and NVDA
(screen readers), both for Windows and MAC users.

Notes, comments, and feedback

Despite our very best efforts to allow anybody to adjust the website to their
needs, there may still be pages or sections that are not fully accessible, are
in the process of becoming accessible, or are lacking an adequate technological
solution to make them accessible. Still, we are continually improving our
accessibility, adding, updating, improving its options and features, and
developing and adopting new technologies. All this is meant to reach the optimal
level of accessibility following technological advancements. If you wish to
contact the website’s owner, please use the website's form

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