Adentro Wi-Fi Network Privacy Policy

Last Updated: December 1, 2024

Adentro, Inc. (“Adentro”, “we,” “us,” or “our”) operates a Wi-Fi and marketing service and software that facilitates access to our Wi-Fi and marketing service (collectively, the “WiFi Services”). Our customers (“Clients”) use our services to help operate their in-store Wi-Fi networks and to understand and communicate with their customers. This Privacy Policy (“Policy”) describes and governs only our information collection, use, and disclosure practices with respect to your use of the WiFi Services including any software you download or otherwise use to access our services. Without limitation then, it does not apply to (1) information we process as a data processor or service provider on behalf of our Clients; (2) information we process from your access and use of our website, adentro.com; and (3) information practices of our Clients, including their handling of information collected from or about you through the WiFi Services, which are subject to our Client’s own privacy policies.

Before you use or submit any information through or in connection with the WiFi Services, please carefully review this Policy. By registering for or otherwise using any part of the WiFi Services, you acknowledge that Adentro will collect, use, and disclose your information as further outlined in this Policy.

1. Information We Collect

We collect information about you in multiple ways, including when you provide information directly to us, automatically through your use of the WiFi Services, and information from third-party sources, as described below.

1.1 Information You Provide to Us Directly

We may collect information from you directly in various ways, such as when you:

Register for the WiFi Services;
Download or install our software for facilitating access to the WiFi Services;
Fill out a survey or provide us with feedback regarding the WiFi Services;
Request certain features (e.g., newsletters, updates, and other products);
Communicate with us, such as for troubleshooting or support services.

The information you provide us with directly may include account registration information such as your name, email address, and birth month and day.

1.2 Information Collected Automatically

We may collect information about you or your device automatically when you use the WiFi Services.

Device/Usage Information. We may collect certain information automatically when you use the WiFi Services, such as your Internet protocol (IP) address, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, operating system, Internet service provider, and information regarding the location of certain routers through which your device has connected to the WiFi Services.

Location Information. When you access, use, or otherwise connect to the WiFi Services, we may collect location information that is inferred based on your proximity to certain routers through which your device has connected to the Wi-Fi. If you do not want to send such information, you can disable the functionality that allows you to connect to Wi-Fi on your device, not register for the WiFi Services, or if you have previously registered for the WiFi Services, terminate your registration to the WiFi Services.

1.3 Information Collected From Other Parties

We may collect information about you from other parties. These other parties include, but are not limited to, publicly available data sources, data brokers, partners, security and fraud detection services, and other commercially available sources.

2. How We Use the Information We Collect About You

We use your information for the following business purposes:

For the purposes for which you provided the information;
To provide the WiFi Services, including access to functionalities and features;
To manage your account, including verifying your identity;
To analyze use of the WiFi Services;
For marketing purposes;
To contact you with information, surveys, or advertising relevant to you;
For internal research and reporting;
To improve the content and features of the WiFi Services;
To enforce legal terms governing your use of the WiFi Services;
To maintain, improve, or troubleshoot services;
To detect, prevent, and protect against illicit activity and comply with legal obligations.

3. When We Disclose Information We Collect About You

We may disclose your information to other parties under the following circumstances:

Clients: If you register and log onto the WiFi Services at locations, you agree to disclose your information to the relevant Client.
Affiliates: We may disclose information to our affiliates.
Vendors: We may disclose your information to employees, consultants, and vendors for services.
Safety and Protection: Disclosure may occur if necessary to protect Adentro or others.
Legal Requirements: We may disclose information to comply with laws and regulations.

4. Analytics and Tailored Advertising

We may use third-party analytics services and collect information for advertising purposes.

5. Your Privacy Choices and Rights

We offer choices regarding the collection, use, or disclosure of your information. You can unsubscribe from marketing emails and submit requests to deactivate or delete your account.

6. Regional Privacy Disclosures

6.1 Residents of Nevada

Residents of Nevada can opt-out of the sale of certain personal information.

6.2 Residents of California

California residents will receive details on personal information categories and their rights under the California Consumer Privacy Act (CCPA).

Category	Categories of Other Parties to Whom We Disclose	Purposes of Use	Categories of Third Parties to Whom Adentro “Shares” and/or “Sells” Personal Information for Advertising or Analytics
Identifiers and other contact information	Vendors, Advertising networks, Data Brokers, Clients	Provide and manage the WiFi Services	Clients, Data Brokers, Advertising networks
Commercial information	Vendors, Clients	Analyze and improve services	Clients, Data Brokers
Internet or other network activity	Vendors, Clients	Analyze and improve services	Clients
Geolocation information	Vendors, Clients	Analyze and improve services	We do not sell or share
Non-Sensitive Inferences	Vendors, Clients	Analyze and improve services	Clients

7. Children’s Privacy

The WiFi Services are not designed for minors under 18. We will delete personal information for individuals under 18 as required by law.

8. Security

We implement technical, administrative, and physical safeguards for the information we collect.

9. Retention of Information

We store the information for as long as necessary for the purposes outlined above.

10. Consent to Transfer

By using the WiFi Services, you consent to the collection and transfer of your information.

11. Links to Third Party Websites/Applications

The WiFi Services may contain links to other websites. We encourage users to review each site’s privacy policy.

12. Updates to this Privacy Policy

We may change this Policy to reflect changes in our practices or legal requirements.

13. Contact Us

For questions about our privacy practices or to exercise your rights, contact us at:

Adentro, Inc.
1 Letterman Drive
Building C, Suite 3500
San Francisco, CA 94129
privacy@adentro.com
(800) 807-WiFi (9434)