General Information

This privacy notice is meant to help you understand what data we collect, why it is collected and what we do with it.

To make this easier to understand, we've added the following quick links, to help you find out the reasons why we process your personal data and to see what we do with it.
 

Introduction

Hillsnet Wireless Limited understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Sites or uses Our Services, and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

The new GDPR legislation that came into force on 25 May 2018 replaced current data privacy law, giving more rights to you as an individual and more obligations to organizations like ours that hold your personal data.

One of the most important rights is a right to be informed about the way in which we use, share and store your personal information. Our privacy notice has been updated, so you can access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Within this policy we’ll tell you:

• why we are able to process your information

• what purpose we are processing it for

• whether you have to provide it to us

• how long we store it for

• whether there are other recipients of your personal information

• whether we intend to transfer it to another country, and

• whether we do automated decision-making or profiling.

The first part of the notice is information we need to tell everybody, so please read this Privacy Policy carefully and ensure that you understand it.

Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site or Services and You will be required to read and accept this Privacy Notice when signing up for an Account. If you do not accept and agree with this Privacy Notice, you must stop using Our Site or Services immediately.

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Hillsnet Wireless as a Data Controller - Our Details

Unless otherwise stated, the controller for the personal information we process is Hillsnet Wireless Limited , a limited company registered in England and Wales under Company No: 494 8173. Our VAT number is GB 860 6694 96.

Our registered address and main trading address is:

 

Hillsnet Wireless Limited

Kemp House, 

124 City Road, 

London 

EC1V 2NX

 

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Data Protection Officers Details

Although Hillsnet Wireless Limited  are not required to formally appoint a Data Protection Officer, our Chief Compliance Officer, (CCO) voluntarily takes on this role for Hillsnet Wireless .

You can contact the CCO by emailing <email> or via the postal address above. Please mark the envelope ‘Data Protection Officer’.

You can find more information about the role of the DPO on the Information Commissioners Office (ICO) website.

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Hillsnet Wireless as a Data Processor

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Hillsnet Wireless are a Business-to-Business organisation. Because of the type of services we provide, we also process personal information on behalf of our Customers, typically venue operators or Partners who are offering WiFi services to their own end Customers.

In this capacity we are the Data Processor, and the Data Controller will be Our Customer. We have no control over the Privacy policies or Notices for our Customers. When you use a Customers WiFi you will be presented with their own terms and conditions of use and a Privacy Notice, which will be different to our own when we are the Data Controller.

Any Subject Access Requests (SAR) or enquiries regarding your rights must be directed to the Data Controller.

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Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Hillsnet Wireless sites and Services.

It does not extend to any websites or services that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

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Your Data Protection Rights

• Under the recent GDPR requirements, you have rights as an individual which you can exercise in relation to the information we hold about you. The rights available to you depend on our reason for processing your information.

• Under GDPR you have:

• The right to be informed

• You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.

• The right of access

• You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.

• The right to rectification

• You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

• The right to erasure

• You have the right to ask us to erase your personal information in certain circumstances

• The right to restrict processing

• You have the right to ask us to restrict the processing of your information in certain circumstances.

• The right to data portability

• You have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests.

• The right to object to processing

• This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

• Rights in relation to automated decision making and profiling.

• You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning or affecting you.

General Considerations

If we are processing your information for criminal law enforcement purposes, your rights are slightly different. Please see the relevant section of the notice.

You are not required to pay any charge for exercising your rights. We have one month to respond to you.

Please contact us at support@Hillsnet Wireless .com if you wish to make a request, 

More information about an individuals rights can be found on the ICO website.

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How Do We Get Information?

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• You are representing your organisation.

• You have made an information request to us.

• You wish to attend, or have attended, an event.

• You subscribe to our e-newsletter.

• You have made a complaint or enquiry to us.

• You have applied for a job or secondment with us.

We also receive personal information indirectly, in the following scenarios:

• Your Organisation has provided us with your details in order to provide you with access to our Products and Services or in relation to an opportunity or project

• You have used the WiFi services at one of our Customers or Partners venues (where we act as a Data Processor on their behalf)

• We have contacted an organisation about a complaint you have made and it gives us your personal information in its response.

• A complainant refers to you in their complaint correspondence.

• We have requested personal information as part of an investigation.

• From law enforcement bodies.

• An employee of ours gives your contact details as an emergency contact or a referee.

If it is not disproportionate or prejudicial, we’ll contact you to let you know we are processing your personal information.

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How We Use Your Information

This privacy notice tells you what to expect when Hillsnet Wireless Limited  (Hillsnet Wireless ) collects and processes personal information. It applies to information we collect about:

• Visitors to our websites;

• People who subscribe to our newsletter or request a publication from us;

• People who complete surveys or questionnaires on the Hillsnet Wirelessblog;

• People who contact us via social media;

• People who call our helplines;

• People who email us;

• People Who Make a Complaint to Us;

• People who use our products and services;

• People who visit Our Offices;

• Job applicants and our current and former employees

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Visitors to our websites

We use a third-party service, WPEngine.com, to publish our website, blog, and some of our affiliated microsites. These sites are hosted at wpengine.com, which is run by WPEngine, Inc. We use a standard WordPress service to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. WordPress requires visitors that want to post a comment to enter a name and email address.

When someone visits hillsnetwireless.uk or one of our affiliated sites we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

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Links to Other Websites

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This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

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Use of Cookies by Hillsnet Wireless 

The Services may also require us to use cookies. A cookie is a text file, invoked by standard browser software, that we place on your hard drive to enable our systems to, among other things, recognize your browser, track transactions, and allow you to navigate the Service without having to re-enter information. The information gathered by cookies is not made available to organisations. We may also automatically receive and store certain other types of information, such as the type of web browser you use or the pages you browse to for statistical analysis and support purposes.

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Security and Performance

Hillsnet Wireless uses a third-party service to help maintain the security and performance of Hillsnet Wireless website. To deliver this service it processes the IP addresses of visitors to Hillsnet Wireless website.

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Purpose & Legal Basis

The purpose for implementing all of the above is to maintain and monitor the performance of our website and to constantly look to improve the site and the services it offers to our users.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

 

 

Your Rights

Although we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes.

 

 

Purpose & Legal Basis

Our purpose for collecting the information is so we can provide you with a service that you requested and let you know about related upcoming events, or products and services changes.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

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Your Rights

Although we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes.

 

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

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People Who Contact Us Via Social Media Channels

We use third-party providers, such as Facebook, Twitter, Google and LinkedIn to deliver our social media interactions. If you send us a private or direct message via social media the message will be stored in line with the Social Media platforms own Privacy and Data Retention Policies.it is important to understand that Hillsnet Wireless do not have any control over those policies and you are encouraged to review those independently prior to any communication.

Any private or direct messages will not be shared with any other organisations.

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Purpose & Legal Basis

Our purpose for processing the information is so that we can communicate with you and respond to requests for information regarding our products and services or to provide support.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

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Your Rights

Although we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes.

 

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

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People Who Email Us

We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with best-practice recommendations. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

We use DKIM (Domain Keys Identified Mail) signatures as an authentication process that can help protect both senders and recipients from forged and phishing emails.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

 

Purpose & Legal Basis

Our purpose for processing the information is so that we can communicate with you and respond to requests for information regarding our products and services or to provide support.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

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Your Rights

Although we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes.

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People Who Make a Complaint to Us

When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

When we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually we do not, identify any complainants unless the details have already been made public.

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Purpose & Legal Basis

Our purpose for processing the information is so that we can investigate your complaint and check on our level of service.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

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Your Rights

We are acting in our official capacity to investigate your complaint, so you have the right to object to our processing of your personal data. There are legitimate reasons why we may refuse your objection, which depends on why we are processing it.

 

People who use Hillsnet Wireless Products & Services

Hillsnet Wireless offers a variety of WiFi connectivity services to Our Customers, who then use our platforms to offer their customers and the public guest internet access services. As such, the majority of data we hold on individuals will only be as a requirement to process data on behalf of the Data Controller, which is typically Our Customer, the venue operator.

We hold the names and contact details of individuals acting in their capacity as representatives of their organisations, across the business.

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Hillsnet WirelessCustomers & Their Representatives

Where technically possible, if you are a representative of Our Customer and/or The Data Controller and accessing the administrative portal for our product or service, you will be presented with a Platform Specific set of Terms and Conditions of Use and Privacy Notice.

In the event of any conflict or inconsistency between this Notice and the platform-specific Notice, the terms of this Notice  shall prevail.

Our Customers Clients

If you are a member of the public who has accessed a Guest WiFi service operated by one of Our Customers or Partners

 

Purpose & Legal Basis

We have to hold and process the details of the people who have requested the service in order to provide it, and for the purposes of meeting country-specific legislative and regulatory compliance. However, we only use these details to provide the service the person has requested and for other closely related purposes.

Where the data or interactions relate to suppliers, contracts, buildings management, IT services etc., the legal basis is article 6(1)(b) of the GDPR, which allows us to process personal data when its necessary for the performance of a contract, unless there is a country-specific legislative or regulatory compliance requirement, which would take precedence, and as such the legal basis we rely on to process your personal data is article 6(1)(c) of the GDPR.

Where the data does not relate to the above, the legal basis is article 6(1)(f) because the processing is within our legitimate interests as a business.

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Your Rights

Where we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes, or we will provide contact details for the relevant Data Controller, where we are the Data Processor.

If the processing is carried out to comply with legislative or regulatory compliance requirements, or where processing is necessary for the performance of a contract, then your rights may vary from the above. Please contact us, if you have any query and we will provide clarification on a case by case basis, where necessary.

 

Complaints or Queries

Hillsnet Wireless tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Hillsnet Wireless s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the info@hillsnetwireless.uk

 

 

Disclosure of Personal Information to Law Enforcement Agencies

In many circumstances we will not disclose personal data without consent. However when we investigate a complaint or respond to a law enforcement agency, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. Where allowed, we will inform you of the factors we shall consider when deciding whether information should be disclosed.

We may disclose your personal information when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating our T&Cs or to protect the safety, property or other rights of our users or the public.

We also may disclose your personal information if we believe in good faith that we are required to do so in order to comply with applicable law or other legal process. We will only disclose this data when requested from a Law Enforcement Agency, and will do so responsibly, protecting the confidentiality, integrity and availability of that data during this process.

 

 

Purpose & Legal Basis

Our purpose is to investigate alleged criminal offences, and to bring legal action against the individual where required, to protect the safety and rights of other users or the public, and to comply with relevant laws such as but not limited to the Regulation of Investigatory Powers Act 2000 (RIPA).

We rely on Schedule 8 1(a)and (b) of the Data Protection Act 2018 to process your personal data. This relates to processing ‘necessary for the exercise of a function conferred on a person by an enactment or rule of law, and is necessary for reasons of substantial public interest’.

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Your Rights

Disclosure in this instance does not require your consent.

 

Data Transfer

As part of operating the website and providing the Services, we may transfer personal data to a third country where this is legally permissible, and we have appropriate adequacy conditions in place, such the EU-US Privacy Shield (or equivalent), approved ‘Model Contract’ clauses, Binding Corporate Rules and contractual confidentiality agreements.

If your personal information is transferred to a server located outside of the country in which you access the website or use Our Services, we operate technical and organisational controls to ensure that you’re the confidentiality, integrity and availability of your data is maintained, through an internationally recognised certification mechanism (ISO/ICE 27001).

 

Data Retention

As part of operating the website and providing the Services, we may transfer personal data to a third country where this is legally permissible, and we have appropriate adequacy conditions in place, such the EU-US Privacy Shield (or equivalent), approved ‘Model Contract’ clauses, Binding Corporate Rules and contractual confidentiality agreements.

If your personal information is transferred to a server located outside of the country in which you access the website or use Our Services, we operate technical and organisational controls to ensure that you’re the confidentiality, integrity and availability of your data is maintained, through an internationally recognised certification mechanism (ISO/ICE 27001).

Changes to this Privacy Notice

We keep our privacy notice under regular review. This privacy notice was last updated on 30 Dec 2024

 

How to Contact Us

If you want to request information about our privacy notice, you can email us at support@hillsnetwireless.uk or write to:

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The Data Protection Officer

Hillsnet Wireless Limited 

Kemp House, 124 City Road, 

London 

EC1V 2NX

 

Definitions and Interpretation

In these Terms and Conditions, unless the context otherwise requires, the following expressions have the following meanings:

• “Account” means an account required to access and/or use certain areas and features of Our Site or Services;

• “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;

• “Our Site” means this website, hillsnetwireless and any other website or web-based service operated by Hillsnet Wireless ;

• "Our Products and Services" means and product or service provided by Hillsnet Wireless either directly, or via an approved Hillsnet Wireless Partner or contracted Customer of Hillsnet Wireless 

• “UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and

• “We/Us/Our” means Hillsnet Wireless Limited , a company registered in England and Wales under Company No: 12326313, whose registered address is Kemp House, 124 City Road, London EC1V 2NX, United Kingdom.