InLinkUK Privacy Notice

Last Updated: 26th May 2018

InLink Limited is committed to protecting and respecting your privacy. This privacy notice ('Privacy Notice') describes who we are, what data we collect, how we collect that data, and what we do with it. Click 'find out more', where available, to view further details about our activities.

Who we are

InLink Limited ("InLinkUK", "we", "us", and "our") is a company incorporated in England with our registered office at Met Building, 22 Percy Street, London, England, W1T 2BU and company number 09977808. Details of how to contact us can be found below in the 'Contacts' section of this Privacy Notice.

Introduction

We collect, use and share information about you through your use of our public communications structures ("InLinks"), which include tablets for public use, the use of wireless internet networks and the use of other services and facilities made available to you via the InLinks (together with the InLinks, the "Services").

The Services are provided by InLinkUK, with BT plc ("BT") as the operator of various services, including the Wi-Fi registration pages, support services and internet access. BT processes any personal data it collects or receives in the course of providing these services on our behalf. InLinkUK is not an agency, office, department or affiliate of BT.

Please read this Privacy Notice carefully to understand how we will treat your personal data. We draw your attention in particular to the sections entitled "International Data Transfer" and "Your Rights". We reserve the right to modify this Privacy Notice at any time, so we encourage you to review it frequently. The "Last Updated" legend above indicates when this Privacy Notice was last changed. If we make any material change(s) to this Privacy Notice, we will notify registered Wi-Fi users via email (provided that you have given us an up to date email address) prior to such changes(s) taking effect.

Please click on the sections below to learn more about our Privacy Notice:

INFORMATION WE MAY COLLECT ABOUT YOU

We may collect, use, store and transfer certain personal data of yours such as identity data, contact data, data used to facilitate your use of the Services and technical data each as described in more detail below. We may anonymise your personal data so that you are no longer identifiable and use that anonymised information as described below. In addition, where we are required to do so in order to fulfil obligations imposed by law, we will log the website(s) you visit and your IP address when using our Services.

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Identity Data

This includes your first name, last name, user name or similar identifier and title.

Contact Data

This includes email address, telephone numbers, social media identifiers and any other contact information that you provide to us in the course of your access to and use of the Services.

Services Data

This includes information used to facilitate your access to, and use and receipt of, the Services, such as URL requests, destination internet protocol ("IP") addresses, other information necessary to provide access to the Services, and other personal data you submit to us in the course of using, accessing or receiving the Services (for example through the completion of forms and survey responses, and by providing us with feedback).

Technical Data

This includes MAC address, IP address, time zone settings, browser plug-in types and versions, operating system and platform, device type, screen resolution, manufacturer and model, the amount of data your device uses when accessing and using the Services, device identifiers, and information about the date and time of your Wi-Fi connection, the duration of your Wi-Fi connection and the location of the InLink providing your Wi-Fi connection.

Anonymised Information

We may combine Services Data and Technical Data and non-personal data about your use of the Services with similar information about other users in an anonymised manner. When we use the term "anonymised", we are referring to data and information that may be derived from your personal data, but which cannot directly or indirectly reveal your identity and so is not considered personal data in law.

Other Collection of Information

InLinkUK will not ask for or request sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background). Nor will we ask for any National Insurance Number or credit card number. Please do not provide this information to us through the Services, emails, feedback forms or in any other way. If you do send or disclose sensitive personal data to us when you submit user generated content to our Services, or to our support services, we will treat this as you consenting to us processing that sensitive personal data for the purposes for which it has been sent or disclosed.

HOW WE COLLECT YOUR PERSONAL DATA

We collect personal data from and about you using different methods including:

HOW YOUR PERSONAL DATA MAY BE USED

We will only process your personal data in accordance with applicable data protection and privacy laws.

Most commonly, we will use your personal data for the following purposes:

In order to use your personal data, we must have a legal basis for doing so. The legal bases that we rely upon are explained further in the "find out more" section below and in summary are:

Generally we do not rely on consent as a legal basis for processing your personal data except where we would like to post your feedback on an attributed basis or to deliver content to you that you have requested.

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The purposes for which we use personal data about you, and which of the legal bases we rely on to do so, are:

Purpose Legal basis for processing
Management of your access to and use of the Services Performance of a contract with you
Responding to your comments and questions and to provide customer service a) Performance of a contract with you

b) Legitimate business interests (to improve customer service)
Operating, maintaining and improving the Services, including for administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes Legitimate business interests (to study how customers use our products and services, to develop them, to grow our business and to improve our Services)
Sending you information about the Services, such as updates to our terms of use, this privacy notice and updates on features of the Services a) Performance of a contract with you

b) Legitimate business interests (to study how customers use our products and services, to develop them, to grow our business and improve our Services)
Maintaining the security of the Services Necessary to comply with a legal obligation
Compliance with laws and regulations, lawful requests and legal process, including responding to requests from public and government authorities, and to protect our rights, privacy, safety or property, and/or that of you or others, as we believe necessary a) Necessary to comply with a legal obligation

b) Legitimate business interests (to protect our rights and those of others)
Understanding how the Services are being used including usage patterns and trends Legitimate business interests (to study how customers use our products and services, to develop them, to grow our business and to improve our Services)
Communicate the views of our users - we may post your first and last name along with your feedback on our Services If you have provided your consent to do so
Deliver content that you have requested, plus any information needed to benefit from this content, to your device following an interaction with the tablet on the InLink If you have provided your consent to do so

We may use aggregated and/or anonymised data and information to:

HOW WE SHARE YOUR PERSONAL DATA

We will not sell your personal data and we will not share your personal data with any third party for that third party's own use, except as provided in this Privacy Notice.

Personal data

We may share your personal data with:

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We may share your personal data with third parties who provide us or you with products or services, such as:

Further details of our third party service providers, subcontractors and agents can be found here.

We may share your personal data with third parties as we believe necessary or appropriate to comply with laws and regulations, lawful requests and legal process, including to respond to requests from public and government authorities, and to protect our rights, privacy, safety or property, and/or that of you or others.

Anonymised Information

We may share anonymised information with third parties in order to operate, maintain and improve the Services, to develop new services, to report on the usage of the Services, and to select and serve relevant advertisements and offers to the InLinks

INTERNATIONAL DATA TRANSFER

Your information, including any personal data, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside and outside the EU, to countries where data protection and privacy regulations may not offer the same level of protection as in the EU. For example, we may transfer your personal data to our affiliates in the United States, and to our third party service providers that are based outside the EU (such as Partner Hero, who have staff in Honduras). Where we transfer your personal data outside the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

If you send or disclose any personal data to our support services, you acknowledge and accept that your personal data may be transferred outside the European Union. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Notice.

COOKIES

To understand more about the kind of cookies we use and how you can disable cookies please visit our Cookie Policy page.

YOUR RIGHTS AND HOW TO MAKE A COMPLAINT

Data protection laws give you the following rights over the way in which your personal data is stored and used by companies:

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If you are in the European Union, you will have the following rights in relation to your personal data:

Your right Detail of this right
To request that we give you access to your personal data This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
To request that we rectify or update your personal data This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
To request that we erase your personal data This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
To request that we restrict our processing of your personal data This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
To object to our processing of your personal data This applies where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
To portability of your personal data We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
To withdraw consent at any time This right applies where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

If you would like to exercise any of the above legal rights, please contact us using the details in the "Contact" section below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce.

For your protection, we may ask you for additional information or documentation in order verify your identity before implementing your request. We will try to respond to your requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will inform you and keep you updated.

If you are unhappy with how your personal data has been used, you have the right to lodge a complaint with a data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

SECURING YOUR PERSONAL DATA

The security of your personal data is important to us. We encrypt personal data we store about you. We also encrypt Wi-Fi connections for compatible devices. To determine whether your device is compatible, please visit here.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will try to protect your information, we cannot guarantee against access to your personal data by unauthorised third parties. The security of your data transmitted via the internet is at your own risk. Once we have received your information, we will use appropriate and necessary administrative, technical and physical controls to assist us in protecting your information.

If an unauthorised person gains access to your information we will notify you as soon as feasible at the last email address you have provided to us unless we determine that no harm is reasonably likely to occur from the unauthorised disclosure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the "Contact" section below.

KEEPING YOUR PERSONAL DATA

We will only retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law (for example for regulatory purposes). If you do not use the InLinkUK Wi-Fi services for six months, we will de-register you from our Services, and will delete any personal data that you submitted as part of the registration process. In addition, you have certain rights to ask us to delete or remove personal data as described in the "Your Rights" section above.

OTHER SERVICES

USB Ports

The InLinks may include one or more USB ports. Our USB ports provide electricity to charge your devices and cannot collect any information from your device.

Phone calls

BT provides phone calling capability from the InLinks and is responsible for all of the data that may be collected or processed in the course of making a phone call. InLinkUK does not have access to personal data collected or processed during phone calls except where calls are made to our support teams.

Smart City Sensors

The InLinks have a modular design that is intended to allow us to collect meaningful insights for the community. As such we may enhance the InLink with sensors which are used to collect useful, real-time environmental information such as information relating to air and noise pollution, outdoor temperature, pedestrian volumes and traffic conditions. These sensors only collect anonymised information and do not collect any personal data.

Cameras

The InLinks contain two cameras above the ad displays as well as one built into the tablet. All three cameras are turned off, and will not be activated without express notice to the public.

BT Wi-Fi and other wireless networks provided via the InLink

Please note that use of the BT or other third party Wi-Fi services provided via the InLinks is governed by the BT Wi-Fi or other provider terms of use and privacy notice.

CHILDREN

If you are under 16 years of age, you are not permitted to submit any personal data to InLinkUK without first obtaining the permission of a parent or guardian. If a parent or guardian becomes aware that his or her child below the age of 16 has provided us with information without their permission, he or she should contact us using the details in the "Contact" section below, including supporting information to enable us to confirm their relationship to the child. In these circumstances, we will delete such information from our files as soon as reasonably practicable.

CONTACT

Should you wish to contact us in order to exercise any of your rights referred to above, or in relation to any other aspect of this Privacy Notice, please write to us at The Privacy Officer, InLinkUK, Met Building, 22 Percy Street, London, England, W1T 2BU or email us at privacy_officer@inlinkuk.com

LINKS TO THIRD PARTY SITES

Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. This Privacy Notice does not cover the privacy practices of such third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Certain websites you visit may provide options regarding advertisements you receive. For more information or to opt out of certain online behavioral advertising, please visit http://www.aboutads.info

CHANGES TO THIS PRIVACY NOTICE

We keep our Privacy Notice under regular review. You will always be able to find the latest copy here.

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