IntroductionThe Site is operated by Boingo Wireless, Inc (Boingo, we, us and our). We are a corporation incorporated under the laws of the state of Delaware, USA. Our corporate headquarters are at 10960 Wilshire Blvd, 23rd Floor, Los Angeles, California, CA 90024, USA.
Collection of Personal InformationYou can access the Site without registering, but we may collect and process the following personal information about you:
• information that is needed in order to create your Boingo account and fulfill our service commitment to you, such as your name, address, phone number, e-mail address and billing information; • in connection with an account sign-in facility, your log-in and password details; • details of any purchase transactions made by you through the Site; • communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site or its content; • information from surveys, promotions and competitions that we may, from time to time, run on the Site for research purposes, if you choose to participate in them; • information collected by certain versions of the software we may provide to you, as further detailed in the “Mobile Application Information” section, below.You are under no obligation to provide the above information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services. We may, from time to time, run referral programs or similar initiatives, such as the “Tell a Friend” program, that invite you to provide us with the contact details of someone who is known to you who may find our products or services to be of interest. By providing us with their details, you confirm that you have their permission to do so and must not provide us with the details of anyone from whom you do not have such permission.
Uses of Your Personal InformationWe treat all personal information that you provide to us as highly confidential. We will use the information you provide to:
• recognize you when you return to the Site; • allow you to navigate the Site more quickly and easily; • store your preferences; • customize elements of the layout and/or content of the pages of the Site for you.Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that. However, you may not be able to take full advantage of the Site if you do so. We use any of the system-related information referred to above, including cookies, to:
• administer the Site and assist in diagnosing technical problems; • identify new and return visitors to the Site; • estimate our audience size and patterns; • carry out research on our users’ demographics; • audit the accessing of resources and downloading of data from the Site; • assist in improving and updating the Site; • assist in improving and developing our products and services.We will also share with our airport partners information on an aggregated and anonymized basis from which all personal information will be removed about your use of the Service, including:
• Number of sessions per unique user; • Number of unique users; • Link between user and session; and • Frequency/total number of sessions for the user.We also record the MAC (Media Access Controller) address from the network card in or used with your computer or other device to enable us to accurately perform our billing functions. Partners also may use their own “cookies.” We do not control the use of our partners’ cookies and expressly disclaim responsibility for information collected through them. Partners may use their own cookies for the delivery/tracking of ads, including sponsored access sessions.
Mobile Application InformationSome versions of the software which we may provide to you to enable you to access and use the Boingo service automatically scan for Wi-Fi access points visible to your mobile device, and attempt to automatically connect to those visible Wi-Fi access points in order to determine whether they are publicly accessible. This functionality may operate even when our software is operating in a “background” mode on your mobile device. Following any connection attempt (whether initiated by you or initiated automatically as described above), this software reports the following information to us: (1) your account username (if you are a paid Boingo member), (2) your mobile device’s MAC address and operating system version, (3) the geographic location (i.e. latitude and longitude of your mobile device at the time of the attempted connection (as reported by your mobile device), (4) the SSID, BSSID and signal strength of the applicable Wi-Fi access point, and (5) a log of any actions that you may take on your mobile device user interface in order to complete a connection to the Wi-Fi access point (e.g., accepting an interstitial terms of service or usage policy). We use this information to improve our services, and to generate a list of publicly accessible Wi-Fi access points which we may make available to our users. When we make this list available, we do not disclose any information which could be used to identify you personally. Any Wi-Fi access point location information that we provide is generated by triangulating and averaging location data from a large number of users. We also use your geographic location in order to determine the correct charges for the location from which you are using the Boingo service, to provide you with information about other Boingo hotspots in that area, and/or to ensure the accuracy of data transmission and improve the overall performance of the Boingo service. When you are using a mobile device which does not provide our software with access to geographic location information, the software will automatically scan for Wi-Fi access points visible to your mobile device, and will report a list of such access points to Boingo. We use this information to triangulate your approximate geographic information, which we then use for the purposes set forth herein. Certain versions of our software may allow you to access our Services without creating a separate Boingo account. When you install and use this type of software for the first time, a unique and random key is generated. This key is then used, each time you access the Boingo service, to communicate between that instance of the software and our central server. The key itself contains no personally identifying data and Boingo uses it for the above purposes only. Boingo does not pair the key with any personal information we hold in relation to you to monitor or track your location, except that we have to pair the key with your billing information, on a per instance basis, solely in order to bill you the correct charges.
• you give us explicit, and specific, prior permission; • the disclosure is required by law or by legal process authorised by a competent court; • we suspect fraud or cyber crime by a customer in which case we may investigate and report any evidence, including personal information, to law enforcement officials and to the courts in the course of seeking legal remedies; • we believe it is necessary to protect the Site or the rights, property or personal safety of any person; and/or • our services are offered in conjunction with the facilities of a business partner with whom you have agreed we may share your information.We may disclose your personal information to any of our affiliates, or to our agents or contractors who assist us in providing the services we offer through the Site, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks, from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions. We will share the following information with our airport operator partners together with a Unique Identifier relating to you (which will typically allow our airport operator partners to identify you):
• Number, length and duration of sessions accessed; • Type of device, browser, operating system used to access the Services; • Language used by you for use of the Services; • Number of times we deny you access for attempting to exceed complimentary use of the Services; and • Length of time on the operator’s website.In instances where we and a partner jointly promote any service, we may provide that partner certain information, such as name and e-mail address, for the sole purpose of allowing us and the partner to evaluate the promotion. In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party. Your personal information will never be sold to any third party. We oppose the emailing of any junk mail, and do not sell customer information to email lists or telemarketers. If any of our partner sites engage in such practices, for any reason, we will immediately investigate, and if appropriate, discontinue services with such parties. If you receive junk email that mentions us or our services, please send details to us firstname.lastname@example.org and we will investigate promptly.