GDPR


PRIVACY STATEMENT


Highland Wi-Fi Ltd values your privacy. What role privacy plays in our service, what steps Highland Wi-Fi Ltd has taken to guarantee privacy and what we do to protect your personal data can be found on this page.


OUR PROMISE


  • ​We are careful with your data and you can trust your data to be safe with us and for us to comply with the law 
  • We do not look at the content of your communication. We do not monitor conversations, do not look at the content of your SMS messages, emails or chat messages and do not keep track of which websites you visit
  • We do not sell your data to any other third parties 
  • We inform you about the use of your data and offer you simple possibilities to view and adjust your data and the choice you have made with regard to privacy 
  • ​You determine what happens with your data. We respect the choices you have made regarding your privacy


OPT-OUT


We give everyone the opportunity to opt-out of our services by submitting their MAC address via our online web service along with their Highland Wi-Fi Ltd usernames to confirm identity. After this, your MAC address is no longer able to use our service at any of our locations. If you have time remaining on your account, this would be forfeited with no refund applicable.


SERVICES


Highland Wi-Fi Ltd, a UK public wireless internet service provider, by law, have to take certain customer details before access to our public wi-fi service can be granted.


WHICH PERSONAL DETAILS ARE PROCESSED

Customer details we process include, name, address, postcode, email address, device MAC address. Additionally to provide our service, we ask for customer mobile numbers to enable username, password resets and password reminders. We do not use your mobile phone number for any other reason and your number is never passed to any third parties.

DATA, DATA SUBJECTS, PURPOSES, DESCRIPTION OF DATA PROCESSING, RETENTION PERIOD AND ACCESS 

DATA


The Data Controller will give the Data Processor access to the following Data which the Data Processor may process:

  • ​First name
  • Surname 
  • Email address
  • Post code
  • MAC address of device
  • Language
  • OS/device type
  • Duration, time and frequency of visits


DATA SUBJECTS:


The Data concerns the following categories of data:

  • ​Customer data 
  • Technical data


PURPOSES


Where necessary, the Data may be processed for the following purposes:

  • ​Branded guest access
  • Analytics 
  • Marketing and interaction


DESCRIPTION OF DATA PROCESSING


Performance of the service agreed in the Principal Agreement



RETENTION PERIOD


The Data Processor will retain the Data for a maximum of 6 months unless it is subject to a longer statutory retention period. This does not prejudice the provisions of Article 11.



ACCESS


Only the following groups of persons will have access to the Data:

  • ​Authorised persons employed by the Data Processor, on a need to know basis




ROLE DESCRIPTION OF PRIVACY OFFICER


The privacy officer has the following responsibility : 

  • ​​Provides development guidance and assists in the identification, implementation and maintenance of organisation, information privacy policies and procedures in coordination with the management team of Highland Wi-Fi Ltd.
  • Performs initial and periodic information privacy risk assessments and conducts related ongoing compliance monitoring activities in coordination with the entity’s other compliance and operational assessment functions. 
  • Works with legal counsel and Highland Wi-Fi Ltd management team and key departments to ensure the organisation has and maintains appropriate privacy and confidentiality consent, authorisation forms and information notices and materials reflecting current organisation and legal practices and requirements.
  • Oversees, directs, delivers and ensures delivery of initial and privacy training and orientation to all employees, contractors and other appropriate third parties.
  • Participates in the development, implementation and ongoing compliance monitoring of all trading partner and business associate agreements, to ensure all privacy concerns, requirement and responsibilities are addressed.
  • Works with management team of Highland Wi-Fi Ltd to establish an organisation wide privacy policy. 
  • Reviews all system related information security plans throughout the organisation’s network to ensure alignment between security and privacy practices and acts as a liason to the information systems department.
  • ​Maintains current knowledge of applicable privacy laws and EU directives and monitors advancements in information privacy technologies to ensure organisational adaptation and compliance.