Privacy Policy for Customers ("PPC")

This Privacy Statement was last modified on Nov, 18th, 2018.

You have chosen to log into our free Wi-Fi network service. To have access to it, you shall read and accept our common Privacy Policy. PLEASE READ WITH ATTENTION.

Please note that if you agree to this PPC and become a part of our community, your personal information will be collected from the use of this Free Wi-Fi network Service (hereinafter the "Service"), including from your social media accounts for commercial prospection, marketing operations and for online behavioral advertising (customers profiling) in an effort to elevate your shopping experience. At all time, you may opt out, rectify or request that we delete your personal information by sending us a request at privacy@jogogo.co with the subject heading: "OPT OUT DIRECT MARKETING".

("Merchant") and Jogogo Media Inc. ("Jogogo") (collectively hereinafter "we", "us", "our"), are the exploiting parties of this free service.

We are joint controllers of the personal information we collect from your use of this free Wi-Fi Service ("Service"). We have determined the following purposes and means of processing personal information, which are for the purpose of this PPC any information relating to an identified or identifiable individual ("you") as the customer; who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, cultural or social identity of that individual (collectively hereinafter your "Data").

We have established our respective responsibilities to comply with the obligations set out in the applicable laws and regulations pertaining to the protection of personal information and privacy laws. The main goal of this PPC is to be transparent and to inform you of what Data we collect, why and how we will use such information and under what circumstances we will disclose it. We also want to inform you of your rights and choices we offer regarding the collection, use or disclosure of your Data and how you can exercise those rights.

If you have questions, comments, requests or complaints regarding this PPC or associated practices, please let us know at privacy@jogogo.co.

Service Description

Merchant provides you with the Free Wi-Fi network services and Jogogo offers to Merchant, in conjunction with the Wi-Fi network, a unified mobile commerce solution allowing Merchant to measure, identify and communicate with you in real time ("Jogogo’s Solution"). We collect Data broadcast from your Wi-Fi enabled mobile devices (like your smartphone), or the one that you choose to provide us with. Jogogo’s Solution help Merchant better understand and interact with you when you visit its location to elevate your shopping experience.

What kind of Data We Collect and How We Do It

There are two kinds of Data we collect:

Passive Data collection ("General visit information"): When you are within the proximity of a Merchant location’s Wi-Fi network with a Wi-Fi enabled mobile device, the Wi-Fi access points may detect the presence of your mobile device and your Media Access Control Address ("MAC Address"). This is a number that the mobile device automatically broadcasts if the Wi-Fi feature is turned on to help it connect to Wi-Fi Access points. We refer to this information as "Passive Analytics". Passive Analytics are Information collected as the mobile device moves across different Merchant venues that use Jogogo’s Solution. Note that this information can be collected if your mobile device’s Wi-Fi is enabled – even if your smartphone remains in your pocket or purse during your visit. You can learn more about "strong Wi-Fi access points" and "MAC Addresses" by searching online.

Active Data collection: We also collect "Registration Information" when you "Register" to our Service, such as your name, email address, gender, age or home zip code. Registration for our Service can occur in several ways, for example:

– When you are in the proximity of a Merchant location and connect to its Wi-Fi network, you may be asked to provide Registration Information as part of logging-in to the Wi-Fi network in order to be on the receiving end of an enhanced shopping experience and be able to use the Wi-Fi network to surf the web, access smartphone apps, etc. ("Log-In").

– Merchant may also provide you with other opportunities to provide Registration Information, such as when you Register for a Merchant loyalty program administered by the Merchant.

Note that Registration Information may be collected directly by Jogogo or directly by the Merchant and then disclose to one another.

Registration Information may also include information coming from third parties. If you Log-In to our free Wi-Fi network via a third-party social media platform Login (such as Facebook, LinkedIn, Instagram, etc.), we may access the information made available by the third-party service’s request for authorization, such as your name, email address, gender, age, and home postal code. Please review your privacy settings with these third-party services to ensure you are only sharing the information you wish to share. Please review these tips to protect your personal information on line: https://www.priv.gc.ca/fr/sujets-lies-a-la-protection-de-la-vie-privee/technologie-et-vie-privee/protection-de-la-vie-privee-en-ligne/. After you Register with our Service, we may also collect information from your mobile device about IP Address, location-related data, device and/or browser type and the mobile devices operating system ("Activity Information").

Note regarding Collection across Merchants, Locations and Time:

When you Register with one of our Partners (Merchants that are Jogogo’s partners ("Partner(s)") for our Services, you also Registered with us and you agree to share your Data with each of us. Until you opt out of our Service as explained in the "How You Can Opt Out, Access and Correct Your Information" section below, you remain Registered with our Service – so we shall continue to collect information as described herein. Please note that your Data is not cross-referenced or shared amongst our Partners. However, as our Services are used across different Merchants, we may collect information through all of them when you change location or venue. For example, if you visit a department store today that is a Jogogo’s Partner and Log-In to their Wi-Fi network – we may collect information from you when you are Logged-In to the Wi-Fi network at a Merchant’s Location concert venue you visit a week later. As noted above, even though you are not asked to Log-In or submit a new Registration Information at a new Merchant location – you will still be Registered with Jogogo’s services. Please note that should you decide to 'opt out' of one of our Partner's list, your opt out will be effective through Jogogo and across the board (for every Merchants).

Why, how we use and share the General Visit Information, Registration Information and Activity Information ("Data") is set forth below.

For what purposes we collect and use your Data?

Passive analytics are used to help us better understand general trends. We do this by generating and studying reports and other analytics products generated from such data. We combine your Passive Data with that of multitudes of people. We use the reports and other analytics products for a variety of purposes, such as:

Also, please note, once you are Registered with our service your Passive Data is combined with your Registration Information and Activity Information – which may be disclosed used for advertising as set forth in the section below.

When you Register with Jogogo’s Services, we combine Registration Information and Activity Information with Passive Analytics from your mobile device that may date back to May 1st, 2017, the launch date of the "Jogogo analytics platform". Your Data shall be keep on our system for a period of at least eighteen (18) months after the collection, after which that it shall be destroyed according to our internal directive, except if we receive a written request from You prior to such deletion or if we have a legal need to keep your Data longer.

As noted above, once you Register, we may combine your Registration Information and Activity Information with your Passive Data. All such information may be used by us so that we may:

Third Party Uses:

We may combine your Passive Data (General visitor information), Activity Information, and Registration Information rendered anonymized from across our Partners, and with other data, such as demographic, location-related data, and preference data from other third parties for research and analytics and behavioral advertising.

In addition, we may use such combined information to create advertising models and serve advertisements based on such models. When used in this manner, your information is combined with the information of many other people. As such, it not used for the purposes of serving you targeted advertisements.

Who We Share (Disclose) Your Data With

It is to be noted that we may share your Data as described in the "Third Party Uses" section above. We may also:

Third-party service providers: We may employ other companies and people to perform tasks on our behalf and need to share your Data with them to provide products or services to you. For example, we may use third parties to provide marketing communications, infrastructure and IT services, provide customer service, and process and administer consumer surveys. In the course of providing such services, these third-party providers may have access to your Data, but, they are only authorized to use or disclose your information in connection with providing us with their services and confidentiality agreement as well as the applicable privacy laws bind them.

Business Transfers: In the event that one of us (Partner or Jogogo) is acquired by or merged with a third-party entity or is potentially going to be acquired by or merged with a third party entity, or if its substantial assets are acquired by a third party, in any partial or total sale of assets including in the event of a bankruptcy, or in any other corporate transfer, we may transfer or assign the Data as part of that actual or potential merger, acquisition, sale, or other change of control. The promises in this Privacy Policy will apply to your Data as transferred to the new entity that will be bound by it.

Legal Protection of Merchants, Jogogo & Others: We reserve the right to access, read, preserve, and disclose any information including in your Data that we believe is necessary to comply with law or court order or governmental request; enforce or apply our terms of use; detect and handle payment fraud, or otherwise to protect the rights, property, or safety of Merchant, Jogogo, our employees, our users, or others.

How you can Opt Out (withdraw your consent), access to, request a correction or a deletion of your information

You may withdraw your consent (opt out) at any time, with a reasonable notice to us by submitting a written request to privacy@jogogo.co. Please write the following in the subject heading: "OPT OUT DIRECT MARKETING". Jogogo will inform the Partner of your desire to opt out. If you elect to opt out, you may still receive ads, but those ads may be less relevant to your interests. In addition, we may still collect Passive Data for analytics purposes. Note that if you delete your cookies, or use a different browser or device, you may need to renew your opt-out choices. In the event that you do not want to share your location info (or any other info), you may disable the Wi-Fi function on your device or turn it off. For clarity, we may still collect and use (except for direct marketing purposes) your General Visit Information.

Rights of Access, Correction and deletion: Upon request, you have the right (i) to be informed of the existence, use, and disclosure of your Data and you shall be given access to that information; (ii) to have corrections made if such Data is not accurate; and (iii) to request deletion, or addition of information to that Data. To request such information, please submit a written request to privacy@jogogo.co or Jogogo Media Inc. (ATTN: Privacy), 4220 Saint-Laurent Boulevard, Montreal, Quebec, Canada, H2W 1Y7. Please write the following in the subject heading: "Privacy Policy Notice of Request". To obtain access to your information we may require that you provide additional information to confirm your identity. This information will be used only for that purpose. To correct any such information, please send any correction request per the same request instructions above. Please note that the amended information shall be transmitted to third parties having access to the information in question as per this PPC.

How do we Safeguard, Store and Destroy Data.

Your Data is protected by security safeguards that includes physical measures, security clearances and limiting access on a "need-to-know" basis, and technological measures, for example, the use of passwords and encryption. Our employees are fully aware of the importance of maintaining the confidentiality of Data and we offer them training session on that subject matter.

If you are not Registered with Jogogo’s Services, we will retain General Visit Information for twenty-four (24) months only after "hashing". Hashing is essentially a way of scrambling the information into a randomized string of numbers and letters. Once General Visit Information is hashed, Jogogo will not attempt to re-identify the original General Visit Information from that hashed data. If you are Registered, General Visit Information, Registration Information, Activity Information and Data is retained for as long as we deem reasonably necessary to continue to provide our Service. All Data that is no longer required to fulfil the identified purposes is safely destroyed, erased, or made anonymous, as explained above. We have developed guidelines and implemented procedures to govern the safe destruction of personal information.

Comments or Complaint?

We will endeavor to resolve complaints or respond to any comments you may have about your Data and our collection, use and disclosure of it. Inquiries or complaints regarding our privacy practices should first be directed to Jogogo at privacy@jogogo.co . Please write the following in the subject heading: "Privacy Policy Comments/Complaint". We have put procedures in place to receive and respond to complaints or inquiries about our policies and practices relating to the handling of Data. We shall investigate all complaints. If a complaint is found to be justified, we shall take appropriate measures, including, if necessary, amending our policies and practices.

Changes to this Privacy Policy.

We reserve the right to modify this PPC from time to time at our sole discretion. The date of the last update is always indicated at the top left of this PPC. We will notify you of any material changes to this PPC by posting a notice on the home page of this Service for a reasonable period of time after such changes are made. We invite you to review this PPC periodically for any changes. If you continue to use this Service after the date of the updates, you will be considered to have accepted the updated version of this PPC.

Contacting Us.

If you have any questions regarding our privacy policies, please send us a detailed message to privacy@jogogo.co or Jogogo Media Inc. (ATTN: Privacy), 4200 Saint-Laurent Boulevard, Montreal, QC H2W 2R2. Please write the following in the subject heading: "Privacy Policy Inquiry".

You can also contact our Data Protection officer at marine@jogogo.co

Thank you!