Privacy Policy

Boingo Wireless®, Inc. Privacy Policy

Boingo Wireless, Inc. and its subsidiaries (“Boingo,” “we,” “us,” and “our”) is concerned about the privacy and security of your information. We want to make your experience with the Boingo® service as enjoyable and rewarding as possible, and also allow you to feel secure that your privacy interests are being respected. This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our website or Services. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. By visiting or using the Website or Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways. Any capitalized terms used herein without definition shall have the meaning given to them in Boingo’s Terms of Use (which is hereby incorporated into this Privacy Policy). If you reside in the European Union, you agree to our EU privacy policy which can be found here.

Collection of Information

Required Information
Boingo collects certain information that is necessary to fully service your Boingo account. As a customer, you will be asked to provide 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. Boingo may use this Information for editorial and feedback purposes, marketing and promotional purposes, for statistical analysis, product development and in connection with our partners, publishers, advertisers or connected sites.

Optional Information
Like any business interested in attracting and offering the highest quality of service to customers, Boingo gathers voluntary demographic information about our customers. These questions seek to gain insight on such things as how an individual became aware of our service, their gender, occupation and travel preferences and practices. In addition, customer comments and inquiries are collected and stored for each customer that submits them. This information is collected and stored with the customer’s individual Boingo account information. Boingo occasionally conducts user surveys to better target our service offering to existing as well as new customers. We sometimes share aggregated demographic information in these surveys with various business partners. Participation in our customer surveys is voluntary. Boingo may offer incentive programs to customers, visitors to the Boingo Web site (www.boingoqa.com), the general public and individuals identified through direct mail lists. These offerings are promoted on the Web site, advertisements and press releases. At a minimum, required information includes name and e-mail address; in some cases, the customer must answer mandatory survey questions about other personal data or enter a program code. The information gathered in the entry form is used to verify the entrant’s identity, to send the entrant an e-mail notification that their entry has been received, and to contact winners and/or prize recipients. Because the rules and terms of each program can vary, all information about each program is clearly posted during the event. All such programs are conducted in full accordance with United States federal and state laws. Boingo has and may institute referral programs or similar programs, such as the “Tell a Friend” program. Boingo’s “Tell a Friend” program allows customers to receive credit for each individual (a “Referral”) that, as a result of their recommendation, also becomes a customer. For a customer to receive a free month of service under this program, (1) the Referral must become a subscriber to Boingo Unlimited and remain a subscriber of Boingo Unlimited for more than 31 days; (2) the Referral cannot be an existing Boingo customer; and (3) the Referral cannot have been previously submitted to the “Tell a Friend” program by another person. Existing customers provide the e-mail address of the Referral, and Boingo may send an e-mail message to the Referral from the referring customer’s e-mail address informing them of the Boingo service. When Boingo collects usage information (such as the numbers and frequency of visitors to the Website), we generally use this data in aggregate form. For example, this aggregate data tells us how often users use parts of the Services, so that we can make the Services appealing to as many users as possible. We may also provide this aggregate information to our partners; our partners may use such information to understand how often and in what ways people use our Services, so that they too, can provide you with an optimal experience. As between you and Boingo, you own the information that you provide to Boingo under this Agreement, and may request its deletion at any time. Additionally, you grant Boingo a nonexclusive, irrevocable worldwide, perpetual, assignable, sublicensable, fully paid up and royalty-free right to copy, prepare derivative works of, improve, distribute, publish, remove, retain, add, process, analyze, use and commercialize, in any way now known or in the future discovered, any information you provide, directly or indirectly to Boingo, including but not limited to, any user generated content, ideas, concepts, techniques and/or data that you submit to Boingo, without any further consent, notice and/or compensation to you or to any third parties.

Geographic Location Information
When you use Boingo’s services on a mobile device (such as your laptop or a smart phone), Boingo may collect and/or track certain geographic location information that is derived from your usage of the Boingo service such as usage patterns, travel patterns, Web site page views, traffic patterns and information about your geographic location. Boingo may use this tracking and location information for statistical or business-related purposes to improve our products, offerings and services and to manage our networks and systems more efficiently.

Cookies, Web Beacons and Media Access Controller Tracking
To keep track of traffic on their servers, Web sites often store a small data file on your hard disk and/or device when you visit them. This file is commonly referred to as a “cookie.” A cookie file can contain user specific information, such as User ID, or it can be used to maintain a connection with you during your visit (so that you can visit pages of a site without retyping the same information over and over). Boingo uses cookies to track customer traffic patterns, to maintain a connection during your visit with us, to track your preferences, and to diagnose problems on our server and administer our site. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, that we may share with a data provider solely in hashed, non-human readable form. Cookies enable you to enter all parts of the Boingo Web site, and are used to save your User ID on the login page (we encrypt the User ID for added security). In addition, cookie files help us assist you with questions about site navigation, functionality or performance. Partners also may use their own “cookies.” IF YOU DO NOT WISH TO HAVE WEB COOKIES PLACED ON YOUR COMPUTER, YOU SHOULD SET YOUR BROWSER TO REFUSE WEB COOKIES, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THIS SITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. IF YOU REFUSE WEB COOKIES, YOU ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY. We do not control the use of our partners’ cookies or do not track policies and expressly disclaim responsibility for information collected or tracked through them. Web sites may contain an electronic file called a “web beacon” that allows a website to track users who have visited that page or to access certain cookies. Boingo may use web beacons in the following ways:
  • Boingo may use web beacons within our Web sites in order to track customers signing up at one of our hotspot locations.
  • Boingo may use web beacons within our Web sites in order to fulfill sponsored access campaigns or other promotions.
  • Boingo may use web beacons to measure where customers leave the signup process in order to improve customer experience.
  • Boingo may use web beacons to track customers that come through our Web sites from advertisements or search engines.
  • Boingo may use web beacons to serve ads to customers after they leave our Web sites.
Boingo also records the MAC (Media Access Controller) address, IDFA, ADID and device identifier numbers from the network card in or used with your computer or other device to enable Boingo to accurately perform our billing functions and in the ordinary course of business.

Information Collected from Other Websites and Do Not Track Policy
Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.

Use and Disclosure of Information
Except as described in this privacy policy, Boingo will not divulge any of your personal information, contact, financial, bill history, or geographic location — to any other organization unless (1) you give Boingo explicit and specific, prior permission (for example, if you opt-in to a sponsorship offer from one of our partners), (2) the disclosure is related to national security reasons; (3) the disclosure is required by law or by legal process authorized by a court of competent jurisdiction, (4) Boingo suspects fraud by a customer involving Boingo, in which case Boingo may investigate and report any evidence, including personal information, to law enforcement officials and to the courts in the course of seeking remedies at law and equity, and/or (5) you make an inquiry, request or complaint that requires follow-up and we share your information with others to satisfy your inquiry. Subject to the terms of this privacy policy, we may disclose information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers who process information on our behalf, participate with us in the provision or operation of our site or provide you with services. We may use your information in aggregate form, or in connection with our partners, publishers, advertisers or connected sites. Boingo may choose to buy or sell assets or companies, or merge with or into other companies. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if Boingo (or its assets) are acquired, or if Boingo goes out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party. We may email you about products and services that we believe may be of interest to you.  If you wish to opt-out of receiving marketing materials from us, please follow the instructions at the bottom of each email for opting out. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes. In instances where Boingo and a partner jointly promote the Boingo service, Boingo may provide that partner certain information, such as name and e-mail address, for the sole purpose of allowing Boingo and the partner to evaluate the promotion. Boingo may contact customers or Web site visitors regarding account status and changes to this privacy policy and any other policies or agreements relevant to Web site visitors. Boingo may use your information to disclose summary information to strategic and business partners. This is obtained by combining data from many individuals with the name and other identifiers removed. Boingo also may create aggregate reports on user demographics and traffic patterns. This information may be used to negotiate with service providers who complement the Boingo service or assist us in our efforts to expand our customer base. We allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in San Francisco to show you ads or offers for San Francisco businesses, but we will not tell such businesses who you are. Advertisers may serve ads that appear on our sites or services, which may contain a feature allowing you to input your email address. If you choose to input your email address in connection with these ads, you understand that we will transmit your email address to the applicable third party advertiser; this Privacy Policy does not apply to such advertisers’ collection and use practices, so please review their privacy policies before providing your email address in this manner.

Correcting and Updating Your Information
As a Boingo customer, you are in full control of the information that we maintain to service you. You can change your information at any time and as often as necessary via our self-care application which can be accessed at:  https://my.boingo.com. You can also request that the data be changed or deleted (requests for deletion of certain information may require closing the account) by calling the following numbers: From North America: 1-800-880-4117 From the UK: Local 0-203-450-6554 Free Phone (charges by mobile provider will vary) 0-800-032-6793 US-based carriers +1-800-880-4117 From Japan: Softbank Telecom 0061-010-800-8804-1170 KDD 001-010-800-8804-1170 NTT 0033-010-800-8804-1170 US-based carriers +1-800-8804-1170 From India: +1-1310-405-8806 From outside of North America, UK, Japan and India: 00-800-2646-4646 Information about a customer may be withheld or exempted from deletion if this is required by law, is part of a fraud investigation or is required for accounting and audit purposes. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: legal@boingo.com.

Opt-out Policy
If you have provided us with a means of contacting you, we may use such means to communicate with you. For example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Services. Boingo automatically opts customers in to providing Boingo with information, as well as a separate opportunity to opt-in to certain location-tracking services, or receiving communications from us and our partners. At any time, customers can contact Boingo to opt-out of any of our promotions, programs, location-tracking services or contests via the following link: https://c01.client.boingo.com/unsubscribe/unsubscribe.app. Alternatively, customers can opt not to provide certain information when enrolling for the Boingo service or when participating in some programs and surveys, although choosing not to provide certain information may hinder our ability to complete your registration process. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.

Commitment to the Privacy of Your Family
We do not knowingly collect information from children under the age of 13. If we determine that we have collected personally identifiable information on children, we will promptly delete it from our system. We recommend that children who are 13-17 years old receive permission from a parent before gaining access to the Boingo service or sending information to Boingo or anyone else online. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to us or on the Services. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at legal@boingo.com.

Security Measures
Your account information is protected by a unique User Identification and password that is issued to you. Your User Identification and password should be kept confidential because it is the key to accessing the information held by Boingo about you. If your computer or other device is accessible to or by others, please log out of the Boingo site before you leave it. Security is also provided through your web browser, which supports 40, 56 or a 128-bit version of encryption with the SSL (Secure Sockets Layer) security protocol. Boingo has instituted internal safeguards to reduce the likelihood of accidental disclosures and unintended access of your information (although it is impossible to eliminate this possibility completely). In general, all employees, contractors and other companies engaged by Boingo are contractually required, through signed, internal non-disclosure agreements, to keep your Personal Information confidential and not to use it in any way other than what is necessary to perform their work for Boingo. Violations of these policies can result in termination in the case of employees, the severing of contractual obligations in the case of contractors and other companies, and in civil and criminal penalties if warranted and applicable by law. While Boingo uses reasonable measures to protect the security of your information, no security measures are foolproof, and Boingo does not guarantee that your information will remain confidential. The Services may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

Security of Third Party Networks
Because of the global nature of our services, there are some places where you cannot access the Boingo Wi-Fi Network. In these places, you may (1) manually search for available third party networks and, if required to do so, assent to Terms of Service or other click-through agreements; or (2) connect to other people’s Wi-Fi networks automatically by using the Boingo Wi-Finder tool if you opt-in to use this feature. Please see our https://www.boingoqa.com/faq/wifinder. Third parties are under no obligation to comply with this privacy policy with respect to information that you provide directly to those third parties or that those third parties collect for themselves. We do not control the third-party sites that may be accessible through this Site or Boingo’s services. Thus, this privacy policy does not apply to information provided to third-party sites or gathered by the third parties that operate them. Before visiting a third-party site, whether by means of Boingo Wi-Finder, manually searching for an available third party network or otherwise, and before providing any information to any third party, you should inform yourself of the privacy policies and practices (if any) of the third party, and should take those steps necessary to your discretion, to protect your privacy.

Affiliated Businesses and Third Party Websites
In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. One such service may include the ability for you to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third party account. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

For Skype Credit Users
You hereby consent to the disclosure by Skype to Boingo of information concerning yourself, including your Skype ID and details of the sessions initiated on Boingo’s hotspots. You understand that such disclosure may entail the transfer of personal data outside of the European Union or assimilated countries. You acknowledge and agree that your usage of Boingo’s hotspots shall constitute consent to such disclosure and transfer.

3rd Party Advertising
Through the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about interest-based ads from participating third parties, please visit the DAA’s or NAI’s consumer opt out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices.

Privacy Policy Changes
Boingo reserves the right, in its sole discretion, to revise, amend, or modify this privacy policy at any time, and in any manner without notice. You shall be responsible for reviewing and becoming familiar with any such modifications. Your use of the Services following such notification constitutes your acceptance of the terms and conditions of this privacy policy as modified.

Additional Information
This privacy policy is effective as of April 11, 2014. Boingo reserves the right to change this policy at any time. By using the Boingo service, you are acknowledging and accepting all terms and conditions outlined in this Boingo Wireless, Inc. privacy policy. If you have any questions regarding this policy statement, please e-mail us at info@boingo.com. This privacy and security pledge is part of our contract with you. Thank you for choosing Boingo Wireless, Inc.