Privacy Policy

Effective as of March 16, 2021

Welcome to Promenade-HR.com (“Company,” “we,” “us,” or “our”). We care about your privacy, so we provide you with this privacy policy (“Policy”) to describe the information we collect, how we use it, and when and with whom we share it. This Policy applies to your registration for, access to, and use of our WiFi service with enhanced marketing features (“WiFi”). You are not required to register for the WiFi to access the Internet we make available in our business, but if you do, by registering for, accessing or otherwise using the WiFi, you acknowledge the applicability of this Policy.

By registering for, accessing, or using the WiFi, you understand that certain data transmitted through the WiFi will be submitted to, Zenreach, Inc. (“Zenreach”). As set forth in this Policy, we may share some or all data collected through our WiFi or other products with Zenreach, that Zenreach acts as a data controller with respect to certain personal data, and you agree that such data shall be subject to Zenreach’s privacy policy. For example, we may share data with Zenreach to enable us or our authorized service providers to send you emails that may interest you, including emails containing promotions, special events, or discounts. Zenreach may also share your information with other companies with products or services that may be of interest to you.

To the extent any provisions of this Policy conflict with the provisions of the Zenreach privacy policy, the latter controls.

INFORMATION WE COLLECT:

We collect information in multiple ways, including when you provide information directly to us and when we passively collect information from you, such as information collected from your browser or device.

Information You Provide Directly To Us

We may collect information from you during your registration for, access to, or use of the WiFi, such as when you register to use our WiFi or when you otherwise communicate with us through the WiFi.

The information you provide directly to us through the WiFi may include, but is not limited to, your name, email address, and birthday. You are not required to provide us with such information, but the provision of certain information is necessary to complete your registration to use the WiFi.

Information from Affiliated and Non-Affiliated Parties

We may collect information about you through any of our affiliates or through non-affiliated third parties. For example, we may obtain information about your interests through nonaffiliated third parties. We may combine information that we collect from you through the WiFi with information that we obtain from such third parties and information derived from any other products or services we provide.

Information that is Passively or Automatically Collected

Device/Usage Information: We and our third-party service providers, including Google Analytics and Zenreach, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile device) you use to access the WiFi. As described further below, we may collect and analyze information including, but not limited to: (1) browser type; (2) ISP; (3) operating system; (4) access time; (5) IP address; (6) unique device identifiers (e.g. IDFA or Android ID); (7 the type of device that you use; (8) the MAC address of your device; and (9) information regarding the location of certain routers through which your device has connected to the Internet. We may also track how frequently you access or use the WiFi. We and/or our service providers use this information (including the information collected by our third-party service providers) for analytics, to assist us in determining relevant advertising, to evaluate the success of our advertising campaigns, and as otherwise described in this Policy.

Location Information: When you access or use the WiFi, we and/or our third-party service providers may collect location information (e.g. through your device MAC address). If you do not want to send such information, you can disable the wifi on your device or not register for the WiFi. See your device manufacturer’s instructions for further details.

Cookies and Other Electronic Technologies: We and our third-party service providers may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the WiFi, or other products and services we provide. We or our third-party service providers also may use certain of these technologies in emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from accessing or taking full advantage of the WiFi.

HOW WE USE THE INFORMATION WE COLLECT

We may use your information for any of the following reasons:

For the purposes for which you provided it;

To enable you to register for, access, or use the WiFi;

For customer support and to respond to your inquiries;

For internal record-keeping purposes;

To improve and maintain the WiFi and other products or services we offer;

To periodically send promotional emails regarding new offerings, special offers, or other information that may interest you;

To allow us to personalize the content and advertising that you may see when using the WiFi and to understand how users interact with and use our advertisements and WiFi;

For other research and analytical purposes; and

To resolve disputes, to protect ourselves and other users of the WiFi or visitors to our establishment(s), and to enforce any legal terms that govern your use of the WiFi.

We may combine information that we collect from you through your registration with, access to or use of the WiFi with information that we obtain from affiliated and non-affiliated third parties, and information derived from any other products or services we provide. For example, we or our service providers may combine information we collect through our WiFi service with information we collect through third parties or through your other interactions with us.

We may aggregate and/or de-identify information collected through the WiFi. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties.

WHEN WE DISCLOSE YOUR INFORMATION

Unless otherwise described in this Policy, we may also share the information that we collect from you through your registration with, access to, or use of the WiFi as follows:

Affiliates. We may share your information with any of our affiliates.

Consent. With your consent, we may disclose your information with non-affiliated third parties. Such consent includes the disclosure of your information (1) to provide services or products that you have requested (please see below for more details); (2) when we have your permission; or (3) as described in this Policy, the Terms of Use, or any other legal terms governing your use of the WiFi.

Service Providers. We may provide access to your information to select third parties who perform services on our behalf and for any other legitimate business purposes. These third parties provide a variety of services to us, including without limitation, sales, marketing, advertising, market research, data storage, analysis and processing, and legal services.

Legal Requirements. We may disclose your information when we believe in good faith that such disclosure is necessary or permitted in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.

Protection of Us and Others. We may disclose your information when we believe it appropriate to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Use or any other legal terms governing use of the WiFi, and/or to protect our rights and property.

Business Transfers. As we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, including the evaluation of such transactions before they are finalized or where there is any change of control of us, user information may be among the transferred or disclosed assets.

Our WiFi is made available through our business partner, Zenreach. We may share some or all data collected through our WiFi or other products with Zenreach, and you agree that such data shall be subject to Zenreach’s privacy policy. Please review Zenreach’s privacy policy to understand how Zenreach uses your information, the circumstances in which Zenreach acts as a data controller of your personal data, and choices available to you regarding your information. Among other things and as further described in Zenreach’s privacy policy, by registering for the WiFi, you understand and agree that Zenreach may obtain location information about you through your access to or use of our WiFi and other wifi locations operated or otherwise affiliated with Zenreach.

ONLINE ANALYTICS AND TAILORED ADVERTISING

Online Analytics

We may use third-party web analytics services through the WiFi, such as those of Google Analytics. These service providers use the sort of technology described in the Information that is Passively or Automatically Collected section above to help us analyze how users use the WiFi. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the WiFi. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on by clicking here.

Tailored Advertising

Third parties whose products or services are accessible or marketed via the WiFi may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your access to or use of the WiFi in order to (i) inform, optimize, and serve marketing content based on your access to or use of the WiFi and (ii) report how our marketing content impressions, other uses of marketing services, and interactions with these marketing impressions and marketing services are related to visits to our establishment(s), access to, or use of our WiFi. We may also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored marketing to you through the WiFi, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the WiFi. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the WiFi by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider in hashed, non-human readable form.

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing (i.e., not just for the WiFi), you may visit the Network Advertising Initiative’s Consumer Opt-Out Link and/or the Digital Advertising Alliance’s Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the WiFi, you may still receive advertising content even if you opt-out of tailored advertising. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.

OUR LEGAL BASES FOR USE OF YOUR INFORMATION

Under applicable law, we are considered the “data controller” of the personal data we handle under this Policy. This means that we are responsible for deciding how to collect, use and disclose this data, subject to applicable law. Our contact information appears at the end of this Policy.

The laws of some jurisdictions such as the laws of the European Union require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing of your information. To the extent those laws apply, our legal grounds are as follows:

Contractual Commitments: We may use, share, or disclose information to honor our contractual commitments to you. For example, to comply with our Terms of Use, which you accept by accessing or otherwise using our WiFi.

With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent. For example, when you registered and consented to receiving marketing materials, you consented to our use of your information for marketing purposes.

Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for our WiFi, preventing fraud, and managing legal issues.

Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.

CALIFORNIA DO-NOT-TRACK DISCLOSURE

We do not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations and solutions.

YOUR CALIFORNIA PRIVACY RIGHTS

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. We currently do not disclose your personal information to third parties for their direct marketing purposes. If this changes in the future, we will update this Privacy Policy and provide information describing how you may request this information. If you would like to make such a request, please contact us using the information provided below. If you would like to make such a request of our service provider Zenreach, please see Zenreach’s privacy policy and contact Zenreach using the information provided therein.

CHILDREN’S PRIVACY

Only persons 16 years of age or older may use the WiFi. If we discover that a child under 16 has provided us with personal data through the WiFi, we will delete such information from our systems.

How we protect information

We have implemented administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology.

Although we take measures to safeguard against unauthorized disclosures of information, we cannot assure you that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

How long we keep information

We generally retain information for so long as it may be relevant to the purposes above and in compliance with applicable law. To dispose of any personal data, we may anonymize it, delete it or take other appropriate steps. Information may persist in copies made for backup and business continuity purposes for an additional period of time.

USE OF THE WIFI BY USERS FROM OUTSIDE THE UNITED STATES

The WiFi is hosted in the United States and is governed by United States law. If you are using the WiFi from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our databases are operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the WiFi, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in our Policy.

LINKS TO EXTERNAL PLATFORMS

The WiFi portal may contain links to other websites or resources over which we do not have any control. Such links do not constitute an endorsement by us of those external websites. You acknowledge that we are providing these links to you only as a convenience, and further agree that we are not responsible for the content of such external websites or the protection and privacy of information you provide while visiting such external websites.

YOUR DATA CHOICES

You may review, correct, and delete certain information about you by contacting us at the email address below. You must promptly update your WiFi registration information if it changes or is inaccurate. You may unsubscribe from our email promotions through the opt-out link provided in our promotional emails. As described above in the Information That is Passively or Automatically Collected section, you may elect not to provide certain information to us by disabling the wifi on your device, but you will not be able to access the WiFi.

We may retain information from deleted WiFi registrations in order to comply with the law, prevent fraud, troubleshoot problems, enforce our Terms of Use, and/or for any other purposes otherwise permitted by law that we deem necessary in our sole discretion.

Your Legal Rights Under Local Law:

Your local laws (e.g., laws of the E.U.) may permit you to request that we:

provide access to and/or a copy of certain information we hold about you;

prevent the processing of your information for direct-marketing purposes; (including any direct marketing processing based on profiling)

update information which is out of date or incorrect;

delete certain information that we are holding about you;

restrict the way that we process and disclose certain of your information;

transfer your information to a third-party provider of services; and

revoke your consent for the processing of your information.

Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

To exercise any of these rights, please contact us as described in the “Contact Us” section below. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

CHANGES TO THIS POLICY

We reserve the right to change this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our WiFi, or advances in technology. Please check this page periodically for changes. As permitted by applicable law, your continued use of the WiFi following the posting of changes to this Policy will mean you acknowledge those changes.

If you have any questions about the Policy or the WiFi, please contact us by sending an email to [email protected] and Zenreach will direct you to our contact information.