What Information Do We Collect About You and Why?
We may ask you to provide us with Personal Data about yourself in order to provide services to you. We may collect the following different categories of Personal Data about you:
- personal and business identifiers and contact information such as name, job title, company name, contact, shipping and billing information, phone number, email address;
- internet or other electronic network activity, i.e. technical data such as domain name, browser type and operating system, web pages you view; links you click; your device’s IP address; login data e.g. username, account number, password; the length of time you visit our Site and/or use our services; the URL or the webpage that led you to our Site; performance and usage data about your use of our products and services; data you provide to us to receive technical assistance or during customer service interactions; your personal or professional interests, demographics, experience with our products and contact preferences; and
- commercial information, i.e. transactional data including credit card and payment data, transaction history.
Personal Data may be required to determine access eligibility for certain restricted parts of our Site or services.
Personal Data about you collected on-line may be combined with information provided off-line or collected from trusted third party sources.
Information We Collect Directly From You or a Third Party. We collect Personal Data about you when you visit our website (“Site”), register or subscribe for our services, order our products or services, create an account on our Site, request marketing or publications to be sent to you, give us feedback on our services or our Site.
We also may collect Personal Data about you from third party sources, such as someone authorized by you to act on your behalf, third party services that you use that utilize or interact with our services, or where Personal Data has been provided by you at an event.
We may also collect your Personal Data from other sources as and when permitted by applicable laws, such as public databases, joint marketing partners, and social media platforms.
Information We Collect Automatically, including via Cookies and Similar Tracking Technologies. We may automatically collect information about your use of our Site or services through cookies, web beacons, and other technologies. We may combine this information with other information that we have collected about you such as your user name.
How Do We Use Your Information?
We use the information collected about you as appropriate and relevant for the following purposes:
- to register you as a new customer;
- to enable you to order products or services, download software updates;
- to provide services to you, including programs, online services and customer support;
- to allow you to make requests, and register for customized communications programs;
- to customize the content and information that we may send or display to you to administer the careers portion of the Site and process your job application;
- for marketing and promotional purposes;
- to assist us in advertising our products and services on third party websites;
We use the information collected about you as appropriate and relevant for the following business purposes:
- to better understand how users access and use our Site, products, and services and for other research and analytical purposes, including data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Site, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities;
- to manage our relationship with you which will include notifying you about changes to our terms or this Policy;
- as we determine it to be necessary and appropriate, including:
- under applicable law, including laws outside your country of residence;
- to comply with legal process;
- to enforce our terms and conditions;
- to protect our operations or those of any of our affiliates;
- to defend our legal claims; and
- to protect our rights, privacy, safety, security, property, and/or that of our affiliates, you or others.
We will only process any special categories of Personal Data (“Sensitive Personal Data”) relating to you for specific purposes outlined above or in relevant supplemental notices, because either:
1. You have given us your explicit consent to process that information; or
2. The processing is necessary to carry out our obligations under employment, social security or social protection law;
3. The processing is necessary for the establishment, exercise or defense of legal claims; or
4. You have made the information public.
Legal Basis of Processing
In order to collect, use and otherwise process your Personal Data for the above listed commercial and business purposes, we may rely on the following legal bases as appropriate and relevant in the specific context:
- Our legitimate interest in providing its websites and making the Services available to you, provided our interest is not outweighed by the risk of harm to your rights and freedoms.
- Your consent, where we have obtained your consent to process your Personal Data for certain activities. You may withdraw your consent at any time by using the contextual preference tools available in the communications or in the user interfaces of the products and services we provide to you. Absent those, please contact us as explained below. However, please note that your withdrawal of consent will not affect the lawfulness of any use of your Personal Data by Bestwifi based on your consent prior to withdrawal.
- To fulfill any contractual obligations, such as where you have purchased a product or service from Bestwifi. For example, we may require your contact details in order to deliver your order if you have purchased a product from us.
- For compliance with Bestwifi’s legal obligations where applicable laws require us to process your Personal Data.
If you have any questions or would like more information regarding the legal basis on which we collect your Personal Data, please review the supplemental privacy notice(s) of the products or services concerned, or contact us.
Processing Of Personal Data For The Purposes Of Fraud Prevention And Network and Information Security
On the basis of legitimate interest, we process Personal Data for fraud prevention and network and information security purposes. Pursuant to the EU General Data Protection Regulation (“GDPR”), organizations have a recognized legitimate interest in collecting and processing Personal Data to the extent strictly necessary and proportionate for the purposes of preventing fraud and ensuring network and information security.
According to the GDPR, network and information security means the ability of a network or of an information system to resist events, attacks or unlawful or malicious actions that could compromise the availability, authenticity, integrity and confidentiality of stored or transmitted data, or the security of the related services offered by, or accessible via those networks and systems.
Both as an organization in our own right, and as a provider of payment security services and cybersecurity technologies and services, it is in our legitimate interests as well as in our customers’, to collect and process Personal Data to the extent strictly necessary and proportionate for the purposes of preventing “Fraudulent Payment Transactions” and ensuring the security of our own, and of our customers’ payment transactions and information networks and systems. This includes the development of payment transaction records and of threat intelligence resources aimed at maintaining and improving on an ongoing basis our ability to detect Fraudulent Payment Transactions, and the ability of networks and systems to resist unlawful or malicious actions and other harmful events affecting information networks and systems (“Cyber-Threats”).
The Personal Data we process for the prevention of Fraudulent Payment Transactions include, without limitation:
- Information related to electronic means of payment and related entitlements;
- Information related to electronic payment transactions;
- Contextual signals and indicators of suspected fraud;
- Verification information to confirm or dispel suspected fraud; and
- Evidence of suspected, detected and/or confirmed fraud.
The Personal Data we process for network and information security purposes include, without limitation, network traffic data related to Cyber-Threats such as:
- sender email addresses (e.g., of sources of SPAM);
- recipient email addresses (e.g., of victims of targeted email cyberattacks);
- reply-to email addresses (e.g., as configured by cybercriminals sending malicious email);
- filenames and execution paths (e.g., of malicious or otherwise harmful executable files attached to emails);
- URLs and associated page titles (e.g., of web pages broadcasting or hosting malicious or otherwise harmful contents); and/or
- IP addresses (e.g., of web servers and connected devices involved in the generation, distribution, conveyance, hosting, caching or other storage of Cyber-Threats such as malicious or otherwise harmful contents).
Depending on the context in which such data is collected, it may contain Personal Data concerning you or any other data subjects.
However, in such cases, we will process the data concerned only to the extent strictly necessary and proportionate to the purposes of detecting, blocking, reporting and mitigating the Fraudulent Payment Transaction or Cyber-Threat of concern to you, and to all organizations relying on our products and services to secure their payment transactions, and information networks and systems. When processing Personal Data in this context, we will only seek to identify data subjects:
- to the extent that it is an inherent part to the services that our customers hire us to perform for them, and as such it is strictly indispensable to the prevention of the fraud and/or the remediation of the Cyber-Threat concerned, or
- if and as required by law.
If you believe that your Personal Data was unduly collected or is unduly processed by Bestwifi for such purposes, please refer to the “Your Rights” and “Contact Us” sections below.
Please be aware that if it is determined that Personal Data concerning you is processed by Bestwifi because it is critical for the prevention of Fraudulent Payment Transactions, or the detection, blocking or mitigation of Cyber-Threats, then in certain cases the legitimate interest to pursue such processing may be compelling enough to override access, objection, rectification or erasure requests related to the data concerned.
With Whom Do We Share Your Information And Why?
Bestwifi does not sell your personal information. We only share your information as described in this Policy.
Bestwifi processes your information for the purposes described in this policy, which include the above-listed commercial and business purposes in the meaning of the CCPA (see the “How Do We Use Your Information?” section above). We may share Personal Data collected about you as follows:
Bestwifi Users. Your user name and any information that you post to our Site, including, without limitation, reviews, comments, pictures and text will be available to, and searchable by, all users of the Site.
Affiliates or Subsidiaries. Data we collect from you may be shared with our affiliates or subsidiaries.
Unaffiliated Third Parties. Certain data about you may be shared with select resellers and/or distributors, particularly if you or your company have purchased through a third party before.
Service Providers. Data we collect from you may be disclosed to third party vendors, service providers, contractors or agents who perform functions on our behalf. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.
Business Transfers. ata we have collected from you may be transferred to another company as part of a merger or acquisition by that company.
Legal Obligations and Rights. We may disclose your Personal Data to any legally entitled recipients: (i) in connection with the establishment, exercise or defense of legal claims; (ii) to comply with laws or to respond to lawful requests or legal process; (iii) for fraud or security monitoring purposes (e.g., to detect and prevent cyberattacks); (iv) to protect the rights of Bestwifi or its employees; or (v) as otherwise permitted by applicable law.
If we disclose your Personal Data, to the extent reasonably practicable and permissible, we will require its recipients to comply with adequate privacy and confidentiality requirements, and security standards.
What About Links To Other Websites?
Our Site and services may contain links to third party websites for your convenience. Any access to and use of such linked websites will cause you to leave the Site.
Third party websites, even if potentially serving content co-branded by Bestwifi, are not governed by this Policy, but instead are governed by their own privacy statements/policies. We recommend that you check the privacy statements/policies of every third party website you visit before providing any Personal Data.
We do not control those third party websites and are not responsible for their content or their privacy policies. Thus, we do not endorse or make any legal representations about them. If you decide to access any of the third party websites linked to our Site, you do so entirely at your own risk.
How Do We Secure Your Personal Data?
We have implemented administrative, technical, physical, electronic, and managerial procedures to safeguard and secure the information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction and to help maintain data accuracy and ensure that your Personal Data is used appropriately.
Bestwifi has an internal Global Customer Privacy Program. Its charter is to ensure appropriate privacy processes are in place in order to meet the practices outlined herein.
Where Personal Data is processed by service providers on behalf of Bestwifi, we take steps to require those vendors to also comply with applicable data protection laws.
Email and Marketing. In most instances, we give you options with regard to the Personal Data you provide, including choices with respect to marketing materials.
You may manage your receipt of marketing and non-transactional communications by: (i) clicking on the “unsubscribe” link located at the bottom of marketing emails; or (ii) checking certain boxes on our preference center which can also be found on certain forms we use to collect Personal Data.
Access. You may request information regarding Personal Data that we collect and hold about you and the source(s) of that information. To access your Personal Data, return to the product, service or web page where you originally entered it and follow the instructions in your user interface or on that web page. If you cannot access your information in this way, please submit your request through the appropriate Request Intake Portal indicated above. If none of these options applies, please contact us as described in the “How Can You Contact Us?” section below.
Rectification. You have the right to request that we rectify any inaccuracies in relation to the Personal Data we hold about you;
Withdraw Consent. You have the right to withdraw consent to us processing your Personal Data. This will not affect the processing already carried out with your consent;
What Choices Do You Have Regarding Our Use Of Your Personal Data?
We will not use or share your Personal Data in ways unrelated to the ones described above without first notifying you and offering a choice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your Personal Data without your knowledge or consent where it is required, or to the extent it is permitted by law.
We will also provide you the opportunity to let us know if you wish to opt out at any time of certain or all contact from us, and we will do our utmost reasonably to honor such requests. This choice will be offered at the bottom of our on-line or off-line communications to you as well as on many of our web registration pages. If you have any difficulty exercising your choices, please contact us.
How Can You Contact Us?
You may exercise your access rights as described in the “Your Rights” section above. You can contact us at https://bestwifi.in/contact-us.
What About Children?
We do not knowingly collect Personal Data relating to children. If you believe that we may have collected Personal Data from someone under the age of thirteen (16), or under the applicable age of consent in your country, without parental consent, please let us know using the methods described in the Contact Us section and we will take appropriate measures to investigate and address the issue promptly.