Street-side, passive telecommunications infrastructure enabling cellular, Wi-Fi and Edge networks. Delivering the next generation of connectivity across the UK.

CONTACT

DEPLOYMENT

info@monoconsultants.com

COMMUNICATIONS

team@fireoth.com

PRIVACY

INTRODUCTION

Welcome to the privacy notice of Communications Infrastructure Networks Limited (CIN).
Communications Infrastructure Networks Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our WiFi service or otherwise acquire your personal data and tell you about your privacy rights and how the law protects you.

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how CIN collects and processes your personal data through your use of this website (www.sentientcin.com), including any data you may provide through this website or through use of our WiFi service.
This website and our WiFi service are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller Communications Infrastructure Networks Limited is the controller and responsible for your personal data (“we”, “us” or “our” in this privacy notice).
Communications Infrastructure Networks Limited is associated with other companies (including King Media Limited, King Media Management Limited and any holding company or subsidiary company or subsidiary company of any holding company of CIN and any company which has the same direct or indirect majority shareholder ownership) (together the Group). Please note that King Media Limited (even though it trades under the business name “CIN” or “Sentient Media”) is a separate legal entity to Communications Infrastructure Networks Limited. This privacy notice is issued on behalf of the Group so when we mention “CIN”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Group responsible for processing your data. CIN is the controller and responsible for this website.

 

CONTACT DETAILS

Our full details are:
Full name of legal entity: Communications Infrastructure Networks Limited
Email address:
Postal address: 90 Westbourne Grove, London, W2 5RT
Telephone number: +44(0) 207 692 4862
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until after May 2018 as we are still working towards getting our systems ready for some of these changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2- The data we collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers. Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or in relation to the use of our WiFi service). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3- How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms (including in relation to the use of our WiFi service) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
– apply for our products or services;
– create an account on our website;
– subscribe to our service or publications;
– request marketing to be sent to you;
– enter a competition, promotion or survey; or
– give us some feedback.

Automated technologies or interactions. As you interact with our website or through our WiFi service, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources (who may be based inside or outside the EU) as set out below:
Technical Data from the following parties:
analytics providers such as Google; advertising networks; and search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services Identity and Contact Data from data brokers.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register

4- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you and in relation to the provision of our Wifi service to you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Group for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, the provision of our WiFi service or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5- Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties as set out in the [Glossary].
External Third Parties as set out in the [Glossary].
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6- International transfers
We do not transfer your personal data outside the European Economic Area (EEA).

7- Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8- Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available by contacting us.
In some circumstances you can ask us to delete your data: see paragraph 9 below [Request erasure] below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10- Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Internal Third Parties
Other companies in the Group.

External Third Parties
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

WIRELESS TERMS OF USE & USER LICENCE AGREEMENT/DISCLAIMER

Communications Infrastructure Networks Limited (We or Us) offer public wireless WiFi internet access services (the Service) to persons who wish to use the Service (User or You or Your). This Service allows You to access the internet by connecting a wireless enabled device to Our network resources. Users seeking to use Our network must first agree to the following terms of use (Terms of Use) and the Terms of Use (as may be amended from time to time) shall apply to any use by You of Our network:

1- You should before using the Service refer to the Legal section of our website
(www.sentientcin.com/legal) which sets out the current version of these Terms of Use together with our website Terms and Conditions, Privacy Policy, Acceptable Use Policy and Cookies Policy (together Our Legal Policies).

Your use of the Service is subject at all times to the Legal Policies which may be amended from time to time as set out on Our website.

You should regularly visit Our website to ensure that you are aware of any amendments to Our Legal Policies which will be binding upon you in any event.

2- When and as available, We will allow You non-exclusive WiFi connectivity while using our kiosks. However, we do not guarantee You an internet connection; the bandwidth provided shall be at Our sole discretion and Your usage may be terminated by Us in our absolute discretion at anytime without further notice.

3- While we may agree to troubleshoot any connectivity problems on Our network, We will not provide technical assistance for any devices not owned by Us. Any assistance you might receive from Us is strictly on an as is basis, without any warranties or representations. We further reserve the right at all times to change the specifications or manner of use of the Service, to change access codes, usernames, passwords or other security information necessary to access the Service.

4- The Services may be used for lawful purposes only. Internet access through Our WiFi Service is filtered, may be monitored, and We may block or restrict access to certain websites based upon Our security policies in place from time to time. Any content deemed illegal, inappropriate or unethical, including but not limited to content considered by Us to be copyrighted or in breach of the intellectual property or other rights of any third party, protected by trade secret regulation, threatening, intimidatory defamatory, pornographic, illegal or terrorist in nature or which contains obscene, profane or abusive language or material or offensive or derogatory images or materials regarding sex, race, religion, colour, origin, age, physical or mental disability, medical condition or sexual orientation , may be blocked. Use of Our WiFi Services for activities deemed by Us to be illegal may be recorded, traced and turned over to the appropriate governmental, regulatory or law enforcement authorities. However, this right to monitor in no way creates an obligation or duty on Our part to monitor Your access and Your access to any content through Our Service in no way implies or warrants the content is either legal or appropriate.

5- From time to time We may monitor the exchange of content through a User wireless access device as part of an investigation regarding the content and/or activities of internet usage (eg in search of hackers, those gaining illegal access to computer systems, and for network management). If pursuant to any such investigation We are granted or obtain access to any User device or content, We will limit Our access and use solely to conduct such investigation and We will, subject to our rights and obligations as referred to in paragraph 3 above, take all necessary and reasonable steps to treat all such accessed content as confidential and will seek protect it from improper disclosure to any third-party or entity.

6- When using Our Service you are giving consent to the use of cookies in accordance with our Cookies Policy referred to in paragraph 1 above. Upon logging into Our Service you may provide some personal information, such as Your e-mail address. By providing this information You consent to allowing Us to periodically send to You e-mails about Our company, products and services. We will never sell or otherwise share Your e-mail address with non-affiliated companies.

You agree and acknowledge that we may keep a log of the Internet Protocol (“IP”) addresses of any devices which access the Service, the times when they have accessed the Service and the activity associated with that IP address.

7- Using Our Service, you may download and upload content to and from Your wireless access device. Be advised that content sent to and from a wireless access device using Our WiFi connection can be captured by anyone with appropriate technical knowledge. Although We incorporate wireless encryption technology into Our Service, use of Our Service is at Your sole risk. We are not responsible for Your content whether it is personal and/or corporate in nature, and You assume sole responsibility for any theft, loss or corruption of Your device or content.

8- We are not responsible for any loss of or damage to, Your software and/or hardware, changes in configuration settings, security or data files while using Our WiFi Services. We are not responsible for any virus, Trojans, worms, malware or any other malicious software infecting Your wireless access device while connected to our WiFi network. We are not responsible for any power anomalies or other events that may cause damage to Your wireless access devices while using Our Services.

9- Your access to other devices on Our private network such as printers, copiers, fax machines, scanners, etc., is strictly prohibited.

10- By agreeing to these terms of use you expressly understand that we may monitor all traffic in and out of Our gateway and therefore may gain access to and/or gain knowledge of content transmitted to or by you while connected to Our services. Our wifi services are provided – as is – we disclaim to the greatest extent permitted by law all warranties of any kind, either express or implied, including, without limitation, implied warranties of merchantability and fitness for a particular purpose. You agree to indemnify and hold Us harmless from any claims resulting from your use of Our wifi services. In no event will We be liable to You or any third party for any direct, indirect, special, incidental or consequential damages (including, without limitation, damages for loss of business/profits, data, hardware, or good will) arising out of the use of or inability to connect to the internet, even if we have been advised of the possibility of such damages.

11- If you are in breach of Our Legal Policies We have the right to suspend or terminate Your use of the Service without giving notice and we accept no responsibility to You or any third party as a result of such cessation.