Boingo Wireless^® Inc. Website Privacy Policy

This is the privacy policy for http://www.boingo.com/uk/ (Site).

The Site is operated by Boingo Wireless, Inc (Boingo, we, us and our). We are a corporation incorporated under the laws of the state of Delaware, USA. Our corporate headquarters are at 10960 Wilshire Blvd, Suite 800, Los Angeles, California, CA 90024, USA.

Where you are a user or customer in the United Kingdom, we provide the Services delivered via this Site or the subject of any Customer Agreement through our subsidiary, Concourse Communications UK Limited ("Concourse"), a company registered in England and Wales with company number 07118962 and whose registered office is 5 New Street Square, London, EC4A 3TW, United Kingdom.

Where throughout this Privacy Policy reference is made to Boingo, this reference shall also be taken to include Concourse as if the same was set out through out the terms of this Privacy Policy. Any reference to "we, us or our" shall be taken to include Concourse as well as Boingo.

The privacy and security of your personal information is one of our foremost considerations. We want to make your experience using the Boingo service as enjoyable and rewarding as possible while allowing you to feel secure that your privacy interests are being respected.

By using the Site, you consent to the collection and use of information in accordance with this privacy policy.

We reserve the right to change this privacy policy from time to time by changing it on the Site. This privacy policy was last updated on 12 January 2012. Use of this Site following any changes constitutes your acceptance of the revised privacy policy then in effect. If you do not agree to this Privacy Policy, please do not use the Site.

You can access the Site without registering, but we may collect and process the following personal information about you:

• 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;
• in connection with an account sign-in facility, your log-in and password details;
• details of any purchase transactions made by you through the Site;
• communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site or its content;
• information from surveys, promotions and competitions that we may, from time to time, run on the Site for research purposes, if you choose to participate in them;
• information collected by certain versions of the software we may provide to you, as further detailed in the "Mobile Application Information" section, below.

You are under no obligation to provide the above information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.

We may, from time to time, run referral programs or similar initiatives, such as the "Tell a Friend" program, that invite you to provide us with the contact details of someone who is known to you who may find our products or services to be of interest. By providing us with their details, you confirm that you have their permission to do so and must not provide us with the details of anyone from whom you do not have such permission.

We treat all personal information that you provide to us as highly confidential.

We will use the information you provide to:

• enable us to process your orders and to provide you with the services and information offered through the Site and which you request;
• administer your account with us;
• verify and carry out financial transactions in relation to payments you make online;
• send you information we think you may find useful or which you have requested from us, including information about our products and services or those of carefully selected third parties, provided you have indicated that you do not object to being contacted for these purposes;
• allow, with your consent, carefully selected third parties to send you information directly which you may find useful regarding their products and services.

You can tell us not to contact you with information regarding our products and services or those of third parties or to share your details with third parties so that they can send you information regarding their products and services, either at the point such information is collected on the Site (by checking or un-checking (as directed) the relevant box) or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. You can also exercise the right at any time by contacting us using the contacting us details at the end of this privacy policy.

When you visit the Site, we may automatically collect system-related information about your visit, such as the type of internet browser you use, the website from which you have come to the Site and your IP address (the unique address which identifies your computer on the internet) which is automatically recognized by our web server. This system-related information does not, of itself, contain any personally identifiable information.

The Site also uses cookies and, although they do identify a user's computer, again, they do not, of themselves, personally identify users.

A cookie is a small data file downloaded from a website to the hard disk of your computer. 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 re-typing the same information over and over). We use cookies to:

• recognize you when you return to the Site;
• allow you to navigate the Site more quickly and easily;
• store your preferences;
• customize elements of the layout and/or content of the pages of the Site for you.

Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that. However, you may not be able to take full advantage of the Site if you do so.

We use any of the system-related information referred to above, including cookies, to:

• administer the Site and assist in diagnosing technical problems;
• identify new and return visitors to the Site;
• estimate our audience size and patterns;
• carry out research on our users' demographics;
• audit the accessing of resources and downloading of data from the Site;
• assist in improving and updating the Site;
• assist in improving and developing our products and services.

We also record the MAC (Media Access Controller) address from the network card in or used with your computer or other device to enable us to accurately perform our billing functions.

Partners also may use their own "cookies." We do not control the use of our partners' cookies and expressly disclaim responsibility for information collected through them. Partners may use their own cookies for the delivery/tracking of ads, including sponsored access sessions.

Some versions of the software which we may provide to you to enable you to access and use the Boingo service automatically scan for Wi-Fi access points visible to your mobile device, and attempt to automatically connect to those visible Wi-Fi access points in order to determine whether they are publicly accessible. This functionality may operate even when our software is operating in a "background" mode on your mobile device. Following any connection attempt (whether initiated by you or initiated automatically as described above), this software reports the following information to us: (1) your account username (if you are a paid Boingo member), (2) your mobile device's MAC address and operating system version, (3) the geographic location (i.e. latitude and longitude of your mobile device at the time of the attempted connection (as reported by your mobile device), (4) the SSID, BSSID and signal strength of the applicable Wi-Fi access point, and (5) a log of any actions that you may take on your mobile device user interface in order to complete a connection to the Wi-Fi access point (e.g., accepting an interstitial terms of service or usage policy). We use this information to improve our services, and to generate a list of publicly accessible Wi-Fi access points which we may make available to our users. When we make this list available, we do not disclose any information which could be used to identify you personally. Any Wi-Fi access point location information that we provide is generated by triangulating and averaging location data from a large number of users.

We also use your geographic location in order to determine the correct charges for the location from which you are using the Boingo service, to provide you with information about other Boingo hotspots in that area, and/or to ensure the accuracy of data transmission and improve the overall performance of the Boingo service.

When you are using a mobile device which does not provide our software with access to geographic location information, the software will automatically scan for Wi-Fi access points visible to your mobile device, and will report a list of such access points to Boingo. We use this information to triangulate your approximate geographic information, which we then use for the purposes set forth herein.

Certain versions of our software may allow you to access our Services without creating a separate Boingo account. When you install and use this type of software for the first time, a unique and random key is generated. This key is then used, each time you access the Boingo service, to communicate between that instance of the software and our central server. The key itself contains no personally identifying data and Boingo uses it for the above purposes only. Boingo does not pair the key with any personal information we hold in relation to you to monitor or track your location, except that we have to pair the key with your billing information, on a per instance basis, solely in order to bill you the correct charges.

We may use your information, on an aggregated, non-personally identifiable basis, 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. We may also 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.

Except as set out in this privacy policy, we will not divulge any of your personal information to any third party unless:

• you give us explicit, and specific, prior permission;
• the disclosure is required by law or by legal process authorised by a competent court;
• we suspect fraud or cyber crime by a customer in which case we may investigate and report any evidence, including personal information, to law enforcement officials and to the courts in the course of seeking legal remedies;
• we believe it is necessary to protect the Site or the rights, property or personal safety of any person; and/or
• our services are offered in conjunction with the facilities of a business partner with whom you have agreed we may share your information.

We may disclose your personal information to any of our affiliates, or to our agents or contractors who assist us in providing the services we offer through the Site, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks, from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.

In instances where we and a partner jointly promote any service, we may provide that partner certain information, such as name and e-mail address, for the sole purpose of allowing us and the partner to evaluate the promotion.

In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.

Your personal information will never be sold to any third party. We oppose the emailing of any junk mail, and do not sell customer information to email lists or telemarketers. If any of our partner sites engage in such practices, for any reason, we will immediately investigate, and if appropriate, discontinue services with such parties. If you receive junk email that mentions us or our services, please send details to us at and we will investigate promptly.

Protecting the safety of children when they use the Internet is very important to us. We recommend that children receive permission from a parent before gaining access to the Boingo service or sending personal information to us or anyone else online.

The Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

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 WiFinder tool if you opt-in to use this tool. Please see our FAQs for more information about these options.

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 WiFinder, 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.

Your account information is kept confidential and secure via a unique user identification number and password that is issued to you. Your user ID and password should be kept confidential because it is the key to accessing the information held by us about you. If your computer or other device is accessible to or by others, please log out of the Site and close your browser when you have finished your user session.

The Site supports encryption using the secure sockets layer (SSL) security protocol, the actual level of encryption (40, 56 or a 128-bit) provided being dependent upon what your web browser will support. When you visit the Site, your personal account information is encrypted when transmitted across the Internet, using the highest degree of security that your browser will support.

Payments made on the Site are made through our payment solutions provider, Paymentech. You will be providing credit or debit card information directly to Paymentech, which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to Paymentech is not within our control and is subject to Paymentech's own privacy policy and terms and conditions.

Boingo has instituted internal safeguards to reduce the likelihood of accidental disclosures and unintended access of customer information. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary. Also, all employees, contractors and other companies engaged by Boingo are contractually required, through signed, internal non-disclosure agreements, to keep customer 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. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk.

Information that you submit via the Site is sent to and stored on [our] secure servers located in the United States. This is necessary in order to process the information and deliver the Services to you. Information submitted by you may also be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above, which may be situated in the United States and other locations outside the European Economic Area (EEA) and may be processed by staff operating in those locations. The countries concerned may not have similar data protection laws to the EEA. Where we transfer your information we will take all reasonable steps to ensure that your privacy rights continue to be protected. By submitting information via the Site, you agree to this storing, processing and/or transfer.

As a Boingo customer, you are always fully in control of the information that we hold in relation to you.

You have a legal right under the Data Protection Act 1998 to a copy of all the personal information about you held by us. On request, we will provide you with a copy of this information subject to a fee not exceeding £10.

You can update your personal information yourself 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 deleted (requests for deletion of certain information may require closing the account). 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.

If you have any questions, concerns or comments regarding this policy statement or any requests concerning your personal data, please contact us by writing to us at:

     Boingo Wireless, Inc.
     Customer Care Department
     10960 Wilshire Boulevard, Suite 800
     Los Angeles, CA  90024
     USA

or by telephoning us (lines are open 24/7):

     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

or by emailing us at .