Privacy Policy

Troglo, Inc. is committed to protecting the privacy of our users’ personal information. This Privacy Statement provides information explaining how troglo.net and related sites collects, uses, and shares information collected from our website, as well as the choices you have regarding our use of this information. This Privacy Policy covers the company Troglo, Inc., its subsidiaries, and any products or trade names associated with the company. These are referred to as “Troglo”, “Troglo Reach WiFi” “we,” “us,” and “our” throughout this policy. This Privacy Policy applies to our tools and software products, including all websites, apps, and online services that link to this Privacy Policy (collectively, “our Services”).

You agree that all transactions relating to our Services shall be deemed to have occurred in Canada, where we currently have all of our personnel and operations. Your information collected through the Services may be stored and processed in Canada, the United States or any other country in which Troglo or our subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from Canadian Law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer. If you are a resident of the EU, you are protected under the GDPR.

This Privacy Statement only addresses Troglo’s collection, use, and disclosure of your information through our website(s) and Services. Troglo Reach WiFi may contain links to other websites with privacy practices that differ from those of Troglo Reach WiFi. If you choose to click on a link and visit another website, please be aware that your information will be governed by that website’s privacy policy. For example, our website includes social media Features such as Facebook Share and other widgets. These Features are governed by the Privacy Policy of the company providing the feature or widget. We encourage you to carefully read and review the policies and practices of the websites you visit.

We understand that Privacy Statements can often contain confusing terminology. To help you better understand our privacy practices, here is what we mean when we say:

Cookies: Cookies are small text files created by a web server that are delivered through a web browser and stored on your computer or device. Cookies are used to identify your computer or device and record your preferences and other data so that the website can personalize your visit(s). There are several types of cookies. For example, many websites use their own cookies, called “first-party cookies,” to make their websites run more smoothly by doing things like keeping track of items in your shopping cart. Some websites also provide space for “third-party cookies,” which are placed on your browser by companies different from the company that runs the website you are visiting and may be used to remember parts of your online activities in order to deliver personalized ads or analyze web traffic.

Personally Identifiable Information (PII): Information that directly identifies or reasonably can be used to figure out the identity of a user, such as your name, address, phone number, and email address. Personal information does not include information that has been made anonymous so that it does not identify a specific user.

Web Beacons: A small, transparent graphic image (also known as a tracking pixel) located on a web page or HTML email that is often used with a cookie. Web beacons are generally invisible because they are very small and the same color as the background of the Web page or email message.

Troglo, Inc. may collect information from you in several ways:

• Information that you voluntarily provide to us; and
• Information that we collect automatically when you visit or interact with our website(s).
• Information that you’ve indirectly shared though supplying your e-mail or social information. If you do not want us to collect information, disconnect from the Troglo Reach WiFi powered network and close this browser window.

Information You Provide

Troglo Reach WiFi collects personally identifiable information that you provide to us when you communicate with us or when you chose to join or access a Troglo Reach WiFi powered network. When you choose to join or access the Internet at a Troglo Reach WiFi powered location, you may be asked to provide the following types of personally identifiable information on our website(s): email address, zip or postal code, first name, last name, gender, birthday, and/or other information you disclose on forms.

We may use the personally identifiable information that you provide to us in the following ways:

• To respond to your requests.
• To contact you with information that might be of interest to you, for analytical and research purposes.
• To contact you on behalf of one of our Clients for Advertising purposes.
• To develop and improve our programs, services, and content.
• To enforce this Privacy Policy and the other rules about your use of the website(s) or Service(s).
• To protect our rights or property.
• To protect an individual’s health, safety, or welfare.
• To comply with a law or regulation, court order, or other legal process.

Information We Collect Automatically

Troglo Reach WiFi automatically collects information about your device when you visit at a Hotspot or website(s). For example, we may automatically collect information such as your device MAC address, dwell time, whether you are a new or returning guest, referring website(s), the login method you choose, the different areas of our website that you visit, and the date and time you accessed our website and your approximate location based on your IP address or geo-coordinates. Troglo Reach WiFi uses technologies, including cookies and web beacons, and presence analytics-enable equipment to collect this type of information. In addition, we collect information that is available via third-party social media companies based on information that you disclose upon connecting.

Cookies, Web Beacons, and Other Tracking Technologies

Troglo Reach WiFi may use, or may engage third-parties on our behalf to use, cookies, web beacons, and other tracking technologies to collect information about you when you interact with our website(s) or email. Cookies and web beacons provide us with information that allows us to:

• Supply information to the location that you are visiting;
• Create aggregated views of location trends and statistics;
• Develop personalized programs, services, or content;
• Customize the information or services that are of interest to you on our website; tailor our communications to you;
• Determine whether an email has been opened and links within the email have been clicked;
• Determine if an e-mail has been read has been redeemed;
• Determine is a voucher or coupon has been redeemed;
• Create features such as “Frequently Asked Questions”

Troglo Reach WiFi also engages third party service providers to serve Advertisements on our behalf across the Internet and to provide analytics services. These third party service providers may use cookies, web beacons, and other technologies to collect information about your use of our website(s) and Services. This information is used to analyze data, determine the popularity of specific content, and deliver advertising based on your interests.

In addition, clients that utilize our platforms for the purpose of supplying guest Internet access at their Hotspot locations will be able to contact you for the purpose of promoting their business.

Troglo Reach WiFi may disclose your personally identifiable information in the following contexts:

Consent

Troglo Reach WiFi will only disclose your personal information to third parties with your consent. We may obtain your consent in writing or online through “click-through” agreements. You grant consent if you supply any personal information upon Connection or if it was received by a social platform that you’ve authorized to share your data.

Service Providers

Troglo Reach WiFi may share your personally identifiable information with other companies that perform services on our behalf (for example, companies that manage, maintain, and perform analytics on our mailing distribution lists). These service providers are permitted to use the information only for the purpose provided to them and in a manner that is consistent with this Privacy Policy. We require our service providers to comply with industry standards around security, retention, and use of any personal information that we provide to them or that they collect on our behalf.

Our Clients

Troglo Reach WiFi shares your personally identifiable information with its Clients (meaning, the provider of the Internet service at the location you’re at when connecting.)

Legal Purposes

Troglo Reach WiFi may access, monitor, use, or disclose your personally identifiable information or communications with us to comply with the law (for example, to comply with a search warrant, subpoena, or court order); to respond to emergencies; to enforce an agreement with you; to protect our rights or property, or the rights or property of our agents, vendors, service providers, members, and customers; or in the case of a corporate sale, merger, dissolution, or acquisition.

Some of the information that Troglo Reach WiFi collects is non-personally identifiable that cannot be directly used to identify or reasonably used to identify an individual. Similarly, Troglo Reach WiFi may take steps to anonymize or aggregate personal information in order to create non-personally identifiable information. This Privacy Statement does not restrict the disclosure to third parties of non-personally identifiable information.

The security of your information is important to Troglo, Inc. Therefore, Troglo Reach WiFi follows generally accepted industry standards to protect the security and confidentiality of your information while it is under our control. We maintain physical, technical, and administrative safeguards to protect against the loss, misuse, and unauthorized access of your information. To the extent that Troglo, Inc. shares information with other companies performing services on our behalf, we may make sure that those companies have adequate security safeguards in place consistent with this Policy.

Correspondence

If you wish to unsubscribe from e-mail communication from Troglo Reach WiFi, you may e-mail us at support@troglo.net. Additionally, most of our email distributions contain an “unsubscribe” link. If you have questions or comments about this Privacy Policy or the practices of Troglo Reach WiFi, you may contact us at support@troglo.net.

Managing Cookies

You can manage cookie settings by using the tools available on most Internet browsers. Instructions for popular browsers are here:

• Apple Safari
• Google Chrome
• Microsoft Internet Explorer
• Mozilla Firefox

Depending upon which web browser you use, you may be able to adjust your settings to reject or delete cookies. However, choosing to reject cookies may result in the loss of some functionality of our website(s).

Notices and Changes to our Privacy Policy

We may update this policy from time to time. If we make any changes to this Policy, we will change the “effective date” below and will post the updated Policy on this page (https://troglo.net/privacy-policy)Continuing to use our Services after we publish changes to this Privacy Policy means you are consenting to these changes.

If you have any questions about this Policy, please contact us at support@troglo.net or by writing to us at:

Troglo, Inc.

2511 5 Street SW

Calgary, Alberta, T2S 2C2

Effective date: September, 2019