Data Privacy

In order to proceed you must read and accept the following terms. Therefore, this notice serves to facilitate complete transparency on how your data is managed.

Definitions

• Fydelia: Refers to the Fydelia WiFi System, wholly owned and operated by Sentinel Software Limited, 19 New Road, Brighton BN11UF Company number
• The Customer: The user of the Fydelia system
• The venue: The company using Fydelia to provide you with an internet access portal, or “Splash” welcome page, like the one you are looking at now.

Scope
At Fydelia, we respect your personal data. This notice explains how Sentinel will use your personal data when you:

• Visit Fydelia welcome “Splash” pages for WiFi access
• Optionally submit personal details through one of the welcome “Splash” pages

This notice does not cover any aspect of how the Venue will manage your personal data.  Please review the associated terms and conditions for more information from the Venue.

Our Contact details

Sentinel Software Limited.  Gemini House, 136 Old Shoreham Road, Brighton, BN3 7BD.

Tel: 0203 368 6164

General enquiries: hello@sentinelactive.com

Data Protection Officer: Tom Savic - dpo@sentinelactive.com

What is Fydelia?

Fydelia is a system that allows venues, such as the one you are in, to publish unlimited numbers of so-called welcome “Splash” pages for venues.  These pages are a portal that allow you to take advantage of free Wi-Fi, and optionally ask their customers for some marketing information.

When you connect to the venue's guest WiFi network, we check your device "MAC address" (a unique identifier built into your device) and, if you have already logged in previously, we can automatically log you in again. Some venues do not collect any personal data at all, while others may invite you to opt-in to newsletters, special offers, promotions etc.

Fydelia also manages your return visits, so that you do not need to fill in the form each time you visit this venue.

What do we do with your data?

We provide a platform that allows venues, such as the one you are currently in, to collect information about you.  When you access a Splash page, there is data captured about you. Fydelia receives information on your IP address, device make and model and device identfier “MAC” address.  For some installations, we also receive information on the WiFi SSID that was used, so that we can display the correct Splash page.

Next, some venues may invite you to provide some personal information. Fydelia is not responsible for the content of splash pages, which are fully managed by the Venue.

If you opt-in to marketing, the venue will be able to contact you for the information you have selected, such as promotions, marketing etc.  The venue is obliged to tell you precisely what you are signing up for. This area is entirely out of our control, and it is an agreement between you and the venue.  We only manage data that we store about you.

How do you opt-out?

There are two ways:

1. Ask the venue to remove you.  They have tools to remove your data entirely from the Fydelia system and should provide you with a contact person
2. Write to us at:  dpo@fydelia.com  We will wipe you from our system within 48 hours.  This will remove you from Fydelia meaning that we will not recognise your device the next time you use Fydelia, and you will be required to sign in again.  We cannot control any marketing data that you have shared with the venue.

Processing information
We will process your device MAC address and use this information for correct functioning of the Splash page system.  This is on the basis of our legitimate interest, although this can be requested for removal at any time by you.

Any other personal details that are requested will be used by the Venue, not by Fydelia.  You will need to contact the venue in order to request removal of this information.

Cookies

We will store session cookies only for functioning of the website, which do not contain any personal identifiable information.   

Summary of key points

• The Venue is responsible for the content of the welcome “Splash” pages.  Fydelia simply provides the platform that allows them to publish their content
• If you request us to remove you, we will wipe you from the system and your device will no longer be recognised by Fydelia.  This will require you to login again.
• You can contact us any time at  dpo@fydelia.com where we will be happy to discuss your data privacy with you
• Cookies are only required for session management, such as social login.  No personal data will be stored in cookies.

Acceptable Use Policy

Definitions

This acceptable use policy (the "Policy") sets out the rules governing:
(a) the use of the domain Fydelia.com, any successor website, any subdomain within Fydelia.com and the services available on that website or any successor website (the "Services"); and
(b) the transmission, storage and processing of content by you, or by any person on your behalf, using the Services ("Content").

• Fydelia: Refers to the Fydelia WiFi System, wholly owned and operated by Sentinel Software Limited, 19 New Road, Brighton BN11UF
• The Customer: Any user of the Fydelia system’s web pages
• The venue: The company using Fydelia to provide you with an internet access portal, or “Splash” welcome page, like the one you are looking at now.
• References in this Policy to "you" are to any Fydelia Client for the Services and any individual user of the Services (and "your" should be construed accordingly); and references in this Policy to "us" are to The Provider (and "we" and "our" should be construed accordingly).

What is Fydelia?

Fydelia is a system that allows venues, such as the one you are in, to publish unlimited numbers of so-called welcome “Splash” pages for venues.  These pages are managed by the Venue, and allow you to take advantage of free Wi-Fi. The venue may optionally ask you for some personal information for marketing use.  

Cookies

We will store session cookies only for functioning of the website, which do not contain any personal identifiable information.   

Acceptable Use Policy

By using the Services, you agree to the rules set out in this Policy.  We will ask for your express agreement to the terms of this Policy before you upload or submit any Content or otherwise use the Services.  You must be at least 18 years of age to use the Services; and by using the Services, you warrant and represent to us that you are at least 18 years of age.
General usage rules

1. You must not use the Services in any way that causes, or may cause, damage to the Services or impairment of the availability or accessibility of the Services.
   You must not use the Services:
   (a) in any way that is unlawful, illegal, fraudulent or harmful; or
   (b) in connection with any unlawful, illegal, fraudulent or harmful purpose or activity.
2. You must ensure that all Content complies with the provisions of this Policy.
3. Unlawful Content
   3.1 Content must not be illegal or unlawful, must not infringe any person's legal rights, and must not be capable of giving rise to legal action against any person (in each case in any jurisdiction and under any applicable law).
   3.2 Content, and the use of Content published on to the Hosted Platform that is any manner licensed or otherwise authorised by you, must not:
   (a) be libellous or maliciously false;
   (b) be obscene or indecent;
   (c) infringe any copyright, moral right, database right, trade mark right, design right, right in passing off, or other intellectual property right;
   (d) infringe any right of confidence, right of privacy or right under data protection legislation;
   (e) constitute negligent advice or contain any negligent statement;
   (f) constitute an incitement to commit a crime, instructions for the commission of a crime or the promotion of criminal activity;
   (g) be in contempt of any court, or in breach of any court order;
   (h) constitute a breach of racial or religious hatred or discrimination legislation;
   (i) be blasphemous;
   (j) constitute a breach of official secrets legislation; or
   (k) constitute a breach of any contractual obligation owed to any person.
   3.3 You must ensure that Content is not and has never been the subject of any threatened or actual legal proceedings or other similar complaint.
4. Graphic material
   • Content must be appropriate for all persons who have access to or are likely to access the Content in question, and in particular for children over 12 years of age.
   • Content must not depict violence in an explicit, graphic or gratuitous manner.
   • Content must not be pornographic or sexually explicit.
5. Factual accuracy
   • Content must not be untrue, false, inaccurate or misleading.
   • Statements of fact contained in Content and relating to persons (legal or natural) must be true[; and statements of opinion contained in Content and relating to persons (legal or natural) must be reasonable, be honestly held and indicate the basis of the opinion].
6. Negligent advice
   • Content must not consist of or contain any legal, financial, investment, taxation, accountancy, medical or other professional advice, and you must not use the Services to provide any legal, financial, investment, taxation, accountancy, medical or other professional advisory services.
   • Content must not consist of or contain any advice, instructions or other information that may be acted upon and could, if acted upon, cause death, illness or personal injury, damage to property, or any other loss or damage.
7. Etiquette
   • Content must be appropriate, civil and tasteful, and accord with generally accepted standards of etiquette and behaviour on the internet.
   • Content must not be offensive, deceptive, threatening, abusive, harassing, menacing, hateful, discriminatory or inflammatory
   • Content must not be liable to cause annoyance, inconvenience or needless anxiety.
   • You must not use the Services to send any hostile communication or any communication intended to insult, including such communications directed at a particular person or group of people.
   • You must not use the Services for the purpose of deliberately upsetting or offending others.
   • You must not unnecessarily flood the Services with material relating to a particular subject or subject area, whether alone or in conjunction with others.
   • You must ensure that Content does not duplicate other content available through the Services.
   • You must ensure that Content is appropriately categorised.
   • You should use appropriate and informative titles for all Content.
   • You must at all times be courteous and polite to other users of the Services.
8. Marketing and spam
   • You must not without our written permission use the Services for any purpose relating to the marketing, advertising, promotion, sale or supply of any product, service or commercial offering that could be deemed as unrelated to the legitimate interest of the Fydelia Client or the Fydelia Venu
   • Content must not constitute or contain spam, and you must not use the Services to store or transmit spam - which for these purposes shall include all unlawful marketing communications and unsolicited commercial communications.
   • You must not send any spam or other marketing communications to any person using any email address or other contact details made available through the Services or that you find using the Services.
   • You must not use the Services to promote or operate any chain letters, Ponzi schemes, pyramid schemes, matrix programs, "get rich quick" schemes or similar letters, schemes or programs.
9. Gambling
   • You must not use the Services for any purpose relating to gambling, gaming, betting, lotteries, sweepstakes, prize competitions or any gambling-related activity.
10. Monitoring
    • You acknowledge that we may actively monitor the Content and the use of the Service.
11. Data mining
    • You must not conduct any systematic or automated data scraping, data mining, data extraction or data harvesting, or other systematic or automated data collection activity, by means of or in relation to the Services.
12. Hyperlinks
    • You must not link to any material using or by means of the Services that would, if it were made available through the Services, breach the provisions of this Policy.
13. Harmful software
    • The Content must not contain or consist of, and you must not promote or distribute by means of the Services, any viruses, worms, spyware, adware or other harmful or malicious software, programs, routines, applications or technologies.
14. The Content must not contain or consist of, and you must not promote or distribute by means of the Services, any software, programs, routines, applications or technologies that will or may have a material negative effect upon the performance of a computer or introduce material security risks to a computer.

Acceptance

By accepting these terms, you as the Customer understand and acknowledge that:

• Fydelia has no responsibility or control over the content of the splash pages you are using
• Once you have signed in, Fydelia has no responsibility or control over the internet connection or its data
• Fydelia has legitimate interest in storing certain aspects of your data, as described in detail in the Fair Processing Notice
• Cookies may be stored on your device specifically for the functioning of this system.  They will not store any personal identifiable data.
• The Venue is responsible for use of your personal data collected if you opt-in

To report any abuse of this system and its content, please write to us at: abuse@sentinelactive.com, providing details of the venue you used and your complaint.