Development Group, Inc. (“DGI,” “we”, “us” or “our”) uses a guest Wi-Fi software service (the “Software”) that enables hotel, cruise and other consumer brands to offer Wi-Fi to their customers and guests.
This privacy policy (“Policy”) sets forth the personal data that DGI collects from you through our interactions with you, the interactions of third parties who support us or who work with us to provide Services to you, and through our products and services. The Policy discusses how we use that personal data and how you may interact with us about your personal data. This Policy covers:
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Services. By accessing or using the Services, you agree to this Policy. This Policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
This Policy applies to data provided through the Software, as well as any data provided by you to DGI via support ticketing systems, knowledgebase and forums, web contact forms for sales/marketing or other inquiries (our “Sites”), as well as via email, phone and other methods of communication (“Communications”) and any support services we may offer (“Support”). Collectively the Software, Sites, Communications and Support, are the “Services” that are subject to this Policy.
This Policy does not apply to any third party site or service linked to our Sites or recommended or referred to by our Sites or by our staff. Applications may be posted by DGI and/or third parties. When applications are posted by DGI and the application links to this Privacy Policy, this Privacy Policy applies. When applications are posted by third parties, the privacy policy of the third party applies.
We collect information from you in several ways. First, you provide us with certain information when you register for, download, access, and otherwise use our Services. Second, we collect certain information automatically as you interact with our Services. Third, we may get information about you from other sources. We may collect personal information from you when you register as a user or to learn more about our products, provide comments and suggestions, sign up for newsletters, enter promotions, interact with us on our social media channels, order products or services, request and utilize maintenance and support services, request white papers, sign up for events or seminars, submit content or send us feedback. If you do not want us to collect this information, please do not provide it. We directly collect the following types of information that you provide to us:
User information. This means information collected about users of the Services and includes without limitation contact information such as name, e-mail address, address, and phone number, room number or other information that you might provide to us while using our Services in an online form, or when you contact us by e-mail or telephone, and any other information you may provide us when you sign up for the Services, including payment information and coupon codes.
Information collected through our cookies, web beacons and other tracking technologies. We (or service providers on our behalf) may use technologies, including “cookies” and “web beacons,” to automatically collect information from you when you use the Services. We collect this information to, among other things, improve our Services and your experience, see which areas and features of our Services are popular and count visits, provide you target advertising based upon your interests and are used in analyzing trends, administering the site, tracking users’ movements around the site, to gather demographic information about our user base as a whole, and to remember users’ settings and for authentication purposes. Cookies are small amounts of data that are stored within your Internet browser, which saves and recognizes your browsing habits. DGI uses both session cookies (which track a user’s progression during one site visit) and persistent cookies (which track a user over time). Web beacons (also called pixel tags or clear GIFs) are web page elements that can help deliver cookies, count visits, track browser type, identify your IP address, understand usage and marketing campaign effectiveness, recognize certain types of information on your computer, in your email or on your mobile device, such as the time and date you viewed a page, which emails are opened, which links are clicked, and similar information.
Log files. As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses and usage data such as browser type, browser language, device identifier, Internet service provider (ISP), referring/exit pages, length of visit, pages viewed, operating system, date/time stamp, clickstream data, crashes, system activity, hardware settings, the date and time of requests, referral URL and other usage data. We may combine this automatically-collected log information with other information we collect about you. If you reach out to us over the telephone or via facsimile, we may also log telephony information such as your phone number, forwarding calls, SMS routing information and types of calls.
Services Use. We may use technologies to automatically collect information from you when you use the Services, including without limitation details of how you used our Services and your search queries. We collect this information to, among other things, provide you information and benchmarking based upon your usage of the Services, which are used in analyzing trends, administering the Services, tracking users’ utilization and to gather information about our customer user base as a whole.
Device Information. We collect information about the device you use to access our Site and our Services, including without limitation the hardware model, operating system and version, unique device identifiers and mobile network information. We may associate your device identifiers and phone number with the account(s) you opened with us.
Location Information. When you use our Services, we may collect and process information about your actual location. We may use IP address, beacons, GPS and other sensors that provide information about nearby devices, Wi-Fi access points and cell towers.
We may use information collected from or about you for any of the following purposes:
Authentication. Authenticate your identity to grant guest Wi-Fi access at a venue. Authentication may include gathering information, validating against 3rd party systems like social media or enterprise authentication systems, or other means of identifying you.
To respond to your requests or to tailor content. We may respond to your requests, which may include processing orders, sending confirmations, providing invoices, processing requests for information about our products and processing downloads for white papers or product demonstrations or evaluations. We may also use your information to customize your interaction with our Site and to provide you with more relevant information and advertisements.
To provide services to you. We may communicate with you about our Services. These may include reports, consulting, educational, training, maintenance and support services for which you have inquired or contracted. We may provide technical support and related product information via customer support portal. As part of these services, we may be required to remotely access your systems or an individual computer in order to troubleshoot a support issue or have direct physical access as part of an onsite engagement. We may also use this data to provide you service and product updates and notices. We may keep a record of your communications and ours to provide improved customer service to you and others, including without limitation recordings of customer support phone calls.
To provide informational services. We may use personal information while providing online forums such as user groups and bulletin boards. We may also do so while delivering live or online events such as training seminars or conferences, including third-party events sponsored by DGI.
Prevent improper or illegal activity. We may use information to protect, investigate and deter against fraudulent, unauthorized or illegal activity.
To meet legal requirements. DGI may be required to provide personal information to comply with legally mandated reporting, subpoenas, court orders, or other legal process requirements.
To market and improve our products and services and to create new products and services. We may inform you about our products, services or events and otherwise perform marketing activities. Further, we may use information for analytics purposes and to operate, maintain and improve our products and services. We may also use information to create new products and services.
Verify users. We may use personal information to manage and verify your account and the identity of users of the Services.
Contests and rewards. We may use information to process contest entries and deliver rewards.
Other purposes. We may use personal information for any other legal, business or marketing purposes that are not inconsistent with the terms of this Policy.
Your Internet browser and mobile device may allow you to adjust your browser settings so that “do not track” requests are sent to the websites you visit. We do not process “do not track” (DNT) signals. Our third party service providers may also not respond to DNT signals.
DGI may disclose personal information in the following circumstances:
Business Partners and Subcontractors. DGI shares personal information with business partners and subcontractors (such as third-party distributors and resellers, vendors, suppliers and other service providers), who may use the information to fulfill product orders, develop and improve products, contact you about product orders or in connection with the performance, operation, and support of the Services or solutions, performing marketing or consulting services, or as otherwise appropriate in connection with a legitimate business need. Further, we may disclose personal information to service providers who host or facilitate the processing of payments, the ability of individuals to access the services, delivery of online training, seminars and webinars; email-delivery services and other technology providers; and third parties that may assist in the delivery of marketing materials, technical support services, or other products, services or other information. These companies are authorized to use your personal information only as necessary to provide these services.
Third Party Analytics Providers. DGI shares personal information with third parties who conduct marketing studies and data analytics, including those that provide tools or code which facilitates our review and management of our Services, such as Google Analytics or similar software products from other providers. For example, we use Google Analytics to analyze site traffic to our Sites and apps. We may also use Google Analytics in conjunction with Google’s advertising services, such as those using the DoubleClick cookie. With this capability, we or Google may link Google Analytics information with information about visits to multiple sites. We use these tracking technologies to provide tailored advertising and evaluate our marketing efforts. For more information about how Google collects and processes data when you visit websites that use Google technologies, please see “How Google uses data when you use our partners' sites or apps” at google.com/policies/privacy/partners.
Transfer or Assignment in Connection with Business Transfers or Bankruptcy. In the event of a merger, acquisition, reorganization, bankruptcy or other sale of all or a portion of our assets, personal information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your personal information and other information we have collected from users of the Services or individuals who provide us personal information under this privacy policy to third parties. Other than to the extent ordered by a bankruptcy or other court, or as otherwise agreed to by you, the use and disclosure of all transferred user information will be subject to this Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
Response to Subpoenas or Court Orders; Protection of Our Rights; Safety. DGI shares personal information as required or permitted by law, regulation, legal process or other legal requirement, or when we believe in our sole discretion that disclosure is necessary or appropriate, to respond to an emergency or to protect our rights, protect your safety or the safety of others, investigate fraud, comply with a judicial proceeding or subpoenas, court order, law-enforcement or government request, including without limitation to meet national security or law enforcement requirements, or other legal process and to enforce our agreements, policies and terms of use.
Publicly Posted Content. If you post comments, images, and other content to a public-facing page, that information (associated with your username) will be publicly viewable.
With Your Consent. We may share some or all of your information to any other third party with your affirmative consent. For instance, we display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at counsel@development-group.net.
Anonymized Data. We may share information that has been anonymized with others for their own uses.
Our Sites contain links to third party websites. We are not responsible for the data collection, use practices, policies, or cookie use of the third party sites that you have accessed from our Sites. We encourage our users to be aware when they leave our Site(s) and to read the privacy policies of each website that collects personal information. This Policy applies solely to information collected on or through our Services.
Our Services may include social media features, such as the Facebook Like button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing it.
Our Services may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy@development-group.net. In some cases, unless required by applicable law, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Some of our pages utilize framing techniques to serve content to from our partners while preserving the look and feel of our Services. Please be aware that you are providing your personal information to these third parties and not to us.
Our Services provide visitors and customers the opportunity to opt-out of receiving specific types of communications from us and our partners at the point where we request information about the visitor or customer. In addition, if you have previously signed up to receive information about our Services, you may unsubscribe or opt out of all future marketing communications from us that do not relate to products or services you have already ordered by removing your contact and personally identifiable information from our marketing and communications databases by (a) sending an email to privacy@development-group.net; or (b) clicking the unsubscribe link on any email marketing communication you receive.
We may partner with a third party to manage our advertising on other sites. Our third party partner may use cookies or similar technologies to provide you advertising based upon your browsing activities and interests. Most Internet browsers allow you to block or delete cookies from your browser. If you do not agree to the use of these cookies, please disable or delete them by following the instructions for your browser set out here: http://www.allaboutcookies.org/, or use automated disabling tools where available. You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) (Link) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (Link) by visiting the opt-out pages on the NAI website and DAA website. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. You can also delete cookie files from your hard drive, or avoid them altogether, by configuring your browser to reject them or to notify you when a cookie is being placed on your hard drive. Not all features of the Services will function as intended if you reject cookies.
You have the right to access your personal information and to correct, amend, or delete such personal information if it is inaccurate or has been processed in violation of the Privacy Shield Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to your privacy or the rights of other persons). You can access, correct, or request deletion of your personal information by logging into your account. Requests for access, correction, amendment, or deletion should be directed to (530) 229-0071 or privacy@development-group.net.
Upon request, DGI will provide you with information about whether we hold any of your personal information. We will respond to any request to access your personally identifiable information within 30 days. It may take us longer if your request is complex or you have made multiple requests in which circumstances we will notify you and keep you apprised of our progress. We will retain your information and the data we process on behalf of our customers for as long as your account is active or as needed to provide you services. We will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you delete any account information, we may retain certain information as required by law or for legitimate business purposes.
If you become an inactive customer, or if we close or suspend your account, we will continue to adhere to the then current Policy when we collected your personally identifiable information so long as we retain it in our databases. We may delete any or all of your information at any time without notice to you for any reason or no reason unless otherwise required by law to retain it.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your information (or to exercise any of your other rights). This is a security measure to ensure that your information 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.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by DGI to a third party for the third party’s direct marketing purposes. To make such a request, please send an email to privacy@development-group.net or write us:
Development Group, Inc.
Attn: Privacy
PO Box 991484
Redding, CA 96099-1484
The Services are not intended for users younger than 16. We do not knowingly collect contact information from children under the age of 16 without verifiable parental consent. If we become aware that a visitor under the age of 16 has submitted personal information without verifiable parental consent, we will remove his or her information from our files. When DGI delivers the Service at the instruction of its customers, it is possible that we may process information about you if you are under the age of 16 under the instruction of our customers and such processing shall be subject to our customers’ process for obtaining appropriate consents for such processing and shall be subject to our customers’ privacy policies.
DGI takes reasonable and appropriate measures to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the personal information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about our security, you can contact us at privacy@development-group.net. We have put in place procedures to deal with any suspected breach of personal information, and we will notify you and any applicable regulator of a breach where we are legally required to do so.
We reserve the right to modify this Policy at any time. When we make only minor modifications, we may do so without notifying you. It is your responsibility to keep current the contact information we have on file for that designated representative. When we make material modifications affecting data practices where we operate as the data controller, we will post and/or email the new Policy. We will notify you either by means of a notice on this website prior to the change becoming effective or at our election we may email you by sending an email to the email address specified in your account. We encourage you to periodically review this page for the latest information on our privacy practices. The Last Modified Date at the top of this Policy will allow you to quickly know when the last changes were made.
If you have questions or concerns regarding this Policy, you should contact us by email at privacy@development-group.net . You can also write to us at:
Development Group, Inc.
Attn: Privacy
PO Box 991484
Redding, CA 96099-1484