- Personal Information (“PI”) and other information that is collected from individuals who use the TW Services or from the devices they use to access TW Services.
- De-Personalized Data, which includes data that can be associated to a mobile device.
- De-Identified Data, which refers to data that cannot be reasonably used to infer information about a specific user, computer, or device. This includes aggregated data, statistical samples, and the like.
b) TW’s related captive portal, website and other TW websites (collectively, “Site”); and
c) All software developed and made available by TW in connection with any of the foregoing.
In many cases, TW Services do not require you to log in or provide any information that can be tied to your personal identity.
Please note that TW Services are intended for adult audiences and TW does not knowingly collect any Personal Information directly from anyone under 13 years of age. If TW learns a child under 13 years of age submitted Personal Information, TW will take reasonable steps to remove the information from its databases.
What information does TW collect?
When you visit locations where the TW Services are available, we collect information about your device. If you use TW Services, we also collect information about how you use them. The information we collect may be obtained from different sources, including: (1) information you give us such as your name, e-mail address, mailing address, and payment information; (2) information we collect automatically, which includes information we use to maintain our systems, optimize performance, and improve our services; (3) information we collect from third party sources; and (4) information we infer or derive from analysis of the above.
TW and its affiliates also collect and use the following types of data:
If you are concerned about cookies, it is possible to turn them off in your web browser preferences. However, please be aware that by disabling cookies, your web surfing experience will be degraded.
MAC Addresses. The TW Services may also record and retain the Media Access Controller (“MAC”) address from your device to enable TW to accurately perform administrative and operational functions and otherwise provide the TW Services. TW may also use the MAC address to develop aggregate market segment profiles for advertisers on TW’s portal.
MAC addresses are immediately hashed before they are stored and are never shared in plain-text format.
Location Data. Transit Wireless may collect geographic location data derived from the use of TW Services. TW Services generate data that is specific to the device location when it is connected to TW Services or when the device communicates with TW Services.
Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to those signals. For more information regarding Do Not Track mechanisms, see allaboutdnt.com.
How does TW use the information it collects?
To manage, monitor, optimize, and ensure the integrity of the services we provide to you. Usage statistics, load factors, incidents, feedback, fair use monitoring, and the like, are all used to make technical improvements to the network and ensure that the service is operating adequately for the benefit of all users.
To create personalized content, or to tailor services and advertising that may be of more interest to you, based on inferences derived from your use of the service.
To generate revenue. TW’s free Wi-Fi service is made available at no charge to end users, transit authorities, or taxpayers. Costs of installing and operating the network are offset through revenue generated by advertising and sponsorship.
To manage advertisements. Advertisements appearing through the TW Services may be delivered by us or one or more third-party web advertisers. Advertisement servers may compile information about where or whether you viewed their advertisements and which advertisements you clicked on. This information allows web advertisers to deliver targeted advertisements that they believe will be of most interest to you.
To generate usage statistics. TW may also compile device information and usage statistics such as usage patterns, travel patterns and website page views. TW may use this information to improve the TW Services and to manage our networks and systems more efficiently. The personal identities of users cannot be identified from these reports.
To improve the transit system. TW may share de-identified geolocation data with its partners so they can better understand the movement patterns throughout the transit system and improve transit rider experiences. The information could include data related to the movement patterns of transit riders generally. TW will not share information that allows for its partners to identify you specifically. If you wish to opt out of this data collection and usage, you may do so using the process provided below.
To detect potential fraud, abuse, unlawful use, and other violations of our Terms of Service. On occasion, it may be necessary to record and trace individual usage and/or personal or technical information in order to maintain the integrity and security of the TW Services. In order to protect our users and maintain a high level of service, TW will use commercially reasonable efforts to track and identify any malicious user that we believe in our sole discretion may be acting in contravention of our Terms of Service. To do so, TW or its representatives may track and record any information that may be considered evidence of misuse. Please refer to the Terms of Service for more information.
To contact you in the future. We may contact you to tell you about products or services we believe will be of interest to you, but only with your explicit consent. TW does not share your e-mail address or other contact information, such as name and address with third parties for marketing purposes without your prior consent. We do not sell customer lists.
To provide you support and customer service. For instance, if you contact us by email, we will use the Information you provide to answer your question or resolve your problem.
To comply with the law and for safety. TW may provide information to law enforcement to comply with a subpoena or any other legal requirement. Otherwise, we only share information with law enforcement to act in the interests of personal or public safety, or national security, if we believe in good faith that such exigent circumstances exist.
Where is my information stored?
If you provide information to the TW Services, your information may be transferred from your current location to the offices and servers of TW and authorized third parties located in the United States or other countries.
How does TW protect my information?
We take security seriously. We use appropriate security measures and take numerous precautions to protect Personal Information. However, we cannot guarantee the security of any information transmitted through TW Services, as no data transmission can be guaranteed as 100% secure.
How long does TW keep my information?
We will keep your information for as long as it remains necessary for the purpose for which we collected it or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law.
What is TW’s policy regarding links to other sites?
TW Services are offered at no charge to end users or taxpayers. In order to help offset the costs associated with providing the TW Services, TW uses sponsorship and targeted advertising to generate revenue, so that the operation of these services can continue to remain free of charge to taxpayers and transit riders.
Should you wish to opt out of targeted advertising, TW provides a number of options to allow you to control how your information is used:
1. Use cellular data. Where available, you can access data using your wireless service provider’s network, which is not subject to any advertising from TW or its partners.
2. Disable cookies. It is possible to turn them off in your web browser preferences. However, please be aware that by disabling cookies, your web surfing experience will be degraded. Please refer to your web browser’s settings to manage website cookies.
3. Opt out of Wi-Fi analytics and TW advertising. If you do not wish to partake in such activities, you may opt out. If you wish to withdraw your consent to Wi-Fi detection and/or direct advertising from TW sponsors, please send an e-mail to email@example.com that includes the MAC address of each mobile device or computer you use.
Please note that this opt-out removes your device ID only for the purposes of analytics and targeted advertising. TW, however, must store and maintain the MAC address to effectuate this opt-out, and each device that a customer wants to opt out must be done so separately. Also note that:
- You may not be able to take advantage of certain optional features offered to transit riders, either now or in the future;
- You may continue to see advertisements – they, however, will not be based on your movement and interests, and therefore may not be as relevant to you.
If you continue to use TW Services, MAC address detection and storage will continue to be used for the purposes of delivering network services, and ensuring the security, performance and integrity of the TW network.
If you have questions…