Surefi Privacy Policy

Last Updated: 01/01/2025

Welcome to Surefi! Your privacy is important to us, and we are committed to protecting your personal information. This Privacy Policy explains how we collect, use, share, and protect your data when you interact with our services, including captive portals, real-time surveys, and analytics tools.

1. Who We Are

Surefi LLC ("Surefi," "we," "us," or "our") provides captive portal services, real-time surveys, and analytics for clients operating in public venues. Our services are designed to deliver insights while respecting your privacy.

2. Information We Collect

We collect the following types of data:

a. Personal Information (PII)

  • Email address or phone numbers (optional, if provided)

  • Location data (if manually provided by the user)

  • Any other personal information voluntarily provided

b. Non-Personal Information (NPI)

  • Device identifiers (e.g., MAC addresses, anonymized)

  • Connection location (e.g., venue-specific, not geolocation-specific)

  • Survey responses (collected and reported anonymously)

We may collect general location data, such as zip codes, during surveys or portal access. This information is anonymized and not linked to any specific user or device.

3. How We Use Your Information

We use your information to:

  • Provide access to Wi-Fi and related services

  • Deliver anonymized insights and analytics to our clients

  • Improve the performance and reliability of our services

  • Communicate with you (if you opted to share contact details)

4. Sharing Your Information

We do not sell your personal information. However, we may share anonymized data with trusted third-party platforms for analytics and marketing purposes, such as:

  • Google Analytics

  • Meta (Facebook, Instagram)

  • Twitter (X)

We anonymize most data as a precaution to avoid it being traced back to individuals.

5. Cookies and Tracking Technologies

We use cookies, pixels, and similar technologies to:

  • Enhance your browsing experience

  • Measure portal performance and user engagement

  • Support analytics and reporting

a. Types of Cookies We Use

  • Essential Cookies: Necessary for our services to function properly.

  • Performance Cookies: Help us analyze usage trends and improve functionality.

  • Functional Cookies: Enable personalized features like remembering preferences.

  • Analytics and Marketing Cookies: Support analytics insights and personalized advertising.

b. Managing Cookies

You have the right to accept, decline, or manage your cookie preferences:

Please note that disabling cookies may impact your experience on our website.

c. Third-Party Cookies

Some cookies are placed by third-party services integrated into our platform. These third parties comply with our privacy and security standards.

6. Children's Privacy (COPPA Compliance)

We do not knowingly collect or solicit personal information from children under the age of 13. If we learn that we have inadvertently collected personal information from a child under 13, we will take steps to delete such information promptly. If you believe that a child under 13 may have provided us with personal information, please contact us at legal@surefi.com.

7. Your Privacy Rights

Depending on your location, you may have the following rights:

  • Access: Request a copy of the personal information we hold about you.

  • Deletion: Request the deletion of your personal information.

  • Opt-Out: Opt-out of data sharing for analytics or marketing.

To exercise your rights, please contact us at: legal@surefi.com.

8. Data Security

We implement standard measures to protect your data, including:

  • Secure data storage

  • Two-Factor Authentication (2FA) for administrative access

  • Segmented databases

While we strive to protect your information, no security measures are foolproof, and we cannot guarantee absolute security.

9. Data Retention

We retain your data as long as we feel necessary to fulfill the purposes outlined in this policy or as required by law. Additionally, we reserve the right to retain your information at our reasonable discretion to fulfill legal obligations, resolve disputes, or enforce our agreements.

10. International Data Transfers

If we transfer your data outside your country, we will comply with applicable laws, such as GDPR Standard Contractual Clauses.

11. Our Role Under GDPR

In most cases, Surefi acts as a Data Processor when collecting and processing personal data on behalf of our clients. In certain scenarios, where we determine the purposes and means of processing independently, we may act as a Joint Controller.

12. Policy Updates

We may update this Privacy Policy periodically. Any changes will be posted on this page with the updated date.

13. Contact Us

For questions or concerns regarding this Privacy Policy, please contact us:

  • Email: legal@surefi.com

  • Mail: Surefi, Attn Legal, 317 Commercial St. NE, Albuquerque, NM 87102