1. Data Protection Officer

We have appointed a Data Protection Officer for all data protection matters at Monzoon.
If you have any questions about the protection and management of personal data you are welcome to contact:

Data Protection Officer:
Matthias R. Koch

Email:
datenschutz@monzoon.net

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2. What personal data do we collect?

Monzoon collects data for the following reasons:

• to comply with legal requirements to identify internet users.
• to be able to optimize technical processes and, in turn, offer high-quality services. An example is the use of technology such as cookies to allow partial automation of hotspot logins.
• to manage the processes of purchase, delivery and invoicing in our online store.
• for managing contractual relationships, for example, to be able to produce invoices or communicate with customers about existing contracts.
• to make it possible to deal with support requests by enabling us to analyze problems effectively and communicate with the customer.
• to allow us to inform users of our services about new developments and promotions from our hotspot partners.

We also receive data from third-party providers, for example, in relation to credit card payments for online purchases.

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3. Where do we store personal data?

Monzoon stores personal data in protected data centers and server rooms. Access to these sites is monitored and they are protected with cameras and alarm systems.

• Services delivered in Switzerland are supported by two data centers and a server room in the Greater Zurich Area.
• Services delivered in Germany or elsewhere in the European Union are supported by two data centers in the Greater Frankfurt/Wolfsburg Area.

Personal data relating to these services are stored mainly in the data centers in the appropriate country as specified above. The data may also be stored temporarily in the other country – in particular if the processing is technically complex. Once this processing is complete they are immediately deleted.

If our customers use roaming services (i.e. their work cuts across countries and services) the roaming partners may process their data in different countries. The roaming partner is the controller, as Monzoon's client: Monzoon is acting in this case as processor.

We use payment service providers such as credit card companies and PayPal® to process payments for our services. If you have any questions about storage of the data related to this, please contact your payment service provider. For credit cards, this is usually your bank.

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4. How do we use personal data for internet access and general operations?

Monzoon uses the data collected for our business activities as an internet service provider, so that we can provide you with the services we offer. We use the following identifiers to enable our customers to access the internet:

• Login
• Password
• Hardware MAC address
• IP addresses
• Session ID
• Location address
• Reference for the order process: depending on the order process this may be e.g. an order number, transaction identifier, (mobile) phone number, or email address.
• Ticket number for support activities

We also use these data to communicate with you, for example, when we send you information about your services (e.g. login or password) or security information. These data are essential for our support organization, which deals with any problems you may have when using our services.

We also use these data so that we can automatically connect you to the internet in WiFi hotspots to improve your user experience.

In WiFi hotspots you may be asked to pass contact information to the owner of the location (e.g. hotel or airport), so that it can give you more information about the services offered at the location. In this case the owner of the location will put explicit information on the hotspot welcome page about how the information it collects will be used. This will include detailed information on who is responsible for storing these data (usually this is not Monzoon).

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5. How do we use personal data in the operation of our online store?

In our online store, we present our services and hardware products, organize the ordering and payment processes, and prepare the necessary data for shipping and service. This data is reproduced in the purchasing software that we use.

To present our offers in an optimal way and to support our customers in the purchasing process, we use the marketing tool «Google Analytics», which will be discussed in a later chapter.

Monsoon uses the following data as part of the ordering and purchasing processes of its online store:

• Pages visited
• Orders, including transactions and ordered products
• Implementation of website objectives (e.g. contact requests and newsletter subscriptions)
• Your behaviour patterns on our pages (e.g. clicks and consultation times)
• Your approximate location (country and city)
• Your IP address (in truncated form so that it is not possible to assign it unequivocally)
• Technical information such as browser, internet service provider, terminal and screen resolution
• Origin of your visit (website or advertising medium that led you to us)

We use this data

• to optimize our sales processes (save the contents of the basket, display the correct language, establish hit lists of products, etc.)
• to process purchase payments and manage delivery processes
• for anti-fraud protection purposes.

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6. What personal data is shared and for how long is it saved?

With your consent, or if it is necessary, we share your personal data in order to complete a purchase transaction or to enable us to provide a service you have requested or authorized. This happens if, for example, you use an online payment service such as a credit card or PayPal® to pay for our services and we then request authorization from the company. If you use roaming services that provide use of Monzoon services, we share with your roaming provider the data that are required for us to provide the service. For audit purposes, Monzoon generally keeps the personal data collected from customers to handle purchases for ten years from the last step of the process. We keep other data for as long as is necessary for performance of the contract and to protect our rights.

As an internet service provider in Switzerland, Monzoon is obliged to be able to identify internet users. To comply with legal requirements we store identifiers such as mobile phone numbers and – if technically unavoidable – connection information for six months, as prescribed by law, and then immediately delete them automatically. These data are stored in Switzerland and only passed to the law enforcement authorities on the basis of court orders.

As a WiFi hotspot provider in Germany, Monzoon is not obliged to be able to identify internet users. We store connection information (connection start and end times and relevant identifiers) for 7 calendar days to enable us to analyze and solve technical problems quickly. Then we immediately delete the information automatically.

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7. Security

To protect your personal data that we are storing from unauthorized access and misuse we have taken significant technical and operational precautions. We regularly review our security procedures and keep them technologically up to date. Protect your access code and password from unauthorized third parties; otherwise they could generate usage costs in your name or commit other crimes. To prevent data being read or tampered with during wireless transmission you need to take special security measures. You as customer are responsible for this. Always use connections with additional security, such as VPN or https-protected websites, to send sensitive data.

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8. Other important information about data protection

You have the following important rights in relation to Monzoon:

• If processing of personal data depends on your consent you have the right to revoke your consent at any time.
• You have the right to demand from us a compilation of all the data we hold about you. Before issuing the data, we are obliged to ensure that the data requested belong to the person making the request.
• You can object to your personal data being processed and demand that it be erased, unless this conflicts with legal regulations.
• You have the right to submit a complaint to a data protection authority.

Our services in Switzerland are governed by the «Federal Act on Data Protection» (DSG) - Federal Act on Data Protection (DSG). This Act is currently being revised: the revised version is expected in 2022. If these services are intended for customers within the European Union as well, the European General Data Protection Regulation (GDPR) also applies. You can find up-to-date information at eu-datenschutz.org.

For our services in Germany and elsewhere in the European Union the processing of personal data is governed by the European General Data Protection Regulation (GDPR) and other national laws if applicable. You can find up-to-date information at eu-datenschutz.org.

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9. Cookies

Some Monzoon websites include cookies: small files that can later be read by a web server in the domain that stored the cookie on your computer.

As a rule, we only use cookies to technically optimize the use of our pages. Another use is described in more detail in the chapter «Google Analytics».

We use cookies on hotspot landing pages to store your preferences and settings (such as your preferred language for the site). We help you when you are logging in by auto-filling input fields, with your permission, if you return to a hotspot you have already used.

We use cookies on our web pages to make the site user-friendly and improve functionality. For example, these files allow us to display information that caters to individual interests. Using cookies also enables security features that protect your privacy. The sole objective is to match our service as closely as possible to your requirements and to make using the site as easy as possible. Webmasters are obliged to follow the General Data Protection Regulation published at eu-datenschutz.org and inform users of the website about the collection and analysis of data.

Your web browser provides functions under Settings (usually in the «Security» section) that enable you as user to block cookies or view existing cookies and delete them.

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10. Google Analytics

We use Google Analytics, a web analysis service from Google Inc. (hereinafter referred to as «Google»). Google Analytics uses «cookies»: these are small text files that are saved on your computer and allow the use of our website to be analysed. The information generated by the cookie about your use of this site is usually transmitted to a Google server in the United States and stored there.

However, due to the fact that IP anonymization is activated on the site, Google first truncates your IP address within Member States of the European Union or other member countries of the European Economic Area Agreement. Only in exceptional cases is the full IP address transferred to a Google server in the US and truncated there. IP anonymization («anonymizeIP») is activated on these websites. On the instruction of the operator of this website, Google will use this information to evaluate your use of the site, to compile reports on your activities on the site and to provide the operator of the site with other services related to the use of the site and the internet.

The IP address transmitted from your browser as part of Google Analytics is not merged with other data from Google. You can prevent cookies from being saved by configuring your browser to do so; however, we would like to point out that in this case you may not be able to fully use all the functions of this website. You can also prevent the collection of the data generated by the cookie and the transmission to Google of data about your use of the website (including your IP address) as well as the processing of this data by Google by downloading and installing the plugin available under the following link: tools.google.com/dlpage/gaoptout?hl=en.

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11. History of change

Below is a summary of all the amendments we have made to this privacy statement:

• 05/20/2018: New version of the privacy statement for EU GDPR.
• 07/16/2018: Adjustment of storage period in Germany to 7 days.
• 08/31/2021: Additions under the Online Store, Cookies, Google Analytics sections.

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