Fair Processing Notice – Free wi-fi



This Fair Processing Notice, or Privacy Notice, covers your use of our on-site wi-fi, which is provided on our behalf by Inkspotwifi Ltd. Under the definitions in the General Data Protection Regulation ((EU) 2016/679) (“GDPR”), The Crown Estate is the Data Controller and Inkspotwifi Ltd is the Data Processor. Our legal basis for processing the information you provide to us – when you sign up for our free wi-fi or to ask for marketing information – is your consent. You have the right to withdraw that consent at any time, and we will stop processing your information.


Please note that section 9(a) of the Data Protection Act 2018 amends Article 8(1) of the GDPR such that children under 13 cannot legally provide their consent for us to process their personal data, so our wi-fi is limited to those 13 and over.


Information We May Collect From You

We may collect and process the following data about you:

  • Information that you provide when you sign up online to use the site wi-fi or to request further information from us;
  • If you contact us by telephone, email, web form or letter, information that forms a record of that correspondence and your contact details;
  • If you visit the site in person, we collect CCTV images and ANPR information for health and safety and security purposes and to for the prevention and detection of crime.
  • Information you may provide by responding to questionnaires, surveys and competitions and attending events.

If you visit one of our dedicated consumer websites or The Crown Estate websites, further information may be collected – please refer to the Privacy Policy available on each website.


We treat all such data as Personal Data for the purposes of GDPR.


Where We Store Your Personal Data

The data we collect is stored on information technology systems owned and run by or on behalf of The Crown Estate or on systems run by those businesses processing it on our behalf, such as Inkspotwifi Ltd. All information you provide to us is stored on secure servers. Unfortunately, the transmission of information via the internet is not completely secure and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the Internet to our site; any transmission is at your own risk. Once we have received your information, we will use all necessary procedures and security measures to try to prevent unauthorised access, loss, disclosure or amendment.


How Your Personal Data Will Be Processed

We use information about you in the following ways:

  • To provide you with free wi-fi;
  • To provide you with information on products, services offers and events provided by us or our retail tenants that you request or which we feel may interest you where you have consented to be contacted for such purposes;
  • To notify you about changes to our service;
  • To perform surveys and analysis with the aim of improving the services we provide;
  • To understand our customers better so we can improve their experience at the site;
  • To ensure that your visit to our site is safe and secure.

We may give your personal data to third parties where:

  • It is necessary for them to provide you with services on our behalf, such as Inkspotwifi Ltd;
  • They provide profiling of our customer base so we can understand our customers better;
  • We sell or buy any business or assets, in which case we may disclose your personal data to the prospective buyer or seller of such business or assets insofar as they relate to them;
  • We are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce agreements or contracts or to protect our rights, our property, or the safety of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.

We will not share your personal data with any other third party for the purposes of direct marketing.


Your Rights


You have the right of access to your information. This includes a description of the data being processed, the purposes of processing and any recipients to whom the data is disclosed. To exercise this right, you must make a Subject Access Request in writing to the Data Protection Officer at The Crown Estate, 1 St James’s Market, London SW1Y 4AH or via [email protected], stating the information you require. We do not charge a fee. We may contact you to verify your identity or to clarify the precise information you require before processing your request, and will answer your request within one month.


You have the right to ask us not to process your personal data for direct marketing purposes. You will be given an opportunity to opt in to processing for direct marketing purposes when you first engage with us. However, you can withdraw your consent to receive marketing material at any time by contacting us on the address or email address above.


You have the right to rectify your personal data at any time.


You have the right to have your personal data erased under certain conditions.


You have a right to restrict or object to some forms of data processing.


You have the right to prevent any unwarranted processing likely to cause damage or distress.


If you feel that a situation has arisen or may arise and you wish to learn more about these rights or to exercise those rights, please contact us on the address above. Please note that this will not include processing where it is necessary to fulfil a contract or where a legal obligation for us to process the information exists.


Transfer of Personal Data Outside the European Economic Area

Your personal data will not be transferred out of the European Economic Area.