Our Privacy Policy

Last Update

26th February 2020

Your privacy is paramount and we respect your privacy and data protection rights. When you connected to the Free WiFi Service, you agreed to use the service in accordance with the Privacy Policy below. This privacy notice aims to give you information on how we collect and process your personal data through your use of our website and our services, including any data you may provide through our websites and our services.

Please take time to read this privacy notice in full, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, to ensure that you understand and are happy with how we collect and process your personal data. This privacy notice supplements the other notices and is not intended to override them.

If you have any queries please contact us or email [email protected]


Inkspotwifi (“Inkspot”,”Inkspot WiFi”, “Inkspotwifi” , “we“, “us” or “our“) respects the privacy rights of users and recognise the importance of protecting and handling information collected in accordance with both the law and best practice. This Privacy Policy, together with our Terms of Service and any other documents referred to below (“Privacy Policy”) tells you (“you” or “your“) how your personal information is collected, used, stored and disclosed by INKSPOTWIFI as well as specific choices you can make about your information.

This Privacy Policy applies to information we collect when you use or access our online or mobile services available at www.inkspotwifi.co.uk or www.hotspotsystems.com or www.adcard.co.uk (” Site “), products, services or applications (collectively, the “INKSPOTWIFI Services”), or when you otherwise interact with us. For the purposes of understanding roles in regard to the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) –INKSPOTWIFI is defined as the data controller a company incorporated in Scotland (registered number SC384468) with registered office at Ground Floor East, Playfair House, 6 Broughton Street Lane, Edinburgh, EH1 3LY

1.        Use of the Website and the Services is also governed by the INKSPOTWIFI Privacy Policy which is incorporated into the terms and conditions.

2.        INKSPOTWIFI, as Data Controller, appoints The Client under license to gain access to and use the Personal Data from its own venues as described in the Term & Conditions of use.

3.        INKSPOTWIFI will only process the Personal Data to provide the Services or otherwise to comply with applicable laws or regulatory requirement.

4.        INKSPOTWIFI will ensure that any person with access to or processing the Personal Data is subject to a duty of confidence.

5.        INKSPOTWIFI will take appropriate technical and organisational security measures to ensure the security of processing and protect the Personal Data from accidental or unlawful destruction, loss, alteration, unauthorised access or disclosure or unlawful processing.

6.        INKSPOTWIFI authorises The Client to appoint sub-processors as they deem appropriate or necessary for the provision of the Services.

7.        INKSPOTWIFI will assist The Client in providing subject access and allowing data subjects to exercise their rights under the GDPR.

8.        INKSPOTWIFI will assist The Client in meeting its GDPR obligations in relation to the security of processing, the notification of personal data breaches and data protection impact assessments.

9.        INKSPOTWIFI will provide mechanisms to delete the record of a single Data Subject, and to delete all Personal Data at the end of the contract. Contact [email protected]

10. INKSPOTWIFI will immediately inform The Client if it appears they are infringing the GDPR or other data protection law of the EU or a member state.

11. Nothing within this contract relieves INKSPOTWIFI as Data Controller or The Client as Data Processor of its own direct responsibilities and liabilities under the GDPR.

Please read the following carefully to understand how we will collect, use and protect your personal information.

Changes to This Policy

We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the “Last Update” date at the top of this Privacy Policy. If there are material changes to this Privacy Policy, we will notify you more directly, for example by posting a clear notice on our homepage or by sending you an email prior to the change becoming effective. We therefore encourage you to review our Privacy Policy whenever you access the INKSPOTWIFI Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy, you will need to deactivate your account with us and stop using the INKSPOTWIFI Services.


If you have any questions about this Privacy Policy or the information that we hold about you, please contact us as provided in the Contacting Us section below.

Information Collected

We collect a variety of information to enable us to provide the INKSPOTWIFI Service, improve our Site and enhance our users’ experience of our services; for example, by determining the location of your Internet Service Provider (“ISP“) we are able to serve a localised version of our Site (for example enabling contact, language and currency modifications). For more information about the purposes for which we use your information please see the Use of Information section below.

We collect the following information (which may include personal information):

1.        Information You Provide To Us

·        We collect information you provide directly to us when you use the Site and when you register for and use the INKSPOTWIFI Services. Examples include: name and gender.

·        We collect information when you register with INKSPOTWIFI for an account, create or modify your profile and online account, access and use the INKSPOTWIFI Services (including but not limited to when you upload, download, collaborate on or share files or other information. The types of information we may collect directly from you include your name, username, email address, postal address, phone number, information about your data storage preferences, employer’s name, job title, transactional information (including services purchased or subscribed to and billing address) as well as any contact or other information you choose to provide. We also store the files or other information that you upload or provide to the INKSPOTWIFI Services (“Content“).

·        If you are providing information (including personal information) about someone else you confirm that they have appointed you to act for them and consent to the processing of their personal information and that you have informed them of our identity and the purposes (as set out in this Privacy Policy) for which their personal information will be processed.

·        If you contact us, we may keep a record of that correspondence.

2.        Information We Collect Automatically – When you access or use the INKSPOTWIFI Services, we may automatically collect information about you, including:

·        We monitor user activity in connection with the INKSPOTWIFI Services and may collect information about the applications and features you use, the websites you visit, the sizes and names of the files or folders you upload, download, share or access while using the INKSPOTWIFI Services, the Content you access and any actions taken in connection with the access and use of your Content in the INKSPOTWIFI Services.

·        Log Information: We log information about you when you access and use the INKSPOTWIFI Services including your Internet Protocol (“IP“) address, access times, browser type and language, ISP, the Web pages that you visit, the Content you use and the URL of the Web page you visited before navigating to the INKSPOTWIFI Services.

·        Device Information: If you access the INKSPOTWIFI Services from a mobile device, we collect information about the device, including the hardware model, operating system and version, unique device identifiers, mobile network information (as allowed by the mobile network) or platform information (as allowed by the specific platform type). We do not ask for, access, or track any location-based information from your mobile device at any time while downloading or using our mobile application.

3.        Information Collected by Cookies and Other Tracking Technologies: We use various tracking technologies such as cookies to collect information and distinguish you from other users of our Site, which may include saving cookies to your computer or mobile device. This helps us to provide you with a good experience when you browse and use our INKSPOTWIFI Services and also allows us to improve our INKSPOTWIFI Services. For more information about how we use cookies and other tracking technologies see the Cookies section below.


4.        Information We Collect From Other Sources. We may also obtain information from third parties and combine that with information we collect through the INKSPOTWIFI Services. For example, we may have access to certain information from a third-party social media service if you create or log into your online account through the service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party social media service is in accordance with the authorisation procedures determined by the social media service.

Using Information

We may use the information (which may include personal information) we collect about you for a variety of purposes, including to:

1.        Provide, operate, maintain and improve the INKSPOTWIFI Services;

2.        Enable you to access and use the INKSPOTWIFI Services, including uploading, downloading, collaborating on and sharing Content and sending emails on your behalf;

3.        Send you technical notices, updates, security alerts and support and administrative messages;

4.        Provide and deliver the services and features you request, process and complete transactions, and send you related information, including purchase confirmations and invoices;

5.        Respond to your comments, questions, and requests and provide customer service and support;

6.        Communicate with you, where you have agreed or where the law permits, for marketing purposes, including to periodically informing you about services and features. We will only share your personal information with anyone else for marketing purposes and/or send you promotional materials where you have given your explicit consent to this processing of your personal information.

7.        Monitor and analyse trends, usage, and activities in connection with the INKSPOTWIFI Services;

8.        Investigate and prevent fraudulent transactions, unauthorised access to the INKSPOTWIFI Services, and other illegal activities;

9.        Personalise and improve the INKSPOTWIFI Services, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customise your experience on the INKSPOTWIFI Services;

10. To process your payment details in order to complete any payment that you make in relation to the Site;

11. To create anonymised data (which we may licence to third parties directly);

12. Link or combine with other information we receive from third parties to help understand your needs and provide you with better service;

13. Enable you to communicate, collaborate, and share files with users you designate; and

14. For other purposes about which we notify you.

Where We Store Your Information

INKSPOTWIFI is based in the United kingdom and your information is stored within the European Economic Area


Transfer of Personal Data Outside the European Economic Area
We will not transfer your personal data out of the European economic Area.

Sharing and Disclosure of Information

We will not share personal information about you or any Content with any third parties except as described in this Privacy Policy or in connection with the INKSPOTWIFI Services. We will only use your personal information for marketing purposes where you have explicitly consented to this processing.


When you use our website, we share information that we may collect from you, such as your email (in hashed, de-identified form), IP address or information about your browser or operating LIVERAMP CONFIDENTIAL 4 system, with our partner, LiveRamp Inc and its group companies (‘LiveRamp’). LiveRamp may drop a cookie on your browser or directly in our emails and match your shared information to their on- and offline marketing databases and those of its advertising partners to create a link between your browser and information in those other databases. Similarly, when you use our mobile apps, we may also share hashed and de-identified email addresses, mobile device ID, location data, and advertising identifiers with LiveRamp, which uses that information to create a link between your mobile device and its databases. This link may be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (e.g. cross device, web, email and in app etc.) by third parties unaffiliated with our website. These third parties may in turn link further demographic or interest-based information to your browser. You have the right to exercise your rights under GDPR including opting out of LiveRamp’s Cookie or Mobile Identifiers and can easily do so by clicking on this link: https://your-rights.liveramp.uk/home


For example, we may share personal information about you including as follows:

1.  Vendors, Consultants and Other Service Providers We may share your information with third-party vendors, consultants and other service providers who are working on our behalf and require access to your information to carry out that work and provide the services to you.

2.  Corporate Account If you are an individual INKSPOTWIFI registered user and the domain of the primary email address associated with your INKSPOTWIFI account is owned by your employer and was assigned to you as an employee of that organisation, and such organisation wishes to establish a INKSPOTWIFI account, then certain information concerning use of your individual account may become accessible to that organisation’s administrator including your email address.

3. With Your Consent We may share your information with your consent, including when you choose to use collaboration features in the INKSPOTWIFI Services that by their nature support sharing with third parties who you choose. Your name, email address, information from your profile and online account (including your photo), and any Content you choose to share will be shared with such third parties, and such third parties may communicate with you (such as by posting comments or emailing you).

4.  Third Party Applications – INKSPOTWIFI provides you with opportunities to connect with third-party applications or services. If you choose to use any such third-party applications or services, we may share information about you including your username and any Content you choose to use in connection with those applications and services, and such third parties may contact you directly as necessary. This Privacy Policy does not apply to your use of such third-party applications and services, and we are not responsible for how those third parties collect, use and disclose your information and Content. We encourage you to review the privacy policies of those third parties before connecting.

5. Compliance with Laws – We may disclose your information to a third party if,

·        We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request.

·        To enforce our agreements, policies and Terms of Service.

·        To protect the security or integrity of the INKSPOTWIFI Services.

·        To protect INKSPOTWIFI, our customers or the public from harm or illegal activities.

·        To respond to an emergency, which we believe in the good faith, requires us to disclose information so preventing criminal activity.

6. Business Transfers – We may disclose you personal information to a seller, buyer or merger partner In the event that we sell, merge with or buy all or a substantial portion of any business or assets.

7.    Aggregated or Unidentifiable Data We may also share aggregated anonymised information with third parties (such aggregated data does not directly identify you).

8.   Our Group We may disclose your personal information to any member of our group, which means any company, which controls, is controlled by or is under common control with INKSPOTWIFI.


While no service is completely secure, INKSPOTWIFI takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction. For example, we encrypt your Content when it is stored in our data centres. In addition, sensitive information such as credit card number and password that we request from you on the INKSPOTWIFI Services is protected with encryption, such as Secured Socket Layer (SSL) protocol, during transmission over the Internet.

The servers on which personal information is stored are kept in a controlled environment with limited access. While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. In addition, we cannot guarantee that any passively-collected personal information you choose to include in documents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.


You may access your account information and our service only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.

Cookie Policy

We use various tracking technologies such as cookies to collect information and distinguish you from other users of the INKSPOTWIFI Services, which may include saving cookies to your computer or mobile device. This helps us to provide you with a good experience when you browse and use our INKSPOTWIFI Services and also allows us to improve our INKSPOTWIFI Services. By using the Site and the INKSPOTWIFI Services you accept the use of cookies, in particular Analytics Cookies, in accordance with this Cookie Policy.

If you do not accept the use of cookies, please follow the below instructions to disable them.

How to disable them?


Internet Explorer 11 for Windows 10

1.        In Internet Explorer, select the Tools button, and then select Internet options.

2.        Select the Privacy tab, and under Settings, select Advanced and choose if you want to allow, block or b prompted for first and third-party cookies. To block or allow cookies


1.        In Internet Explorer, select the Tools button, and then select Internet options.

2.        Select the Privacy tab, and under Settings, move the slider to the top to block all cookies (or the bottom to allow all cookies), and then select OK.



1.        Click the menu button and choose Preferences.

2.        Select the Privacy panel and go to the History section.

3.        In the drop-down menu, next to Firefox will: choose Use custom settings for history.

4.        Check mark Accept cookies from sites to enable cookies, and uncheck it to disable them

5.        Choose how long cookies are allowed to be stored:

Keep until:

·        they expire: Each cookie will be removed when it reaches its expiration date, which is set by the site that sent the cookie.

·        I close Firefox: The cookies that are stored on your computer will be removed when Firefox is closed.

6.        Close the about:preferences page. Any changes you’ve made will automatically be saved.



1.        On your computer, open Chrome.

2.        At the top right, click More Settings.

3.        At the bottom, click Advanced.

4.        Under “Privacy and security”, click Content settings.

5.        Click Cookies.

6.        Turn Allow sites to save and read cookie data on or off.



Choose Safari > Preferences, click Privacy, then do any of the following.

Change which cookies and website data are accepted: Select a “Cookies and website data” option:

1.        Always block: Safari doesn’t let any websites, third parties, or advertisers store cookies and other data on your Mac. This may prevent some websites from working properly.

2.        Allow from current website only: Safari accepts cookies and website data only from the website you’re currently visiting. Websites often have embedded content from other sources. Safari does not allow these third parties to store or access cookies or other data.

3.        Allow from websites I visit: Safari accepts cookies and website data only from websites you visit. Safari uses your existing cookies to determine whether you have visited a website before. Selecting this option helps prevent websites that have embedded content in other websites you browse from storing cookies and data on your Mac.

4.        Always allow: Safari lets all websites, third parties, and advertisers store cookies and other data on your Mac.

What is a cookie?


”Cookies are small data files sent by a website containing information that is stored on your browser or hard drive of your computer”

Your Choices & Privacy management

Account Information & Retention – You may update, correct or delete information that we control about you at any time by clicking on our Privacy Manager, Located in the bottom right hand side of this website, or by emailing us at [email protected].


You may be asked for your Audit ID, please make sure to keep a note of this. Your Audit ID can be found in the privacy manager.


We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy. If you wish to deactivate your account, please email us at [email protected].

In some circumstances we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. We will respond to your access request within 30 days. To request removal of your personal information, which we hold, contact us at the email address listed above. In some cases, 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.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information to comply with our legal obligations, resolve disputes and enforce our agreements.

Promotional Communications – To stop receiving emails from us follow the unsubscribe instructions provided in those emails. You may still receive emails such as security alerts and notices related to your access to or use of the INKSPOTWIFI Services or those about your online account or our on-going business relations.


Cookies/tracking technologies – Most web browsers (such as Internet Explorer, FireFox and Safari) are set to automatically accept cookies as the default setting. If you don’t want to receive cookies or other tracking technologies, you can follow the instructions provided in the section “Cookie Policy” above. Alternatively, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie. You can also delete cookies that have already been set. The “Help” function within your browser should tell you how.

Social Media Features and Widgets


Our website includes third party social media features, such as the Facebook Like button and third party widgets. These features may collect your IP address, which page you are visiting on our site, and set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the third party company providing it.



Our website offers publicly accessible blogs or community pages. You should be aware that any information you provide in these areas might be read, collected and used by others who access them. We do not moderate these blogs or community pages and cannot be held liable for their content.



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.

Linking to Third Party Websites


We may place links on the INKSPOTWIFI Services. When you click on a link to a third party website from our website, your activity and use on the linked website is governed by that website’s policies, not by those of INKSPOTWIFI. We encourage you to visit their websites and review their privacy and user policies. We do not accept any responsibility or liability for these policies.

Our Policy Towards Children


The INKSPOTWIFI Services are not directed to individuals under 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information, please contact us at [email protected]. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information.

Contacting Us

Any questions, comments and requests regarding this Privacy Policy should be addressed to [email protected].

The End