Privacy Policy

Last update: 14.12.2023

Introduction: Who We Are and Why We Collect Your Information

Sigmawifi, LLC (“Sigma,” “we,” “us,” “our”) provides managed WiFi services, including procuring and installing hardware and equipment, ongoing management, monitoring, troubleshooting and upgrades to the equipment and WiFi network, (“Services”) to restaurants, hotels, golf courses, campgrounds, marinas, mobile home parks and other retail and hospitality related industries (“Customers”).

Please read the following to learn more about our Privacy Policy. By using our Services or visiting or using the our website owned and operated by Sigma under the domain, including, without limitation, the website (“Website”), you acknowledge that you accept the Terms of Use, as well as the practices and policies outlined in this Privacy Policy, and you hereby consent to our collection, use, and sharing of your information in the following ways.

1. What Does This Privacy Policy Cover?

Sigma respects the privacy of information that identifies you or is identifiable to you (“Personal Information”). This Privacy Policy covers our treatment of (1) personally identifiable information, as defined by numerous statutes in the United States (such statutes, the “PII Laws”), (2) information protected by the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) amendments, and the California Online Privacy Protection Act (“CalOPPA”), (3) the Colorado Privacy Act (“CPA”), (4) the Connecticut Personal Data Privacy and Online Monitoring Act (“CTDPA”); (5) the Montana Consumer Data Privacy Act (“MCDPA”); (6) the Oregon Consumer Privacy Act (“OCPA”); (7) the Texas Data Privacy and Security Act (TDPA”); (8) the Virginia Consumer Data Protection Act (“VCDP”), and (9) Utah Consumer Privacy Act (“UCPA”, and collectively with the PII Laws, CCPA, CPRA, CalOPPA, CPA, CTDPA, MCDPA, OCPA, TDPA, and VCDP, the “Privacy Laws”),  (collectively, “Personal Information”), which we gather when you are accessing, viewing or using our Website, and/or Services.  

In certain situations, Sigma may partner with certain third parties, such as GoZone WiFi, LLC, or refer you to third party websites or online resources in the course of providing the Services to Customers, and such third parties may have their own policies and practices regarding the collection and processing of Personal Information. The manner in which these third parties collect and process Personal Information is governed by the policies that apply to these third parties, not this Privacy Policy. Since Sigma does not control the policies of these third parties, we encourage you to review the policies of any such third parties. 

2. What Information Does Sigma Collect?

Sigma does not collect Personal Information indiscriminately. We limit the type of Personal Information and the amount of Personal Information to what is necessary to fulfill the purposes identified in this Privacy Policy. With that in mind, we collect the following types of information:

A. Information You Provide to Us

We may collect Personal Information from you when you visit our Website, register for Services, contact us with questions or concerns, and/or otherwise interact with us. For example, when you register for our Services, we may collect your name, phone number, user name, hotel room number or other accommodation information, physical address, and/or e-mail address in combination with a password or security question to access the Services, and your payment information, such as your credit or debit card. You can choose not to provide us with certain information, although that may affect the functionality of the Services.

B. Information Collected Automatically

Whenever you interact with our Website or use the Services, we automatically receive and record information on our server logs from your browser including network traffic data and usage data, which can include the amount of data used, websites and online content accessed, quality of service, and location information when your device communicates with WiFi routers or access points, data related to your use of the Services, IP address, device, and “cookie” information.

An “IP address” is a number assigned to a computer by an Internet service provider “ISP” to access the Internet. In most consumer cases, an IP address is dynamic (changing each time you connect to the Internet), not static (unique to a particular user’s computer).

“Cookies” are small text files we transfer to your computer or mobile device that allow us to recognize your browser or mobile device and make our website work more efficiently, as well as tell us how and when pages in our Website are visited and used and by how many people. You may be able to change the preferences on your browser or mobile device to send “do not track” signals or to prevent or limit your computer or device’s acceptance of cookies, but this may prevent you from taking advantage of some of our Website’s features. If you click on a link to a third party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.

C. Information from Customers

Sigma may receive Personal Information about individual users from Customers as part of facilitating the Services that Sigma provides to Customers. This information may include names, phone numbers, hotel room numbers or other accommodation information, physical addresses, and/or e-mail addresses.


D. E-mail and Other Communications

We may contact you, by email or other means; for example, we may communicate with you about your use of the Services. When we do this, we may receive a confirmation when you open an email from us. This confirmation helps us make emails more interesting and improve our service.

If you do not want to receive email or other mail from us, please inform us using the contact information in Section XIV below. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Website, and you are responsible for reviewing such legal notices for changes.

E. Video Footage

Some Customers retain Sigma to install and maintain video cameras as part of the Services. When such installation and maintenance are part of the Services, Sigma may have access to the video footage taken at the Customer’s facilities, including video images of the Customer’s guests and customers.

F. Special Categories of Personal Information and Sensitive Personal Information

Except as otherwise stated in this Privacy Policy, we do not knowingly collect Special Categories of Personal Information or Sensitive Personal Information, including (1) Personal Information revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, and (2) genetic data, biometric data, data concerning health, and data concerning a natural person’s sex life or sexual orientation, etc.

G. Personal Information Sigma Has Collected in the Last 12 Months

Sigma has collected all categories of Personal Information listed in section II (A), (B), (C), (D), and (E) of this Privacy Policy in the 12 months immediately preceding the Effective Date of this Privacy Policy. Please see the other portions of Section II above for an explanation of the categories of sources from which we collect the information described in the previous sentence. The business purposes of this information are described in Section III below. The categories of third parties we share this information with are described in Section IV.

3. What Does Sigma Do With Personal Information?

A. Personal Information Sigma Has Collected in the Last 12 Months

Sigma uses all categories of Personal Information listed above for any and all legal and legitimate businesses purposes, including:

  1. To provide, develop, maintain, and enhance the Services, and the Website;
  2. To allow users to set up their user accounts and profiles;
  3. To communicate with users and fulfill your requests for certain services;
  4. To provide support for the Services including responding to requests, questions, feedback, and technical support;
  5. To understand how users utilize the Website and Services;
  6. To protect user accounts with user names or e-mail addresses in combination with passwords;
  7. To help Customers identify users;
  8. To process payments to Sigma;
  9. To infer your geographic location;
  10. To operate, maintain, develop, and grow Sigma;
  11. To maintain the safety, security, and integrity of our Services;
  12. To send you marketing and promotional communications;
  13. To comply with legal and regulatory obligations; and
  14. To establish, enforce, and otherwise exercise our rights and defend against claims.

B. Storage of Personal Information

We store and process all electronic Personal Information that we collect in the United States.

4. Will Sigma Disclose Any of the Personal Information it Collects?

We disclose your Personal Information with third parties as described below.

A. Customers

We may provide Customers with any or all of the Personal Information we collect while you use the Services at a Customer’s facility. For example, at the request of a Customer, we may disclose the amount of data the user in a particular hotel room on a certain date downloaded or streamed through the Services. If Sigma has installed video cameras at a Customer’s facility, Sigma may share footage recorded by that camera that includes users.  

B. Affiliated Businesses and Third Party Websites We Do Not Control

In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through a website (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites as to privacy or anything else, so if you choose to enter into such transaction or to receive such service, please review the applicable third party websites’ policies.

C. Agents and Service Providers

We may disclose Personal Information to other companies or people in order to perform tasks on our behalf while providing the Services to you and our Customers. These task include, but are not limited to, cloud storage and processing credit card payments. Unless we tell you differently, our agents and service providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. We acknowledge our potential liability if our agents misuse your Personal Information.

D. Business Transfers

We may choose to buy or sell assets. In these types of transactions, Personal Information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.


E. Protection of Sigma and Others

Sigma will disclose any Personal Information that Sigma reasonably believes is necessary or appropriate to comply with law or court order, enforce or apply Sigma’s Privacy Policy, and other agreements, or protect the rights, property, or safety of Sigma, our employees, our customers, our users, the public, or others. This includes disclosing Personal Information to third parties for fraud protection and credit risk reduction. In addition, in certain situations, Sigma may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Sigma will notify you of any such requests unless prohibited by law. 

F. With Your Consent

Except as set forth above, we will obtain your consent before disclosing your Personal Information to a third party.


G. Personal Information Sigma Has Sold to Customers or Shared with Third Parties in the Last 12 Months

The CCPA (as amended by the CPRA) defines the sale of Personal Information very broadly. In the traditional sense, Sigma does not sell Personal Information, however we disclose certain Personal Information to our Customers as part of the Services we provide to them. As part of our commercial relationships with our Customers, Sigma has disclosed the following categories of Personal Information to Customers in the 12 months immediately preceding the Effective Date of this Privacy Policy, listed at the bottom of this document: names; phone numbers; user names; hotel room numbers and other accommodation information; physical addresses; e-mail addresses; credit and debit card information; contents of messages from users; network traffic data and usage data; geographic location; data related to use of Services; IP addresses; device information; “cookie” information; and video footage. Other than to our Customers as part of the Services, Sigma does not sell Personal Information.

Sigma relies on third party vendors to support the Services, including, but not limited to, cloud hosting platforms for all data storage. As a result, all Personal Information collected and described in Section II.G has been disclosed to third party vendors in the 12 months immediately preceding the Effective Date.

If and to the extent you want to opt-out of the sale, sharing, trading, or exchanging of your Personal Information, please complete and submit the Privacy Rights Request Form on this Site, and we will address such requests as described in Section VII of this Privacy Policy.

5. What Is Sigma’s Legal Basis for Collecting and Using Your Personal Information?

As relevant, Sigma collects and uses your Personal Information (1) pursuant to your informed consent, which you have granted by confirming the prompts produced by the Website and Services, consistent with this Privacy Policy, (2) in order to pursue Sigma’s legitimate business interests in providing the Services and maintaining the Website, and/or (3) in order to perform a contract to which you are a party. Any one or more of the bases in the previous sentence are the legal basis for Sigma’s collection and use of your Personal Information, depending on how your use of the Website and/or Services, and your relationship with Sigma.

6. What Is Sigma’s Legal Basis for Collecting and Using Your Personal Information?

Except upon the request of an individual, as explained in Section VII below, and except as the law permits and requires, the duration for which we retain Personal Information varies significantly, depending on the types of Services that Sigma provides to particular Customers, the duration and depth of Sigma’s relationship with any particular Customer, and the nature of the Personal Information in question. Sigma retains Personal Information for only as long as is necessary or appropriate.

7. What Are Your Rights to Control Your Personal Information?

You have the following rights regarding Sigma’s collection and use of your Personal Information, although the scope and conditions for each of these vary depending on the circumstances and local law:

A. Requests to Sigma

You may request the following from Sigma with respect to your Personal Information:

  1. Be informed about how your Personal Information is being processed, the categories of Personal Information being processed, and the categories of sources from which your Personal Information has been collected;
  2. Be informed about whether and how your Personal Information being processed is being sold, shared, traded, exchanged or brokered with unaffiliated third parties, and which categories of your Personal Information are being sold, shared, traded, exchanged or brokered with unaffiliated third parties;
  3. Access or receive a copy of your Personal Information;
  4. Rectify, update or correct inaccurate or incomplete Personal Information about you;
  5. Erasure or deletion of your Personal Information;
  6. Object and opt-out of processing of your Personal Information;
  7. Limit processing of your Personal Information;
  8. Opt-out of the sale, sharing, trading, exchange, and brokering of your Personal Information with unaffiliated third parties;
  9. Portability of your Personal Information in a commonly used format;
  10. Withdrawal of your consent to processing of your Personal Information to the extent such processing is based on your consent, provided that such withdrawal will not affect the lawfulness of Sigma’s use of your Personal Information before such withdrawal; and
  11. Non-discrimination for exercising your privacy rights.

To make a request concerning these rights, please complete and submit the Privacy Rights Request Form on our website. We will confirm receipt of all such complete Privacy Rights Request Forms within 10 days of receipt. We will substantively respond to all such requests within 30 days, subject to any lawful extension of that period. Please note that there may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized person.

Please be aware there may be valid reasons to refuse a request, including legal and regulatory requirements that we retain and process certain information. Also, please be aware that certain requests may limit or prevent us from providing Services to you. In those situations, we will notify you in writing within 30 days. You may also contact our Data Privacy Officer for help with those situations. Contact information is in Section XIV below.

Sigma will not discriminate against you if you exercise any of the foregoing rights or any other rights under Privacy Laws, including, by not denying Services to you, not providing a different level or quality of Services to you, and not suggesting that you will receive a different level or quality of Services. However, as noted above, certain requests may limit or prevent us from providing Services to you. 

Sigma retains records of all of the above requests and our responses for 24 months, unless otherwise prohibited by the Privacy Laws.

B. “Do Not Sell or Share My Personal Information”

Sigma does not sell Personal Information (although the Personal Information it provides to Customers as part of the Services may fall within the broad definition of “sell” under the CCPA, as amended under the CPRA), but your Personal Information is shared as described in Section IV above. You may opt out of Sigma’s disclosure and sharing of your Personal Information by completing and submitting the Privacy Rights Request Form.

C. Authorized Agent

You may authorize an agent to take any of the acts permitted in this Section VII on your behalf. To do so, you must provide written and signed authority to the agent, and written and signed notice to Sigma that Sigma may act on such requests by that agent.

D. Filing a Complaint

Regulatory authorities that oversee the Privacy Laws typically advise individuals to file an objection or challenge with the company before lodging a formal complaint with a regulatory authority. Please contact us as outlined in Section XIV of this Privacy Policy for any complaints and inquiries. We appreciate the opportunity to discuss and solve your complaint.

If you are dissatisfied with Sigma’s response or you wish to file a complaint with a regulatory authority first, please contact the office of the attorney general where you reside or the state agency that oversees enforcement of privacy regulation.

E. Accessibility for Users with Disabilities

If you are unable to review this Privacy Policy or any portion of this Policy, please contact us as outlined in Section XIV below.

F. Non-Discrimination

Sigma will not discriminate against you because you have exercised any of the rights above or any other rights you retain pursuant to Privacy Laws, including, but not limited to by:

  1. Denying goods or services to you;
  2. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  3. Providing a different level or quality of goods or services to you; and
  4. Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Consistent with Privacy Laws, Sigma: (i) retains the right to charge you a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to Sigma by your Personal Information; (ii) may offer financial incentives, including payments to you as compensation, for the collection, disclosure, or deletion of your Personal Information; (iii) may enter you into a financial incentive program only if Sigma clearly describes the material terms of the financial incentive program, so long as you give Sigma prior opt-in consent, which you may revoke at any time; and (iv) shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature. Please see Section VIII for an explanation of Sigma’s service differences.


8. Is Personal Information About Me Secure?

We employ appropriate administrative, organizational, technical, and physical measures to protect your Personal Information, which we regularly review and update as necessary.

If you have an account with us, that account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

The Website and Services may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

9. Children’s Privacy

We do not intend to, and do not knowingly, process Personal Information about individuals who are minors in the jurisdictions where they reside (Children). Individuals who are Children should not provide any Personal Information to us, and individuals should not provide Personal Information to us about Children. If we discover or are informed that we have Personal Information about Children, we reserve the right to delete that Personal Information from our systems.

10. Failure to Provide Personal Information

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of the Services or some of our special features.

11. Automated Decision Making

Sigma does not rely on automated decision making, including profiling, and will not subject you to decisions based solely on automated processing which will produce legal effects concerning you or similarly significantly affecting you.

12. Periodic Review

Sigma will conduct a self-assessment at least once every year to ensure that our attestations and assertions with regard to processing of Personal Information are accurate and that Sigma has appropriately implemented these practices.

13. Changes to this Privacy Policy

Sigma reserves the right to change or amend this Policy at any time and for any reasons, including to remain in compliance with Privacy Laws.

14. Questions or Concerns; Contact Information

For questions or concerns, please contact our Data Privacy Officer as follows:


Last Updated: 14.12.2023