Privacy Policy

At Travelwifi, we believe that anyone who uses the internet should be fully aware of how their information is used - so we've put together this document to explain exactly how we approach handling your data.

Before you read it, the most important thing you need to know is this: your privacy is as important to us as it is to you. Giving us your personal details is an act of trust, and one that we take seriously. We will never show your details to anyone else, sell, rent or otherwise disclose any of your personal information, including your email address, to any third party without your prior and explicit consent.

What this policy covers

Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you.

This Privacy Policy covers the information we collect about you when you use our products or services, or otherwise interact with us, unless a different policy is displayed. Travelifi, we and us refers to Fonmigo Ltd., based in the UK, operating under the brand Travewifi. We offer a wide range of products, and refer to all of these products, together with our other services and websites as "Services" in this policy.

This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

What information we collect about you

We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.

Information you provide to us

We collect information about you when you input it into the Services or otherwise provide it directly to us.

Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services. These include: Contact information, delivery information and billing information when you register for the Services.

Content you provide through our websites:  Content you provide through our websites: We collect other content that you submit to our website, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.

Information you provide through our support channels: The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.

Payment Information:  We collect certain payment and billing information when you register for Services. For example, we ask you for name and contact information upon registration. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.

Information we collect automatically when you use the Services

We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.

Your use of the Services:  We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use and the links you click on.

Device and Connection Information:  We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages and device identifiers. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.

Cookies and Other Tracking Technologies:  Travelwifi and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookies and Tracking Notice, which includes information on how to control or opt out of these cookies and tracking technologies.

How we use information we collect

How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.

To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services.

To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including confirming your purchases, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. These communications are part of the Services and in most cases you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.

To market, promote and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by Travelwifi ads on other companies' websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions and contests. You can control whether you receive these communications as described below under "Opt-out of communications."

Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services.

For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.

To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.

Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:


      • We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
      • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
      • You give us consent to do so for a specific purpose; or
      • We need to process your data to comply with a legal obligation.


If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

How we share information we collect

We want our Services to work well for you. This means sharing information with certain third parties. We share information we collect about you in the ways discussed below, but we are not in the business of selling information about you to advertisers or other third parties.

Sharing with third parties

We share information with third parties that help us operate, provide, support and market our Services.

Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.

Travelwifi Partners: We work with third parties who provide logistics and customer service services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services, such as to assist with delivery, billing and collections, to provide localized support. We may also share information with these third parties where you have agreed to that sharing.

Social Media Widgets: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.

Third-Party Widgets: Some of our Services contain widgets and social media features, such as the Twitter "tweet" button. These widgets and features collect your IP address, which page you are visiting on the Services, and may set a cookie to enable the feature to function properly. Widgets and social media features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing it.

With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.

Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Tep, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

Sharing with affiliated companies

We may share or transfer information we collect under this privacy policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Services if a transaction takes place, as well as any choices you may have regarding your information. The protections of this privacy policy apply to the information we share in these circumstances.

How we store and secure information we collect

Information storage and security

We use data hosting service providers in the United States and Ireland to host the information we collect, and we use technical measures to secure your data.

While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.

If you use our Services, responsibility for securing storage and access to the information you put into the Services rests with you and not Tep.

How long we keep information

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your Tep account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

Backups are stored for 30 days

How to access and control your information

You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.

Your Choices:

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.

Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Access and update your information: Our Services give you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.

Deactivate your account: If you no longer wish to use our Services, you may be able to deactivate your Services account. If you can deactivate your own account, that setting is available to you in your account settings. Please be aware that deactivating your account does not delete your information; your information remains visible to other Service users based on your past participation within the Services. For more information on how to delete your information, see below.

Delete your information: You can remove certain profile information within your profile settings. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved.

Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings.

Turn off Cookie Controls: Relevant browser-based cookie controls are described in the section "Cookies & Tracking Notice".

Send "Do Not Track" Signals: Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Services do not currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving marketing from us as described above.

How we transfer information we collect internationally

International transfers of information we collect

We collect information globally and primarily store that information in the United States and Ireland. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.

International transfers to third parties: Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the European Economic Area or Switzerland, we make use of European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.

Cookies & Tracking Notice

Travel Wifi and our third party partners, such as our advertising and analytics partners, use various technologies to collect information, such as cookies and web beacons.

What types of technologies do we use?

We use cookies, web beacons and other technologies to improve and customize Services and your experience; to allow you to access and use the Services without re-entering your username or password; to understand usage of our Services and the interests of our customers; to determine whether an email has been opened and acted upon; and to present you with advertising relevant to your interests.

How do we use them?

Where strictly necessary: These cookies and other technologies are essential in order to enable the Services to provide the feature you have requested, such as remembering you have logged in.

For functionality: These cookies and similar technologies remember choices you make such as language or search parameters. We use these cookies to provide you with an experience more appropriate with your selections and to make your use of the Services more tailored.

For performance and analytics: These cookies and similar technologies collect information on how users interact with the Services and enable us to improve how the Services operate. For example, we use Google Analytics cookies to help us understand how visitors arrive at and browse our products and website to identify areas for improvement such as navigation, user experience, and marketing campaigns.

Targeting Cookies or Advertising Cookies: These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. They remember the websites you have visited and that information is shared with other parties such as advertising technology service providers and advertisers.

Social media cookies: These cookies are used when you share information using a social media sharing button or "like" button on our websites or you link your account or engage with our content on or through a social media site. The social network will record that you have done this. This information may be linked to targeting/advertising activities.

How can you opt-out?

To opt-out of our use of cookies, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our Services. Travelwifi and our third-party partners also collect information using web beacons (also known as "tracking pixels"). Many browsers include their own management tools for removing HTML5 local storage objects. You may be able to opt out of receiving personalized advertisements as described in the Privacy Policy under "Your Choices." You will not be able to opt-out of any cookies or other technologies that are "strictly necessary" for the Services.

Other important privacy information

Our policy towards children

The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us.

Changes to our Privacy Policy

We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We encourage you to review our privacy policy whenever you use the 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, you will need to stop using the Services and deactivate your account(s), as outlined above.

Data Processing Agreement

This Data Processing Agreement ("Agreement") is incorporated by reference into Tep Wireless Terms of Service and entered into between Tep Wireless. and you (the "Controller"), and reflects the parties' agreement with regard to the Processing of Personal Data in accordance with the requirements of the Data Protection Laws (as defined herein).
Capitalized terms not otherwise defined herein shall have the meaning given to them in the Terms of Service for products and services between Tep Wireless and the Controller (the "Principal Agreement"). Except as modified below, the terms of the Principal Agreement shall remain in full force and effect.
Except where the context requires otherwise, references in this Agreement to the Principal Agreement are to the Principal Agreement as amended by, and including, this Agreement.


1.1 In this Agreement, the following terms shall have the meanings set out below:
1.1.1 "Adequate Level of Protection" means a finding under the relevant Data Protection Laws that a transfer of personal data to a third country or an international organization may take place because the third country or international organization in question ensures an adequate level of protection by way of a certification (such as Privacy Shield), contract, or other legal act.
1.1.2 "Applicable Laws" means (a) European Union or Member State laws with respect to any Controller Personal Data in respect of which Controller is subject to EU Data Protection Laws; and (b) any other applicable law with respect to any Controller Personal Data in respect of which Controller is subject to any other Data Protection Laws;
1.1.3 "Controller Affiliate" means an entity that owns or controls, is owned or controlled by or is or under common control or ownership with Controller, where control is defined as the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract or otherwise;
1.1.4 "Controller Personal Data" means any Personal Data Processed by a Contracted Processor on behalf of Controller;
1.1.5 "Contracted Processor" means Tep Wireless or a Subprocessor;
1.1.6 "Data Protection Laws" means EU Data Protection Laws and, to the extent applicable, the data protection or privacy laws of any other country;
1.1.7 "EEA" means the European Economic Area;
1.1.8 "EU Data Protection Laws" means EU Directive 95/46/EC, as transposed into domestic legislation of each Member State and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR;
1.1.9 "GDPR" means EU General Data Protection Regulation 2016/679;
1.1.10 "Privacy Shield" means the EU-U.S. and SWISS-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.
1.1.11 "Restricted Transfer" means: a transfer of Controller Personal Data from Controller to a Contracted Processor; or an onward transfer of Controller Personal Data from a Contracted Processor to a Contracted Processor, or between two establishments of a Contracted Processor,
in each case, where such transfer would be prohibited by Data Protection Laws (or by the terms of data transfer agreements put in place to address the data transfer restrictions of Data Protection Laws) in the absence of an Adequate Level of Protection;
1.1.12 "Services" means the services and other activities to be supplied to or carried out by or on behalf of Tep Wireless for Controller; and
1.1.13 "Subprocessor" means any person (including any third party, but excluding an employee of Tep Wireless or any of its sub-contractors) appointed by or on behalf of Tep Wireless to Process Personal Data on behalf of Controller.
1.2 The terms, "Commission", "Controller", "Data Subject", "Member State", "Personal Data", "Personal Data Breach", "Processing" and "Supervisory Authority" shall have the same meaning as in the GDPR, and their cognate terms shall be construed accordingly.

2.Details of the Processing

2.1  Categories of Data Subjects. The Data Subjects are Controller's End Users who purchase products and/or services from Controller or submitted a review via the onsite reviews widget that is installed on the Controller website, and the Controller's employees.
2.2  Types of Personal Data. The Personal Data processed is name, email address, telephone number, email data, system usage data, location data (physical address, IP address), and other electronic data submitted, stored, sent, or received by the Data Subjects.
2.3  Subject Matter and Nature of Processing. The Subject Matter of Processing the Personal Data is the provision of services to the Controller that requires the Processing of Personal Data as set forth in the Principal Agreement.
2.4  Purpose of Processing. Personal Data will be processed for purposes of providing the services set forth in a Principal Agreement between Tep Wireless and the Controller.
2.5  Duration of Processing. The Personal Data will be processed for the duration of the Principal Agreement.
2.6  Subprocessors. Travelwifi may share End-Users personal information with some or all of the following Tep Wireless partners, as described below, depending upon which functions you enable:


      •  AWS – to host back ups
      •  Google Gdocs – to process and track order data.
      •  Linode – to host our website
      •  Stripe – to process customer payments
      •  Paypal – to process customer payments
      •  Twilio – to allow SMS messaging
      •  Mailchimp – used for email marketing
      •  GetAmbassador – used for referral scheme; both referrer and referee
      •  Ingram Micro – fulfilment and logistics
      •  Yotpo – website feedback system
      •  Imaginary Cloud – website development
      •  Hotjar – user feedback and website tracking


3. Processing of Controller Personal Data

3.1 Tep Wireless shall:
3.1.1 comply with all applicable Data Protection Laws in the Processing of Controller Personal Data; and
3.1.2 not Process Controller Personal Data other than on the relevant Controller's written instructions unless Processing is required by Applicable Laws to which the relevant Contracted Processor is subject, in which case Tep Wireless shall to the extent permitted by Applicable Laws inform the relevant Controller of that legal requirement before the relevant Processing of that Personal Data.
3.2 Controller:
3.2.1 instructs Tep Wireless (and authorizes Tep Wireless to instruct each Subprocessor) to: Process Controller Personal Data; and in particular, transfer Controller Personal Data to approved countries in accordance with this Agreement, as reasonably necessary for the provision of the Services and consistent with the Principal Agreement; and
3.2.2 warrants and represents that it is and will at all relevant times remain duly and effectively authorised to give the instruction set out in section 3.2.1 on behalf of each relevant Controller Affiliate. 3.2.1 on behalf of each relevant Controller Affiliate.

4. Tep Wireless Personnel

Tep Wireless shall take reasonable steps to ensure the reliability of any employee, agent or contractor of any Contracted Processor who may have access to the Controller Personal Data, ensuring in each case that access is strictly limited to those individuals who need to know / access the relevant Controller Personal Data, as strictly necessary for the purposes of the Principal Agreement, and to comply with Applicable Laws in the context of that individual's duties to the Contracted Processor, ensuring that all such individuals are subject to confidentiality undertakings or professional or statutory obligations of confidentiality.

5. Security

5.1 Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Tep Wireless shall in relation to the Controller Personal Data implement appropriate technical and organizational measures to ensure a level of security appropriate to that risk, including, as appropriate, the measures referred to in Article 32(1) of the GDPR.
5.2 In assessing the appropriate level of security, Tep Wireless shall take account in particular of the risks that are presented by Processing, in particular from a Personal Data Breach.

6. Subprocessing

6.1 Controller authorizes Tep Wireless to appoint (and permit each Subprocessor appointed in accordance with this section 6 to appoint) Subprocessors in accordance with this section 6 and any restrictions in the Principal Agreement.
6.2 Tep Wireless may continue to use those Subprocessors already engaged by Tep Wireless as at the date of this Agreement, which are set forth in 2.6 above, which Processor may update from time to time, subject to Controller's prior written approval.
6.3 Tep Wireless shall give Controller prior written notice of the appointment of any new Subprocessor, including full details of the Processing to be undertaken by the Subprocessor. If, within ten days of receipt of that notice, Controller notifies Tep Wireless in writing of any objections (on reasonable grounds) to the proposed appointment:
6.3.1 Tep Wireless shall work with Controller in good faith to make available a commercially reasonable change in the provision of the Services which avoids the use of that proposed Subprocessor; and
6.4 With respect to each Subprocessor, Tep Wireless shall:
6.4.1 before the Subprocessor first Processes Controller Personal Data (or, where relevant, in accordance with section 6.2), carry out adequate due diligence to ensure that the Subprocessor is capable of providing the level of protection for Controller Personal Data required by the Principal Agreement;
6.4.2 ensure that the arrangement between on the one hand (a) Tep Wireless, or (b) the relevant intermediate Subprocessor; and on the other hand the Subprocessor, is governed by a written contract including terms which offer at least the same level of protection for Controller Personal Data as those set out in this Agreement and meet the requirements of article 28(3) of the GDPR;
6.4.3 if that arrangement involves a Restricted Transfer, ensure that an Adequate Level of Protection exists before the Subprocessor first Processes Controller Personal Data; and
6.4.4 provide to Controller for review such copies of the Contracted Processors' agreements with Subprocessors (which may be redacted to remove confidential commercial information not relevant to the requirements of this Agreement) as Controller may request from time to time.
6.5 Tep Wireless shall ensure that each Subprocessor performs the obligations under sections 3.1457.18.29 and 11.1, as they apply to Processing of Controller Personal Data carried out by that Subprocessor, as if it were party to this Agreement in place of Tep Wireless.
6.6 Controller acknowledges and agrees that Tep Wireless has appointed Amazon Web Services as a Subprocessor for cloud storage of data.

7. Data Subject Rights

Taking into account the nature of the Processing, Tep Wireless shall assist Controller by implementing appropriate technical and organizational measures to respond to requests to exercise Data Subject rights under the Data Protection Laws.

8. Personal Data Breach

8.1 Tep Wireless shall notify Controller without undue delay upon Tep Wireless or any Subprocessor becoming aware of a Personal Data Breach affecting Controller Personal Data
8.2 Tep Wireless shall co-operate with Controller and take such reasonable commercial steps as are directed by Controller to assist in the investigation, mitigation and remediation of each such Personal Data Breach.

9. Data Protection Impact Assessment and Prior Consultation

Tep Wireless shall provide reasonable assistance to Controller with any data protection impact assessments, and prior consultations with Supervising Authorities or other competent data privacy authorities, which Controller reasonably considers to be required of Controller by article 35 or 36 of the GDPR or equivalent provisions of any other Data Protection Law, in each case solely in relation to Processing of Controller Personal Data by, and taking into account the nature of the Processing and information available to, the Contracted Processors.

10. Deletion or return of Controller Personal Data

10.1 Subject to sections  10.2 and  10.3  Tep Wireless shall within 45 of the date of cessation of any Services involving the Processing of Controller Personal Data(the "Cessation Date"), return or delete all copies of those Controller Personal Data.
10.2 Subject to section  10.3 , Controller may in its absolute discretion by written notice to Tep Wireless within 45 days of the Cessation Date require Tep Wireless to (a) return a complete copy of all Controller Personal Data to Controller by secure file transfer in such format as is reasonably notified by Controller to Tep Wireless; and (b) delete and procure the deletion of all other copies of Controller Personal Data Processed by any Contracted Processor. Tep Wireless shall comply with any such written request within 45 of the Cessation Date.
10.3 Each Contracted Processor may retain Controller Personal Data to the extent required by Applicable Laws and only to the extent and for such period as required by Applicable Laws and always provided that Tep Wireless shall ensure the confidentiality of all such Controller Personal Data and shall ensure that such Controller Personal Data is only Processed as necessary for the purpose(s) specified in the Applicable Laws requiring its storage and for no other purpose.
10.4 Tep Wireless shall provide written certification to Controller that it has fully complied with this section  10  within 60 days of the Cessation Date.

11. Audit rights

11.1 Subject to section 11.2, Tep Wireless shall make available to Controller on request all information necessary to demonstrate compliance with this Agreement, and shall allow for and contribute to audits, including inspections, by Controller or an auditor mandated by Controller in relation to the Processing of the Controller Personal Data by the Contracted Processors.
11.2 Information and audit rights of the Controller only arise under section  11.1 to the extent that the Principal Agreement does not otherwise give them information and audit rights meeting the relevant requirements of Data Protection Law (including, where applicable, article 28(3)(h) of the GDPR).
11.3 Controller or the relevant Controller Affiliate undertaking an audit shall give Tep Wireless reasonable notice of any audit or inspection to be conducted under section  11.1 and shall make (and ensure that each of its mandated auditors makes) reasonable endeavors to avoid causing (or, if it cannot avoid, to minimize) any damage, injury or disruption to the Contracted Processors' premises, equipment, personnel and business while its personnel are on those premises in the course of such an audit or inspection. A Contracted Processor need not give access to its premises for the purposes of such an audit or inspection:
11.3.1 to any individual unless he or she produces reasonable evidence of identity and authority;
11.3.2 outside normal business hours at those premises, unless the audit or inspection needs to be conducted on an emergency basis and Controller or the relevant Controller Affiilate undertaking an audit has given notice to Tep Wireless that this is the case before attendance outside those hours begins; or
11.3.3 for the purposes of more than one audit or inspection, in respect of each Contracted Processor, in any calendar year, except for any additional audits or inspections which: Controller or the relevant Controller Affiliate undertaking an audit reasonably considers necessary because of genuine concerns as to Tep Wireless compliance with this Agreement; or Controller is required or requested to carry out by Data Protection Law, a Supervisory Authority or any similar regulatory authority responsible for the enforcement of Data Protection Laws in any country or territory, where Controller or the relevant Controller Affiliate undertaking an audit has identified its concerns or the relevant requirement or request in its notice to Tep Wireless of the audit or inspection.

12. General Terms

Governing law and jurisdiction
12.1 Without prejudice to clauses 7 (Mediation and Jurisdiction) and 9 (Governing Law):
12.1.1 the parties to this Agreement hereby submit to the venue stipulated in the Principal Agreement with respect to any disputes or claims howsoever arising under this Agreement, including disputes regarding its existence, validity or termination or the consequences of its nullity; and
12.1.2 this Agreement and all non-contractual or other obligations arising out of or in connection with it are governed by the laws of the country or territory stipulated for this purpose in the Principal Agreement.
Order of precedence
12.2 Nothing in this Agreement reduces Tep Wireless obligations under the Principal Agreement in relation to the protection of Personal Data or permits Tep Wireless to Process (or permit the Processing of) Personal Data in a manner which is prohibited by the Principal Agreement.
12.3 Subject to section 12.2, with regard to the subject matter of this Agreement, in the event of inconsistencies between the provisions of this Agreement and any other agreements between the parties, including the Principal Agreement and including (except where explicitly agreed otherwise in writing, signed on behalf of the parties) agreements entered into or purported to be entered into after the date of this Agreement, the provisions of this Agreement shall prevail.
Changes in Data Protection Laws, etc.
12.4 Controller may propose any other variations to this Agreement which Controller reasonably considers to be necessary to address the requirements of any Data Protection Law.
12.5 If Controller proposes variations under section 12.4, the parties shall promptly discuss the proposed variations and negotiate in good faith with a view to agreeing and implementing those or alternative variations designed to address the requirements identified in Controller's notice as soon as is reasonably practicable.
12.6 Neither Controller nor Tep Wireless shall require the consent or approval of any Controller Affiliate to amend this Agreement pursuant to this section 12 or otherwise.
12.7 Should any provision of this Agreement be invalid or unenforceable, then the remainder of this Agreement shall remain valid and in force. The invalid or unenforceable provision shall be either (i) amended as necessary to ensure its validity and enforceability, while preserving the parties' intentions as closely as possible or, if this is not possible, (ii) construed in a manner as if the invalid or unenforceable part had never been contained therein.

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Your information is controlled by Fonmigo Ltd. If you have questions or concerns about how your information is handled, please direct your inquiry to Fonmigo Ltd., which we have appointed to be responsible for facilitating such inquiries,

Fonmigo Ltd. DBA Travelwifi 

Unit 217, 222 Kensal Road, 
London W10 5BN, UK