Privacy Policy

Introduction

7SIGNAL Solutions, Inc. (7SIGNAL) respects your privacy and is committed to protecting it through our compliance with all applicable laws and this Notice.

This Notice describes the personal data that we collect, how that data is processed, and your rights and choices in relation to it.

7SIGNAL may change this Notice from time to time, due to changes in our business, technology, applicable laws, or any other reason. Please check this page from time to time to be informed of the latest changes.

  1. 7SIGNAL’s Role

    7SIGNAL is a provider of Wi-Fi network management services. Our customers are generally large organizations such as hospitals, educational institutions, enterprises, managed service providers, retail stores, warehouses, or manufacturing and distribution centers. Our Sapphire EyeTM(network hardware) and Mobile EyeTM(user device software) products (the “Wi-Fi Products”) help our customers to test, optimize the performance of and identify and resolve problems with their Wi-Fi networks. This may involve the collection of certain personal data from employees, clients, or other visitors, which is then processed by 7SIGNAL on our customers’ behalf.

    In these cases, the “data controller” (the entity that decides on the purposes of the data processing and ways in which it is processed) is our customer, and 7SIGNAL is a “data processor” that processes data on behalf of and on the instructions of each customer. In this Notice, we set out some general information about 7SIGNAL’s data processing but you should consult the relevant data controller for further details.

    For other data processing activities, relating to data collected from staff working for our customers and suppliers, or visitors to our website, 7SIGNAL is the data controller.

    For any question or request relating to personal data processing., 7SIGNAL can be contacted at:

    7SIGNAL Solutions, Inc
    6155 Rockside Road, Suite 110
    Independence, Ohio 44131
    info@7signal.com

    We have appointed Dave Demchak as Data Protection Officer to address data protection related inquiries, and he can also be reached at the above address.

    We have appointed Tuomas Aaltonen our representative in the EU.

  2. Categories of data, sources of data, purposes of the processing and legal basis for the processing

    Data Categories Source Purpose of processing Legal Basis Comments
    End-User and Wi-Fi Network Monitoring Data Depending on the Wi-Fi Product and the customer’s configuration:

    1. Sapphire Eye Product:
      • Passive measurements e.g. network name, signal  level, noise level, data rates
      • Active measurements e.g. throughput, connectivity, latency
      • 802.11 protocol data e.g. management and control frames
      • Radio frequency (spectral) data
      • Local area network meta data e.g. DNS address, gateway
        Wi- Fi end-user data (optional):
      • Radio MAC address and meta data e.g. device manufacturer, radio adapter type
      • full 802.11 packet capture (optional, ad-hoc administrator access) includes IP addresses, unencrypted data transmitted
    2. Mobile Eye Product:
      • Passive measurements e.g. network name, signal level, data rates
      • Active measurements e.g. throughput, connectivity, latency
      • Limited 802.11 protocol data e.g. beacon frames containing Wi-Fi network meta data
      • Wi-Fi network meta data e.g. network name, supported data rates, BSSIDs seen
      • Local area network meta data e.g. DNS address, gateway
        Wi- Fi end-user data:
      • Radio MAC address
      • Device IP address
      • Device location
      • Measurement collection times
      • Device unique identifier
      • Device alias e.g. hostname
      • Device manufacturer, platform, model, and software version
    Data is obtained through our customers who source and install 7SIGNAL Wi-Fi Products on their networks and/or user devices.

    • To provide Wi-Fi monitoring services to 7SIGNAL customers.
    • The legal basis for this processing will be decided by each customer – the most frequent legal basis may be that the processing is necessary for the customer’s legitimate interests in monitoring, testing, and optimizing that customer’s Wi-Fi network.
    To provide Wi-Fi monitoring services to 7SIGNAL customers. The legal basis for this processing will be decided by each customer – the most frequent legal basis may be that the processing is necessary for the customer’s legitimate interests in monitoring, testing, and optimizing that customer’s Wi-Fi network. In general, we only process anonymous data about users’ devices and usage patterns, and cannot identify any individual. The customer whose network you are using will provide additional information.
    Solution Administration 7SIGNAL processes data allowing and measuring usage of its products by customer solution administrators

    • Administrator email address (login user name)
    • System access records (login, logout)
    • General System usage screens visited, and reports run (not tied to an individual user)
    • Identity management feature
    • Server logs
    • Cookies in administrator devices in order to communicate with our servers
    • To secure solution access and auditing
    • To provide training. customer services, and support and maintenance services in relation to the Wi-Fi Products
    • To support the development of improved products, services, educational materials, and research activities (using anonymized data)
    Necessary for our legitimate interests in operating and improving our services. This data relates to secure access to and usage of our solutions and is used for no other purpose.
    Commercial Contacts Data 7SIGNAL will process data about the representatives of customers or suppliers (or potential customers or suppliers), e.g.

    • name
    • employer
    • work address
    • work email
    • work phone
    • title
    • ualifications / business interests
    • contractual information
    This obtained directly from you or from your employer, or in some cases (such as for business development) from public sources such as trade shows or professional networking.
    • To provide customers with information, products or services
    • To evaluate, obtain and pay for supplies
    • To carry out our obligations and enforce our rights arising from our customer or supplier contracts
    • To invoice and collect fees
    • To develop our business.
    • To notify interested parties about changes to our Wi-Fi Products
    • To keep records for accounting, tax, or legal compliance purposes
    • To analyze usage and trends (using aggregated / anonymized data)
    • To protect our legal position and comply with applicable laws e.g. relating to tax, accounting and record-keeping.
    • For the performance of our contracts with our customers and suppliers
    • That it is necessary for our legitimate business interests
    • To comply with 7SIGNAL’s legal obligations
    This information relates to your business life and business data and so has minimal privacy impact.
    Visitors to our Website
    • pages visited
    • clicks
    • searches made
    • device operating system
    • approximate location
    • IP address
    • browser ID
    • browsing activity
    • name and contacts (e.g. on contact forms or inquiries)
    • From visitors’ browsers or devices.
    • From website contact forms or public contact addresses.
    • To help improve the website
    • To monitor the performance of our website and services.
    • To respond to inquiries or questions.
    That it is necessary for our legitimate interests in operating and promoting our business. This data processing is typical for almost all websites, does not allow us to identify or contact you (except where you voluntarily provide details or request a contact). You are able to change your cookie consents at any time as set out in our Cookie Policy below.
  3. Recipients and International Transfers of Personal Data

    Your personal information may be stored and processed in any country where we have facilities or have engaged data sub-processors, e.g. for data storage or analysis. We store data in particular in Germany (for Sapphire Eye EU/EEA/UK data) or the USA (for Sapphire Eye for the rest of the World and all Mobile Eye data). Customers may also use on-premise data storage for data collected by our Sapphire Eye product.

    We may disclose personal information to the following categories of third parties:

    • our subsidiaries and affiliates involved with the provision of the Wi-Fi Products or associated services (e.g. training, support);
    • our customers as part of our services (e.g. we may provide analyses and insights, and access to raw data collected);
    • in the event of merger, acquisition, or any form of sale of some or all of our assets, in which case personal information held by us may be transferred to the buyer;
    • other organizations that provide services in support of our services and business such as:
    • providers of IT-related services (e.g. data storage, website development, hosting, management, or maintenance);
    • data analytics providers; or
    • accounting, legal, compliance, insurance or banking service providers.

    These organizations process personal data on 7SIGNAL’s behalf, but our contracts with them oblige them to meet data protection standards as strict as those that apply to us, and not to use your data for any other purpose.

    Where these are not based in the EU/EEA/UK, or other countries that are officially regarded as having adequate data protection laws, then this will be done only on the basis of legal safeguards aimed at ensuring that your data is kept as secure as under applicable laws. These may include the European Commission’s standard contractual clauses for data exports, or the EU-U.S. Privacy Shield. A copy of such safeguards may be available from us if we receive a valid request.

    If 7SIGNAL receives a request from a government, law enforcement agency, or regulator requesting data from us, and we would normally comply with such request without having to notify you or other users.

  4. Storage period

    We only retain data for as long as necessary for the purpose for which the data was collected.

    Personal data from our Wi-Fi monitoring products is stored for up to 3 months and then permanently deleted. Where our customers store data on-premise, they may have different retention periods.

    We may retain business contact data for at least the time that you or your organization has an account or agreement with us. If you have subscribed for a newsletter or other information, we will keep your contact details until you unsubscribe.

    We keep data relating to customer or supplier contracts for at least the applicable legal limitation period in order to be in a position to resolve any claims. We may also keep data for longer periods where required for accounting, tax or legal reasons (in which case data use will be limited to such purposes).

  5. Your RightsIf you are located in the EU/EEA/UK, the General Data Protection Regulation and national implementing laws grant you various rights including the following:
    • To access your personal data;
    • To require us to correct mistakes in your personal data;
    • To have personal data concerning you erased (“the right to be forgotten”);
    • To receive personal data which you have provided to us (“portability”);
    • To object to processing of your personal data for direct marketing or for certain other purposes;
    • To restrict our processing of your personal data in certain circumstances.

    If our data processing is based on your consent, then you can always withdraw that consent (but any processing that took place before withdrawal will still be legal).

    If you wish to exercise any of your legal rights, as a user of one of our Wi-Fi Products you should in the first instance contact the 7SIGNAL customer through whom your data was collected. For other cases, or in case of any doubt, please contact 7SIGNAL using the details in this Notice and we will try to assist. If you believe that we or any customer have not respected your rights, then you also have a right to make a complaint to the Supervisory Authority in your country.

    For California residents, California Civil Code Section § 1798.83 permits users of our Wi-Fi Products to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as indicated above.

    The Wi-Fi Products are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe that we might have any information from or about a child under 13, please contact us as indicated above.

  6. Cookies Policy

    A cookie is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing that website. Every time the user loads the website, the browser sends cookie information back to the server to notify the website that it recognizes the user.

    You can find more information about different types of cookies here.

    Use of cookies helps us to improve our Wi-Fi Products and our website and to deliver a better and more personalized service by enabling us to:

    • Estimate our audience size and usage patterns;
    • Store information about your preferences;
    • Recognize you when you use the Wi-Fi Products or our website.

    You may refuse to accept cookies by activating the appropriate setting on your device. You can also remove cookies from your web browser by following the directions provided in your browser’s “help” section. Some cookies are essential for securing access to and using features of our Wi-Fi Products Administrative Interfaces or website, so if you clear all cookies then those features may not work as expected or at all, or you may need to accept some cookies on your next visit.