GDPR Policy

mportant information

This document sets out the terms and conditions for the provision of Free Wi-Fi access provided to Cretan Flavor customers by Collectifi on behalf of Cretan Flavor ("service"). Your agreement with Collectifi ("we" or "us") for the provision of this service is made up of the following terms (each including any other document or information we refer to in those terms): 
•These terms and conditions 
•Any relevant Special Offer Terms

If any of these documents contradict each other, the terms will prevail in the order set out above.

What we provide

1. In consideration of you accepting these terms and conditions; Cretan Flavor paying us to provide this service for your benefit; and us sharing the service usage data with Cretan Flavor; we agree to provide you with the service free of charge and this gives you: 
•the ability to access the internet and send and receive data through our wireless broadband network and through the internet using wireless technology from a designated site with access points for the service (a Cretan Flavor hotspot); 
•any other facilities that we agree to provide under your agreement.

2. The service we provide to you under these terms is for business and consumer use.

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When the service starts, ends and your cancellation rights

3. The service starts when you access it by entering your email address and pressing the submit button on one of the relevant log on pages or when you correctly register your personal details on a registration page when logging on at a Cretan Flavor. The length of time that you will be allowed to access the service free of charge at a Cretan Flavor hotspot will vary depending on Cretan Flavor preferences.

4. Your agreement ends when the service you receive ends. You may cancel your agreement with us by logging out of the service.

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Using the Service

5. If the service at a Cretan Flavor hotspot requires you to register you personal details in order to access it, then it is your responsibility to provide accurate information about yourself.

6. The service does not include: 
•connection from our network to any customer network; 
•any services when you are connected to the internet; 
•providing you with any computer equipment to access the service or the internet

7. The service may be impaired by geographic, atmospheric or other conditions or circumstances beyond our control.

8. You agree to get any permission needed from someone else if you want to use the service in any country in which this is necessary. This includes the UK.

9. Certain websites are blocked from the Cretan Flavor hotspot for policy reasons. If you try to access a blocked website address at a Cretan Flavor hotspot, then the service will not allow you to access that website but will still allow you to access other websites during your internet session.

10. Except for website address blocking described in paragraph 10, you accept that we have no control over the information transmitted via the service and that we do not examine the use to which you put the service or the nature of the information you send or receive. We have no obligation to compensate you for such information and such use.

11. We cannot guarantee access to any Cretan Flavor hotspot for you to use the service, or guarantee that service will continue to be available from any Cretan Flavor hotspot.

12. You must not use the service or allow the service to be used: 
• in any way which breaks any law or the conditions of any licence or rights of others, or our acceptable use policy which we may amend from time to time and can be found at 
• to make offensive, indecent, menacing, nuisance or hoax calls or to cause annoyance, inconvenience or needless anxiety; 
• to send, knowingly receive, upload, download, or use any material which is offensive, abusive, indecent, defamatory, obscene or menacing; or 
• in any way that we reasonably think is, or is likely to, adversely affect how we provide the service to you or any of our customers, including but not limited to trying to circumvent the website address blocking functionality to access blocked websites at the Cretan Flavor hotspot.

We take the types of misuse described in this paragraph 13 very seriously, and you agree to take all reasonable steps to make sure that it does not happen. If we reasonably believe you have misused the service, we may take immediate action to suspend the service or end your agreement with us without telling you first, even if you were not aware that your service was misused.

13. You agree that any content, software or other copyright material is supplied to you for your own private or business use only. You must not copy, modify or publish such material or resell, transfer or supply it to any other person or permit any other person to do these things.

14. You are responsible for making sure any equipment you use to access the service is: 
• suitable for use with the service; 
• adequately protected against external threats such including but not limited to viruses, worm, trojans; and 
• meets any instructions for its use.

15. If you are a business customer you also accept that the service depends on your communications network (including any local area network and intranet) being suitable.

16. If you use the service to access content or software owned or licensed by others who ask you to accept their terms of use, you must keep to these terms.

17. You agree to compensate us fully for any claims or legal action made or threatened against us by someone else because you have used the service in a way that breaks paragraphs 13, 14 and 15 of these general terms, or any other term of this agreement. We will tell you of such claims or legal action and update you on their progress. We will consider any representations you want to make.

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18. The service does not prevent you from having extra security e.g. firewalls on your equipment or customer networks.

19. Due to the nature of the service, you accept that we cannot guarantee the security of the service against unlawful access or use. You should make sure that you have adequate security to prevent unlawful access to or use of the service, access to your computing equipment or disclosure of confidential information.

20. You accept that we do not guarantee the integrity, authentication and confidentiality of the information, files and data (including credit card PIN) you may wish to exchange over the internet.

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Other things we may need to do

21. Occasionally, for operational reasons we may have to: 
• interrupt the service and if we do so, we will restore it as quickly as we can; 
• make minor changes to certain technical specifications, including data-transfer limits associated with the service.

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Our responsibility to you

22. Unfortunately, we cannot guarantee that the service will never be faulty.

23. Unless these terms and conditions say otherwise, we have no responsibility (to the extent permitted by law) to compensate you (whether or not we are negligent) for any direct financial loss, loss of profit, revenue, time, anticipated savings or profit or revenue, opportunity, data, use, business, wasted expenditure, business interruption, loss arising from disclosure of confidential information, loss arising from or in connection with use of the service or inability to use or access the service or a failure, suspension or withdrawal of all or part of the service at any time or damage to physical property or for any other similar direct loss that may arise in relation to this agreement whether or not we were advised in advance of the possibility of such loss or damage.

24. Unless these terms and conditions say otherwise, we have no responsibility (to the extent permitted by law) to compensate you (whether or not we are negligent) for any indirect or consequential loss or damage whatsoever.

25. We do not guarantee that the service will be compatible with your equipment, any software that you may use or your communications network. We cannot guarantee performance of the internet or that you will be able to use the internet. Using the internet is at your own risk.

26. If you are a consumer, nothing in paragraphs 26 to 29 affects your rights under the law relating to faulty or wrongly described service.

27. If any paragraph that limits our responsibility to you is disallowed or is not effective, the other paragraphs will continue to apply.

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Matters beyond our reasonable control

28. Sometimes we may be unable to do what we have agreed because of something beyond our reasonable control, which may include: lightning, flood, severe weather, fire, explosion, terrorist activities, anything done by Government or other competent authority or industrial disputes. There may be other reasons too. In these cases, we do not accept responsibility for not providing you with the service.

If you break this agreement

29. Other than for serious misuse described in paragraph 13, we will normally give you an opportunity to put matters right within a reasonable time if you break this agreement.

30. However, if you do not do so, we may suspend or end this agreement for the service. We may also suspend the service or end this agreement for the service if you break any other agreement you have with us and do not put matters right within a reasonable time. If we suspend the service or end this agreement for the service, we will tell you what needs to be done before we reinstate it.

31. Sometimes we may choose to ignore it if you break one of our terms and conditions, or we may choose not to enforce a particular term. But even if we do this, we can still choose to enforce that term or take action because you break that or any other term in the future.

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Resolving disputes

32. We will try to work through any disputes that you may have with us. However, if we cannot do this, you may refer the matter to any relevant dispute resolution service. Details of these, and of how to refer a dispute, are set out in our code of practice for residential customers and small businesses available on or any other website we may tell you.

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Other things we need to tell you

33. We both agree that the terms of this agreement are not enforceable by a third party under the Contracts (Rights of Third Parties) Act 1999.

34. Your agreement with us is governed by the law of England and Wales and is subject to the non-exclusive jurisdiction of the English courts.

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How is your personal data collected?

Identity Data includes email or similar identifier. If you interact with us through social media, this may include your social media user name, title, first name, last name.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We will treat all the personal data included in designs or products as ordinary personal data.

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.

When you log in via wifi, if you register on one of our sign up forms or contact customer services.

How we use your personal data

Where we need to perform the contract we are about to enter into or have entered into with you.

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud.

For direct marketing communications we rely on consent

Explaining the legal bases we rely on to process personal data

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

We do not carry out any automated decision making.

If you ever have any questions about this, all you have to do is ask, please see the section contacting Collectifi below.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so

Data retention

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.

We also make a promise to you that you can come back at any time in the future and re-order products you have ordered from us in the past. So, unless you actively delete this information, we keep it, so we can keep our promise to you.

In some circumstances you can ask us to delete your data; see Your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:

  • The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing that in this privacy policy);
  • The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
  • The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
  • The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
  • The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
  • The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
  • The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
  • Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.

These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.

If you wish to exercise any of the rights set out above, please contact us (see How to contact Collectifi about privacy).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details in How to contact Collectifi about privacy below.

You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

How to contact Collectifi about privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at or write to us with your letter addressed to: Data Privacy Manager, Collectifi Ltd, Suite 3, Plum Park Estate, Watling Street, NN12 6LQ, United Kingdom.

A little request from Collectifi to you

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can do this by updating your account. Thank you.

Changes to this privacy policy

The General Data Protection Regulation is new and the ICO is still issuing new bits of guidance about how businesses should follow it. So, you may see little updates to our privacy policy over the coming months. Be sure to check in and have read every now and then. Thank you. These terms were updated 20/05/18.

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