Colony is committed to protecting your privacy and earning and keeping your trust. We understand that you value your privacy, and that you may have concerns about how the data is collected, stored and utilized.

What we collect from Clients and Users

When you register for an account. In order to sign up as a Client to use the Colony Service, you must register for a Colony account (your “Account”). To create your Account, you will need to provide information about yourself and your business, including contact information (your name, address, email address, phone number, and so on), and Account login information.

If you contact Colony. You may request information about Colony or the Service. We may ask you to provide personal information with your request such as your name, email address, and phone number. Based on the nature of your request, we may also ask for additional information, such as how you anticipate you will make use of our Service and how you heard about us.

We may also periodically request your feedback through surveys or other mechanisms. Providing feedback in these contexts is entirely voluntary, but if you choose to participate we may ask you to provide personal information such as your name, email address, and phone number, in addition to your feedback.

When you visit our Sites or use our Apps. We automatically collect certain information when you use our Sites or Apps, including (i) information about your interaction with the Sites or Apps, including the actions you take, the pages or other content you view or otherwise interact with, and the dates and times of your visits; and (ii) device information, such as your IP address or other device address or unique device identifier, operating system information, web browser and/or device type and language.

We collect certain information through the use of “cookies” and other tracking technologies to better understand how our Users navigate through the Sites, learn what content is being reviewed, and administer the Sites. Cookies are small text files that Web servers place on an internet user’s computer that are designed to store basic information and to recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used on subsequent visits to the Sites. Please consult your web browser to learn the proper way to modify its cookie settings. Please note that if you delete, or choose not to accept, cookies from the Sites, you may not be able to utilize the features of the Sites to their fullest potential.

How we use the data we collect from Clients and Users

We may use the information we collect, including your personal information, for the following purposes:

How we share Client and User data

Service providers and other third parties. We share your information with service providers and other third parties to perform functions and process data on our behalf. Service providers have access to your information only to perform services on our behalf and are obligated not to disclose it or use it for any other purposes. Some of these service providers and other third parties, such as analytics providers, may collect information about your online activities over time and across different websites or online services when you use our Service.

Marketing and advertising partners. We may share your information with third party marketing partners so that they may send promotional communications to their customers on our behalf.

We may also share your information with third party advertising partners in order to offer you tailored content, including more relevant advertising for products and services which may be of interest to you.

Other sharing. We may also disclose Client and User Data:

Accessing and modifying your information

You can access, modify, correct, or delete your personal information by accessing your Account on our Sites or Apps or, if you don’t have a direct account with us, by contacting us as indicated below.

Third party links

Our Sites and Apps may contain links to other websites not operated or controlled by us (“Third Party Sites”). The policies and procedures we describe here do not apply to the Third Party Sites. The links from the services do not imply that we endorse or have reviewed the Third Party Sites.


Visitor Data that we may collect

We collect information from or about individuals that visit your locations (“Visitor Data”). Visitor Data may include—

Presence data. When a Visitors enters (or is near) your location while carrying a mobile device with either: (i) its Wi-Fi function enabled or (ii) its Bluetooth function enabled and a third party application installed that has integrated Colony’s SDK (a “Colony-Enabled App”), we detect the presence of the device. We also may receive the Visitor’s mobile device MAC Address.

Wi-Fi registration data. You may choose to offer your Visitors free wireless internet access through the Colony Service when they visit your locations. Visitors who opt into this free access may be asked to submit their name and email address or other identifying information.

Point of Sale data. You may choose to provide Point of Sale data to us through one of our Point of Sale partners.

Demographic and other information. We have partnerships with the providers of Colony-Enabled Apps. These Colony-Enabled Apps share demographic and other information, including personal information, about Visitors with us. We also collect device information such as unique device identifiers through Colony-Enabled Apps.

Additional sensor data. Colony Devices may include sensors, such as infrared sensors that detect the fact that an individual passed through an entrance and enable us to count the number of Visitors that enter and exit your location.

How we use Visitor Data

Visitor Data is combined and used to provide our Service to our Clients. We also use Visitor Data to improve and promote our Service, to develop new products and services, and to monitor and analyze usage and trends.

How we share Visitor Data

How we share with our Clients: We share non-personally identifiable Visitor Data with our Clients. In some instances, we collect personal information on the Client’s behalf and provide it to them, such as when a Visitor signs up for Colony-powered Wi-Fi. We don’t share line-item transactions from one Client with another Client, but we share information such as the categories of places that Visitors frequent. We may also share with Clients information about which Colony-Enabled Apps a Visitor has installed.

Clients may use our Service for purposes such as analytics and to send coupons, loyalty points, sales information, or other marketing communications to Visitors. Clients may send these offers via an in-app notice, push notifications, email, or other means of communication. We are not responsible for the privacy policies of Clients or partners, and make no representations to Visitors about their accuracy. Clients and Visitors who have questions about third parties’ practices should check the third parties’ privacy policies and/or contact them directly.

Service providers. We may share Visitor Data, including personal information, with service providers and other third parties to perform functions and process data on our behalf. Service providers have access to Visitor Data only to perform services on our behalf and are obligated not to disclose it or use it for any other purposes.

Third party partners. We disclose non-personally identifiable Visitor data to our third party partners. For example, we share non-personally identifiable Visitor Data with providers of Colony-Enabled Apps.

Other sharing. We may also disclose Visitor Data:

How Visitors can opt out

Visitors can always control Colony’s collection of their data directly on their mobile devices by using their device’s Wi-Fi and Bluetooth settings. Visitors may also opt out of having Colony collect their data by entering their MAC address below:

Your mac address:


Data security

We take reasonable steps to protect the data that we collect from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. To that end, we use certain physical, managerial, and technical safeguards that are designed to protect the information that we collect and maintain. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other types of misuse.

Children’s privacy

We do not knowingly collect personal information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

International Users

Our Sites, Apps, and Service are hosted in the Canada. If you choose to use them from the European Union, the United States of America or other regions of the world with laws governing data collection and use that may differ from Canadian law, then please note that you are transferring your information outside of those regions to the Canada for storage and processing. By providing your information, you consent to any transfer and processing in accordance with this Policy. We also may subcontract processing to, or share your information with, third parties located in countries other than your home country.

Changes to this policy

This Privacy Policy is effective as of the date set forth above. This Privacy Policy may be revised from time to time without prior notice, so we encourage you to periodically review it. If we make material changes to this Privacy Policy, we will notify you of such changes by posting them on our Sites, Apps, and to other places we deem appropriate or by sending you an email or other notification. By continuing to access or use our Sites, Apps, or Service after those changes become effective, you are agreeing to be bound by the revised policy.

Do Not Track

Because an industry-standard Do Not Track protocol has not yet been established, Colony’s information collection and disclosure practices, and the choices it offers, will continue to operate as described in this Privacy Policy regardless of choices made regarding the use of Do Not Track technologies. We comply with CASL rules and explicitly require you to opt into receiving messages from us when you sign up through one of our captive portals of apps.

Posting to your Facebook account

The Colony app and services will not post any items to your facebook account without your explicit approval.

How your data is stored

Colony stores all data on a secure data storage infrastructure in our data centers in Vancouver and Toronto. No data is hosted in the United States of America.

If you have any further questions or concerns regarding privacy, you can reach us at:

Suite 220,  1501 West Broadway

Vancouver BC, V6J 4Z6

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