Privacy Policy 

Effective: October 20, 2020 

CityBee Wireless, LLC (“CityBee”) is a provider of wireless hotspot services for consumers. This Privacy Policy describes how we process and handle data provided to CityBee in connection with your use of our products, services, apps, and websites that link to this policy (we refer to these collectively as our “services”). 

Information security and privacy are at the heart of what CityBee values and promotes as a company. As such, we think it’s important to be transparent about how we handle your information. That level of transparency also makes for a lengthy document, but we’ve tried to make it more readable by organizing it into a logical structure and by using plain language. 

CityBee offers a variety of services, and certain services may process data differently, or in additional ways, to other services and what’s described in this policy.  

This policy uses the term “personal data” to refer to information that is related to an identified or identifiable natural person and is protected as  personal data under applicable data protection law. 


Who is CityBee Wireless? 

In this policy, “CityBee”, “we”, “us” and “our” refer to the company that comprise CityBee Wireless, LLC that are responsible for your data. 


Business Customers 

Some of CityBee’s services are offered to businesses. For those services, our customer is a business or other organization who may authorize individual end users to use the services that it has purchased from us. Where an organization is our customer, it may maintain accounts with CityBee through which it and its users may submit information (“Customer Data”). That organization typically controls those accounts and any  associated Customer Data. In this case, CityBee is generally a processor of Customer Data and the organization is the controller. 


  1. What information do we collect about you? 

This section describes the various types of information we collect from and about you. This information is not collected in all situations, but only  in specific situations. For example, our products only collect a limited amount of information. To understand the context in which collection  occurs, see Section 2 (How do we use your information?). More information about some of the mechanisms we use to collect this information,  such as cookies, is available in Section 4 (Tracking Technologies & Cookies). 

1.1. Information you provide to us 
1.2. Information collected when you use our services 
1.3. Information provided to us by third parties 

You generally do not have a duty to disclose personal data to us unless you have a contractual obligation to us to do so. However, we need to  collect and process certain information that is necessary or legally required in order to provide the services to you or otherwise perform our  contractual relationships with you. 

  1. How do we use your information? 

We use the information we collect for various purposes described below. 

  1. Who do we share your information with and why?

3.1. In General 

We may disclose your information in the following circumstances: 

3.2. Free Products Only 

Displaying Ads. We do not display third party ads in our paid products. With respect to our free mobile apps and other free products, we may serve ads to users in certain regions. Although the money we make from displaying these ads offsets only part of the costs of making these apps  and services available for free, we provide free apps because we believe it’s important that everyone has the opportunity, regardless of their  situation, to have secure and private access to the internet. 

The ads we display in our services are supplied either by advertisers or affiliate networks we have relationships with, or by Google, a third party  advertising network (“Google Ads”). To display these ads in our apps, we may integrate into them a software development kit (SDK), which consists of software code provided by a third party, such as an ad network. 

We do not provide Google Ads with any personal data about you, except for an approximate city-level latitude and longitude which lets them show  ads which are more relevant for your approximate geographic location. However, Google Ads may collect information through their SDKs, such  as your mobile advertising identifier, IP address, and device information, for the purpose of serving you with “personalized” ads (ads that they  think are more relevant to you) and measuring your response to those ads.  

Google collects this information according to the Google advertising privacy notice. 

  1. Tracking Technologies & Cookies 

4.1. About Tracking Technologies 

CityBee uses various technologies in our services to help us collect information, primarily on our websites and in our marketing emails. For  convenience, we refer to these as “tracking technologies,” although they are not always used to track individuals and the information collected is in  a non-identifiable form that does not reference any personal data. Tracking technologies include: 


Cookies are small portions of text that are stored on the device you use to access our services. Cookies enable us (or third parties that we allow to  set cookies on your device) to recognize repeat users. Cookies may expire after a period of time, depending on what they are used for. 

Pixel Tags / Page Tags / Web Beacons / Tracking Links 

These are small, hidden images and blocks of code placed in web pages, ads, and our emails that allow us to determine if you perform a specific  action. When you access a page, ad, or email, or click a link, these items let us know that you have accessed that page, opened an email, or clicked  a link. 


SDKs or software development kits are software code provided by our business partners that let our software interact with the services those  partners provide. For example, in our free mobile apps, we may use an SDK to enable our app to serve ads from an advertising network.  Sometimes these interactions will involve that business partner collecting some information from the device on which the software is run.

4.2. Why we use Tracking Technologies 

We use tracking technologies: 

4.3. Third Parties 

We may allow our business partners to place certain tracking technologies in our services. These partners use these technologies for the following  purposes: 

4.4. Your Choices 
  1. Security 

Securing personal data is an important aspect of protecting privacy. CityBee employs a range of administrative, organizational, technical, and  physical safeguards designed to protect your data against unauthorized access, loss, or modification. We endeavor to use reasonably available  state-of-the-art network and information security standards, protocols and technologies, including encryption, intrusion detection and data loss  prevention, and we monitor our systems to ensure that they comply with our security policies. 

We implement rigorous physical, technical and organizational safeguards to protect your personal data in our custody, both at rest and in transit,  and should these measures fail to prevent a data breach, we will promptly take the necessary remedial measures, and we will notify you as well as  applicable regulators of any such breach, as required by applicable law. 

If you have any questions about the security of your personal data or the security of our products, or wish to report a potential security issue, please  contact us directly. When reporting a potential security issue, please describe the matter in as much detail as possible and include any information  that might be helpful. 

  1. International Data Transfers 

6.1. Transfers to Other Countries 

CityBee may transfer your personal data to countries other than the one in which you reside. We do this to facilitate our operations, and transferees  include other CityBee partners. Laws in other countries may be different to those that apply where you reside. For example, personal data collected  within Switzerland or the European Economic Area (EEA) may be transferred and processed outside Switzerland or the EEA for purposes  described in this policy. However, we put in place appropriate safeguards that help to ensure that such data receives an adequate level of  protection. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between  us and our business affiliates and associates to which we choose to transfer the information that requires these companies to protect personal  information they process from the EEA in accordance with European Union data protection law. You may contact us if you would like more  information about such safeguards. We implement similar appropriate safeguards with our third-party service providers and further details can be  provided upon request. 

  1. Data Retention

CityBee generally retains your personal data for as long as is needed to provide the services to you, or for as long as you have an account with us.  We may also retain personal data if required by law, or for our legitimate interests, such as abuse detection and prevention, and defending  ourselves from legal claims. Residual copies of personal data may be stored in backup systems for a limited period as a security measure to protect  against data loss. 

  1. Your Rights 

You may have certain legal rights in relation to your personal data that we maintain. Subject to exceptions and limitations provided by applicable  law, these may include the right to: 

Please note your rights and choices vary depending upon your location, and some information may be exempt from certain requests under  applicable law. 

You may be able to exercise some of these rights by using the settings and tools provided in our services. For example, you may be able to update  your user account details via the relevant account settings screen of our apps. You may also be able to opt out from receiving marketing  communications from us by clicking an “opt out” or “unsubscribe” link in such communications. 

Otherwise, if you wish to exercise any of these rights, you may contact us using the details in the “Contact Us” section below. As permitted by  law, we may ask you to verify your identity before taking further action on your request. 

  1. Technology Licensing 

CityBee occasionally licenses its technology to third party partners who may integrate it with applications developed and offered by those partners.  Our partners, and not CityBee, are responsible for those applications and for determining what data is collected by those applications and how it is  processed. Please contact the relevant partner and refer to their Privacy Policy to learn more about how those applications process your personal  data. 

  1. Age Restrictions 

Our services are not intended for and may not be used by minors. In this context, minors are individuals under the age of 16. CityBee does not  knowingly collect personal data from minors or allow them to use our services except in certain cases, minors over the age of 13 may use certain  of our services but only with the consent of their parent or legal guardian. If we discover that we have collected personal data from a minor without  appropriate consents, we may delete such data without notice. Please note that the legal terms under which we make certain services available may  require users to be older than 16 years of age. 

  1. Privacy Policy Updates 

CityBee may update this Privacy Policy from time to time in accordance with this section for reasons such as changes in laws, industry standards,  and business practices. CityBee will post updates to this page and update the “Last updated” date above. If we make updates that materially alter  your privacy rights, we will also provide you with advance notice, such as via email or through the services. If you disagree with such an update to  this policy, you may cancel your services account. If you do not cancel your account before the date the update becomes effective, your continued  use of our services will be subject to the updated Privacy Policy. 

  1. Contact Us 

We expect this Privacy Policy to evolve over time and welcome feedback from our users about our privacy practices. If you have any questions or  complaints about our privacy practices, you can contact us at