Privacy Policy
Last updated: June 2026
This Privacy Policy explains how CaptiveWiFi, a division of ClubWizard Ltd ("we", "us", "our"), collects, uses and protects personal data when you use our website at captivewifi.com and our guest WiFi captive portal platform.
1. Who we are
Data Controller: ClubWizard Ltd
Registered in England and Wales
Registered address: 26 Fitzroy Square, London, W1T 6ES
ICO Registration: Z8359853
Contact: hello@captivewifi.com
2. What personal data we collect
Depending on the context (website visitor vs. guest WiFi user vs. venue operator), we may collect:
- Name and email address (provided at WiFi login or via our website contact forms)
- IP address and approximate geolocation
- Device type, operating system and browser
- WiFi connection timestamps and frequency of visits
- Marketing consent status and opt-in timestamp
- Feedback and survey responses submitted through the platform
3. Lawful basis for processing
| Processing activity | Lawful basis (UK GDPR Article 6) |
|---|---|
| Guest WiFi login data capture with explicit opt-in | Consent (Art. 6(1)(a)) |
| Operating and improving the CaptiveWiFi platform | Legitimate interests (Art. 6(1)(f)) |
| Communicating with venue operators about their account | Contract performance (Art. 6(1)(b)) |
| Compliance with legal obligations | Legal obligation (Art. 6(1)(c)) |
4. How we use personal data
We use data collected through the CaptiveWiFi platform to:
- Authenticate guests on venue WiFi networks
- Provide venue operators with guest analytics and CRM sync features
- Enrol guests in loyalty programmes they have consented to join
- Send marketing communications where consent has been given (operators manage this via their CRM)
- Improve platform performance and security
5. Data controller vs. data processor
When a hospitality venue uses CaptiveWiFi, that venue is the data controller for their guests' personal data. CaptiveWiFi (ClubWizard Ltd) acts as the data processor, processing data only on behalf of and under the documented instructions of the venue operator.
Our Data Processing Agreement, incorporated into our Terms of Service, sets out the obligations of each party.
6. Data retention
Guest data collected through the WiFi captive portal is retained for as long as the venue operator's account is active, or as otherwise specified in the Data Processing Agreement. Operators may request deletion of guest records at any time via the dashboard or by contacting us.
Website enquiry data (contact form submissions) is retained for up to 24 months.
7. Third-party sharing
We do not sell personal data. We share data only with:
- CRM and loyalty platforms that venues have connected (e.g. SevenRooms, Klaviyo, Airship, OpenTable) — always under the venue operator's control
- Infrastructure providers (hosting, database, analytics) who process data on our behalf under appropriate data processing agreements
- Legal or regulatory authorities where required by law
8. Cookies
Our website uses strictly necessary cookies for session management, and optional analytics cookies (Microsoft Clarity, Google Analytics) which are only loaded where permitted by your consent preferences. You may manage cookie settings at any time via the "Cookie Preferences" link in the site footer, or the consent banner shown on first visit.
9. Your rights
Under UK GDPR you have the right to:
- Access the personal data we hold about you
- Correct inaccurate data
- Request erasure ("right to be forgotten")
- Object to or restrict processing
- Data portability (where applicable)
- Withdraw consent at any time (where consent is the lawful basis)
To exercise any of these rights, contact us at hello@captivewifi.com. We will respond within 30 days.
You also have the right to lodge a complaint with the ICO: ico.org.uk.
10. Changes to this policy
We may update this Privacy Policy from time to time. Material changes will be communicated to venue operators via email. The "Last updated" date at the top of this page reflects the most recent revision.
11. Contact
For any privacy-related queries, contact our team at hello@captivewifi.com.