Hotspot Scorecards
For every criterion, a hotspot may fully , partially satisfy
or not satisfy the criteria .
1. Availability
of Privacy Policy and TOS
An easily accessible
privacy policy and Terms of Service (TOS) documentations are important to define
users' responsibility toward the service and for communicating any privacy
implications to the hotspot users.
Fully Satisfy : The captive portal
contains a link to the privacy policy and TOS documents.
Partially Satisfy if either of them is
missing.
2. Mandatory
Signup
Hotspots can provide internet
access without any explicit personal data collection. However, it can
use social login
(Facebook, LinkedIn, Google, Instagram) or a registration page to collect
significant amount of personal information.
Fully Satisfy : The hotspot allows
access without requiring any personal information (via social login or
registration form).
3. Tracking
Users
Hotspots can use various
techniques to track users. This include identifiers locally stored on the
user's device by thirdparties (e.g., HTTP cookies), which are commonly used to uniquely
identify users.
Fully Satisfy : The hotspot does not have any known or possible trackers
on the captive portal.
Partially Satisfy
: The hotspot only has possible trackers on the captive portal (i.e., It does not have any known trackers).
4. Cross-Tracking
Users
The captive portal can use tracking cookies to track
user's across hotspots.
Fully Satisfy : The hotspot does not perform any tracking across
hotspots.
5. Tracking Users before Consent
The captive portal
should not perform any web tracking activities before the user consent before
acceptance of terms and conditions.
Fully Satisfy : The hotspot does not
perform any kind of web tracking prior to user's consent including satetful and stateless tracking.
6. Collecting
Personal Information (PII)
Hotspots can collect a
wide range of information while trying to get access to the internet.
Fully Satisfy
: The hotspot allows
access without requiring any personal information (via social login or
registration form).
Partially Satisfy : The hotspot collects only
Email address or phone number, assuming email or phone number is used to communicate privacy
policy and TOS changes to the user.
7. Collecting
System Information
Hotspots can perform device/system fingerprinting
to uniquly identify users. : The hotspot does not
collect system information about user's
device or browser including the MAC address.
8. Linking
PII to MAC Address
Hotspots can link the users MAC address to the collected personal information.
Fully Satisfy : The hotspot does not
link the users MAC address to the collected personal information.
9. Sharing
Information
Hotspots may share
users' data with third-parties and affiliates.
Fully Satisfy : The hotspot does not
share any information collected with third-parties (e.g., Use third-party captive portal).
10. Securing
Information
Protecting users'
information is a major concern as any leak could lead to identification of
individual users and their location.
Fully Satisfy : The hotspot uses TLS
for all communications between the captive portal and back-end servers to
protect user's personal informaion.