Effective Date: April 14th, 2022
We respect your privacy and are committed to protecting it. This Privacy
Policy describes our practices in connection with the information that we
collect. Therefore, please read it carefully to understand how Smart City
Networks, Limited Partnership, and its subsidiary and affiliate corporations,
successors, and assigns (collectively referred to herein as “Smart City”, “we”
or “our”) uses and protects the information provided by any individual person
who accesses, uses or registers to use this or any of our other related
websites and blogs (collectively, our “Websites”), our web-based and mobile
software applications and services (collectively, our “Applications”), and our
HTML-formatted email messages (collectively, including the Websites and the
Applications, our “Services”).
of the Services. Your using, accessing or registering to use our Services is
agreement and acknowledgement to be bound by them. If you do not agree with
Whose Information We Collect
We collect information from any one or all of the following three categories
a) “Customer“: A Customer is one of Smart City’s direct
customers (such as show managers, event planners, meeting space providers,
venues and other entities for whom we create Applications and who use our
Services) and customer personnel who are assigned a login id and are
authorized to access and use our Services.
b) “End-User“: An End-User is a Customer’s business
contact, marketing partner, or other third party contact who uses any of the
Services to interact with Customers. For example, an individual who
registers for an event organized by a Customer, downloads an event-related
mobile app, or completes an online survey, is an End-User.
c) “Visitor“: A Visitor is anyone who interacts online with
one of the Services.
The Information We Collect
Smart City and our Customers may collect several types of information from and
about End-Users, including:
a) “Personal Information“: This refers to information that
may be used to identify, contact or locate you, such as your name, mailing
address, telephone number, e-mail address, social media account ID or other
identifiers by which End-Users and Visitors may be contacted online or
offline, billing address, payment information, financial institution
information, information about uploads, Internet Protocol (IP) address,
global positioning system (GPS) and other physical location markers, and
time-stamp data, including meta-data. Smart City may collect Personal
Information when you use the Services including, without limitation, when
you set up an account, download materials, fill out surveys, correspond or
otherwise communicate with Smart City through the Internet, or otherwise
volunteer information about yourself.
b) “Non-Personal Information“: This refers to information
that, by itself, does not identify you or cannot be used to identify you.
Non-Personal Information does not directly relate to an individual on its
own or in combination with other information we have collected or that has
been provided. If we combine any Non-Personal Information with Personal
Information, the combined information will be treated by us as Personal
Information as long as it is combined.
The Information That We Might Have But Do NOT Use
Certain Smart City subsidiaries might possess what is known as CPNI or
Customer Proprietary Network Information. CPNI is information that is made
available to these subsidiaries because you purchase telecommunications
services from them. CPNI includes the type, destination, technical
configuration, location and amount of use of our telecommunications services
and related billing information.
How We Collect Personal Information and Non-Personal Information
We collect Personal Information and Non-Personal Information as follows:
a) Prior to your use of certain Services, Smart City requires
certain Personal Information and Non-Personal Information to enable features
or functionality of those Services. Failure to provide all required
information may prevent access to any or all of the Services. Inaccurate
information may result in suspension or termination of access to any or all
b) Uploading and Downloading Materials. If you use the Services to
upload or download materials, the materials may include meta-data or be
transmitted with data, such as the type of device through which the
materials were created, the device’s
IP address, the domain name of your Internet service provider, GPS data, time-stamp
data, and other such data. This data may necessarily be provided to and
collected by Smart City when materials are uploaded, posted to or downloaded
from the Services.
c) Information Collected Through Technology. Smart City collects
Personal and Non-Personal Information about your use of the Services (e.g.,
your Internet browser, operating system,
IP address, connection speed, and the domain name of your Internet service provider).
Such information may be gathered by the following methods:
Cookies. Cookies (including browser cookies, session cookies,
persistent cookies, flash cookies and other local shared objects) are
small pieces of information that are stored by your browser on your
computer’s or device’s hard drive which work by assigning to your
computer or device a unique number that has no meaning outside of the
Services. Cookies do not generally contain any Personal Information.
Most web browsers automatically accept cookies, but you can usually
configure your browser to prevent this. Not accepting cookies may make
certain features of the Services unavailable to, or not perform properly
for, you. For more information about cookies and how to disable them,
IP Address. Smart City collects IP addresses automatically. An
is a number that is automatically assigned to your computer or device
whenever you begin services with an Internet service provider. Each time
you access the Services and each time you request one of Smart City’s
pages, the server logs the
Web Beacons. Web beacons (also referred to as clear gifs, pixel tags and
single-pixel gifs) are small pieces of data that are invisibly embedded
in web pages and e-mails. Smart City may use these technical methods in
HTML e-mails that Smart City sends to you to determine whether you have
opened those e-mails and/or clicked on links in those e-mails, the
volume of users who have visited those pages and other related website
statistics. The information from use of these technical methods may be
collected in a form that is Personal Information.
Tracking Materials Usage. If you use the Services and you upload or download materials,
Smart City tracks and captures Personal Information and Non-Personal
Information associated with registered accounts and the use of
Location and Proximity Tracking. If you use the Services
and your Bluetooth®, Wi-Fi and/or cellular carrier services are turned
on, Smart City tracks and captures the location of your device using
beacons, GPS and other physical location markers while you are on-site
at a venue. This enables Smart City to provide a positive user
experience, including mapping services, guides and directions to event
Third Party Advertisers and Analytics. Information is collected directly from End-Users using Services and
from Visitors navigating through the Services using technologies
collecting browser and device information, details regarding use of the
Services, IP addresses and information collected through cookies, web
beacons and other technologies.
Third Party Sources. We use public databases, joint marketing partners, and social media
platforms to collect Personal Information and Non-Personal Information.
If a Visitor or End-User connects to his or her social media account for
our Services, certain Personal Information from the social media account
will be shared, which may include Personal Information that is part of
the Visitor’s or End-User’s profile or his or her friends’ profiles.
Please note that any such information posted or disclosed on the
Services may be available to other Visitors, End-Users and to the
Anyone submitting Personal Information relating to other people to
Smart City in connection with the Services represents that he or she
has the authority to do so and to permit us to use the information in
d) Personal Information Directly From You. We collect Personal
Information that a person provides when utilizing one of our Services, such
as when an End-User registers to attend a meeting organized by a Customer,
fills in a form on our Services, uses a chat function, purchase services or
products, or downloads a mobile software application to the End-User’s
iPhone, Android or other device, when receiving technical or customer
account support, or responds to surveys.
How We Use Personal Information and Non- Personal Information That We Collect
We may use information that we collect or that is provided to us, including
Personal Information, for any of the following purposes:
a) System Administration. Smart City may use Non-Personal Information
for the purposes of system administration, assisting in diagnosing problems
with Smart City servers, monitoring Smart City’s system performance and
traffic and to gather broad demographic information about Smart City
addresses and your Personal Information to track features to deliver
materials specific to your interests, and to inform you about, present you
with and offer you new relevant products, Services, and their contents,
including third-party offerings, and to better tailor your experience in
using the Services.
c) Performance of Services. If you have registered for an account,
Smart City may use your Personal Information to receive payments from you,
to provide customer service, to allow Customers and Visitors to participate
in online product demos, surveys, and online sweepstakes or contests
(including to verify participant eligibility and deliver prizes) and use
other interactive features on our Services, facilitate social sharing
functionality, and communicate with you about these activities.
d) We may use your Personal Information to send e-mails to you to
verify your identity, to notify you if Smart City believes your use of the
Services violates any applicable agreement, to advise you of changes to our
Services and to notify you of any products or services that may be of
interest and that are offered by us, our affiliated companies or other third
e) Advertising & Promotion. Smart City may use Non-Personal
Information to assist in optimizing the delivery of advertisements. In
addition, Smart City may use your Personal Information to send you e-mails
periodically listing promotions or events relating to the Services or from
Smart City’s marketing partners or sponsors. You have the choice to opt-out
of receiving such promotional e-mails by sending an e-mail to
f) Contact Information. If you contact Smart City by any means, Smart
City may keep a record of your contact information and correspondence. If
you report a problem, Smart City may collect this information in a file
specific to you.
g) Research & Analytics. We may use and retain your Personal
Information to perform research and analyze use of, or interest in, our
products, services or content (or products, services or content offered by
others on our Services), and for our business purposes, such as data
analysis, audits, fraud monitoring and prevention, developing new products,
enhancing, improving or modifying our Services, identifying usage trends,
determining the effectiveness of our promotional campaigns and operating and
expanding our business activities.
h) As we believe necessary or appropriate: (i) under applicable law,
including laws outside your country of residence; (ii) to comply with legal
process; (iii) to respond to requests from public and government authorities
including public and government authorities outside your country of
residence; (iv) to carry out our obligations and enforce our terms and
conditions applicable to the Services and other agreements, including for
billing and collection purposes; (v) to protect our operations or those of
any of our affiliates; (vi) to protect our rights, privacy, safety or
property, and/or that of our affiliates, you or others; (vii) to allow us to
pursue available remedies or limit the damages that we may sustain; and
(viii) to protect against or identify fraudulent transactions.
How We Might Disclose The Personal Information and Non- Personal Information
That We Collect
We might disclose Personal Information, pursuant to the terms of this Privacy
a) To our Customers when you use our Services to transact business with our
Customers, or when you use our Services is connection with a services we
provide our Customers. In that event, any Personal Information you provide
is transferred to the exclusive control of the Customer. Smart City does
not, and cannot, take responsibility for or maintain control over the
privacy practices of our Customers.
b) To our subsidiaries and affiliates, except those that are in possession
of CPNI, if Smart City is the party responsible for the management of the
jointly-used Personal Information.
c) To contractors, service providers and other third parties to provide and
maintain support our Services.
d) To your social media connections, including social media account
providers, where you connect to your social media account through the
Services or connect to the Services through your social media account. You
agree that by establishing this connection, you authorize us to share
information with your social media account provider, and you understand that
the use of the information we share will be governed by the social media
with your social media account provider, please do not participate in social
sharing on the Services.
e) To a third party in the event of a merger, divestiture, restructuring,
reorganization, dissolution or other sale or transfer of some or all of
Smart City’s assets.
f) To fulfill the purpose for which the Personal Information is provided or
for any other purpose disclosed by us when you provide the Personal
Information or with your consent.
g) As we believe to be necessary or appropriate: (i) under applicable U.S.
law; (ii) to comply with legal process; (iii) to respond to requests from
public and government authorities including public and government
authorities outside your country of residence; (iv) to carry out our
obligations and enforce our terms and conditions applicable to the Services
and other agreements, including for billing and collection purposes; (v) to
protect our operations or those of any of our affiliates; (vi) to protect
our rights, privacy, safety or property, and/or that of our affiliates, our
Customers, you or others; and (vii) to allow us to pursue available remedies
or limit the damages that we may sustain.
In addition, we may disclose information which does not identify any
individual, in an aggregated form such that it is very difficult to relate
such information back to a unique individual.
You Have Choices About Our Use And Disclosure Of Your Information
You can limit your Personal Information and Non-Personal Information that we
collect. In almost all cases, doing so will also limit the effectiveness,
user-friendliness and/or availability of the Services you are trying to use.
If you do wish to place limitations, here are some things you can do:
a) You can set your web browser to restrict or to entirely block cookies, to
configure cookie notification settings and/or to delete cookies already
present on the browser or device. Information on how to do this should be
provided in the web browser’s help/reference section.
b) You can choose to opt out from receiving communications from us or a
Customer (i) by checking the appropriate box on the form where your data is
collected, (ii) by unsubscribing at the bottom of emails you receive from us
(or from our Customers), (iii) at any other time by sending an email request
to firstname.lastname@example.org, or (iv)
where available, the Service itself. We will comply as soon as we reasonably
can. Opting out does not mean that we will not be able to send you important
administrative messages. If we need to get in touch with you for an
administrative reason, we will do so.
We might also keep certain information for recordkeeping purposes, as required
by law for a mandated retention period, to complete transactions and because
our databases will retain some residual data.
Children Under the Age of 13
Our Services are not intended for children under 13 years of age. We do not
knowingly collect Personal Information from children under 13. If you are
under 13, do not (i) use or provide any information on these Services or on or
through any of its features, (ii) register to use any of our Services, (iii)
make any purchases through our Services, (iv) use any of the interactive or
public comment features of our Services or provide any information about
yourself to us, including your name, address, telephone number, e-mail address
or any screen name or user name you may use. If you believe we might have any
information from or about a child under age 13, please contact us using one of
the means provided below (see Contact Information).
How We Use Third Party Analytics And Deliver Advertising To You
We may use third party analytics and social media providers to collect
information about your use of the Services, see the overall patterns of usage
on the Services, deliver advertisements (including advertisements from our
Customers) to your social media account based on email addresses, optimize ad
performance, and to determine whether our advertising is effective.
We use analytics tools and other third party technologies to collect Personal
Information and Non-Personal Information in the form of various usage and user
metrics when you use our Services. These tools and technologies collect and
analyze certain types of information, including cookies, IP addresses, device
and software identifiers, referring and exit URLs, onsite behavior and usage
information, feature use metrics and statistics, usage and purchase history,
MAC Address, mobile unique device ID, and other similar information.
The third party analytics companies who collect information on our Services
and other online products and/or services may combine the information
collected with other information they have independently collected from other
websites and/or other online or mobile products and services relating to your
activities across their network of websites as well as online and/or mobile
products and services. Many of these companies collect and use information
under their own privacy policies.
You may opt out of Google Analytics by visiting the Google Analytics opt-out
https://tools.google.com/dlpage/gaoptout. Google has additional information available about their Remarketing Privacy
Guidelines, and Restrictions. You may learn more at
We do not currently respond to Do Not Track signals.
Third Party Services
We are not responsible for the privacy, information, collection, usage and
disclosure policies and practices of independent third parties, including any
such party operating a site or service outside of the Services, app
developers, app providers, social media platform providers, operating system
providers, wireless service providers and device manufacturers who we may
direct you to when you leave our Site.
The Services are controlled and operated by us from the United States, and are
not intended to subject us to the laws or jurisdiction of any state, country
or territory other than that of the United States. Any use of the Services by
you from outside the United States, alone, does not subject us to the laws or
jurisdiction of any state, country or territory outside the United States.
We seek to use organizational, technical and administrative measures to
protect Personal Information. Unfortunately, no data transmission or storage
system can be guaranteed to be 100% secure. If you have reason to believe that
your interaction with us is no longer secure (for example, if you feel that
the security of any account you might have with us has been compromised),
please immediately notify us of the problem by contacting us using the
“Contact Information” section below.
We will retain your Personal Information for as long as we believe is
longer retention period is required or permitted by law.
Your State Privacy Rights
Residents of certain states, under certain provisions of relevant state law,
have certain rights as it relates to how their Personal Information is
handled. These are the “right to know,” the “right to delete,” and the “right
(1) Right to Know. You may request us to provide you the specific
pieces of Personal Information that we have about you, categories of Personal
Information we have collected about you, categories of sources from which the
Personal Information is collected, categories of Personal Information that we
sold or disclosed for a business purpose about you, categories of third
parties to whom the Personal Information was sold or disclosed for a business
purpose, and the business or commercial purpose for collecting or selling
Personal Information. Please note that much of the information for which you
can make a request is already contained in this Policy. Should you wish to
exercise this right, please contact us via one of the methods noted below
under “Exercising Privacy Rights.” If you do not have an account with us, we
may ask for some Personal Information in order to verify your identity and
your rights to the data subject to your request.
(2) Right to Delete. Some state law gives residents a limited right to
request deletion of their Personal Information. However, this right is limited
by a number of exceptions. Fundamentally, if we have a permissible need to
retain Personal Information, we are not under an obligation to delete such
information, even when requested. Generally, we retain Personal Information so
we may complete the transaction for which the Personal Information was
collected, provide a good or service requested by you, or reasonably
anticipated within the context of our ongoing business relationship with you,
or otherwise perform a contract between us and you; detect security incidents,
protect against malicious, deceptive, fraudulent, or illegal activity; or
prosecute those responsible for that activity; debug to identify and repair
errors that impair existing intended functionality of our online properties;
enable solely internal uses that are reasonably aligned with your expectations
based on your relationship with us; comply with a legal obligation; or
otherwise use your Personal Information, internally, in a lawful manner that
is compatible with the context in which your provided the information. As
such, we generally do not accept requests to delete Personal Information.
However, we will respond to requests to remove Personal Information from some
of our systems as a part of a request to close or otherwise disable an
account. If you would like to request deletion of Personal Information, please
contact us via one of the methods noted below under “Exercising Privacy
Rights.” If you do not have an account with us, we may ask for some Personal
Information in order to verify your identity and your rights to the data
subject to your request.
(3) Right to Opt-Out. While we do not sell your Personal Information to
unaffiliated third parties in the traditional sense, some state laws define
our advertising practices as “selling” personal information. Should you wish
to opt out of our disclosure of your personal information for this kind of
marketing, please contact us via one of the methods noted below under
“Exercising Privacy Rights.” Additionally, you may use the opt-out methods
described above in the “Opting Out” section of this policy.
(4) Designating an Authorized Agent. Some state law permits those
state’s residents to designate an agent to manage their rights under state
law. If you would like to designate an agent to manage your privacy
preferences, you may do so using the mechanisms noted below under “Exercising
Privacy Rights.” Note that if you do not have an account with us, we may ask
for some Personal Information in order to verify your identity and your rights
to the data subject to your request. We will also need sufficient Personal
Information about your authorized agent to be able to identify them. As part
of this process, you must have permission from your authorized agent to
disclose their Personal Information to us for the purpose of acting as your
(5) Non-discrimination. Some state’s law prohibits us from
discrimination against you because you exercised any your rights under this
title, including, but not limited to, by: denying you access to goods or
services; charging different prices or rates for goods or services, including
through the use of discounts or other benefits or imposing penalties;
providing a different level or quality of goods or services; or suggesting
that you will receive a different price or rate for goods or services or a
different level or quality of goods or services.
(6) Exercising California privacy rights. If you are a resident of a
state that provides you the above rights, and would like to exercise any of
your rights, you may do so by contacting us as described below or via
toll-free number 888-446-6911. Please be aware that we will need to have
sufficient information to be able to verify your identity and the rights you
have in the data subject to your request.
the Services following these changes means that you accept the revised Privacy
practices, contact us at:
Attention: Customer Care Privacy Representative
PO BOX 22555 (mailing)
3100 Bonnet Creed Rd. (overnight delivery only)
Lake Buena Vista, FL, 32830-2555
Or email us at: email@example.com
Please note that email communications are not always secure; so please do not
include credit card information or sensitive information in your emails to us.
Copyright © Smart City Networks, Limited Partnership 2000-2022. All rights
Document Date: 04/14/2022