Effective Date: January 1st, 2020
Whose Information We Collect
We collect information from any one or all of the following three categories of users:
- 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 the Services.
- 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, see //www.allaboutcookies.com/.
- IP Address. Smart City collects IP addresses automatically. An IP address 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 IP address.
- 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 materials.
- 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 activities.
- 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.
- 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 customers.
- 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 parties.
- 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 firstname.lastname@example.org
- 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
- 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.
- 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 aggregated information, which does not identify any individual, and therefore is Non-Personal Information.
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 email@example.com, 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 page https://tools.google.com/dlpage/gaoptout. Google has additional information available about their Remarketing Privacy Guidelines, and Restrictions. You may learn more at www.google.com/policies/privacy/partners/.
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 third parties, including any such party operating a site or service to which the Services link, app developers, app providers, social media platform providers, operating system providers, wireless service providers and device manufacturers.
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.
Your California Privacy Rights
Residents of the State of California, under certain provisions of the California Civil Code, 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 to opt-out.”
(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 California 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. California 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 California 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. We do not sell your Personal Information to unaffiliated third parties. As such, there is no need for you to opt-out of the sale of information to such parties.
(4) Designating an Authorized Agent. California law permits California residents to designate an agent to manage their rights under California 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 California 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 agent.
(5) Non-discrimination. California law does not permit us to discriminate 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 California resident 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.
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: firstname.lastname@example.org
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 2000-2020. All rights reserved.
Document Date: 02/11/2020