SMART CITY® NETWORKS, LIMITED PARTNERSHIP PRIVACY POLICY

Effective Date: January 1st, 2020

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”).

This Privacy Policy https://www.smartcitynetworks.com/privacy-policy/ is incorporated into and is a part of the Terms of Use https://www.smartcitynetworks.com/termsofuse/ of the Services. Your using, accessing or registering to use our Services is subject to the Terms of Use and this Privacy Policy, and indicates your agreement and acknowledgement to be bound by them. If you do not agree with our Terms of Use or Privacy Policy, you may choose not to use our Services. Please check the Terms of Use and this Privacy Policy periodically for the latest versions.

This Privacy Policy does not apply to information collected by any third party, including through any third-party application or content (including advertising), that may link to or be accessible from our Services.

Whose Information We Collect

We collect information from any one or all of the following three categories of users:

The Information We Collect

Smart City and our Customers may collect several types of information from and about End-Users, including:

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.

Smart City does not use CPNI as described in this Privacy Policy.

How We Collect Personal Information and Non-Personal Information

We collect Personal Information and Non-Personal Information as follows:

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:

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 Policy:

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:

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.

Opting-Out

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.

Cross-Border Transfer

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.

Data Security

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.

Retention Period

We will retain your Personal Information for as long as we believe is necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

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.

Changes to Our Privacy Policy

We may change this Privacy Policy. Please take a look at the “Effective Date” section at the top of this page to see when this Privacy Policy was last revised. Please check this Privacy Policy for the latest version. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Smart City
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: privacycompliance@smartcity.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 2000-2020. All rights reserved.

Document Date: 02/11/2020