Link Wi-Fi App Privacy Policy

Effective as of: June 8, 2018

This is the Privacy Policy of Intersection Parent, Inc. (“Intersection,”  “we”, “us”, and “our”). We are committed to protecting and respecting your privacy and your data.  This Privacy Policy is written to explain what information we collect, how we use it, with whom we share it, and the choices you have to control your information.  This Privacy Policy applies to the Link Wi-Fi app (the “App”), the public displays where Intersection displays advertising or other content, including the digital public displays on either side of the LinkNYC public communication structures (“Link Kiosks”), as well as posters, billboards and digital public displays owned or operated by third parties (collectively, the “Public Displays”),  and any services or products that display notice to this policy (collectively, the “Services”).

Privacy Practices of LinkNYC and InLinkUK

This Privacy Policy applies to the services offered by Intersection, including the App.

The App provides encrypted network access for mobile devices and automatically connects when you are within range of the free Wi-Fi services offered on Link Kiosks.

In New York City, the Link Kiosks and the Wi-Fi services offered on Link Kiosks (the “Citybridge Wi-Fi Services”) are offered by Citybridge, LLC, one of our affiliates.  The privacy practices of the Link Kiosks, including the Citybridge Wi-Fi services, are governed by the LinkNYC Privacy Policy. We strongly encourage you to read both policies.  

InLinkUK is governed by its own privacy policy.

The website Intersection.com is governed by its own privacy policy.

Please read this Privacy Policy carefully to understand how we treat your information. BY DOWNLOADING ANY OF OUR APPS, REGISTERING FOR ANY OF OUR SERVICES, OR OTHERWISE AFFIRMATIVELY INDICATING YOUR CONSENT, YOU CONSENT TO THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF, FOR ANY REASON, YOU DO NOT CONSENT TO THESE PRACTICES, PLEASE DO NOT USE THE SERVICES.

Please visit the sections below to learn more about our Privacy Policy:

1. INFORMATION WE MAY COLLECT
2. HOW WE USE INFORMATION WE COLLECT
3. HOW WE MAY SHARE YOUR INFORMATION
4. REQUESTS FOR YOUR INFORMATION BY GOVERNMENT AGENCIES
5, HOW LONG WE KEEP INFORMATION
6. HOW WE SECURE YOUR INFORMATION
7. COOKIES
8. YOUR CHOICES
9. CHILDREN
10. LINKS TO THIRD PARTY SERVICES
11. INTERNATIONAL
12. CHANGES TO OUR PRIVACY POLICY
13. CONTACT

1. INFORMATION WE MAY COLLECT

1.1 Information We Collect When You Register for the Services.

[Some of the Services] may require that you register with us.

For example, in order to register to use the App, we require your email address.

You may be able to register using your Facebook or Google log-in credentials.  By doing this, you are asking them to send us only the email address associated with those accounts, and you are authorizing us to collect, store, and use your email address in accordance with this Privacy Policy.  We do not collect any other information from Facebook or Google in this process.

1.2 Information We Collect When You Use the App

1.2.1 Technical Information.  When you use the App, we automatically collect certain information about the device you are using and your use of the Services (“Technical Information”).  The Technical Information we collect when you use the App may include some or all of the following:

  • Time zone setting (e.g., Eastern Standard Time),
  • Operating system and platform (e.g., Apple iOS),
  • Device type (e.g., smartphone),  and
  • Your device’s mobile advertising identifier, if you have downloaded one of our apps. See Sections 2.3 (Technical Information) and 8 (Your Choices) for more information on how we use and share mobile advertising identifiers,  and your choices around the collection and sharing of your device’s mobile advertising identifier, including how you can change it.

1.2.2. Location Information.  The App provides encrypted network access for mobile devices and automatically connects when you are within range of the Citybridge Wi-Fi Services.   When location services are enabled in the App, and you are within range of one of the Public Displays, including a Link Kiosk, we collect your precise geographic location (e.g., latitude and longitude).  

We never share your precise geographic location with any other party.

Even when location services are enabled, the ads on the Public Displays will never be targeted to you as a specific individual based on your current GPS location.

1.2.3 Browsing and Other Information Generated When You Use the Citybridge Wi-Fi Services

The App does not collect or store any browsing data generated when you use the Citybridge Wi-Fi Services, including your browsing history, and we do not track the websites you visit or services, you use when you are on the Citybridge Wi-Fi Services.   

1.6 Information You Provide When You Communicate with Us

If you send us an email, fill out a feedback form,  call us, sign up for an email list on our website, or choose to communicate with us in another way, we will collect the information necessary to respond to your request, feedback, or question. We will use and share information you provide to us only as described in this Privacy Policy.

1.8 Information We Collect When you Purchase Additional Products or Services

We may offer additional paid products and services.  To enable payment, you may have to provide name, address, telephone number, email address, credit payment card information, and other billing information.   This information will only be shared with third parties solely to help to complete the purchase transaction. We do not process, record, or maintain your payment card information; instead, payment information is processed by a third party payment processor.

1.9. Third Party Data Sources and Limits

1.9.1 We may supplement the information we collect from you with information collected by third parties.

1.9.2 We will use, collect, and share third party information in accordance with this Privacy Policy.

1.9.3 The information we obtain from third parties is limited to the types of data we can collect under this Privacy Policy.  If we do not collect a type of information about a device directly, we will not purchase that information from a third party.  For example, we may purchase mobile advertising identifiers of devices that are likely to be near the Public Displays because we collect mobile advertising identifiers directly via our apps: however, we will not purchase health care information about users of those devices, because we do not collect that sort of information ourselves.

1.9.4 Click [HERE] for a list of third parties from whom we obtain device information.

1.10 We Do Not Collect Sensitive Information

We will not ask for and do not collect – either directly or through third parties – sensitive information such as social security numbers, medical information, or financial information (other than for payment of optional services). Please do not provide this information to us through emails, feedback forms or in any other way.

2. HOW WE USE INFORMATION WE COLLECT

2.1 In General.  

We may use any information we collect to:

  • Allow us to operate, maintain, or improve the Services, including administration, internal operations, troubleshooting, data analysis, testing, research, statistical, and survey purposes,
  • Manage your use of the App and access to the Citybridge Wi-Fi Services.,
  • Send you information about the Services,
  • To provide you with customer service and respond to your comments and questions,
  • Comply with laws and regulations, and
  • Maintain the security of the Services.

We will not use any of the information we have about you to target ads on Links  or other Public Displays to you as an individual. For example, we may use insights and information about the kinds of people who tend to be at certain locations to display more relevant ads (e.g., sports enthusiasts near a sporting arena or businesspeople in a financial district), but we will never show an ad on a Public Display that is targeted to a specific individual.  

2.2 How We Use Technical Information

2.2.1 We may use Technical Information, including your device’s mobile advertising identifier, to:

  • Improve the Services,
  • Deliver relevant advertising on Public Displays,  including the Public Displays on the Link Kiosks, and
  • Enable measurement of the effectiveness of advertising we show to you on Public Displays.

2.3 How We Use Personal Information

Personal Information is information that can be used to identify or contact a single person.  We may use your Personal Information, such as your email, to:

  • Deliver the Services or respond to your requests,
  • Communicate with you as permitted by the Privacy Policy, including in the case of a law enforcement request, and
  • If you have requested, provide you with information about goods or services that may interest you.

3. HOW WE MAY SHARE YOUR INFORMATION

3.1 How We Will and Won’t Share Your Personal Information

3.1.1 We will not sell your Personal Information.

3.1.2 We may share any information, including your Personal Information, with:

  • Our affiliates, including Citybridge[, and Place Exchange, Inc.] (for example, we will give Citybridge the email address you provided at registration so that they can contact you in the event of a change to their products or services.  Citybridge can only use your email in accordance with their posted privacy policy.
  • Service providers and sub-contractors to the extent reasonably necessary to enable us to provide the Services (for example, we use a third party platform to send email to our users; we cannot communicate with you without disclosing your email address to our third party email provider),
  • A third party that acquires Intersection or a majority of its assets, if that third party obtains the rights to provide the Services and remains subject to the provisions of this Privacy Policy,
  • A third party with whom we believe we must legally share information about you, or
  • Other third parties, if you have given us your express consent to do so after we’ve explained the purpose.

3.1.3. We will not share your Personal Information with any third party for that third party’s own use unless permitted by this Privacy Policy.

3.2 How We Share Technical Information, Including Mobile Advertising Identifiers

3.2.1 We may share any Technical Information, including your mobile advertising  identifier with:

  • Analytics, search engine, or other service providers that help us improve the Services,
  • Our affiliates, including Citybridge[ and Place Exchange, Inc.], or
  • Our advertising partners (which include advertisers, advertising agencies, and advertising technology platforms) to report, analyze and measure the delivery and effectiveness of advertising presented to you on Public Displays.  This information may also be used by our advertising partners to plan their advertising campaigns and select the locations and contexts where their advertisements will be displayed.

3.2.2. Sharing of Mobile Advertising Identifiers and Zip Location.  Specifically, we may share with the relevant advertising partner the mobile advertising identifiers of devices that were exposed to their ad in or near a given zip code.   Importantly, we do not share the precise GPS location of the devices or the Public Displays on which their ad was presented. Instead, we use randomization algorithms and other technology to obfuscate the location so that the advertising partner can only be aware that an ad was displayed somewhere in or near a given zip code. We share this information so that they can plan their advertising campaigns and select the locations and contexts where their advertisements will be displayed.

3.2.3 In zip codes that have fewer than six (6) Public Displays, we do not share mobile advertising identifiers at all.   

3.2.4 We never share the precise GPS location of users.  We will never share mobile advertising identifiers that are linked to precise locations.  We do not use or share your mobile advertising identifier in a way that would allow advertising partners to target an ad on a Public Display to you as specific individual.

3.2.5. If you do not want us to share your device’s mobile advertising identifier, you can go [here] for instructions on how you can configure your device or app settings.  If we receive an opt-out signal in connection with your mobile advertising identifier, we will not share it.

3.3 Location Information

3.3.1 We Do Not Share Precise Location. We do not share your precise  location (specifically, your GPS latitude and longitude) with any third parties for their own purposes.  We delete your precise location information within 3 days after collecting it.

3.3.2 We May Share Zip Code Location.  As described in Section 3.2.2 (Sharing of Mobile Advertising Identifiers and Zip Location), we will share with the relevant advertising partner information that would allow them to know  the zip code you were in when you were exposed to their ad. Importantly, we do not share the location of the Public Display on which an ad was presented. Instead, we obfuscate the location so that the advertising partner can only be aware that an ad was displayed somewhere in or near a given zip code.  This location obfuscation prevents outside parties from being able to track the precise location of users. We share this information so that they can plan their advertising campaigns and select the locations and contexts where their advertisements will be displayed. This may include deciding to show you an ad on another device or in another context.  

If you want to disassociate zip code location information from your device, you can go here for instructions on how you can configure your device or app settings to prevent sharing of your mobile advertising identifier.

4. REQUESTS FOR YOUR INFORMATION BY GOVERNMENT AGENCIES

We may access, preserve and share your information in response to a valid legal request (like a search warrant, court order, or subpoena) or (1) if we have a good faith belief that the law requires us to do so; (2) to protect and defend our rights and property; (3) to protect against misuse or unauthorized use of the Services; or (4) to protect the personal safety or property of our users or the public.  For information on the number of valid legal requests we receive each year, and the information we share, please see our annual Transparency Report.

4.2 If we receive a valid legal request demanding that we provide a governmental entity with your Personal Information, we will attempt to notify you by email, if we have your email address, unless (1) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (2)  we believe that providing notice would be futile, ineffective, or create a risk of injury or bodily harm to an individual or group.

5. HOW LONG WE KEEP YOUR INFORMATION

5.1 How Long We Keep Personal Information  

We keep your Personal Information, which may include email address, user name and password, for as long as required by law, or for as long as we have a reasonable business need. For example, we will keep your email to send you messages regarding changes to the Services or this Privacy Policy.

5.2 How Long We Keep  Randomly Hashed MAC Addresses, Mobile Advertising Identifiers, Your Location Information, and Other Technical Information  

Mobile Advertising Identifiers. We keep your device’s mobile advertising identifier for up to 60 days after it is collected, after which we delete it.

Precise Location Information.  We keep your location information for up to 3 days, after which we delete it.

Everything Else.  We keep all other Technical Information about individual Wi-Fi sessions, including general location information, for 60 days from the end of the session, after which we delete it.

6. HOW WE SECURE YOUR INFORMATION

All information you provide will be stored by, and may only be transferred or accessed by, entities in the United States. The security of your information is important to us. We encrypt Personal Information we store about you. If you use a password to access any of our Services, you are responsible for keeping this password confidential. Do not share your password with anyone.

Unfortunately, the transmission of information as you use the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee against access to your Personal Information by unauthorized third parties. The security of your data transmitted to or through our Services is at your own risk. Once we have received your information, we will use appropriate and necessary administrative, technical, and physical controls to prevent unauthorized access, including deleting your information in accordance with this Privacy Policy.

If we learn that an unauthorized person gains access to your information we will notify you as soon as feasible at the last email address you have provided us, unless we determine that no harm is reasonably likely to occur from the unauthorized disclosure.

7. YOUR CHOICES

7.1 Your Choices Regarding Mobile Advertising Identifiers

For information on how to limit our receipt, use, and sharing of your device’s mobile advertising identifier, including for instructions on how you can configure your device or app settings, please go [here].

7.2 Your Choices Regarding Location Information

In order to access the Wi-Fi services from your mobile device, you must download the Link Wi-Fi app and enable location services on your device. The Link Wi-Fi app provides encrypted network access for mobile devices and automatically connects when you are within range of our Wi-Fi Services.  If you do not wish to share your location with us, you can disable location services, but you will not be able to access the Wi-Fi services.

7.3 Your Choices Regarding Email

If you have given us permission, we may send you emails with marketing and promotional messages. You can update your communications preferences, including opting out of marketing messages, at any time by clicking “unsubscribe” at the bottom of these emails.  

7.4 Your Choices Regarding Network Diagnostic Information

We use some of the Technical Information collected from your device to help us  understand how the App is operating and if there are any problems. This information gives us a device-level picture of how the App is connecting to the Citybridge Wi-Fi Services.  For example, we can use any connection failures your device records in order to identify Wi-Fi dead zones or which devices or operating systems have difficulty accessing the Wi-Fi Services.  Without the network diagnostic information, we would simply see that you have accessed and left the Wi-Fi Services; the network diagnostic information can help us understand if you left Wi-Fi range, or if there was a problem with the network. We do not store network diagnostic information in a way that it can be tied back to your Personal Information.  

You can configure your app settings to opt out of sharing  network diagnostic information. If you turn off sharing of network diagnostic information, our network will still log your access and use of the Wi-Fi Services, but network diagnostic information will be not collected from your device.

8. CHILDREN

The Services are not directed toward children under 13 years of age nor does Intersection knowingly collect information from children under 13.  If you are under 13 years of age, you are not permitted to submit any Personal Information to Intersection.

9. LINKS TO THIRD PARTY SERVICES

The App may contain links to and from the websites of our partner networks, advertisers and affiliates. For example, websites you visit when using the secure access to the Citybridge Wi-Fi Services have their own privacy policies and may request information from you, including Personal Information. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

10. INTERNATIONAL

Our Services are offered in the United States.  If you are visiting from the European Union or other regions, please note that you are transferring your information to the United States which has laws governing data collection and use that may differ from those in your home country.  By using the Services, you consent to the transfer of your information to the US, and to the uses set forth in this Privacy Policy.

11. CHANGES TO OUR PRIVACY POLICY

If you provide us with your current email address, we will send an email to that email address, notifying you of any material updates or changes we may make to the Privacy Policy prior to the changes becoming effective.  All changes (material or otherwise) will also be posted on this page so please check back frequently. After we notify you of changes to the Privacy Policy, please discontinue use of the Services if you do not consent to the changes.

12. CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to: Intersection, 10 Hudson Yards, 26th Floor, NY, NY 10001 or privacy@intersection.com.