Effective as of: July 6, 2018
Intersection Parent, Inc., together with its wholly owned subsidiary Place Exchange, Inc. (“Intersection,” “we”, “us”, and “our”), is committed to protecting and respecting your privacy and your data.
About Our Affiliates
- 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 YOUR INFORMATION
- 6. HOW WE SECURE YOUR INFORMATION
- 7. YOUR CHOICES
- 8. CHILDREN
- 9. LINKS TO THIRD PARTY SERVICES
- 10. INTERNATIONAL
- 12. CONTACT
1.1 Information We Collect When You Register
We require your email address the first time you use the App in order to register your device for access to the Link Wi-Fi Services.
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:
- Operating system and platform (e.g., Apple iOS),
- Device type (e.g., smartphone), and
- Your device’s mobile advertising identifier. See Sections 2.2 (How We Use Technical Information) and 7 (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 access for mobile devices and automatically connects when you are within range of the Link 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 Link Wi-Fi Services Via the App.
The App does not collect or store any browsing data generated when you use the Link Wi-Fi Services, including your browsing history, and we do not track the websites you visit or the apps or services you use when you are on the Link Wi-Fi Services.
1.3 Information You Provide When You Communicate with Us
1.4 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.
1.5 Third Party Data Sources and Limits
1.5.1 We may supplement the information we collect from you with information collected by third parties.
1.6 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.
2.1 In General
We or our Affiliates 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,
- 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 (and will not allow our Affiliates to) use any of the information we have about you to target ads on Links or other Public Displays to you as an individual. While 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), 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 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,
- If you have requested, provide you with information about goods or services that may interest you.
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:
- 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 with whom we believe we must legally share information about you, or
- Other third parties, only if you have given us your express consent to do so after we’ve explained the purpose.
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 or other service providers that help us improve the Services,
- Our advertising partners (which include advertisers, advertising agencies, and advertising technology platforms) to report on, analyze and measure the delivery and effectiveness of advertising delivered on Public Displays. This information may also be used by our advertising partners to plan their advertising campaigns and select the general locations and contexts where their advertisements will be displayed.
3.2.2. Sharing of Mobile Advertising Identifiers and Zip Location. Specifically, we, through Place Exchange, 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 with advertisers or unaffiliated third parties the precise GPS location of the Public Displays on which their ad was presented, or the devices exposed to the ad. 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 general 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.
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, we will not share your mobile advertising identifier at all.
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 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 precise 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 locations of users. We share this obfuscated information with our advertising partners so that they can plan their advertising campaigns and select the general 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 do not wish to share your precise location with us, you can disable location services, but you will not be able to access the Link Wi-Fi Services via the App. If you want to disassociate precise or zip code location information from your device, you can go here for instructions on how to configure your device or app settings to prevent sharing of your mobile advertising identifier.
4.1 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.
5.1 How Long We Keep Personal Information
5.2 How Long We Keep 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 precise location information for up to 3 days, after which we delete it.
Everything Else. We keep all other Technical Information, including general location information, for up to 60 days from the end of the session, after which we delete it.
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.
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.
7.1 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
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 Link Wi-Fi Services via the App.
iOS users can select when they want to share their precise location information by managing their location permissions in their device settings.
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 or promotional emails, 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 provides a device-level picture of how the App is connecting to the Link Wi-Fi Services. For example, when your device records connection failures, we can work with CityBridge to determine if there are Wi-Fi dead zones or if certain devices or operating systems have difficulty accessing the Link Wi-Fi Services. Without the network diagnostic information, we would simply see that you have accessed and left the Link Wi-Fi Services; the network diagnostic information can help us understand if you simply 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, your connection to the Link Wi-Fi Services will still be logged by the network, but network diagnostic information will be not collected from your device.
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.
The App may contain links to and from the websites of our partner networks, advertisers and affiliates. Websites you visit when using the encrypted access to the Link 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.