Effective as of: October 12, 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
LinkNYC and CityBridge, LLC
Many of our Services, including the Wi-Fi Services, are provided in fulfilment of our obligations under an agreement between us and our public partners (for example, cities, transit authorities, and airports) (collectively, “public partners”). We are not an agency, office, department, or affiliate of our public partners. We provide our public partners limited information created in the course of providing the Services, which is described in Section 3.4 (How We Share Information with Our Public Partners).
- 1. INFORMATION WE COLLECT
- 2. HOW WE USE INFORMATION WE COLLECT
- 3. HOW WE MAY SHARE INFORMATION
- 4. REQUESTS FOR YOUR INFORMATION BY GOVERNMENT AGENCIES
- 5. HOW LONG WE KEEP YOUR INFORMATION
- 6. HOW WE SECURE YOUR INFORMATION
- 7. OUR WEBSITE AND COOKIES
- 8. YOUR CHOICES
- 9. CHILDREN
- 10. LINKS TO THIRD PARTY SERVICES
- 11. INTERNATIONAL
- 13. CONTACT
1.1 Information We Collect When You Register for the Services
Some of the Services may require that you register with us. In order to register to use the Services, we may require some or all of the following:
- A user name;
- Your email address;
- A password for your account.
1.2 Information We Collect When You Use the Wi-Fi Services
1.2.1 Technical Information.
When you use the Services, 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 Wi-Fi Services may include some or all of the following:
- Browser type (e.g., Chrome) and version,
- Time zone setting (e.g., Eastern Standard Time),
- Browser plug-in types (e.g., Adobe Flash Player) and versions,
- Operating system and platform (e.g., Apple iOS),
- Device type (e.g., smartphone),
- Your devices ’s randomly hashed MAC address. We do not store MAC addresses unless they have been assigned a randomly generated (i.e., “hashed”) identifier; and
- Your device’s mobile advertising identifier, if you have downloaded one of our apps. See Sections 2.2 (How We Use 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
Location Information Collected Via our Apps.
In order to access the Wi-Fi Services from your mobile device, you must download the Link Wi-Fi app and enable location services. 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. When location services are enabled in the Link Wi-Fi app, and you are within range of a Public Display, including Links and other Structures, we collect information about your precise geographic location (e.g., latitude and longitude). We do not share (and will prevent our affiliates from sharing) your precise geographic location with any unaffiliated third party.
Even when location services are enabled, the ads on the Public Displays will never be targeted to you as a specific individual.
Location Information Collected Via Non-Mobile Devices.
If you access the Wi-Fi Services from a laptop or other non-mobile device, we do not collect information about your device’s location. However, we know where we provide Wi-Fi Services, so when you use the Wi-Fi Services we can infer your general location.
1.2.3 Browsing and Other Information Generated When You Use the Wi-Fi Services
We do not collect or store the browsing data generated when you use the Wi-Fi Services, including your browsing history, and we do not track the websites, services, or apps you use or visit using Wi-Fi Services. Instead, the data generated when you use the Wi-Fi services are used only to provide those services; we do not collect or otherwise store that information. For example, destination IP addresses, configuration details, and other similar information is necessary to provide access to the Services, but we do not store or compile that information.
1.3 Information We Collect When You Use the Free Calling Services
When you use the Link tablet in order to make a free call, we, via our calling partner, log that call, as well as the time, duration, and the number called. No log-in or registration is required and we do not record the calls.
1.4 Information We Collect When You Visit Our Websites
When you visit our websites, including www.intersection.com and www.cities.link, we may collect Technical Information about the computer, mobile device, or other device you use to visit the site, as well as IP address. We may also use “cookies,” web beacons, tags and scripts, and other similar technologies in order to help us understand your visit to our website. Our websites do not respond to browser-based “do not track” signals.
1.5 Information You Provide When You Communicate with Us
1.6 Images Captured By Cameras
Some of the Structures incorporate digital cameras. For example, Links have security cameras mounted on each side above the digital Public Displays, and in the Link tablet. The cameras are designed to capture images and video footage of the area surrounding the Structure, and those images may include you. See Section 2.5 (How We Use Camera Footage) below for more information on how we use and store camera footage.
Security cameras are not operational in all cities. Please review our FAQs to see if the security cameras on the Structures in your city are active.
1.7 Information We Collect When you Purchase Additional Products or Services
We may offer additional paid products and services. To enable payment via the Services, 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.
1.8 Third Party Data Sources and Limits
1.8.1 We may supplement the information we collect from you with information collected by third parties.
1.9 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.
1.10 USB Ports Do Not Collect Information
Our Structures, including Links, may include one or more USB ports. Our USB ports provide electricity to charge your devices and cannot and do not collect any information from your device.
1.11 Tablets Do Not Collect Your Information
Our Structures, including Links, may include a tablet. Tablets do not require registration and do not collect any Personal Information, though the individual third party apps on our tablets may request information, including Personal Information. Please see Section 10 (Links to Third Party Services) for information on data that may be collected when you interact with third party services on our tablets.
2.1 In General.
We or our affiliates may use any information we collect to:
- Allow us to operate, maintain, or improve the Services, administration, internal operations, troubleshooting, data analysis, testing, research, statistical, and survey purposes,
- Manage your access to the 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 (and will not allow our Affiliates to) use any of the information we have about you to target ads on Structures 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, and we will never use the Wi-Fi Services to insert advertisements directly onto the apps or websites you may visit using the Wi-Fi Services.
2.2.1 We may use Technical Information, including randomly hashed MAC addresses and your device’s mobile advertising identifier, to improve the Services and present content in the best way for you and for your device.
We do not log the MAC addresses of devices passively scanning for wi-fi connectivity.
We do not use or share hashed or unhashed MAC addresses for purposes of displaying or measuring advertising.
We use randomly hashed MAC addresses only to track usage and performance of the network.
2.2.2 We may use Technical Information other than randomly hashed MAC addresses to:
- Deliver relevant advertising on Public Displays, including on Links and other Structures, 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,
- Provide you with information about goods or services that may interest you.
2.4.1 We will not use facial recognition or any other technology to attempt to identify you, and we will not use our cameras to track your movement throughout the city.
2.4.2 We will not use or disclose footage collected by our cameras except:
- To improve the Services and ensure the performance and security of the Services, including the security of the Links,
- To detect or address illegal activity on or associated with our Services,
- To identify, contact, or bring legal action against someone who appears to be causing injury to or interfering with our property, or
- If we believe that disclosure is required by law or useful to protect your safety or the safety of others, including when there is an emergency involving potential harm, loss of security, or serious injury to people or threats of such emergencies.
2.4.3 Security cameras are not operational in all cities. Please review our FAQs to see if the cameras on the Structures in your city are active.
3.1 How We Will and Won’t Share Your Personal Information
3.1.1 We will not sell your Personal Information.
3.1.3 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, 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, but specifically excluding your randomly hashed MAC addresses, with:
- Analytics, search engine, 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 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 the precise 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 3 Structures, we do not share mobile advertising identifiers at all.
3.2.4 We never share the precise location of users.
3.2.5. 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. We do not use or share hashed or unhashed MAC addresses for purposes of displaying or measuring advertising.
3.2.6. 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 latitude and longitude) with any third parties for their own purposes. We delete your precise location information 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 may share with the relevant advertising partner the zip code you were in when you were exposed to their ad. Importantly, we do not share with advertisers or unaffiliated third parties the location of the Public Display on which an ad was presented to you. 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.
3.4. 1 In General.
We do not share Personal Information, randomly hashed MAC addresses, mobile advertising identifiers, or other information about you or your individual use of the system with our public partners, except as may be required by law. We may provide aggregate or statistical reporting on the different Services, including statistics on Link usage (for example, we may provide our public partners with reports of the number of 911 calls made or the total number of new users). Those reports may also be made available through the public partner’s open data tools and policies.
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 Randomly Hashed MAC Addresses, Mobile Advertising Identifiers, Your Location Information, and Other Technical Information
Randomly hashed MAC Addresses.
Randomly hashed MAC addresses are stored for 12 months after your last use of the Wi-Fi services.
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.
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.
5.3 How Long We Keep Camera Footage
We delete footage captured by any camera within 7 days, unless that footage is necessary to investigate an incident.
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 If you fill out a feedback form on our websites, sign up for an email list or choose to communicate in another way, your information will be collected in order to respond to your request, feedback, or question. We will not share that information with any third party for their own use.
7.2 We may also collect information about the IP address, as well as the computer, mobile device, or other device you used to visit our website.
7.3 Our website uses “cookies,” web beacons, tags and scripts, and other similar technologies to help understand website visitors. The website does not respond to browser-based “do not track” signals.
7.4.1 You can find out more about Google Analytics cookies here. You can avoid the use of Google Analytics relating to your use of our website by downloading and installing the Browser Plugin available here.
8.1 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.
8.2 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.
8.3 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.
8.4 Your Choices Regarding Network Diagnostic Information
We use some of the Technical Information collected from your device to help us understand how the Wi-Fi Services are operating and if there are any problems. This information gives us a device-level picture of how the Wi-Fi Services are working for you. 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.
The Services are not directed toward children under 13 years of age and Intersection does not 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.
Our Services may contain apps or links to and from the websites of our partner networks, advertisers and affiliates. For example, the tablet on the Links may take you to third party websites. Those websites 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.