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Privacy Policy - St.Louis, MO

Introduction

IKE SMART CITY, LLC (“We”, “Us”, “Our”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit an IKE Kiosk (“Kiosk”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Kiosks. By accessing or using a Kiosk, you agree to this privacy policy. This policy may change from time to time. Your continued use of a Kiosk after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

User Information Collected by a Kiosk

General

Many of the features, services and information available on a Kiosk can be accessed by you anonymously and without requiring that you provide any information about yourself. The Kiosk will collect information on each user’s interactions with the Kiosk, such as which features, services and information are most often used and how they are used, so we can improve the Kiosk platform and your experience with the Kiosks. We may share this information without restriction with the city where the Kiosk is located and its agencies, Visit Berkeley and our technology partners.

Interactive Features

The following features offered by a Kiosk are interactive: (a) 311; (b) Get Around; (c) Photo Booth; and (d) Survey Says. To access these interactive features, the Kiosk will prompt you to scan a QR code with your mobile device. The QR code will anonymously link your mobile device to the applications. If your mobile device is not capable of accessing the applications by scanning the QR code, you may access these features by providing the information requested by the Kiosk, some of which may personally identify you. The Kiosk will only ask you for information that is necessary to perform the service you request based on the interactive feature you select. Additionally, the Kiosk will only store this information long enough to perform that service, and during that time, we will not share, sell or otherwise disclose this information to any third parties, subject to any features operated by a Third-Party Partner, as described in the following paragraph. After that, the information will no longer be retained by the Kiosk or IKE.

The following interactive features of the Kiosk platform are operated or provided by, incorporate the API(s) of, or otherwise require communication or coordination with third parties (a “Third Party Partner”), and in choosing to engage these features, you agree that we can provide the information you give to a Kiosk, including any information that may personally identify you, to that Third Party Partner: (a) 311; (b) Get Around; and (c) Photo Booth. By way of example, the 311 feature enables you to send a message to the city and receive updates on the status of your message. When engaging the 311 feature, it will not only ask you for your email address but will also provide your email address to the city so that you can receive the updates you requested. We will always disclose whether an interactive feature is operated by a Third-Party Partner, and this disclosure will appear prominently on the screen when you select one of these features. With respect to any feature operated by a Third-Party Partner, the Kiosk will only store the information you provide long enough to perform the service you request. After that, the information will no longer be retained by the Kiosk or IKE, but it may continue to be retained by the Third-Party Partner. We will only share this information with the Third-Party Partner, and we will not share, sell or otherwise disclose this information to any other third parties. We do not exercise control over our Third-Party Partners, and you will be subject to their policies and terms and conditions when you engage with any feature operated by a Third-Party Partner. For this reason, we recommend that you review their policies and terms and conditions prior to engaging with any feature operated by a Third-Party Partner.

Other Services

WIFI Service

Each Kiosk may be equipped to provide Wi-Fi service to personal devices able to receive a wireless Wi-Fi signal that are located within close proximity to the Kiosk. We engage with Third Party Partners to enable us to provide the Wi-Fi service to you. If your personal device has Wi-Fi turned on, your personal device may share certain technical information with the internet service provider across the Wi-Fi signal. The technical information is available to us only for twelve (12) months, after which it is deleted and no longer available to us. We do not store your browser history or track the websites you visit.

Environmental Sensors

Each Kiosk may have environmental sensors that are able to collect data about the environment near a Kiosk, such as air quality. The environmental sensors do not collect any data from or about you. We will share this data without restriction to the city, our local partners and our technology partners or any other party as we reasonably deem necessary.

Camera

Each Kiosk may be equipped with one or more cameras. The cameras capture images of the area surrounding the Kiosk, and those images may include you. We will not keep any footage captured by any camera for longer than 15 days, unless the footage is necessary to investigate an incident. We may elect to share camera footage with local governmental authorities in furtherance of public safety, however we will not otherwise use or disclose data collected by our cameras except to improve the functionality and ensure the security of the Kiosks or as necessary to address illegal activity on, associated with or perpetrated against the Kiosks or in the surrounding area. We will not use facial recognition technology.

Disclosure of Information

In addition to the disclosures we have identified elsewhere in this policy, we may also disclose any and all information collected by us or that you provide to us via a Kiosk as described in this policy to our parents, subsidiaries and affiliates, and/or any entity who acquires, by any means, some or all of the assets or ownership interests of IKE Smart City, LLC.

Data Security

We have implemented measures designed to secure any information you provide to us via a Kiosk from accidental loss and from unauthorized access, use, alteration and disclosure. Although we do our best to protect your information, we cannot guarantee the security of the information you provide to us via a Kiosk.

Children

The Kiosks are not intended to be used by children under the age of 13 nor do we knowingly or intentionally collect personal information from children under the age of 13. If you are under the age of 13, you are not permitted to submit any personally identifiable information to us. We adhere to the Children’s Online Privacy Protection Act in our operation of the Kiosks.

Privacy Policy Changes

We may update this Privacy Policy from time to time to reflect changes in applicable law. Because any personal information you provide to us is not stored or maintained in databases owned or created by us, we will be unable to notify you as and when this Privacy Policy is updated. Therefore, we encourage you to visit this Privacy Policy page periodically to view any updates.

Last Updated: January 16, 2020

State Specific Regulations

California: For more information regarding the rights entitled to California residents under the California Consumer Privacy Act, click here.

Contact Information

To ask question or provide comments about this policy and our privacy practices, contact us at:

250 N Hartford Ave
Columbus, Ohio 43222

614.294.4898

privacy@ikesmartcity.com

 


 

Rights Under the California Consumer Privacy Act

General

The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information. This section describes the information collected from you, describes your CCPA rights as they pertain to your use and access to a Kiosk, and explains how to exercise those rights.

The CCPA defines “Personal Information” as information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or device. By using a Kiosk, you agree to give certain Personal Information to IKE. IKE has not sold any Personal Information to third parties in the past 12 months. IKE will not sell any of your Personal Information.

Categories of Personal Information Collected by IKE

IKE has disclosed, but not sold, the following categories of Personal Information from its users to its Third-Party Partners within the last twelve (12) months:

Categories of Personal Information Disclosed to Third Parties

IKE has disclosed, but not sold, the following categories of Personal Information from its users to its Third-Party Partners within the last twelve (12) months:

Right to Know About Your Personal Information Collected or Disclosed

You have the right to make a verifiable user request that IKE disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable user request (see Exercising Access and Deletion Rights), we will disclose to you:

Right to Request Deletion of Personal Information

You have the right to make a verifiable consumer request that IKE delete your Personal Information that we have collected or maintained over the past twelve (12) months.

Exercising Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access twice within a twelve (12) month period. All verifiable consumer requests must:

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identify or authority to make the request. We may retain some categories of your Personal Information for shorter periods of time than other categories. Therefore, we may not be able to provide the Personal Information you request if we no longer retain it. Please see the section of this Privacy Policy titled “User Information Collected by a Kiosk” for details on how long information is retained by us.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Please note that the mere nature of certain features and services from the Kiosk require personal information in order to be used. By refusing to provide certain Personal Information, you may not be able to utilize all features offered by the Kiosk.

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