Privacy Policy
Effective as of: March 11, 2019
Intersection Design and Technology, Inc., together with its affiliates in the Intersection family of companies (“Intersection”, “we”, “us”, and “our”), is committed to protecting and respecting your privacy and your data.
This Privacy Policy applies to the Shoutable app and any services or products that display notice to this policy (collectively, the “Services”).
About Our Affiliates
Intersection is a family of companies and products that bring digital experiences to public space. Among other things, Intersection owns or manages networks of public displays, including digital screens and billboards. The Services governed by this Privacy Policy will interact with the other services offered by our affiliates, including Link kiosks and Place Exchange.
Link Kiosks, including LinkNYC and CityBridge, LLC
The LinkNYC network of kiosks are presented by Citybridge, LLC, one of our affiliates, and is governed by its own privacy policy.
All other Link networks are presented by Intersection and governed by this Privacy Policy.
Place Exchange
Place Exchange, Inc. offers a digital advertising technology platform that connects buyers of out-of-home advertising space (typically advertisers and their agencies) with sellers of that advertising space (for example, the operators of billboards and digital signage). We may share your information with Place Exchange for its own use. The privacy practices of Place Exchange are governed by the Place Exchange 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 click on the sections below to learn more about our Privacy Policy:
2. HOW WE USE INFORMATION WE COLLECT
3. HOW WE MAY SHARE INFORMATION
4. COMPLIANCE WITH LEGAL PROCESS
5. HOW LONG WE KEEP YOUR INFORMATION
6. HOW WE SECURE YOUR INFORMATION
8. YOUR CHOICES
9. CHILDREN
10. LINKS TO THIRD PARTY SERVICES
11. INTERNATIONAL
12. CHANGES TO OUR PRIVACY POLICY
13. CONTACT
1. INFORMATION WE COLLECT
1.1 Information We Collect When You Register for the Services
Some of the Services may require that you register. In order to register, we may require some or all of the following:
- A user name;
- Your email address;
- A password for your account.
You may also be able to register for the Services by using your social media account log-in credentials (for example, Facebook or Google). 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 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 Services may include some or all of the following:
- Operating system and platform (e.g., Apple iOS),
- Device model (e.g., iPhone 6), and
- Your device’s mobile advertising identifier. 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 use the Services, you are required to download an app. When location services are enabled, 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.
1.3 Information We Collect When You Visit Our Websites
When you visit our websites, including Shoutable.app, 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.
1.4 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.
1.5 Information You Provide When Purchase Products or Services
We offer paid products and services. To enable payment via the Services, you may have to provide name, address, telephone number, email address, credit card payment information, and other billing information. This information will only be shared with third parties solely to help to complete the purchase transaction.
1.5.1 Payment Card Information. Our servers do not receive, process, record, or maintain your payment card information; instead, payment card information is sent to and processed by a third-party payment processor. Our payment Processor is Stripe. For more information, please visit their website.
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 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 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 in public space to you as an individual.
2.2 How We Use Technical Information
2.2.1 We will use Technical Information, including your device’s mobile advertising identifier, to measure use of, or improve the Services and present content in the best way for you and for your device.
2.2.2 We, or our affiliates, may use Technical Information to:
- Deliver relevant advertising on public displays (including on Links) and other platforms (including online), and
- Enable measurement of the effectiveness of advertising we or our affiliates show to you.
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, including to display Shouts, or respond to your requests,
- Communicate with you as permitted by the Privacy Policy, including in the case of a law enforcement request, and
- Provide you with information about goods or services that may interest you.
3. HOW WE MAY SHARE 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 will not share your Personal Information with any third party for that third party’s own use unless permitted by this Privacy Policy.
3.1.3 We may share any information, including your Personal Information, with:
- Our affiliates, including any of our any subsidiaries, joint venture partners or other companies that we control or that are under common control with us. Affiliates are required to comply with the terms of this 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.
3.2 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,
- Intersection affiliates, including Place Exchange, who may use it only as permitted under its Privacy Policy , or
- 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.
If you were exposed to an ad on one of our public displays, our affiliates may share your mobile advertising identifier with the relevant advertising partner. Precise location of mobile advertising identifiers is always scrambled to somewhere in or near a given zip code before it it shared with third parties.
3.2.3 If you do not want us to share your device’s mobile advertising identifier, you can configure your device or app settings to prevent your device from sharing your mobile advertising identifier. 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 three days after collecting it.
3.3.2 We May Share Zip Code Location.
Neither we nor our affiliates share the precise location of users with third parties for their own use.
We, through out affiliate Place Exchange, scramble your location to somewhere in or near a given zip code before sharing it with third parties for their own use.
For more information on how Place Exchange operates, please visit its Privacy Policy.
You can change your location sharing permissions in your device settings at any time. Some features of the Services, including the map in Shoutable, may not function fully with location sharing turned off. In the case of Shoutable, you can post a Shout with location permissions turned off.
4. COMPLIANCE WITH LEGAL PROCESS
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.
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/or 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 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 three days, after which we delete it.
Everything Else
We keep all other Technical 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. OUR WEBSITE AND COOKIES
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 Our website may also use cookies issued by third parties. For example, Google Analytics is used to track the websites visited or search terms used by visitors immediately prior to visiting the website, or to collect information about how visitors use the website. Google Analytics uses its own cookies. These cookies don’t collect information that identifies you. The information collected is only used to improve how our website works.
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. YOUR CHOICES
8.1 Your Choices Regarding Mobile Advertising Identifiers
If you do not want us to receive or share your device’s mobile advertising identifier, you can configure your device or app settings to prevent your device from sharing your mobile advertising identifier.
8.2 Your Choices Regarding Location Information
If you do not wish to share your location with us, you can disable location services in your device’s settings, but certain features including the map in Shoutable, may not function fully with location permissions turned off. In the case of Shoutable, you can still post a Shout with location permissions turned off.
8.3 Your Choices Regarding Email
From time to time 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.
9. CHILDREN
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.
10. LINKS TO THIRD PARTY SERVICES
Our Services may contain links to and from the websites of our partner networks, advertisers and affiliates. 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.
11. 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.
12. CHANGES TO OUR PRIVACY POLICY
If you provide us with your current email address, we will send an email 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.
13. 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@shoutable.app