INTRODUCTION
IKE SMART CITY, LLC (“IKE”, “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.IKE adopts this Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.
Please read this policy carefully to understand our policies and practices regarding your information, how we will treat it, and your rights pertaining to your information. 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 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 Kiosks offer interactive features, including transit resources, business directory listings, and survey applications. To access mobile versions of these interactive features on a personal smart device, the Kiosk will prompt you to scan a QR code with your mobile device. The QR code will anonymously direct your mobile device’s internet browser to an external website containing the requested information. If your mobile device is not capable of accessing the applications by scanning the QR code, you may access the same information by providing your mobile phone number to the Kiosk. This information 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 the service of transmitting to you a link to the information requested, 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: IKE’s transit application, Get Around, IKE’s business directory applications and any other feature that incorporates IKE’s mobile hand-off solution to deliver presented information to a your mobile phone. 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 may engage with Third-Party Partners to enable us to provide the Wi-Fi service. We will disclose the Third-Party Partner at the time you use the Wi-Fi services. If your personal device has Wi-Fi turned on, your personal device may share its MAC address with the Kiosk across the Wi-Fi signal. We do not store this technical information, your browser history, or track the websites you visit.
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 at any time sold any Personal Information to third parties, including within the past 12 months. IKE will not sell any of your Personal Information.
Categories of Personal Information Collected by IKE
IKE has collected the following categories of Personal Information from its users 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, in each case, as appliable:
It is possible that during your interaction with a Kiosk no information was collected from you. If that is the case, then we will not have any information to disclose to you in response to your verifiable user request.
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 to a reasonable certainty 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.
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: August 30, 2022
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