Privacy

CITILABS, INC WEBSITE PRIVACY POLICY

EFFECTIVE DATE: June 20, 2018

Citilabs, Inc. (“Company”, “we” or “our”) is a global provider of mobility analytics for businesses and government agencies which values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website www.citylabs.com (the “Site”) and the services available through our Site, including our communities platform where individuals with an account can ask questions, seek support and advice, and share tips and tricks concerning Citilabs products and services (collectively, the “Services”).

By visiting the Site, or using any of our Services, you acknowledge that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms and Conditions, including its applicable limitations on damages and the resolution of disputes.

  1. The Information We Collect About You
  2. How We Use Your Information
  3. How We Share Your Information
  4. Our Use of Cookies
  5. Third-Party Advertisers and Analytics
  6. Security of Your Personal Information
  7. Access to My Personal Information
  8. Direct Marketing
  9. Children Under 16
  10. Information for EU Individuals
  11. California Privacy Rights
  12. Contact Us
  13. Changes to this Policy

1. THE INFORMATION WE COLLECT ABOUT YOU

We collect information about you directly from you and our affiliated companies, as well as automatically through your use of our Site or Services.

Information We Collect Directly From You. Most content of the Site is accessible without an account, however one particular area of our Site requires registration - in particular our platform accessible here http://community.citilabs.com.

  • To create an account, you must provide your name, email address and create a login password.
  • If you fill out forms on our website to inquire about any Services, we will collect your first name, last name, email address, company name, a note of what Services you are interested in and a note of whether you are an existing client. These fields are mandatory and we are unable to respond to your query without these data fields. There is also a free text box field and you have the option to provide a telephone number.
  • If you submit comments/feedback on our community forum, we maintain a copy of this content. We may also collect certain information metadata associated with your content (e.g., location, date / time stamp, device type).

 

Information We Collect Automatically. We automatically collect the following information about your use of our Site or Services through cookies and other web tracking technologies: your IP address; your browser type and operating system; domain name; the pages you visit on our Site, and details about the time you access or use our Services; and the referring URL or the webpage that led you to our Site. We may combine this information with other information that we have collected about you, including, where applicable, your name, location and other personal information such as your browsing patterns. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Information We Collect Indirectly.

We collect data through our affiliated companies in the course of business and sometimes will gather contact information that is made publicly available online - where required by law, we will inform you of these sources when this is applicable.

2. HOW WE USE YOUR INFORMATION

We use your information, including your personal information, for the following purposes:

  1. To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service and opportunity purposes.
  2. To tailor the content and information that we send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site or our Services, including targeted advertisements for purpose C below.
  3. For marketing and promotional purposes. For example, we may use your email address to send you newsletters about events special offers, and promotions, or to otherwise contact you about products or information we think will interest you. You have the right to opt-out of these emails at any time.
  4. To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other data analytical purposes.
  5. To monitor responses on our community platform.
  6. To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
  7. Where we believe necessary to investigate, prevent or take action regarding illegal activities or situations involving potential threats to the safety of any person or violations of our Terms and Conditions or this Policy.

3. HOW WE SHARE YOUR INFORMATION

We share your information as follows:

  • Support Community Users. If you upload feedback to the community platform feature of the Site, your user name and any information that you post, including, without limitation, reviews, comments, and text will be available to, and searchable by, all users of the Services.
  • Service Providers. We disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
  • Associated Companies, Sales Representatives and Resellers. We share information for the purpose of providing local support/sales opportunities.
  • Social Media Providers and Platforms. If you have cookies enabled, data will be shared with HubSpot and Google Analytics for the purpose of website usage tracking. If you log on through Facebook, Twitter, Google or Yahoo, your username and profile picture (if applicable) may be visible to other community users, and the company application may be visible in the social media platforms.
  • Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
  • Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we will transfer the information we have collected from you to the other company.
  • In Response to Legal Process. We might also disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
  • To Protect Us and Others. We will disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or this Policy, or as evidence in litigation in which Company is involved.
  • Aggregate and De-Identified Information. We share aggregate or de-identified information about users with third parties for research purposes.

4. OUR USE OF COOKIES

We and our third party service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services.

Cookies.  Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
  • Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

For a list of the cookies that we use, please see our separate cookies policy available here.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Do Not Track. Currently, our systems do not recognize browser “do-not-track” requests. You can, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

Users in the United States can opt out of many third-party ad networks. For example, you can go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You can also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. If you are in the EU, you can opt-out of certain third party cookies that we and other websites may use for targeted advertising through the European Interactive Digital Advertising Alliance (EDAA) Your Online Choices Page or www.aboutads.info. Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites.

5. Third-Party Advertisers and Analytics

We work with third party ad networks to display more relevant advertising on our Sites, and to manage our advertising on third-party sites, mobile apps and online services. In order to display more relevant ads on our behalf and others, these third party ad companies may use cookies and other tracking mechanism. These third party ad companies may use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.

Third Party Analytics. We use automated devices and applications, in particular Google Analytics and HubSpot, to evaluate usage of our Site. We also use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. These entities are likely to use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google privacy policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

6. SECURITY OF YOUR PERSONAL INFORMATION

We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, in particular encryption measures. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. Where we use third parties, for example Google and Hubspot, we require them to implement appropriate security measures to protect your data. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

User Generated Content: We invite you to post content on our Site, including your comments, feedback, and any other information that you would like to be available on our Site. If you post content to our Site, all of the information that you post will be available to all visitors to our Site. If you post your own content on our Site, your posting will become public and Company cannot prevent such information from being used in a manner that violates this Policy, the law, or your personal privacy.

7. ACCESS TO MY PERSONAL INFORMATION

You are able to modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.

8. DIRECT MARKETING

Where you have subscribed for a newsletter, we will send periodic promotional or informational emails to you. You can opt-out of such communications by following the opt-out instructions contained in the e-mail. If you opt-out of receiving emails about recommendations or other information we think may interest you, we will still send you e-mails about your account or any Services you have requested or received from us.

9. CHILDREN UNDER 16

Our Services are not designed for children under 16 years of age (16). If we discover that a child under 16 has provided us with personal information, we will delete such information from our systems.

10. INFORMATION FOR EU INDIVIDUALS

The Data Controller of the information collected through the Services is Citilabs, Inc. which is headquartered in the United States at 2005 N Street, Sacramento, CA 95811 | USA . To exercise any rights that you have with regard to your personal information, you can contact us using the following details: privacy@citilabs.com.

The legal bases for using your personal Information. We collect your information as a Data Controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:

  • Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you. This applies to our processing activities described at 2A above.
  • Our use of your personal information is in our legitimate interest as a commercial organization to make improvements to our products and services and to expand our business. This applies to our processing activities described at 2B, 2C (save where we need consent by local law), 2D and 2E.
  • Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have in particular, where we are required to disclose personal information to a court, tax authority or regulatory body in the event of an investigation. This applies to our processing activities described at 2F and 2G.
  • Our use of your personal information is in accordance with your consent. This applies to our processing activities described at 2C (where required by local law).

If you would like to find out more about the legal bases on which we process personal information, please contact us.

Your Legal Rights. Subject to certain exemptions, and dependent upon the processing activity we are undertaking, European Union individuals have certain rights in relation to personal information:

Right to access, correct, and delete your personal information: You have the right to request access to the personal information that we hold about you and: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information is transferred. You also have the right to request that we correct any inaccuracies or delete your information. We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defence of legal claims.

Right to restrict the processing of your personal information: You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests verification as to whether we have a compelling interest to continue to use your data. We can continue to use your personal information following a request for restriction, where: (a) we have your consent; or (b) to establish, exercise or defend legal claims; or (c) to protect the rights of another natural or legal person.

Right to data portability: To the extent that we process your information (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.

Right to object to the processing of your personal information: You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

How to Exercise Your Rights: If you would like to exercise any of the rights described above, please send us a request privacy@citilabs.com. In your message, please indicate the right you would like to exercise and the information to which it relates. We will ask you for additional information to confirm your identity and for security purposes before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We will not always be able to fully address your request, for example if it would affect the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Cross-border Transfer of Information. We maintain servers and systems in the United States hosted by third party service providers. As a result, where the personal information that we collect through or in connection with the Services is processed in the United States, we will take steps to ensure that the information receives the same level of protection as if it remained within the European Union/EEA. You have a right to receive details of any safeguards that we have where your data is transferred outside the European Union, (e.g. to request a copy where the safeguard is documented, which may be redacted to ensure confidentiality).

Retention. We will keep your information accurate, complete and up to date. We will retain your data for the period necessary to fulfil the different purposes outlined in section 2. Where we are required to do so to meet legal and regulatory requirements, we will retain your data for longer periods of time, but only where permitted to do so, including so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a possibility of legal action relating to your data or dealings.

11. CALIFORNIA PRIVACY RIGHTS

California residents have the right to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclose to third parties for their own direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to info@citilabs.com.

12. CONTACT US

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at privacy@citilabs.com.

13. CHANGES TO THIS POLICY

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site at http://www.citilabs.com/privacy. If we make any changes to this Policy that materially affect our data privacy practices with regard to the personal information we have collected from you, we will provide you with notice in advance of such change.