Last Revised: October 7, 2019
CityGuy’d Mobile, LLC. (“CityGuyd”, “our”, “we” or “us”) respects the privacy of and is committed to protecting the personal information that is collected from or shared by:
(i) visitors to our website located at www.cityguydapp.com (respectively, the “Visitors” and “Website”); and
(ii) users of the CityGuyd real-world augmented reality mobile application (respectively, the “App Users” and the “CityGuyd App” or “App”).
The Visitors and App Users are also referred to collectively in this document as “User(s)”, “you” and/or “your.”
1. YOUR CONSENT
BY ENTERING, CONNECTING TO, ACCESSING AND/OR USING THE CITYGUYD PROPERTIES AND SERVICES:
PLEASE NOTE: you are not obligated by law to provide us with any personal information about you or about any other App User associated with your Account.
2. INFORMATION WE MAY COLLECT
We may collect, access and/or process several types of data and information:
a. The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the individual from whom we have collected the Non-personal Information. Non-personal Information which is being gathered consists of aggregated, statistical or otherwise any technical information and behavioral analysis which is not associated with any identified or identifiable individual. Such Non-personal Information may contain, among other things, aggregated information concerning Users’ device model, operation system and browsers, other technical information regarding devices used by Users to access the CityGuyd App and Website such as language, time zone and mobile operator, duration of usage of the CityGuyd Properties and Services, and clickstream.
b. Other type of information is information related to an identified or identifiable living individual, or such information that, with reasonable efforts, or together with additional information we have access to, enables the identification of an individual (“Personal Information”). For the avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
The Personal Information that we may collect and process, consists of the following types of information:
- Information voluntarily and actively provided by Users as part of their subscription or registration (as made available by CityGuyd) to the CityGuyd Properties and Services, such as their full name, App login credentials such as user name and password, location, email address, etc.
- Information collected from you through your access and use of the CityGuyd App and Services, such as your IP address, tokens of social networks you choose to connect to your account (as described below), information regarding your clicks, views and engagement with the Services and with advertisements we may display on the Service, information concerning your traffic to and from the Services, your referral URL, our communications with you, your historical map searches on the Services, information about your use and interaction with the Services, including the duration of such use (session logs), as well as in-app settings such as profile pictures and App Users’ personal experience and feedback submitted to us.
- Geo-location information and other device sensors data, such as your present geo-location and historical route or travel information (for example, routes and times of travel from one landmark or point of interest to another) in order to provide you with the Services. When using the CityGuyd App, we collect detailed location including GPS signals and other necessary device sensors data such as gyro/oscilloscope sent by your mobile device on which the Service is installed and activated.PLEASE NOTE THAT CITYGUYD COLLECTS YOUR LOCATION DATA EVEN WHEN YOU ARE NOT USING THE MOBILE APPLICATION TO PERSONALIZE THE SERVICES AND MAXIMIZE YOUR EXPERIENCE AND TO DEVELOP AND ENHANCE OUR TOUR GUIDE AND INFORMATION SERVICES. YOU MAY CHOOSE TO DISABLE AND OPT-OUT FROM THIS BACKGROUND COLLECTION OF DATA UNDER THE MOBILE APPLICATION’S PRIVACY SETTINGS SCREEN.
- Information that is provided to us by potential job candidates, when they apply for work with us by submission of application through the Website.
3. HOW WE COLLECT INFORMATION
There are two main methods we use:
a. We collect information automatically through your use of the CityGuyd Properties and Services. In other words, we are aware of Visitors’ and App Users’ usage of the CityGuyd Properties and Services, and may gather, collect and record the information relating to such usage, including by using our third party service providers as detailed in Section 7 (Sharing Information with Third Parties) below, by issuing a unique install ID (associated with the specific installation of the CityGuyd App), and by using “cookies” and other tracking technologies, as further detailed in Section 12 below.
b. We collect information which you provide to us voluntarily. For example, we collect the Personal Information that our Users provide us when registering or subscribing to our CityGuyd Properties and Services or when contacting us through the “contact us” option on the Website, etc. We also collect experience feedback provided to us by App Users pertaining to their individual user experiences.
c. Social Media. We may allow you to share information with social platforms or use social platforms to create your account or to connect your account with the respective social platforms. Those social platforms may give us automatic access to certain Personal Information retained by them about you (e.g., name, profile picture, email, etc.). You control the Personal Information you allow us to have access to through the privacy settings on the applicable social platforms and the permissions you give us when you grant us access to the Personal Information about you retained by the respective social platforms.
4. PURPOSES FOR WHICH WE COLLECT AND PROCESS INFORMATION
- When performing an agreement with you: Your information may be processed on the basis that such processing is necessary for the establishment and performance of our contractual engagements with you. Under such engagement, we provide Visitors and App Users with access and use of the CityGuyd Properties and Services, maintain and improve the CityGuyd Properties and Services, develop new services and features for our Users, and personalize the CityGuyd Properties and Services in order to provide Users with a better user experience and enhanced performance.
- Provide, improve and operate our CityGuyd Properties and Services;
- Verify the identity of our App Users for correct provisioning of access to and use of the CityGuyd Properties and Service and, in general, management, development and fulfillment of the relationship;
- Gain statistical data and discover trends in our mobile reality augmentation process;
- Improve the accuracy of the Services by running machine learning algorithms on collected and aggregated data;
- Send you updates, notices, notifications, announcements, and additional information related to the CityGuyd Properties and Services;
- Provide our Users with technical assistance and support and to handle requests and complaints, and collect feedback in connection with the performance of the Services;
- Display or send the most relevant marketing and advertising material when App Users are using the Services;
- Create cumulative statistical data and other cumulative information analysis and/or other conclusive information that is non-personal, of which we might make use in order to operate and improve our CityGuyd Properties and Services and to provide related services;
- Perform functions or services as otherwise described to you at the time of collection; or
- Comply with any applicable rule or regulation and/or respond to or defend against legal proceedings brought against us or our affiliates.
5. WHERE WE STORE YOUR PERSONAL INFORMATION
Information regarding our Users will be maintained, processed and stored by CityGuyd and our authorized affiliates and service providers in the United States, and as necessary, in other territories, in secured cloud storage, provided by our third-party service providers.
You hereby accept the transfer and storage of information as described above.
6. JOB CANDIDATES
We may publish open positions on our Website. In such event, CityGuyd welcomes all qualified candidates to apply to any of the open positions posted by sending us their contact details and CV (“Candidate Information”). Since privacy and discreetness are very important to our candidates, we are committed to keep Candidate’ Information private and use it solely for our internal recruitment purposes (including for identifying candidates, evaluating their applications, making hiring and employment decisions, and contacting candidates by phone or in writing).
Please note that CityGuyd may retain Candidate Information for a reasonable time period even after the applied position has been filled or closed. This is done so we can re-consider candidates for other positions and opportunities that may arise, use the Candidate Information as reference for future applications, and, in case the candidate is hired, for additional employment and business purposes related to their work.
If you previously submitted your Candidate Information to the CityGuyd and now wish to access it, update it or have it deleted from our systems, please contact us at firstname.lastname@example.org.
7. SHARING INFORMATION WITH THIRD PARTIES
CityGuyd may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
a. Third Party Services: We are partnering with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include:
- third parties providing hosting, database and server co-location services: Google Cloud ML, Amazon EC2 servers, AWS, and Google Firebase; and
- our business, legal and financial advisors (collectively, “Third Party Service Providers”).
- Law enforcement, legal proceedings, and as authorized by law: We may disclose or otherwise allow access to Personal Information pursuant to a legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud, or other wrongdoing.
- Protecting Rights and Safety: We may share Personal Information with others, with or without notice to you, if we believe in good faith that this is reasonably required to protect the rights, property or personal safety of CityGuyd, any of our Users, or any member of the general public.
8. UPDATING, OBTAINING A COPY OF OR DELETING YOUR INFORMATION
If the law applicable to you grants you such rights, you may ask to access, correct, or delete your Personal Information, or if you are an App Users who is associated with another User’s account (which will be deemed hereunder as User Personal Information), that is stored in our systems or that we otherwise control. You may also ask for our confirmation as to whether or not we process your Personal Information or ask to withdraw any consent you have previously provided to us in connection with our use and processing of your Personal Information.
Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any Personal Information the accuracy of which you contest while we verify the status of that data.
Subject the limitations in law, you may also be entitled to obtain the Personal Information you (or an App User associated with your account) directly provided us in a structured, commonly used, and machine-readable format and may have the right to transmit such data to another party.
You may request that we delete any and all information collected regarding the minor App User associated with your account that are using your account subject to your explicate informed consent and approval.
If you wish to exercise any of these rights or withdraw your consent, please contact us at email@example.com. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or respond to or defend against legal proceedings brought against us or our affiliates, or as we are otherwise permitted under such law applicable to you.
To find out whether these rights apply to you and on any other privacy-related matter, you can contact your local data protection authority if you have concerns regarding your rights under local law.
9. DATA RETENTION
We may retain your Personal Information for as long as is legitimately necessary and only to the extent required for the achievement of the purposes listed under Section 4, including without limitation, as reasonably necessary to comply with our legal obligations and/or protect our legitimate interests and, with respect to data used for marketing activity, for as long as we have your consent therefor. We then either delete such Personal Information from our systems or anonymize it without further notice to you.
10. MINORS AND THIRD-PARTY INFORMATION PROVIDED BY YOU
At CityGuyd, we believe in the importance of protecting the privacy of children online. To subscribe to our Services or use our CityGuyd App, you must be over the age of sixteen (16). We do not knowingly collect Personal Information from minors under the age of sixteen (16) and do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Services.
To use the CityGuyd App or Services, a minor individual under the age of sixteen (16) must receive informed parental consent from his parents or otherwise from a legal guardian. Parents or legal guardians of a minors under the age of sixteen (16) can always review the Personal Information we may possesses, direct us to delete it or revoke our right to further collection. In the event that it comes to our attention that a minor under the age of sixteen (16) subscribed to the CityGuyd App, we will prohibit and block such User from accessing the CityGuyd App and will make all efforts to promptly delete any Personal Information stored with us with regard to such minor.
Other than as described herein, our Services are not intended to actively solicit sensitive Personal Information of any kind from children under the age of thirteen (13). If you believe that we have received information from or about a minor individual under the age of thirteen (13) without the active and verifiable consent of their parents or legal guardians, please contact us immediately at firstname.lastname@example.org.
11. DATA SECURITY
We take great care in implementing and maintaining the security of the CityGuyd Properties and Services and our Users’ Personal Information that we collect and process. CityGuyd employs industry-standard procedures and policies to ensure the protection of Personal Information, and to prevent unauthorized use of any such information.
Please note however, that regardless of the measures we take and the efforts we make, we cannot and do not guarantee the absolute protection and security of any Personal Information.
We strongly encourage you to set strong passwords for your User account and to protect your account against unwanted access on your end (for example, do not share your login credentials with others, or allow them free access to your logged-in devices).
If you have any questions regarding the security of our App and Website, please feel free to contact us at email@example.com.
12. USING COOKIES AND OTHER TRACKING TECHNOLOGIES
We may use certain monitoring and tracking technologies (such as “cookies” or “pixel tags”) to understand how you use our Properties and Services, including ones offered by Third Party Service Providers. These technologies are used in order to maintain, provide and improve our Properties and/or Services on an ongoing basis, and in order to provide a better experience to our Users. For example, these technologies enable us to: (i) keep track of and “remember” our Users’ preferences and authenticated sessions, (ii) secure our Website by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our Properties, (iv) create and monitor analytics, and (v) deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests and track ad performance (For more information about this practice, click here: http://www.aboutads.info/choices/).
13. DIRECT MARKETING
You hereby agree that we may use your contact details provided during the filling of a contact form or during the registration process for the purpose of informing you regarding our products and services which may interest you, and to send to you other marketing material. You may withdraw your consent via sending us written notice by email to the following address: firstname.lastname@example.org.
Please note that the CityGuyd may also contact you with important information regarding our Properties. For example, we may notify you (through any of the means available to us) of changes or updates to our Properties, technical issues, or service maintenance, etc. You will not be able to opt-out of receive such service messages.
15. GENERAL INFORMATION
16. HAVE ANY QUESTIONS?
By contacting CityGuyd, and accessing the CityGuyd App and Properties, you warrant and agree that you are free to do so, and that you are not providing CityGuyd with information which violates any third party intellectual or privacy rights.