Privacy Notice
The short version
- This notice covers everything we operate: kiosks, sensors, Wi-Fi, the Citypost app, Campaign Manager and our website.
- We don't sell your data, we don't use facial recognition, and kiosk ads are contextual, not targeted at you.
- We keep data only as long as needed, encrypt it, and are moving to post-quantum encryption.
- You can ask to see, correct or delete your data at any time.
Who we are
These policies are provided by Pivotal Intelligence LLC, a Smart City Media company (“Pivotal Intelligence,” “we,” “us,” or “our”). “Smart City Media” means Smart City Media LLC and its subsidiaries and affiliates other than Pivotal Intelligence. “Affiliates” means Smart City Media and any entity that controls, is controlled by, or is under common control with Pivotal Intelligence.
Pivotal Intelligence operates the Citypost™ digital kiosks, the Citypost mobile app, the Campaign Manager advertising platform, the kiosk sensor network, the Citypost Wi-Fi service, and this website (together, the “Services”).
1. What this notice covers
This notice applies to personal information we collect through all of our Services, both online and in public spaces: Citypost kiosks and their touchscreens, built-in sensors and cameras, the Citypost Wi-Fi service, the Citypost mobile app, the Campaign Manager platform, and our websites. “Personal information” means information that identifies, relates to, or could reasonably be linked to a particular person or household.
When we deploy Services under contract with a city, town or transit agency (a “Municipal Partner”), that contract may impose additional restrictions on us. Where it does, we follow the stricter rule.
2. What we collect, and from where
| Source | What we collect | What we do not collect |
|---|---|---|
| Kiosk touchscreen | Anonymous interaction data (screens viewed, buttons tapped, session length, language chosen). Anything you choose to type, such as a search, a destination, or an email address to send yourself directions. | We do not link touchscreen sessions to your identity unless you choose to sign in or enter contact details. |
| Kiosk sensors & cameras | Environmental readings (air quality, temperature, noise). Anonymous counts, such as how many people passed by or how long a screen was viewed, generated on the kiosk itself. Equipment health and tamper alerts. | No facial recognition, no biometric identifiers, no license plate reading, and no images of people sent to the cloud for audience measurement. See the Sensor & Camera Policy. |
| Citypost Wi-Fi | Device identifiers needed to run the network (MAC address, which we hash or rotate), session start/stop times, data volume, the kiosk you connected to, and acceptance of the Wi-Fi Terms. An email address only if you choose to provide one. | We do not read the content of your browsing, sell browsing data, or use it to target advertising. |
| Citypost app | Account details you provide, preferences, approximate location (only when you allow it, to show nearby kiosks and information), crash and performance data. | No precise background location tracking. No access to contacts, photos or microphone unless a feature you use requires it and you grant permission. |
| Campaign Manager (advertisers) | Business contact and billing details, uploaded ad content, campaign settings and reports. Payments are processed by Stripe, Inc., under Stripe's privacy policy; we do not store full card numbers. | — |
| Website | Information you submit through forms, and device and usage data collected through cookies and similar technologies (see Section 6). | — |
| Emergency call buttons | Where a kiosk includes a 911 or emergency button, the call is handled directly by the public safety or carrier provider. | We do not record or keep the content of emergency calls. |
3. What we never do
- We do not sell personal information, and we do not share it for cross-context behavioral (targeted) advertising.
- We do not use facial recognition or collect biometric identifiers from people near our kiosks.
- We do not use personal information to make automated decisions that have legal or similarly significant effects on you.
- Ads shown on kiosks are contextual: they are chosen by location, time of day, weather, events and aggregate, anonymous audience counts, not by who you are.
- We do not knowingly collect personal information from children under 13 (see Section 10).
4. How we use information
- To operate, maintain and secure the kiosks, Wi-Fi network, app and website.
- To provide information you request, such as directions, transit times, local services and public alerts.
- To give Municipal Partners and advertisers aggregated, de-identified reports (for example, kiosk usage and footfall counts).
- To run Campaign Manager, including billing, ad review and campaign reporting.
- To detect and prevent fraud, abuse, and security incidents, and to enforce our Terms.
- To send service and account messages. We send marketing email only with your consent, or as otherwise permitted by law, and you can unsubscribe at any time.
- To improve and develop our Services, using de-identified or aggregated data wherever possible.
- To comply with law and respond to valid legal process.
When we de-identify data, we take reasonable measures to ensure it cannot be re-linked to a person, we commit publicly not to re-identify it, and we require recipients to make the same commitment.
5. When we share information
- Service providers that host, maintain, secure or support our Services, under written contracts that limit their use of the data to providing services to us and require security protections at least as strong as ours. For example, we use Microsoft Power BI to analyze aggregated kiosk, Wi-Fi and campaign data and to prepare reports for Municipal Partners and advertisers, and Stripe to process payments.
- Municipal Partners, who receive aggregated, de-identified reports, and personal information only where the law or our contract with them requires it.
- Advertisers, who receive aggregated campaign performance reports only.
- Affiliates, including Smart City Media, to help operate the Services, subject to this notice.
- Legal and safety: when we believe in good faith that disclosure is required by law or valid legal process, or is necessary to protect someone's safety. Where the law allows, we will notify affected users and Municipal Partners of government requests for their data.
- Business transfers: in a merger, acquisition, financing or sale of assets, subject to the recipient honoring this notice for data collected under it.
6. Cookies, analytics and opt-out signals
Our website does not use advertising or tracking cookies of its own. To understand how the site is used, we use Google Analytics, which may set its own analytics cookies in your browser. It is configured so that we do not send it names, email addresses or other directly identifying information. Google processes this data under Google's privacy policy, and you can also opt out using the Google Analytics opt-out browser add-on. You can also block or delete cookies at any time through your browser settings.
We honor Global Privacy Control (GPC) and similar browser-based opt-out preference signals as a valid request to opt out of sale, sharing and targeted advertising, and our website will confirm when a signal has been received.
7. How long we keep information
| Data | Retention |
|---|---|
| Wi-Fi session logs (hashed device identifier, times, data volume) | 30 days, unless longer retention is required by law or a security investigation |
| Kiosk interaction and anonymous audience counts | Kept only in aggregated form; raw on-device interaction data is discarded within 24 hours |
| Camera images used for equipment security or tamper detection | 14 days, then overwritten, unless preserved for an incident or legal hold |
| App accounts | While your account is active, and deleted within 45 days of a deletion request |
| Campaign Manager accounts and billing records | For the life of the account, plus the period required for tax and accounting records |
| Website analytics | Up to 12 months |
Keeping less data for less time is also part of our security strategy: data that no longer exists cannot be stolen today or decrypted in the future.
8. How we protect information
We use administrative, technical and physical safeguards appropriate to the sensitivity of the data. These include TLS 1.2 or higher for data in transit (moving to TLS 1.3 with hybrid post-quantum key exchange), AES-256 encryption at rest, role-based access controls with multi-factor authentication, signed kiosk software, and continuous monitoring. Our Security & Quantum Readiness statement explains our encryption practices and our transition to post-quantum cryptography. No system is perfectly secure, but we work to meet or exceed recognized industry standards.
9. If there is a security incident
If we learn of a breach affecting your personal information, we will notify you, the affected Municipal Partners, and regulators as required by applicable law, without unreasonable delay. Notices will explain what happened, what information was involved, what we are doing, and what you can do. We will notify you by email if we have your address, and otherwise by notice on our website and kiosk screens.
10. Children
Our kiosks are in public spaces and show general-audience information, but our Services are not directed to children under 13, and we do not knowingly collect personal information from them. Creating an app account requires being at least 13, and users under 18 need permission from a parent or guardian. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete it promptly. In line with the Children's Online Privacy Protection Act (COPPA), as amended, we do not disclose children's personal information to third parties or use it for targeted advertising. Parents can contact privacy@pivotal-intelligence.com to review or delete their child's information.
11. Your privacy rights
Depending on where you live, and in many cases whether or not your state's law requires it, you can ask us to:
- Access the personal information we hold about you, and receive a portable copy;
- Correct inaccurate information;
- Delete your information;
- Opt out of sale, sharing, targeted advertising and profiling (we do not do these, but you may still submit the request);
- Limit the use of sensitive personal information;
- Withdraw consent you previously gave.
To make a request, email privacy@pivotal-intelligence.com. We will verify your request using information proportionate to its sensitivity, and we respond within 45 days, or within the time your state's law requires. You can use an authorized agent. If we deny your request, you may appeal by replying to our decision with “Appeal” in the subject line. If you are not satisfied with the outcome of your appeal, you may contact your state attorney general. We will not discriminate against you for exercising these rights.
Much of the data our kiosks and Wi-Fi network collect is anonymous or hashed and cannot be linked to you. In those cases we may not be able to locate records about you, and we will tell you so.
12. Additional information for California residents
In the past 12 months we have collected the following categories of personal information, as defined by the California Consumer Privacy Act (CCPA): identifiers (such as email address and hashed device identifiers); commercial information (Campaign Manager purchases); internet or other electronic network activity (Wi-Fi session metadata and website usage); approximate geolocation (app, with permission); and professional information (advertiser business contacts). We collect this information from the sources described in Section 2, for the purposes in Section 4, and disclose it to the categories of recipients in Section 5. We do not sell or share personal information, and we do not use sensitive personal information to infer characteristics about you. Retention periods are listed in Section 7.
13. International users
Our Services are operated in the United States and data is stored in the United States. If you use our Services from outside the U.S., your information will be processed in the U.S. under this notice and applicable law.
14. Changes to this notice
We will post any changes here and update the effective date. If a change is material, we will give at least 30 days' notice before it takes effect, by email to account holders and by notice on this website. Changes will not apply retroactively to information collected under a previous version without your consent where consent is required.
15. Contact us
Pivotal Intelligence LLC, Attn: Privacy
privacy@pivotal-intelligence.com