Privacy Policy

Last updated: December 18, 2023

Introduction

Metropolis Technologies, Inc. ("Metropolis") provides a technology platform to facilitate innovative parking and transportation services. This Privacy Policy ("Privacy Policy") is designed to help you understand how we collect, use and disclose your personal information in connection with the use of all websites, applications, and other online products and services provided by us that link to this Privacy Policy, including www.metropolis.io and all related subdomains (collectively, the "Site") and online and offline services related thereto, including physical locations where we collect your information, and including any services, transactions, or engagement you might have with us (collectively, the "Services").

The Services allow consumers ("Consumers") to make use of our and our customers' and business partners' (collectively, "Customers") mobility, parking, and hospitality services, such as garages, parking lots, valet operations, hospitality lounges, car cleaning or repair services, refueling and/or vehicle charging services, ride-share platforms, carpool programs, restrooms, vending machines, convenience stores, rentals for bikes, scooters and/or other vehicles. This Privacy Policy also applies to individuals who use the Services on behalf of a Customer ("Customer Users") (collectively, with Consumers and visitors to the Services, "Users").

Please carefully read this Privacy Policy, which is part of our Terms of Service, before using our Services. If you do not agree with the Terms of Service and/or this Privacy Policy, you must refrain from using our Services. By accessing or using our Services, you agree to our use of your information consistent with the Terms of Service and this Privacy Policy. If you are a Customer User accessing our administrative portals or similar offerings ("Portals") pursuant to an agreement between you and Metropolis (such as Terms for Enterprise Customers), then your use of the Portals and Services is also governed by such agreement(s).

I. Information We Collect

Information you provide to us

We collect information you choose to provide to us, including information you enter through the Services. For example, if you are a Consumer or visitor to the Site, we may collect information in relation to:

Account Creation. When you create an account to use the Services, we may collect certain contact information (such as your name, phone number, email address), other registration information (such as license plate number and state, details about your vehicle, including color, make, model and year, and activation code (if using an employer-provided benefits account)), and payment information.

Interactions with the Services. When you interact with the Services to add profile, payment, or subscription information, we may collect additional account-related information and when you use our or our Customers' parking or related hospitality services, we may collect information to identify and verify your vehicle and the extent and scope of your use of the Services. To provide our Services, we may use automated license plate reader ("ALPR") and similar systems to collect video or pictures of your vehicle and license plate (see "ALPR Information" below).
Payment Information. We use third-party payment processors to process payments made to us. In connection with the processing of such payments, we retain limited information such as the last 4-digits of your card and your zip code. All such information is provided directly to our third-party processors, whose use of your information is governed by their privacy policies.
Your Communications with Us. We collect information from you (such as name, email address, phone number, or mailing address along with any information you provide in connection with your outreach) when you request information about our Services, register for our newsletter or loyalty programs, request customer or technical support, or otherwise communicate with us.
Surveys, Promotions, and Sweepstakes. If you decide to participate in any surveys, promotions, or sweepstakes, you may provide certain information, such as basic contact information and other information relevant to the survey, promotion, or sweepstakes.
Conferences and Trade Shows. We may attend conferences and trade shows where we collect information from individuals who interact with or express an interest in Metropolis and/or the Services.

If you are a Customer User, work for a potential customer or business partner, or visit the Site, we may collect information in relation to:

Account Creation. When you create an account to use or access the Services, we may collect certain contact information (such as your name, phone number, email address, and business address), business information (such as your job position, function, and title, and the size, location, and needs of your company), and registration information.
Interactions with and Performance of the Services. We collect information when you interact with the Services (such as to manage and operationalize the use of our offerings in connection with your business or real estate), to remit and charge amounts owed (such as financial information, including bank account and ACH information), and when you enter information through the Services. We may also collect information from you when you assist in the performance of the Services, such as performing valet services.
Your Communications with Us. We collect information from you (such as name, email address, or phone number, along with any information you provide in connection with your outreach) when you request information about our Services, register for our newsletter or loyalty programs, request customer or technical support, or otherwise communicate with us.
Surveys, Promotions, and Sweepstakes. If you decide to participate in any surveys, promotions, or sweepstakes, you may provide certain information, such as basic contact information and other information relevant to the survey, promotion, or sweepstakes.

Information Collected Automatically or From Others

Automatic Data Collection

When you interact with our Services, we (and our vendors) may collect technical information about your browser, your device, and how you use the Services by automated means, including through cookies, pixels/web beacons, local storage, JavaScript, Software Development Kits (SDKs), Application Programming Interfaces (APIs), and other similar technologies. We may also collect this kind of information when you interact with email messages or other communications we send you. Some of these technologies (such as cookies) involve storing unique identifiers or other information on your browser or device for later use. As we and our service providers adopt other technologies, we may also gather information using other methods.

Information about your browser or device

We and certain of our vendors may automatically collect certain information about your browser or device when you use our Services, such as:

your user, system, or device settings (for example, time zone, language, and permissions status);
cookie identifiers;
mobile advertising identifier (MAID);
other device or online identifiers (such as proprietary IDs, hashed IDs, or other pseudonymous IDs used by us or our partners or Service Providers); and
browser or device information (for example, the name and version of your device and the operating system it is running, telemetry, and screen resolution)

Information about how you use our Services

We and certain of our vendors may collect information regarding your use of our Services, such as:

your activities and transactions in the course of use of our Services;
information about the links you click, the types of content you interact with, and the frequency and duration of your activities;
information about your online activity directly preceding or following your use of the Services, such as whether you were "referred" to our websites through another app, website, or shared link;
real-time information about the ways that you use, interact with, and navigate the Services, including cursor movements and clicks, pages you visit, links you click on, how you scroll through the Services, customer service interactions and other uses of chat functionality, screen recordings; and
other information about how you use our Services

Information about your internet connection

When you interact with our Services from an internet-connected device (for example, when you use our mobile or desktop app or web platform), we collect information about your internet connection including MAC address, internet protocol (IP) address, internet service provider, and mobile carrier.

Location Information

We may collect location information, such as the location where you park or use our Services, the duration of your stay, the date and time at which you were at our location, and the locations you visit during your stay for parking validation related purposes. We may also collect general location information (such as your city and state inferred from your IP address).

Information from Other Sources

We may obtain or collect information about you from other sources, including from affiliates, Customers, payment service providers, analytics service providers, security service providers, and survey providers. For example, we utilize certain analytics tools to improve the Services experience for Users and Customers.

We may also collect information from business partners who use and integrate our Services to provide services to their customers and otherwise promote our Services, for instance, if you utilize our Services through a partner's application or service. This information may include name, desired parking location, email, and vehicle license plate number. This information allows us to verify your eligibility to use and otherwise facilitate the use of our Services.

We obtain contact and business information from conferences, events, sales partners, data brokers, public records, and service providers who assist in verifying identity and consumer information.

II. How We Use Your Information

We use your information for a variety of business purposes, including to:

Fulfill our contract with you and provide you with our Services, such as:

Managing, verifying, and authenticating your information, accounts, and interactions with our Customers' and others' parking, mobility, and hospitality services;
Providing you with information you request, a customized experience, and access to certain areas, functionalities, and features of our Services and our partners' and Customers' physical locations and services;
Communicating with you about your account, activities on our Services and policy changes;
Undertaking activities to verify or maintain the quality or safety of a service or device;
Processing your financial information and other payment methods for products or Services purchased and contacting you about your account, billing, remitting, or charging you or your organization for our Services;
Providing advertising, analytics and marketing services; and
Providing Services on behalf of our Customers and business partners, such as maintaining or servicing accounts, providing customer service, and verifying customer information; and processing transactions.

Analyze, protect, and improve our Services pursuant to our legitimate interest, such as:

Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
Undertaking research for technological development and demonstration;
Researching, improving, upgrading, enhancing and developing products, Services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
Securing the Services and investigating and helping prevent fraud, security issues, and abuse, including by detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

Understanding, detecting, and resolving problems with the Services and other issues being reported;
Complying with any procedures, laws, and regulations where necessary for our legitimate interests or legitimate interests of others;
Establishing, exercising, or defending our legal rights where necessary for our legitimate interests or the legitimate interests of others, including the enforcement of our Terms of Service, other usage policies and agreements, and other legal terms or controls, or engaging in other legal matters;
Auditing relating to interactions, transactions and other compliance activities; and
Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.

Provide you with additional content and Services, such as:

Furnishing you with customized materials about offers, products promotions, and Services that may be of interest to you (in accordance with any privacy preferences you have expressed to us) via email, text messaging, and/or push notifications and display media;
Inviting you to participate in promotions, sweepstakes, surveys and provide feedback to us, and further uses in relation to those offerings and communications; and
Fulfilling other requests and purposes you consent to, are notified of, or are disclosed to you when you provide the information.

Combined Information

For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

De-identified and Aggregated Information

We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device ("Aggregate/De-Identified Information"). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data with any third parties in our discretion.

Share Content with Friends or Colleagues

Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends or colleagues through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

Process Information on Behalf of Our Customers (as processors)

Our Customers may choose to use our Services to process certain data of their own, which may contain personal information. In such cases, the data that we process through our Services is processed by us on behalf of our Customer, and our privacy practices will be governed by the contracts that we have in place with our Customers, not this Privacy Policy.

If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the business or data controller) who has contracted with us to use the Services to process this data. Our Customers control the personal information in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to our Customers to address any concerns you may have, in accordance with the terms of our contract with them.

III. Cookies and Similar Technologies

To collect the information in the "Information Collected Automatically or From Others" section above, we and our vendors may use web server logs, cookies, tags, SDKs, tracking pixels, localStorage and similar tracking technologies. We use these technologies to improve our Services and in order to offer you a more tailored experience in the future.

A web server log is a file where website activity is stored.

An SDK is a set of tools and/or code that we embed in our applications and software to allow third parties to collect information about how users interact with the Services.
A cookie is a small text file that is placed on your computer or mobile device when you use the Services, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.
Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information like ad impressions or clicks and email open rates; (2) measure popularity of the Services and associated advertising; and (3) access user cookies.
LocalStorage is a web storage object for storing data on the client -- that is, locally, on your computer. Data stored locally has no expiration date and will exist until it's been deleted.

As we adopt additional technologies, we may also gather information through other methods.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.

IV. Online Analytics and Advertising

Analytics

We may use third-party analytics services (such as those of Google Analytics) as well as self hosted data collection services on our Services to collect and analyze usage information through cookies and similar technologies; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. For more information about Google Analytics, please visit Google's Privacy & Terms page. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Advertising

We may work with a number of companies that assist in marketing our services to you on third party websites, mobile apps, and online services. These third parties may use cookies, web beacons or other tracking technologies to collect information about your use of certain parts of the Services and your activities across other websites and online services, which they may associate with persistent identifiers. Sometimes, these identifiers may be derived from a hashed or encrypted version of personal information such as your email address. We may use this information to measure the performance of our advertising as well, for instance, to evaluate which ads or content our users prefer, or which are most effective. In addition, sometimes we or an advertising partner may tailor advertising to you across different devices.

Their activities and your choices regarding their use of your information to personalize ads to you are subject to and set out in their own policies. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated, third-party providers. As described below, these providers may offer you a way to opt-out of the collection of information that is used for our interest-based advertising to you. We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each third-party service provider, not us. We do not present third-party advertising within the Services.

More Information

If you are interested in more information about interest-based advertising and how you can generally control cookies other tracking technologies from being put on your computer to deliver such advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out link, the Digital Advertising Alliance's (DAA's) Consumer Opt-Out link, or TrustArc's Advertising Choices Page. To opt out of the display of interest-based advertising from Google, please visit the Google Ads Settings page. For more information and to exercise your choices regarding Facebook and/or Instagram ads, please visit the Facebook Ads Settings page and/or the Instagram Ads Settings page. For more information and to exercise your choices regarding LinkedIn ads, please visit LinkedIn Ads Settings.

V. How We Disclose Information

We may disclose your information to the following third parties for the purposes identified below.

Service Providers

We may provide access to and disclose your information to select third-party service providers who perform services on our behalf, such as online hosting and maintenance; marketing and promotion design and management; payment processing and collection; identity and information verification; marketing and email delivery and analysis; analytics; customer service; security and fraud prevention; and legal services; and to vendors to support the provision of the Services.

Business Partners

We may provide your information to business partners with whom we jointly offer products or services, including when you utilize our Services through a partner's application or service. Additionally, some of our Services may from time-to-time partner with another brand, retailer or other third party to offer services, products, events and promotions on a co-branded or cross-promotional basis. In such cases, our business partner's name should appear along with ours. Your information may be collected directly by, or disclosed to the third party, as well as with any participating sponsors or advertisers of such Services. We will seek your consent beforehand where required by applicable law. These third parties will use your information in accordance with their own privacy policies.

Customers

In certain situations, we may disclose your information to our Customers to the extent you engage with their parking, mobility, hospitality, or other services in connection with our Services. For instance, if you are enrolled in an employer-provided parking benefits account, we may provide your information to your employer in order to administer the parking benefits. We may also disclose personal information to our real-estate partners (e.g., owners or operators of a parking asset) for their legitimate business purposes, including in order to facilitate your access and/or for security purposes. Additionally, if you are a Customer User, we may disclose your information to the Customer your account is associated with.

Affiliates

We may disclose personal information to our affiliated companies.

Advertising Partners

We may disclose the information we collect, including information about your interaction with our Services, with partners in relation to personalizing advertising and integrations related to their services. Our advertising partners may use this information (and similar information collected from other third-party sites or services) for purposes of delivering both basic and personalized advertisements to you when you visit digital properties within their networks, and measuring the effectiveness of advertising, both on and off our Services.

Sweepstakes and Contests

When you participate in a sweepstakes or contest and win a prize, we may publicly disclose your personal information (such as your name and state of residence) in connection with publicity purposes.

Comply with Laws and Protect Our Rights and the Rights of Others

We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud, identity theft, or trespass to our or our Customer's property; to protect the security of the Services; to enforce or apply our Terms of Service or other agreements; or to protect our own rights or property or the rights, property, or safety of our Users or others. We may also disclose your information to obtain legal counsel in relation to any such activities.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers

As we continue to develop our business, we may buy, merge with, or engage in a corporate or significant business transaction with other companies. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider (or are contemplating any such transaction or activity), then your information may be sold or transferred as part of such a transaction or disclosed in contemplation of such transaction, as permitted by law and/or contract. If such transfer is subject to notifications or restrictions under applicable law, we will comply with such requirements.

With Your Consent or At Your Direction

We may disclose information to third party entities when you direct us to do so or if you have consented to additional sharing of your information (including as set out in this Privacy Policy).

VI. ALPR Information

In order to provide a seamless experience, our Services may utilize Automated License Plate Readers (ALPR) and similar systems to capture and process video or still images of your vehicle and license plate. For instance, many of our parking lots offer a drive-in drive-out experience using cameras and machine learning to allow you to enter and exit a facility without delay or hassle. We use the information captured through the ALPR systems to identify your vehicle and account, which allows us to charge the payment information associated with your account or communicate with you about arranging for such payment. We take pride in this technology and also take responsibility for designing and implementing these systems with Consumers in mind. We undertake efforts to limit access to the ALPR systems and information captured by those systems to those employees, agents, and service providers who have a legitimate business purpose in accessing such systems. We regularly monitor and enhance our ALPR systems along with the rest of our Services to protect the underlying information, comply with applicable law, and improve the accuracy of the information collected (including through correcting data errors based on feedback from our Consumers). As further explained in this Privacy Policy, we limit how information collected through our ALPR systems can be processed and disclosed, focusing our efforts on providing a seamless and optimal experience for you. We store information collected through our ALPR systems for as long as is necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable law.

VII. Third Party Links and Features

Please be aware that third-party websites accessible or recommended through our Services may have their own privacy and data collection policies and practices. These other websites are not controlled by us. These links and features are provided for your reference and convenience only and do not imply any endorsement of information provided through these third-party links and features, nor any association with their operators. We are not responsible for any actions, content of websites, or privacy policies of such third parties. We urge you to read the privacy and security policies of these third parties.

VIII. Your Rights, Choices, and Privacy Information

In addition to the other rights and choices described in this Privacy Policy, you have these rights and choices regarding your information:

Marketing Communications

You may instruct us not to use your information to contact you by email, postal mail, or phone regarding products, services, updates, promotions and special events that might appeal to your interests by contacting us using the information below. You may use the unsubscribe link found at the bottom of emails we send to you to opt out of receiving future marketing emails. Alternatively, you may email us at privacy@metropolis.io. If you receive an unwanted SMS or text message from us, you may reply STOP to opt out of receiving future messages. Please note that, regardless of your request, we may still use and disclose certain information as permitted by this Privacy Policy or as required by applicable law. For instance, you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy). We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law. Processing your request to unsubscribe from an email list we maintain may take a reasonable amount of time.

Rights Regarding Your Information

Residents of certain states (such as Colorado) may have the right to make certain requests regarding your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:

Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
Provide you access to and/or a copy of certain personal information we hold about you.
Correct or update personal information we hold about you.
Delete certain personal information we have about you.
Provide you with information about the financial incentives that we offer to you, if any.
Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. When we delete any information, it will be deleted from the active database, but may remain in our archives to be overwritten or deleted in the ordinary course. We may also retain your information for fraud or similar purposes. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address.

Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

If you would like further information regarding your legal rights or would like to exercise any of them, please visit this link or email us at privacy@metropolis.io.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you. To exercise such an appeal right, emails us at privacy@metropolis.io.

Residents of Colorado

Residents of Colorado may click here to view more information regarding each category of personal information we process, the purposes for which we process each category, and the categories of entities to whom the personal information is disclosed. Please note that we do not engage in profiling that produces legal or similarly significant effects.

Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes.

Residents of certain states (such as Colorado) may also have the right to opt out of “sales” of your information and “sharing/use of your information for targeted advertising.”

We have not sold personal information in the last 12 months. However, as noted below, if you would like to request that we not sell information associated with your name/email address at any point in the future, you can visit this link.

In the future, we may disclose other personal information to unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you. We may also provide other personal information to third-party advertising providers for targeted advertising purposes or use advertising analytics partners to assist us in analyzing use of our services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the processing/sharing of personal information for targeted advertising purposes.

Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age.

Notice of Financial Incentives

We may offer opportunities to receive certain services or benefits, including money to participate in surveys, sign up for communications, or other similar incentives, which may require the provision of personal information, such as registering for an account and answering surveys or providing additional feedback or information. Such opportunities could be considered a financial incentive under applicable law (each, an “Incentive Program”). Your participation in Incentive Programs is purely voluntary. When you participate in an Incentive Program, you agree to the terms of that Incentive Program, and we may revoke your participation depending on the Incentive Program.

Mobile Devices

We may send you push notifications through our mobile application. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.

"Do Not Track"

Do Not Track ("DNT") is a setting that users can enable in certain web browsers. Please note that DNT signals do not have a commonly agreed up meaning and we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Tailored Advertising

The information we collect in connection with the Services may be used to tailor the advertising you see, both by us and by third parties. You have choices about how information about you is used to tailor the ads you see online.

On the web

Opting out of interest-based advertising

Certain information we collect through the Services may be used or shared to tailor ads you see on the web. To learn more about this type of advertising or to opt out of participating companies (including certain of our advertising partners), please visit the Digital Advertising Alliance's (DAA) opt-out program at https://www.aboutads.info/ or the Network Advertising Initiative's (NAI) opt-out page at https://optout.networkadvertising.org/. We make no representation about the accuracy or effectiveness of these opt out mechanism.

Browser settings

Some tailored advertising is carried out using cookies. You may be able to set your browser to refuse certain types of cookies, or to alert you when they are being used. Some browsers offer similar settings for HTML5 local storage and other technologies. Please consult the "Help" section of your browser for more information. However, if you block or otherwise reject cookies or other similar technologies, certain websites (including our Services) may not function as expected. Because we and third parties may use non-cookie technologies with your browser or device, browser settings that block cookies used in isolation may not affect the functioning of those technologies.

On mobile devices

Mobile devices often include settings to help you manage how your device collects and shares information for advertising purposes. For more information on how to manage those devices settings, please visit the Network Advertising Initiative's mobile choice page at https://www.networkadvertising.org/mobile-choice.

Using other pseudonymous identifiers

Some of our advertising partners rely on hashed email addresses or other pseudonymous or proprietary identifiers to tailor advertising. We may use other partners for similar purposes. You can also opt of participating companies that tailor advertising in this way by visiting the NAI opt out at https://optout.networkadvertising.org/optout/email.

More choices you can make

You can also make certain choices by using the options described in the "Information Collected Automatically or From Others" portion of the "Information We Collect" section and "Cookies & Similar Technologies" section above. Modifying your mobile device or browser settings, or opting out of interest-based advertising using your web browser, may have different results depending on the type of device you are using, the type of web browser you are using, and the version of the device operating system you are running. Opting out of tailored advertising does not prevent you from seeing advertising online; instead, the ads you see are less likely to be customized to your interests. Opting out is generally effective only on a device-by-device, or browser-by-browser basis. If you use more than one browser or device, the effect of any opt-out mechanism you use may be limited to the device on which you used the mechanism.

IX. Data Retention

We retain your information only for as long as is necessary to provide the Services and to fulfill the transactions you have requested, and for other necessary purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements, and for fraud prevention and related security purposes. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. For example, we retain your email address as an authentication credential (where applicable) as long as you have an account with us and an additional period of time after that for our legitimate interests and for our fraud and legal compliance purposes. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. We may retain cached or archived copies of your information.

X. Security of Your Information

We recognize the importance of implementing a variety of security safeguards designed to protect the confidentiality of your information. We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no data transmission over the Internet or other network is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure. As a result, while we strive to protect information you transmitted on or through our Services, you do so at your own risk.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

When you create an account, you may be prompted to create a username or password or utilize a device for authentication. If you create an account with us, you are responsible for maintaining the confidentiality of your account password or authentication feature and for any activity that occurs under your account. We are not responsible for any loss or damage arising from your failure to maintain the confidentiality of your account. We urge you to change your passwords often, use a combination of letters and numbers, and make sure you are using a secure browser. We also urge you to keep your authentication device secure. If you have reason to believe that your interaction with us is no longer secure or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the "Contact Us" section below.

XI. Children’s Information

The Services are not directed to children under sixteen (or other age as required by local law), and we do not knowingly collect or maintain personal information from persons under the age of sixteen. If we learn that we have inadvertently collected any personal information (as defined by the United States Children's Online Privacy Protection Act) in violation of applicable law, we will promptly take steps to delete such information and terminate the child's account. If you believe that we may have an personal information from a person under 16, please contact us as indicated in the "Contact Us" section below.

XII. Supplemental California Privacy Notice

This California Privacy Notice applies only to California residents and supplements our general Privacy Policy. Terms used in this section and not otherwise defined have the meaning given to them under the California Consumer Privacy Act ("CCPA").

California Privacy Rights

This section supplements our Privacy Policy with additional information for California residents about our information collection and use practices as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”). In this section, the terms “personal information” and “sensitive personal information” have the meaning set forth in the CCPA.

The following sections provides information about our practices in the 12 months leading up to the effective date of this Privacy Policy in relation to the categories of personal information that we collected from California residents generally the purposes for which we use the information, and the categories of third parties to whom we disclose the information for business purposes.

Categories of information collected

See the “Information We Collect” and “How We Disclose Information” sections above for additional information.

Identifiers

Examples: such as name, license plate number and state, and other similar identifiers.

Purpose of use:

Process orders
Provide the Services and customer service
Verify and authenticate your information, account, and interactions with us
Communicate with you
Personalize your experience and customize the Services
Understand your interests and engage in research, analysis, and reports
Our marketing and advertising purposes
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Service providers who perform functions on our behalf, such as data storage and hosting providers, identity and information verification providers, email and notification providers, network and system management providers, communication tools, IT support providers, CRM providers, payment providers (“Service Providers”)
Affiliates
Business partners and Customers
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent

Contact and account registration information

Examples: such as telephone number, email address, other contact information; details about your vehicle, including color, make, model and year; and activation code.

Purpose of use:

Process orders
Provide the Services and customer service
Verify and authenticate your information, account, and interactions with us
Communicate with you
Personalize your experience and customize the Services
Understand your interests and engage in research, analysis, and reports
Our marketing and advertising purposes
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Service Providers
Affiliates
Business partners and Customers
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent

Customer service information

Examples: such as questions and other messages you address to us and summaries or voice recordings of your interactions with customer service.

Purpose of use:

Process orders
Provide the Services and customer service
Communicate with you
Improve the Services
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Service Providers
Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent

Financial information

Examples: such as billing information, financial account information (including credit card, bank account, and ACH information), and related information held by our payment processors on our behalf.

Purpose of use:

Process orders
Communicate with you
Verify and authenticate your information, account, and interactions with us
Provide the Services and customer service
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Third party payment processors

Entities for legal and security purposes

Transactional information

Examples: such as information about your transactions with us or related to your attendance at events or programs.

Purpose of use:

Process orders
Communicate with you
Provide the Services and customer service
Improve the Services
Understand your interests and engage in research, analysis, and reports
Our marketing and advertising purposes
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Service Providers
Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent

User-generated content

Examples: such as any user-generated content you voluntarily decide to provide through the Services, or other information you provide in connection with an order or your account.

Purpose of use:

Process orders
Communicate with you
Provide the Services and customer service
Improve the Services
Understand your interests and engage in research, analysis, and reports
Our marketing and advertising purposes
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Service providers

Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent

Survey, research, feedback, or sweepstakes information

Examples: such as information you provide in response to a survey or sweepstakes in relation to the Services.

Purpose of use:

Communicate with you
Provide the Services and customer service
Improve the Services
Understand your interests and engage in research, analysis, and reports
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Service providers
Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent

Geo-information

Examples: such as information pertaining to your employer and position (including title, business address, business email address, business phone number, business size, location, and needs), your engagement with us, and means of contacting you.

Purpose of use:

Communicate with you
Provide the Services and customer service
Understand your interests and engage in research, analysis, and reports
Our marketing and advertising purposes
Improve the Services
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Service providers
Affiliates
Entities for legal and security purposes
Advertising partners and advertisers
Entities for sales or transfer of business or assets
Others with your consent

Connection and usage data

Examples: such as landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, time spent on each page, search terms, and information about network web traffic (including traffic from a specific user).

Purpose of use:

Provide the Services and customer service
Personalize your experience and customize the Services
Improve the Services
Understand your interests and engage in research, analysis, and reports
Our marketing and advertising purposes
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Service providers
Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent

Audio or visual information

Examples: such as CCTV footage, as well as other information related to the security of our premises, collected if you visit one of our physical locations or attend an off-site event or program, or audio recordings if you call our customer service phone number.

Purpose of use:

Provide the Services and customer service
Personalize your experience and customize the Services
Improve the Services
Understand your interests and engage in research, analysis, and reports
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Service providers
Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent

Location information

Examples: such as your approximate location based on IP address and activity at a physical premises.

Purpose of use:

Process orders
Provide the Services and customer service
Personalize your experience and customize the Services
Improve the Services
Understand your interests and engage in research, analysis, and reports
Our marketing and advertising purposes
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Service providers
Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent

Other information

Examples: such as if you submit information about others, for instance in relation to an order or a referral program.

Purpose of use:

Process orders
Communicate with you and others
Provide the Services and customer service
Improve the Services
Understand your interests and engage in research, analysis, and reports
Our marketing and advertising purposes
Bug detection and error reporting
Security, fraud, and legal compliance

Categories of third parties to whom we disclose the information for business and operational purposes:

Service providers
Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent

Other information

Examples: any other information that you provide in the course of using the Services.

Purpose of use:

Purposes of use will depend on the additional information you provide

Categories of third parties to whom we disclose the information for business and operational purposes:

Disclosure will depend on the additional information you provide

Retention

We retain personal information as described in Section IX above.

Other CCPA Rights

Please see Section VIII above for information about the additional rights you have with respect to your personal information under California law and how to exercise them. That section also includes information on financial incentives we offer in exchange for your personal information.

Sale and Sharing of Personal Information

To the extent we engage in such activity in the future, if you would like to opt out of the disclosure of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” or processing for purposes of targeted advertising, please review the information and follow the instructions in Section IV above and “Opting out of interest-based advertising” sub-section above. You must make this choice on each site/app on each browser/device you use to access the Services. You must also renew this choice if you clear your cookies or your browser is set to do that. You can also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes by visiting this link. You may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age.

California "Shine the Light" Disclosure

The California "Shine the Light" law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes unless you affirmatively agree to such sharing.

XIII. Privacy Rights for Nevada Residents

Under Nevada law, certain Nevada residents may opt out of the "sale" of "covered information" (as such term is defined under Nevada law) for monetary consideration. We do not engage in such activity as of the effective date of this Privacy Policy.

XIV. Changes to our Privacy Policy

We may update or revise this Privacy Policy from time to time in our sole discretion. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be made accessible through use of the Services with an updated "Last Revised" date. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have been made aware of and have accepted the updated Privacy Policy if you continue to use the Services after the updated Privacy Policy takes effect.

XV. How to Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

Metropolis
510 LaGuardia Place
4th Floor
New York, NY 10012
privacy@metropolis.io

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