Privacy Policy

Effective: October 2010

Privacy Policy Scope

This Privacy Policy identifies and describes the way the subsidiaries and their affiliates of SMART CITY HOLDINGS, LLC. (“SMART CITY”, “we”, “our”, and “us”) uses and protects the information we collect about Customers and Users. The term “you” or “your” includes any of your subsidiaries, affiliates, employees and parent or legal guardian. All use of SMART CITY’s products and services, as well as visits to SMART CITY’s Site, are subject to this Privacy Policy.

The Information We Collect, How We Collect It, And How We Use It

SMART CITY collects different types of personal and other information based on your use of our products and services and our business relationship with you. Some examples include:

  • Contact Information that allows us to communicate with you – including your name, address, telephone number, and e-mail address;
  • Billing information related to your financial relationship with us – including your payment data, credit history, credit card number, Social Security numbers, security codes, and service history.

We collect information in three primary ways:

  • You give it to us when you purchase or interact with us about a product or service we offer or provide;
  • We collect it automatically when you visit our Web sites or use our products and services;
  • We obtain it from other sources, such as from credit agencies.

We use the information we collect in a variety of ways, including to:

  • Provide you with the best customer experience possible;
  • Provide the services you purchase, and to respond to your questions;
  • Communicate with you regarding service updates, offers, and promotions;
  • Deliver customized content and advertising that may be of interest to you;
  • Address network integrity and security issues;
  • Investigate, prevent or take action regarding illegal activities, and violations of our Terms of Use Policy; and
  • For local directory and directory assistance purposes.

Online Activity Tracking and Advertising

We collect information about your activity on the SMART CITY Web site for a number of purposes using technologies such as data files (“Cookies”), Web beacons, widgets and server log files.

Information Sharing


Subject to applicable legal restrictions, such as those that exist for Customer Proprietary Network Information (“CPNI”), the SMART CITY HOLDINGS companies may share your Personal Information with each other to make sure your experience is as seamless as possible, and to make sure you have the full benefit of what SMART CITY has to offer.


We share your Personal Information only with non-SMART CITY companies that perform services on our behalf, and only as necessary for them to provide those services to you.

  • We require those non-SMART CITY companies to protect any Personal Information they may receive in a manner consistent with this policy;
  • We do not provide Personal Information to non-SMART CITY companies for the marketing of their own products and services without your consent.

In Other Circumstances:

We may provide Personal Information to non-SMART CITY companies or other third parties for purposes such as:

  • Responding to 911 calls and other emergencies;
  • Complying with court orders and other legal process;
  • Enforcing our agreements and property rights; and
  • Obtaining payment for our products and services, including the transfer or sale of delinquent accounts to third parties for collection.

Aggregate or Anonymous Information:

We may share aggregate or anonymous information in various formats with trusted non-SMART CITY entities for purposes such as:

  • Universities, laboratories and other entities that conduct scientific research; and
  • Media research companies and entities that may use the data for purposes such as municipal planning and coordinating disaster responses.

Our Online Privacy Policy for Children

  • Our Web site is not designed to attract children under the age of 13;
  • We do not knowingly collect personally identifying information from anyone under the age of 13 unless we first obtain permission from that child’s parent or legal guardian;
  • We comply with the Children’s Online Privacy Protection Act of 1998 and all other applicable laws relating to children’s privacy.

Safeguarding Your Information: Our Policy on Data Protection and Security

  • We do not sell your Personal Information to anyone for any purpose. Period.
  • We maintain information about you in our business records while you are a customer, or until it is no longer needed for business, tax, or legal purposes;
  • We have implemented encryption or other appropriate security controls to protect Personal Information when stored or transmitted by SMART CITY;
  • We use all commercial reasonable efforts to protect the privacy of information we collect; however, we are not responsible for the Cookies used by web sites linked to or from our web site.

Customer Privacy Controls and Choices

  • You can review and correct your Personal Information collected by us;
  • You can limit certain types of solicitation communications from SMART CITY, including marketing contacts made via telephone and e-mail updates;
  • You are responsible for periodically reviewing this policy on for any changes which may have been made to the policy.