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1This document covers the Privacy Policy for use of www.link.nyc website. For the Privacy Policy covering use of LinkNYC services, please view our CityBridge Privacy Policy.1For more information, read our Frequently Asked Questions about Security and Privacy.
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3Effective October 27, 2015
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5LinkNYC and our operating entity, CityBridge, LLC ("We") are committed to protecting and respecting your privacy. This Privacy Policy describes how We collect, use and share information about you that We obtain through your use of our websites or other online services (together, the "Services").4Effective November 4, 2014
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7Please read this Privacy Policy carefully to understand how We will treat your information.6Last Updated: March 17, 2017
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9BY USING THE SERVICES, YOU ARE ACCEPTING AND CONSENTING TO THE PRACTICES DESCRIBED IN THIS POLICY (INCLUDING AS UPDATED OR AMENDED FROM TIME TO TIME). IF, FOR ANY REASON, YOU DO NOT AGREE TO THE TERMS OF THIS POLICY, PLEASE STOP USING THE SITE IMMEDIATELY.8CityBridge LLC (“CityBridge”, "we", “us”, and “our”) is committed to protecting and respecting your privacy. This Privacy Policy describes how we collect, use and share information about you through your use of our Public Communications Structures (“Structures”), including any related websites or advertising from the Structures (together, the "Services"). While we cannot guarantee the security of your information, we have taken appropriate steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
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10The Services are provided by CityBridge in fulfilment of its obligations under an agreement between the City of New York and CityBridge. CityBridge is not an agency, office, department or affiliate of the City of New York. We provide the City of New York limited information created in the course of providing the Services, which is described in the section below titled “How We Share Information with the City Of New York.”
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12Please read this Privacy Policy carefully to understand how we will treat your information. BY REGISTERING WITH US OR OTHERWISE AFFIRMATIVELY INDICATING YOUR CONSENT, YOU CONSENT TO THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF, FOR ANY REASON, YOU DO NOT CONSENT TO THESE PRACTICES, PLEASE DO NOT USE THE SERVICES.
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11Please click on the sections below to learn more about our Privacy Policy:14Please click on the sections below to learn more about our Privacy Policy:
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13WHO WE ARE16WHO WE ARE
14INFORMATION WE MAY COLLECT FROM YOU17INFORMATION WE MAY COLLECT FROM YOU
15HOW YOUR INFORMATION MAY BE USED18HOW YOUR INFORMATION MAY BE USED
16HOW WE SHARE YOUR INFORMATION19DISCLOSURES OF YOUR INFORMATION
17COOKIES20COOKIES
18YOUR CHOICES21YOUR CHOICES
19SECURING YOUR INFORMATION22WHERE WE STORE YOUR INFORMATION
23OTHER SERVICES
24CHILDREN
20LINKS TO THIRD PARTY SITES25LINKS TO THIRD PARTY SITES
21CHANGES TO OUR PRIVACY POLICY26CHANGES TO OUR PRIVACY POLICY
22CONTACT27CONTACT
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24WHO WE ARE29WHO WE ARE
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26As used in this Privacy Policy, the terms "CityBridge", “LinkNYC” and “We” include CityBridge, LLC and its affiliates and member companies. These terms also include our suppliers and contractors, except as otherwise stated in this Privacy Policy.31As used in this Privacy Policy, "CityBridge" means CityBridge LLC.
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28INFORMATION WE MAY COLLECT FROM YOU33INFORMATION WE MAY COLLECT FROM YOU
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35Registration:
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37If you register with us to use the Services, during registration, we collect:
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39A user name;
40Your email address;
41A password for your account.
30Using the Services42Using the Services
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32We collect certain information to help us operate and provide the Services to you. We collect this "Technical Information" when you use the Services, including:44We collect certain information to help us operate and provide the Services to you. We collect this "Technical Information" when you use the Services, including:
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34Information about the device(s) you use to access the Services, including MAC address, IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, and device identifiers;46MAC address (anonymized), IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, and device identifiers;
35Information about your visits to websites we provide, including the full URL clickstream to, through and from these websites (including date and time); Information We need and use to facilitate your use of the Services (including to provide access to third party websites and services), such as URL requests, destination IP addresses, or device configuration details;47Information about your visits, including the full URL clickstream to, through and from (including date and time) websites owned or operated by CityBridge, including: https://www.link.nyc/ and https://wifi.citybridge.com/;
36Pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.48Information used to facilitate your use of the Services, such as access to third-party websites and services, including URL requests, destination IP addresses, configuration details, or other information necessary to provide access to the Services;
49We will not store your browsing history or track the websites you visit when you use your personal device to access the Services.
50We retain anonymized MAC addresses for 1 year in order to facilitate automatic log-in to the network without reregistration. We delete all other Technical Information about individual sessions 60 days from the end of the session.
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37Information You Provide to Us52Information You Provide to Us
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39If you send us an email, fill out a feedback form, call us, or choose to communicate with us in another way, We will collect that information in order to respond to your request, feedback, or question. We will use and share information you provide to us only as described in this Privacy Policy.54If you send us an email, fill out a feedback form, call us, or choose to communicate with us in another way, we will collect that information in order to respond to your request, feedback, or question. We will use and share information you provide to us only as described in this Privacy Policy.
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41Personally Identifiable Information56Personally Identifiable Information
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43Some of the information We collect through your use of the Services or communications with us, such as your name or email address, may personally identify you. We will treat this information as “Personally Identifiable Information.” We will also treat as Personally Identifiable Information any non-identifiable information that is combined with Personally Identifiable Information.58Some of the information we collect, including information we collect during registration, or in the course of providing the Services or through your communications with us, such as your name or email address, may personally identify you. We will treat this information as “Personally Identifiable Information,” along with any Technical Information that is combined with Personally Identifiable Information.
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45Aggregate or Anonymized Information60Anonymized Information
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47We may combine Technical Information or non-Personally Identifiable Information about your use of the Services with similar information We obtain from other users for use in an aggregate or anonymous manner.62We may combine Technical Information or non-Personally Identifiable Information about your use of the Services with similar information about other users in an anonymized manner.
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64Location Information
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66We do not collect information about your precise location. However, we know where we provide WiFi services, so when you use the Services we can determine your general location.
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49Other Collection of Information68Other Collection of Information
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51We will not ask for or request sensitive information such as government identifiers, medical information, or financial information (other than for payment of optional services). Please do not provide this information to us through emails, feedback forms or in any other way.70CityBridge will not ask for or request sensitive information such as government identifiers, medical information, or financial information (other than for payment of optional services). Please do not provide this information to us through emails, feedback forms or in any other way.
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72We may offer additional paid products and services. For these products and services, we will collect payment information in order to process any order from you. This payment information is processed by a third-party payment processor. We do not process, record or maintain your payment card or bank account information.
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74Sometimes we supplement anonymized Technical Information we collect from you with information collected by third parties. Third parties may include advertising partners or other providers that help us understand our users.
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76We will not share any information that is not anonymized with any third parties for their own use.
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53HOW YOUR INFORMATION MAY BE USED78HOW YOUR INFORMATION MAY BE USED
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55We may use any information We collect to:80We will not add or insert advertising on your personal device. We may use any information we collect to:
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57Allow us to operate the Services, including administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes;82Allow us to operate the Services, including administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes;
58Manage your access to the Services;83Manage your access to the Services;
59Send you information that allows you to use the Services;84Send you information about the Services or your usage of the Services;
60Comply with laws and regulations;85Comply with laws and regulations;
61Maintain the security of the Services.86Maintain the security of the Services.
62We may use Technical Information or non-Personally Identifiable Information to improve the Services and present content in the best way for you and for your device(s).87We may use Technical Information that is unassociated with you and your device to:
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64In addition, We may use your information, including Personally Identifiable Information, to: Provide you with information about goods or services that may interest you; Send you emails about updates, information, or alerts regarding the Services.89Improve the Services and present content in the best way for you and for your device;
90Deliver relevant advertising on the Structures;
91Measure or understand the effectiveness of advertising we serve on the Structure to you and improve the effectiveness of advertising;
92In addition, with your express opt-in consent, we may use your information, including Personally Identifiable Information, to:
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94Provide you with information about goods or services that may interest you; and
95Permit selected third parties to provide you with information about goods or services that may interest you.
66HOW WE SHARE YOUR INFORMATION96HOW WE SHARE YOUR INFORMATION
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68We will not sell your Personally Identifiable Information or share your Personally Identifiable Information with third parties for the third party's own direct marketing purposes. We may share information, including Personally Identifiable Information, with our service providers and agents to the extent reasonably necessary to provide you with the Services. For example, we use a third party platform for email and cannot communicate with you without disclosing your email address to our third party email provider. These third parties use any information we share only to support Us and our efforts to provide the Services.98CityBridge will not sell Personally Identifiable Information and CityBridge will not share Personally Identifiable Information with any third party for that third party's own use.
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100We may share information, including Personally Identifiable Information, with our third-party service providers and agents to the extent reasonably necessary to provide you with the Services. For example, we use a third party platform for email and cannot communicate with you without disclosing your email address to our third party email provider. These third parties use any information we share only to support CityBridge and our efforts to provide the Services.
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70We may share any information, including Personally Identifiable Information with:102We may share any information, including Personally Identifiable Information with:
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72Service providers and sub-contractors to the extent reasonably necessary to enable us provide the Services;104Service providers and sub-contractors to the extent reasonably necessary to enable us provide the Services;
73A third party that acquires CityBridge or a majority of its assets, if that third party obtains the rights to provide the Services and subject to the provisions of this Privacy Policy; A third party with whom We must legally share information about you;105A third party that acquires CityBridge or a majority of its assets, if that third party obtains the rights to provide the Services and subject to the provisions of this Privacy Policy;
106A third party with whom We must legally share information about you;
74You, upon your request;107You, upon your request;
75Other third parties with your express consent to do so.108Other third parties with your express consent to do so.
76We may share non-Personally Identifiable Information, aggregate or anonymous data with analytics, search engine, or other service providers that help us improve the Services.109We may share Technical Information that is unassociated with you and your device:
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78In the event that We receive a request from a governmental entity to provide it with your Personally Identifiable Information, We will take reasonable attempts to notify you of such request, to the extent possible.111With analytics, search engine, or other service providers that help us improve the Services;
112To advertisers and advertising networks to select and serve relevant advertisements.
113REQUESTS FOR YOUR INFORMATION BY GOVERNMENT AGENCIES
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115We will not disclose your information unless disclosure is required by law, such as in response to a subpoena or court order. In the event that we receive a subpoena or court order demanding that we provide a governmental entity with your Personally Identifiable Information, we will attempt to notify you of such request by sending an email to the email address that you provide during registration. If we do not have your current email address, then we will not be able to notify you of any requests.
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117HOW WE SHARE INFORMATION WITH THE CITY OF NEW YORK
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119We may provide Technical Information that is unassociated with you and your device to the City of New York, such as statistics on usage, which may also be available through the City’s Open Data Portal. We do not provide Personally Identifiable Information or other information to the City of New York about you or your individual use of the system, except as may be required by law.
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80COOKIES121COOKIES
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82The Services may use cookies and similar technologies to support the functionality of the Services. This provides a better experience when you visit our websites and allows us to improve the Services.123The Services may use cookies and similar technologies to support the functionality of the Services. This provides a better experience when you visit our websites and allows us to improve the Services.
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125DO NOT TRACK
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127The websites owned or operated by CityBridge do not support a “Do Not Track” feature, which provides a signal that you do not wish operators to track certain of your online activities over time and/or across different websites.
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84YOUR CHOICES129YOUR CHOICES
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86You may have the opportunity to receive certain communications from us related to the Services. If you provide us with your email address in order to receive communications, you can opt out at any time by using the unsubscribe links at the bottom of our emails.131When you register with us, you may choose to receive certain communications from us related to the Services. You can update your communications choice at any time by clicking "unsubscribe" at the bottom of these emails.
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88Please note that certain emails may be necessary for the operation of the Services. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.133There are certain communications regarding your use of the Services, for example if you need to reset your password or responding to a question from you, which are necessary for the operation of the Services. You will continue to receive these emails, if appropriate, even if you choose not to receive our optional communications.
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90Some Browsers and devices support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Certain legal obligations require that we disclose how websites we operate react to Do Not Track signals. The Services do not currently change the way they operate based upon detection of a Do Not Track or similar signal.135Certain websites you visit may provide options regarding advertisements you receive. For more information or to opt out of certain online behavioral advertising, please visit http://www.aboutads.info.
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92SECURING YOUR INFORMATION137SECURING YOUR INFORMATION
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94The security of your information is important to us. Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your information, we cannot guarantee against access to your Personally Identifiable Information by unauthorized third parties. The security of your data transmitted to or through our Services is at your own risk. Once We have received your information, We will use appropriate and necessary administrative, technical and physical controls to prevent unauthorized access to it.139All information you provide will be stored by, and may only be transferred or accessed by, entities in the United States. The security of your information is important to us. We encrypt Personally Identifiable Information we store about you. We also encrypt WiFi connections we provide for compatible devices. To determine whether your device is compatible, please visit here. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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141Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee against access to your Personally Identifiable Information by unauthorized third parties. The security of your data transmitted to or through our Services is at your own risk. Once we have received your information, we will use appropriate and necessary administrative, technical and physical controls to prevent unauthorized access.
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143If an unauthorized person gains access to your information we will notify you as soon as feasible at the last email address you have provided us unless we determine that no harm is reasonably likely to occur from the unauthorized disclosure.
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145We will make reasonable efforts to retain Personally Identifiable Information that you provide to us during registration no longer than 12 months after your last login. If you do not access the Services for 12 months or longer, you may be required to register again.
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147OTHER SERVICES
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149Environmental Sensors
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96LINKS TO THIRD PARTY SITES151Structures may include environmental sensors that collect information about the environment surrounding the Structures. These environmental sensors collect data such as temperature, humidity, ambient noise, light, pressure and air pollutants, but do not collect data from or about you.
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98The Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check the policies applicable to a website you access via the Services before you submit any personal data to such website.153Other than the City or governmental law enforcement, we will only share data collected by environmental sensors if 1) we are legally required to, 2) it is necessary to operate and maintain the System and the Services, or 3) we get advanced, written permission from the City.
154Cameras
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100California Civil Code Section 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e­mail to hello@link.nyc.156Structures may include two cameras camera mounted on each side of the Link above the ad panels. The cameras capture images of the area surrounding the Structure, and those images may include you, but the use of video footage will be limited to the following conditions.
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158We will not keep any footage captured by any camera for longer than seven days, unless the footage is necessary to investigate an incident.
159We will not use or disclose data collected by our cameras except (1) to improve the Services and ensure the performance and security of the Structures, (2) to detect or address illegal activity on or associated with our Services, (3) to identify, contact or bring legal action against someone who appears to be causing injury to or interfering with our property, or (4) if we believe that disclosure is required by law or useful to protect your safety or the safety of others, including when there is an emergency involving potential harm, loss of security, or serious injury to people or threats of such emergencies.
160We will not use facial recognition technology for any reason, and we will not use our cameras to track your movement throughout the city.
161The Tablets also contain a built-in camera. When available, the camera could be used for video calls in the future. The Link tablet camera will only activate if initiated by a LinkNYC user for a specific feature. It will not automatically activate during phone calls, wayfinding, charging or accessing city services.
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163USB Ports
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165Structures may include one or more USB ports. Our USB ports provide electricity to charge your devices and cannot collect any information from your device.
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167CHILDREN
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169The Services are not directed toward children under 13 years of age nor does CityBridge knowingly collect information from children under 13. If you are under 13 years of age, you are not permitted to submit any Personally Identifiable Information to CityBridge.
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171LINKS TO THIRD PARTY SITES
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173Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
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102CHANGES TO OUR PRIVACY POLICY175CHANGES TO OUR PRIVACY POLICY
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104Changes to this Privacy Policy will be posted on this page when the changes become effective. Changes to the Privacy Policy will be effective with respect to you upon your use of the Services after the changes have been posted or any other indication of your consent. Note that we may condition your continued access to the Services on your consent to changes to this Privacy Policy.177If you provide us with your current email address, we will send an email to that email address, notifying you of any material updates or changes we may make to the Privacy Policy prior to the changes becoming effective. All changes will also be posted on this page so please check back frequently. After we notify users of changes to the Privacy Policy, users will have the option to decline continued use of the services if they do not consent to the changes.
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106CONTACT179CONTACT
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108Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to CityBridge, LLC, 100 Park Avenue, Suite 610, New York, NY 10017 or hello@link.nyc.181Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to: CityBridge, 10 Hudson Yards, 26th Floor, NY, NY 10001 or hello@link.nyc.
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