- May 2017
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link.nyc link.nyc
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We delete all other Technical Information about individual sessions
This time-limit to data storage applies to personal information, not the "environment data", which includes ambient noise. (See below)
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LinkNYC's new privacy policy falls far short of making us feel safe on our streets.
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Questions
How do I opt out of the display ads? By sticking a fork in each eye?
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children under 13 years of age
The Services are not directed toward children under 13 years of age. But if we happen to scoop up their info, so much the better! :) We can just spy on them until they’re officially of age! :)
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we will not use our cameras to track your movement
Can you make the same assurance about the other, non-camera data you collect?
How about committing to not tracking our movements, by any means?
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facial recognition technology
What about other forms of recognition, e.g. gait recognition?
How about committing to not identifying New Yorkers without our explicit, opt-in consent?
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We
What about people you share this with? Even if LinkNYC forbids itself from using facial recognition technology, it can easily share its video with third parties, such as the NYPD or another Google subsidiary, who do use facial recognition technology.
To remedy this, LinkNYC ust be forbidden from sharing its video with any third parties.
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to detect or address illegal activity
Come back with a subpoena! (Who decides what's illegal?)
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to improve the Services and ensure the performance and security of the Structures
Is "providing more targeted advertising" "improving the Services" ? Even if LinkNYC does not use facial recognition, the advertisers (like Google and Facebook) can already recognize faces.
This privacy policy should explicitly exclude sharing camera data with advertisers and exclude any third-parties sufficient image data to identify individuals.
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to improve the Services
This gives LinkNYC leeway to share video data for pretty much any reason! There should be much stricter rules against sharing video; in fact, the cameras should be entirely removed.
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unless the footage is necessary to investigate an incident
Oh gosh, there was that incident where the suspicious-looking bearded man walked by! Better hold onto that footage indefinitely!
And there was the dog that pooped near the kiosk. Better hold onto that indefinitely!
And the two people walking by with backpacks! Holding onto that footage indefinitely!!
What qualifies as an "incident"?!?!
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it is necessary to operate and maintain the System and the Services
Is serving ads one of the 'Services' -- does that mean "ambient noise" -- i.e. all audio recording can be sent to or used by advertisers?
At the least, this should exclude advertising.
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ambient noise
This means that LinkNYC is collecting and recording all of the surrounding sound including voices. Unlike the video section, LinkNYC doesn't say they ever destroy this data, and unlike other sections, it allows law enforcement full and direct access to it -- thus the police might be live streaming all audio conversations near all kiosks in the city!
Law enforcement should need a subpoena or warrant for audio data, and audio should not be collected at all -- and if it is, it should be destroyed within 7 days, just like video.
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Sometimes 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.
This clause undermines most of this whole privacy policy. Most advertisers collect and store "Anonymized Technical Information" otherwise known as your Digital Fingerprints, to correlate your behavior across all kinds of services and websites. When LinkNYC 'supplements' their information, it means they send your digital fingerprints to advertising warehouses (which save that info) and map it back to personal attributes—including more personally identifying information (You may not have shared your relationship status with LinkNYC, but they will now know).
LinkNYC should not be allowed to share "Technical Information" with third parties and especially advertisers—even if they can, then it should be only in aggregate without any unique 'fingerprintable' records.
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precise location
LinkNYC kiosks determine location quite precisely. It's disingenuous to say they 'only' determine 'general location.' Why do they collect that information at all?
Furthermore, this privacy policy is for people that 'use the Service" -- If I just walk by without connecting to wifi, do they save any Technical Information about me?
LinkNYC shouldn't save any information about our location -- precise or 'general'.
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only as described in this Privacy Policy
Only as described in this version of the privacy policy. This policy can be updated at any time.
We would like this privacy policy to explicitly commit a to a charter that insures that updates are publicly reviewed.
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We will use and share information
Third-parties are not bound by this privacy policy, so technical information can be used by them to easily de-anonymize user data.
This privacy policy should declare that these restrictions apply to the data collected, even after it is shared.
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when you use your personal device
This means that your browsing history on the Kiosk tablet is tracked (even though free-form tablet browsing is currently disabled).
This policy should also cover all tablet-based browsing and application access.
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anonymized
Anonymized MAC addresses are a good start, but if the MAC address is consistently anonymized, individual users can be uniquely tracked, even if they can't be identified.
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We collect this "Technical Information" when you use the Services
What information is saved even if I don't "use the services?" If I walk by, is my device information (MAC address and/or bluetooth identifier) collected?
Kiosks should not collect or save any device information of those that do not actually connect to the WiFi.
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