01 · Introduction
Introduction
City Black Card, LLC ("City," "we," "us," or "our") respects your privacy and is committed to being transparent about how we collect, use, disclose, and protect your information. This Privacy Policy ("Privacy Policy") describes how we handle Personal Information in connection with our website, mobile applications, SMS and messaging tools, merchant dashboards, booking and engagement systems, and related services (collectively, the "Services").
Please read this Privacy Policy carefully before you start to use the Services. By accessing and/or using the Services, you accept and agree to be bound and abide by this Privacy Policy, and our terms of service available at https://cityos.ai/terms-of-service/, as updated from time to time (the "Terms of Service") incorporated herein by reference and to comply with all applicable laws, rules and regulations (collectively, "Applicable Laws").
If you do not want to agree to this Privacy Policy, and the Terms of Service, you must not access or use the Services.
For purposes of this Privacy Policy, "Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual or household. Personal Information does not include information that is publicly available from government records, de-identified or aggregated data that cannot reasonably be used to identify an individual, or information that is otherwise excluded from the scope of Applicable Laws.
02 · Our Business
Our Business
City is an AI-powered engagement and fulfillment platform that enables businesses to communicate and interact with their customers. Through our Services, businesses can manage customer communications, run campaigns, analyze engagement, and coordinate bookings or transactions.
The Services involve three primary groups of users:
| User Type | Relationship to Services | Example |
|---|---|---|
| Merchants | Businesses, venues, operators, and partners who use the Services to run campaigns, manage engagement, analyze performance, and coordinate bookings or transactions. | A restaurant, retail store, gym, clinic, or other business using the Services to communicate with customers. |
| Authorized Users | Individuals authorized by a Merchant to access and use the Services on the Merchant's behalf. These users may manage campaigns, respond to customer messages, review analytics, or administer the Merchant's account. | A restaurant manager sending promotional messages, a front desk employee responding to customer inquiries, or a marketing team member managing campaigns. |
| Customers | Individuals who are current or prospective customers of a Merchant and who receive communications through the Services or interact with City-powered messaging tools. | A diner receiving a promotional SMS from a restaurant or a shopper responding to a campaign message. |
In many cases, City processes Customer information on behalf of the Merchant that collected the information. The Merchant is responsible for its own privacy practices and its relationship with its customers. Merchants are responsible for ensuring they have appropriate rights and permissions to provide Customer information to the Services and to communicate with their customers through the platform, including obtaining any required consents under applicable messaging, marketing, and privacy laws.
03 · Information We Collect
Information We Collect
From Merchants
| Category of Information | Specific Data Elements | How We Collect It |
|---|---|---|
| Business Information | Business name, business address, industry, business contact details, and other company profile information | Provided by the Merchant when registering for or configuring the Services |
| Account Information | Account owner name, login credentials, email address, phone number, and account preferences | Provided directly by the Merchant during account creation and administration |
| Payment and Billing Information | Billing contact information, payment method details, billing address, and transaction records | Provided by the Merchant when purchasing or subscribing to Services |
| Service Configuration Information | Messaging templates, campaign settings, contact lists, customer segmentation data, and other configuration details | Uploaded or configured by the Merchant when using the Services |
| Communications with Us | Support inquiries, feedback, requests, and other communications with City. | Provided when Merchants contact us or interact with our support teams |
From Authorized Users
| Category of Information | Specific Data Elements | How We Collect It |
|---|---|---|
| Identity and Contact Information | Name, email address, phone number, and job title | Provided by the Merchant when adding Authorized Users to the account or provided directly by the Authorized User |
| Account Credentials | Username, password, authentication details, and account permissions | Created when an Authorized User account is established |
| Usage and Activity Information | Login activity, feature usage, campaign activity, and actions taken within the platform | Automatically generated when Authorized Users interact with the Services |
| Communications with Us | Support requests, feedback, and other communications with City. | Provided when Authorized Users contact us |
From Customers
| Category of Information | Specific Data Elements | How We Collect It |
|---|---|---|
| Contact Information | Name, email address, phone number, mailing address, and similar contact details | Provided by Merchants when they upload or sync their customer contact lists or collected when you provide your information to a Merchant. |
| Communication Data | SMS messages, emails, chat messages, and other communications sent through the Services | Generated when Merchants send communications using our Services |
| Interaction Data | Message responses, campaign engagement, appointment confirmations, and similar interaction data | Collected when you respond to or engage with communications sent through the Services |
| Technical and Usage Information | IP address, browser type, device information, timestamps, and related log data | Automatically collected when you interact with a City-powered communication channel or interface |
| AI Interaction Data | Prompts, responses, and related metadata associated with AI-powered messaging features | Collected when you interact with AI-enabled messaging or chat features powered by the Services |
| Preferences and Profile Information | Dietary restrictions, food and beverage preferences, allergen information, lifestyle preferences, interests, and any other personal characteristics or preferences you voluntarily share through the Services or that the platform learns through your interactions, including information you may not have explicitly provided but which the Services infer or derive from your engagement history, AI interactions, or communications. | Provided directly by you when completing a profile or interacting with the Services, or derived by the platform through AI-enabled analysis of your communications, requests, and engagement activity. |
| Transaction and Reservation Information | Purchase details, booking or reservation records, transaction timestamps, merchant location, and related fulfillment information | Provided by Merchants or partner systems when transactions, reservations, or bookings occur |
| Inference Data | Preferences, behavioral insights, engagement patterns, or likely interests inferred from usage activity, requests, or interaction history | Derived from analysis of user interactions and engagement patterns |
04 · How We Collect Information
How We Collect Information
Directly From You
We collect Personal Information that you provide to us directly when you use the Services. This includes information you submit when creating or managing an account, configuring platform settings, uploading contact lists or campaign materials, communicating with us, or otherwise interacting with the Services.
The categories of information you may provide directly are described in Section 3 (Information We Collect) above.
Automatically
When individuals interact with our Services, we may automatically collect certain technical and usage information to operate, secure, and improve the Services.
| Category of Information | Examples | How We Collect It |
|---|---|---|
| Device Information | Device type, operating system, browser type, device identifiers | Automatically when a device connects to the Services |
| Approximate Location Information | City-level location inferred from device data, phone number area code, or user-provided location information | Automatically collected or provided by users |
| Usage Information | Pages viewed, features used, time spent, interaction activity | Generated through normal use of the platform |
| Log and Diagnostic Data | IP address, timestamps, error logs, system activity | Automatically recorded by our systems |
| Cookie and Tracking Data | Cookies, pixels, tags, SDKs, and similar technologies | Collected through standard website and application technologies |
We use this information to operate the Services, analyze system performance, troubleshoot issues, improve functionality, and protect the security of the platform.
From Third Parties
In some cases, we receive Personal Information from third parties that help Merchants operate their businesses or support the functionality of the Services.
| Third-Party Source | Example of Information Received | Purpose |
|---|---|---|
| Merchant Integrations | Customer contact data, transaction or booking details, CRM data | To enable messaging, campaign management, and customer engagement tools |
| Service Providers | Payment confirmation data, analytics reports, technical system data | To support billing, platform operations, and analytics |
| Advertising and Marketing Partners | Attribution data, campaign performance metrics, audience insights | To measure and improve marketing performance |
| Social Media Platforms | Public profile information or interaction data when users engage with our content | To manage social media engagement and communications |
Information received from third parties is handled in accordance with this Privacy Policy and Applicable Laws.
Third-Party Applications and Integrations
The Services may integrate with or rely on certain third-party platforms and services (collectively, "Third-Party Applications") to operate and support functionality.
These may include:
- Payment processors
- Messaging infrastructure providers
- Analytics and reporting tools
- CRM and customer engagement systems
- Marketing and advertising platforms
- Social media platforms
When Merchants connect or authorize these integrations, the Third-Party Applications may exchange certain information with our Services. We process this information solely to provide and support the functionality of the Services. Third-Party Applications operate under their own privacy practices and policies.
05 · How We Use Personal Information
How We Use Personal Information
We may use Personal Information for the following purposes:
| Purpose | Description |
|---|---|
| Provide and Operate the Services | To create and manage accounts, provide access to the platform, operate messaging tools, manage campaigns, and deliver the features and functionality of the Services. |
| Facilitate Merchant Communications | To enable Merchants to send SMS messages, emails, chat responses, AI-generated communications, and other messages to their customers through the Services. |
| Manage Accounts and Business Relationships | To administer Merchant accounts, manage subscriptions and billing, provide onboarding support, and maintain our business relationship with Merchants and Authorized Users. |
| Customer Support and Communications | To respond to inquiries, troubleshoot issues, provide technical support, and communicate with users about the Services. |
| Analytics and Service Improvement | To analyze usage trends, evaluate campaign performance, improve platform functionality, and develop new features and services. |
| Marketing and Promotional Activities | To send promotional communications, personalized offers, and marketing messages to Merchants, Authorized Users, and Customers, including through SMS, email, and other channels, based on usage activity, preferences, and engagement history. |
| Security and Fraud Prevention | To detect, investigate, and prevent unauthorized access, fraud, abuse, or other harmful activity affecting the Services. |
| AI and Automation Features | To operate and improve AI-powered messaging, automation tools, and related platform functionality, including generating responses and improving system performance. We may also analyze interaction patterns, engagement activity, and transaction-related information in aggregated or de-identified form in order to improve automated recommendations, campaign optimization, and AI-enabled features of the Services. |
| Legal and Compliance Purposes | To comply with Applicable Laws, enforce our Terms of Service and agreements, protect our rights and property, and respond to legal requests or regulatory requirements. |
We may also use aggregated, anonymized, or de-identified information that cannot reasonably identify an individual for purposes such as improving the Services, analyzing trends, developing new features, and supporting research and analytics.
07 · Where Your Information Is Stored
Where Your Information Is Stored
We store and process Personal Information using secure infrastructure operated by trusted service providers. Personal Information may be stored and processed in the following ways:
Cloud hosting and platform infrastructure. Personal Information, including account information, contact details, communications data, and system activity data, may be stored using secure cloud hosting providers and other infrastructure that support the operation of the Services. These providers help us operate the platform, maintain system reliability, and deliver features such as messaging, analytics, and customer support.
Third-Party Applications. Certain Personal Information may be processed by Third-Party Applications that support the Services, including payment processors, messaging infrastructure providers, analytics tools, marketing platforms, and customer support systems. These providers process Personal Information as necessary to perform services on our behalf or to support integrations that Merchants enable through the Services.
Data Location. To provide the Services, Personal Information may be stored and processed in the United States, where City operates its business.
By using the Services or otherwise providing information to us, you acknowledge that your Personal Information may be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction.
08 · Personal Information and Marketing
Personal Information and Marketing
City does not currently intend to sell Personal Information, but reserves the right in the future to sell, license, or otherwise commercialize aggregated or anonymized data in compliance with Applicable Laws. If our practices change, we will update this Privacy Policy accordingly. We may share Personal Information with trusted service providers and partners in order to operate the Services, support platform functionality, and conduct analytics or marketing activities as described in this Privacy Policy. Certain disclosures to partners or advertising providers may be considered "sharing" or "targeted advertising" under applicable privacy laws. Where required by Applicable Laws, individuals may opt out of such processing as described in this Privacy Policy. We may also use Personal Information to market our Services and those of our Merchant partners to users, consistent with applicable law and the choices described in this Privacy Policy.
09 · Third-Party Links and Websites
Third-Party Links and Websites
The Services may contain links to or integrations with websites, platforms, or services operated by third parties (collectively, "Third-Party Services"). We do not control the content, policies, or practices of these Third-Party Services. Any information you provide to those services is governed by their own privacy policies and terms. Your interactions with Third-Party Services are at your own risk, and we encourage you to review the privacy policies of any third-party services you use.
10 · Our Content on Third-Party Services
Our Content on Third-Party Services
Our Services or marketing content may appear on or be distributed through third-party platforms such as social media sites, advertising networks, or other online services. These third parties may use cookies, pixels, or similar tracking technologies to collect information about interactions with our content or advertisements. This information may be used to measure the effectiveness of advertising campaigns or to deliver advertisements that may be more relevant to your interests. The data practices of those third parties are governed by their own privacy policies.
11 · Your Choices
Your Choices
You have certain choices regarding how we collect, use, and share your Personal Information, as described below:
Modifications to Personal Information. You may review and request modifications to certain Personal Information by contacting us at support@cityos.ai. Please note that we will retain Personal Information for as long as reasonably necessary to fulfill the purposes for which it has been collected or as required or permitted by Applicable Laws. If you provide us with updated information, we will make reasonable efforts to keep your information accurate and up to date and to implement requested changes in active systems as soon as practicable.
Marketing communications. You may opt out of promotional marketing communications by using the unsubscribe mechanism included in our emails or by contacting us at support@cityos.ai. If you opt out, we may still send you non-promotional communications, such as transactional messages related to your orders, account, or our ongoing business relationship.
Ad choices. Some advertisements and other content may be delivered by third-party advertising networks, attribution partners, and advertisers that may use cookies, pixels, SDKs, or similar technologies to collect and use information such as inferred interests, aggregated information, and activity across websites and applications in order to deliver advertising that is more relevant to your interests. To learn more about interest-based advertising and available opt-out mechanisms, please visit www.aboutads.info. You may opt out of certain interest-based advertising in desktop and mobile browsers at www.aboutads.info/choices, or in mobile applications by downloading the AppChoices app at www.aboutads.info/appchoices.
Tracking technology. You may disable or limit certain tracking technologies through your browser or device settings. On mobile devices, you may also be able to limit ad tracking through your device settings. Please note that disabling tracking technologies may limit the functionality of certain features of the Services.
Location and analytics. If we use Third-Party Applications or services to automatically collect information about your interactions with the Services, those third parties may offer you choices to limit or opt out of certain data collection. Please refer to Section 4 (How We Collect Information), Sections 4(b) and 4(c), above for additional information regarding our use of tracking technologies.
Cookies. Most web browsers accept cookies by default. You may adjust your browser settings to remove or reject cookies. Please note that disabling cookies may affect the availability or functionality of certain features of the Services.
Not providing Personal Information. You may choose not to provide certain Personal Information to us; however, doing so may limit your ability to access or use some or all features of the Services.
12 · Information Security
Information Security
We use commercially reasonable security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. However, we cannot guarantee the complete safety of your information. It is your responsibility to keep your information confidential.
13 · How Long We Keep Your Information
How Long We Keep Your Information
We retain, store and use your information for the minimum period reasonably necessary to support our relationship with you and to provide you access to our Services and in accordance with data retention policies and Applicable Laws.
14 · Our Services are Not Intended for Children
Our Services are Not Intended for Children
The Services are not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under 13. If you believe that a child has provided us with Personal Information, please contact us at support@cityos.ai, and we will take appropriate steps to delete such information.
15 · U.S. State-Specific Privacy Information
U.S. State-Specific Privacy Information
If you reside in any of the following states, you may be entitled to certain rights under applicable state data privacy laws: California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia.
Information. This Privacy Policy describes the categories of Personal Information we collect and process, the sources from which that information is obtained, and the purposes for which it is used. These disclosures are described in the sections titled "Information We Collect," "How We Use Personal Information," "How We Collect Information," and "How We Share Personal Information."
Access. You may request access to, or a copy of, the Personal Information we maintain about you.
Deletion. You may request that we delete Personal Information we have collected from or about you, subject to certain exceptions permitted by Applicable Laws.
Correction. You may request that we correct inaccuracies in Personal Information we maintain about you.
Opt-out of sale and sharing / targeted advertising. You may direct us not to sell or share your Personal Information, or to stop processing it for purposes of targeted advertising or profiling that produces legal or similarly significant effects, where applicable. Instructions for exercising these choices are provided in the "Your Choices" and "Personal Information and Marketing" sections of this Privacy Policy.
Appeal. If we deny a request you submit, you may have the right to appeal our decision, as permitted by Applicable Laws.
California law requires that we disclose whether we have "sold" or "shared" Personal Information, as those terms are defined under California law, during the 12 months preceding the date of this Privacy Policy. During that period, we have not sold Personal Information for monetary consideration. We may have shared Personal Information for purposes such as targeted advertising, as described in this Privacy Policy. You have the right to exercise the rights described above without being subject to unlawful discrimination.
16 · Exercising Your Rights (if applicable)
Exercising Your Rights (if applicable)
To exercise the rights described in the "U.S. State-Specific Privacy Information" section above, you may submit a request as follows:
Access, correction, or deletion requests. To request access to, correction of, or deletion of Personal Information collected through your use of the Services, please email us at support@cityos.ai.
Opt-out of interest-based advertising and tracking. To learn how to opt out of interest-based advertising and certain online tracking, please see the "Your Choices" section of this Privacy Policy.
Identity verification. To protect your privacy and security, we may need to verify your identity before responding to your request. Where we request additional information for verification purposes, we will use it solely to verify your identity or your authority to make the request on behalf of another individual.
Authorized agents. You may designate an authorized agent to submit a request on your behalf. Authorized agents may submit requests using the same methods described above; however, we may require proof of the agent's authority and may also require you to independently verify your identity.
Please note that, where permitted by Applicable Laws, we may limit the number of requests we are required to fulfill within a 12-month period.
17 · California Shine the Light
California Shine the Light
This Privacy Policy describes how we may share your Personal Information for marketing purposes. If you are a California resident, the Shine the Light law permits you to request and obtain from us once per calendar year information about any of your Personal Information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us at support@cityos.ai.
18 · "Do Not Track" Policy as Required by California Online Privacy Protection Act ("CalOPPA")
"Do Not Track" Policy as Required by California Online Privacy Protection Act ("CalOPPA")
Our Services do not respond to Do Not Track ("DNT") signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
19 · Usage and Deletion of Personal Information
Usage and Deletion of Personal Information
You may request what Personal Information we have collected, used and disclosed about you as well as the identity of the third parties to which we have disclosed your Personal Information. You may also request deletion of your Personal Information. Please note that we may not delete all of your information if: (1) we need it to complete a service as requested by you or perform under a contract we have with you; (2) we need such information to repair any errors to our Services or detect data security violations; or (3) we need such information to protect against fraud or illegal activity or to comply with Applicable Laws. Please note that if we delete your Personal Information, we may not be able to provide you the Services with the same functionality.
To make any request for Personal Information or deletion, please send an email to support@cityos.ai.
20 · Changes to this Privacy Policy
Changes to this Privacy Policy
We have the discretion to update this Privacy Policy at any time. We encourage you to frequently check this page for any changes. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Subject to Applicable Laws, your continued use of our Services shall be deemed an acceptance of our revised policy.
21 · You Can Contact Us
You Can Contact Us
If you have any questions about this Privacy Policy, you can email us at support@cityos.ai.