We take user privacy seriously. This Privacy Policy outlines the privacy practices of ParkSmart Inc. (“Company,” “us,” “we,” or “our”) in connection with our services, websites, mobile applications, and software programs (collectively, “Services”) and our collection, use, and disclosure of personal information. By using our Services, you acknowledge that you have read, understood, and agree to be bound by our terms, policies, and this Privacy Policy and to the outlined collection and use of information. If you do not consent, you should stop any use or access of the Services.

Who are we?

We are a leader in the parking industry specializing in the development of creative partnerships in high-end downtown shopping districts and software development.Where applicable, individuals can provide information or login to our respective mobile application or use our respective website to pay for use of parking spots at facilities using our Services. At certain locations outlined more below, we may use a license plate recognition vehicle to monitor and enforce parking policies.

What does this Privacy Policy cover?

This Privacy Policy outlines how we collect, use, and disclose information of users, both online and offline. Generally, we collect information that you provide to use the Services, such as your contact information, license plate number, and invoice number as applicable. We use a payment processor and other service providers to process and store information and to help us provide the Services.

Unless otherwise expressly stated, this Privacy Policy does not apply to any third-party practices, websites, or services, whether or not referenced in or linked from our Services. Each third party will have its own privacy practices and policies, which you should review before using them.

How do we collect and use information?

We generally collect personal information directly from you at various points, for example:

• When you contact us or use the Services and provide data;
• When you post a review or comment about us;
• When you communicate with us; or
• When you apply for a job with our Company.

In particular, Company collects the information necessary for the use and payment of parking spots. For example, if applicable, customers may choose to pay for parking via a physical pay station using their credit card number and parking stall number (no license plate required) and they may choose a printed receipt; in other circumstances, individuals may choose a text-message receipt and pay for parking using their license plate, phone number, and/or invoice number.

In some locations, License Plate Recognition (“LPR”) or Automated License Plate Recognition (“ALPR”) technology may utilize cameras to capture digital images of vehicle license plates. This data is only used by authorized individuals for business purposes, namely to validate, process, pay for, and enforce parking. For more information, see below section on “How is ALPR data used?” 2 Further, like most websites, we collect personal information through automated technologies, such as cookies, web beacons, and pixels. These practices are discussed more fully below. We may combine information collected about you through various means and sources described herein.

We may also collect personal information from third parties, such as if employers provide information about their employees to authorize use of parking spaces, if third parties respond to social media comments, or from business partners or business transfers if and when applicable.

We primarily collect personal information for our business purposes, namely, to provide, improve, and customize our Services. Part of this includes providing appropriate parking-related services, responding to communications, and processing payments through our service provider; and part of this includes compliance with laws, such as responding to legal requests and addressing legal claims. We may use information for short-term, transient use for an interaction with you and to personalize your experience. We may use information for security purposes and to protect against harmful activity, as well as for debugging for functionality, auditing interactions, and internal research. We may also use information as instructed by you and with your consent.

In addition, we may collect information for commercial purposes, meaning to market our goods and services, in limited circumstances. For example, we may publicly display user reviews; and we may collect device-related data to create a more personally relevant experience. See more below.

We use information for the same reasons that we collect it. For example, we primarily use information for business purposes for our Services and for commercial purposes in limited cases.

Here is a chart outlining how we collect and use information and for what purposes.

Category	Examples of Data Collected	Collection Point	Purpose for Collection and Use
Identifiers	Contact Information, such as name, email address, and telephone number. Account Information, such as username and password if applicable. This information may include data under Cal. Civ. Code §1798.80(e)).	We collect this information when you provide it, such as when you contact us or pay for a parking space using our Services and provide data. For example, depending on the location and option selected, consumers may be directed to provide a parking stall number and phone number, e.g., if requesting a text copy of a receipt. Individuals may also provide account information to access our parking application/software.	We collect and use data for business purposes, such as complying with laws, providing and improving our Services, responding to communications, and for security and auditing purposes. In particular, this data is used to register for a parking permit or pay for parking or to use our parking application/software.
Parking and License Data	Parking Data, including license plate number, and invoice and parking stall number. Images and Recordings, such as license plate readings and visual data. For more on ALPR technology, see below. Geolocation	We collect this information when you provide it, such as when you contact us or pay for a parking space using our Services and provide data. In certain cases, you provide your license plate number to use the Services and pay. In certain locations, we may also use a service provider to store and process ALPR data. Third parties such as property managers or employers may provide information to assist the Services, discussed below. We may also collect geolocation information if you choose certain services.	We collect and use data for business purposes, such as complying with laws, providing and improving our Services, and for security and auditing purposes. In particular, this data is used to register for a parking permit or pay for parking. Geolocation may be used to verify a parking location and display relevant parking locations.
Commercial Information	Financial Data, such as name and last four digits of a credit card number. We use a third-party, Stripe, for processing payments. See Stripe’s Privacy Policy at https://stripe.com/ us/privacy. Transaction Data, such as information about Services used.	We collect this information when you provide it, such as when you provide your credit card information via Stripe to make a payment.	We collect and use data for business purposes, such as complying with laws, providing and improving our Services, and for security and auditing purposes. In particular, this data is used for transaction reference in use of our Services.
Device Data	Internet and Network Data, such as page views. For more on cookies, see below.	We collect this data when you provide it to us or when you use our website and certain technical data is provided to us, such as through cookies and other automated technologies.	We collect and use data for business purposes, such as complying with laws, providing and improving our Services, and for security and auditing purposes.
Other Personalized Data	Employment, such as professional history. Education, such as education history. Protected Class Data, such as age and sex. Other Information, such as communications	We may collect this information in limited circumstances if you provide it, such as if you apply for a job, send us a message, or participate in an offer. You should take caution in providing other personal information.	We collect and use data for business purposes, such as reviewing job applications and providing and improving the Services.
Other NonPersonalized Data	Public information Aggregate Information or DeIdentified Data	We may collect this information from public, third party, and other sources in limited circumstances. For example, we may collect information from a review or comment that you post to social media about us.	We may collect and use this data for business or commercial purposes. For example, we may share a public review that you posted about us or use aggregate data for our internal analytics purposes.

When do we disclose information?

As part of our business, we disclose information as follows and for the purposes outlined above, which include business purposes to provide and improve the Services and comply with legal and contractual obligations, as well as commercial purposes in the limited circumstances outlined.

• Services Providers and Contractors. We share information with service providers, such as payment processors, which allows us to provide and improve the Services. Service providers only use your information for a contracted business purpose. Such disclosure is for our business purposes, in particular to provide the Services. We may likewise share information with contractors that are not service providers but to whom we disclose information for a business purpose. Such disclosure is for the business purpose of providing Services, and personal information is only shared subject to appropriate contract terms.
• Company Parties; Merger or Sale. We may share information with other partner businesses and other affiliated companies that are related to us under a common ownership where they comply with this Privacy Policy. Such disclosure is for our business purposes, e.g., to provide and improve our offers. We may share information as part of a sale, merger, acquisition, or other change in control or status, either in whole or in part. We reserve the right to transfer or assign your information as part of any such transaction or investigation.
• Disclosure of Device Data. For information about our use of cookies and other technologies, see further below. Such disclosure is for business purposes, i.e., to provide the Services.
• Disclosure for Legal Process and Protection. We may disclose information as necessary to comply with our legal obligations, such as to respond to government requests, law enforcement inquiries, legal processes, subpoenas, and court orders, subject to applicable laws. We may disclose information when we believe it is necessary to investigate, prevent, or respond to illegal, fraudulent, or injurious actions or security incidents that may cause harm to us, the Services, or others. We may also disclose information in good faith where necessary to investigate or enforce a violation of our Privacy Policy, terms, or rights.
• Other Users of the Services. For certain Services, employers may use a ParkSmart app to provide and use data about their employees (e.g., to determine who is authorized to park in a facility or in certain parking spaces), where the employer is collecting the information and responsible for providing notice to their respective employees. For other Services, property managers or designees may request limited data (e.g., type of vehicle and parking space, but not ALPR data as discussed below) for business purposes, such as safety and parking management. Furthermore, if you post or publicly display information about our Services, we cannot control who reads your postings or what they do with the information.
• Disclosure Upon Consent. We may disclose information as requested or consented to by you. Such disclosure may be for any business or commercial purpose as described to you.

How do we use cookies and similar technologies?

As with many companies, we may use cookies, pixels, gifs, web beacons, log files, and/or similar technologies to automatically collect certain information when you use the Services or interact with our digital media content, such as when you visit our website. For example, unless you have opted out of cookies or changed your cookie settings in your internet browser, your browser may send us certain device and internet activity information. You can change your cookie settings in your internet browser or use settings on our opt-out form or your device to manage your privacy controls. For more information and ways to opt out, see https://www.allaboutcookies.org/, and learn how more or opt-out of third-party cookies and mobile device ID practices.

Please note that there are different types of cookies and related technologies, which may be placed by us or third parties, including essential cookies that are required to display and provide the Services; preference cookies that are used to store preferences and improve user experiences; and analytics cookies to determine how the Services are used e.g., we may analyze page views on our website. If a Google Analytics tool is used i.e., for internal analytics in limited circumstances, please see Google Cookie Policy, Google Analytics Opt-Out Browser Add-On, or Ads Settings.

Do we sell or share information?

We do not sell data or share personal information for cross-context advertising. From time to time, we may use analytics i.e., to assess website page views, which has the potential to be classified as a data “sale” under certain state privacy laws, including the California Consumer Privacy Act (“CCPA”) if applicable. For more information or to make a privacy request, please contact us.

How is ALPR data used?

Purpose: In certain circumstances/locations, we may use ALPR technology (i.e., a visible camera on a vehicle), through our service provider, to capture license plate data for the Services, namely 6 to register for a parking permit, determine how long vehicles have been parked at a location, pay for parking, validate paid and permitted license plates, and determine accurate parking fees. This purpose of this provision is to ensure respect for individuals’ privacy and civil liberties.

Data Collection/Use: In these circumstances, the following data may be collected (but not necessarily accessed): vehicle license plate image, number, and state; and date, time, and location. We may use this data to determine how long a vehicle has been parked at a location, identify abandoned vehicles, identify open parking spaces, permit gate entry/exit if applicable, respond to legitimate inquiries from law enforcement or court orders or legal process, or issue fees or notices. For example, data can be used to assess parking time limits.

Authorization: ALPR data is not available to employees for personal use. We use an independent third-party service provider, who collects and stores the data. Our authorized users include employees and contractors (if applicable) with an operational need to have access, i.e., the President and Vice President, Office Manager, Operations Manager, and Product Development, as well as parking supervisors, auditors, and IT staff if applicable. These individuals will be required to comply with the following training requirements: review of applicable legal requirements, review proper use of and access to the system, and review of escalation procedures as applicable.

Monitoring: The ALPR system will be monitored by the President and Vice President, or their designee(s), to ensure the security and accuracy of the information and compliance with applicable privacy laws, including by correcting any errors made known to them and to ensure that only authorized personnel with a legitimate business need be granted access. ALPR system audits shall be conducted on a regular basis. Logins and queries are stored and include the username, date, time, purpose, and query criteria. Data is stored for a legitimate purpose, as outlined to users and above. We will commit to monitoring and auditing the collection, access, and storage procedures.

Transfer of Data: The sale and unauthorized sharing or transfer of ALPR information is prohibited by Company policy. Violations will include disciplinary action up to and including termination. The process for sharing or transfer of ALPR information shall include at least a written request with the name of the requestor, the intended purpose of obtaining the information, and the lawful basis or other legal authorization for obtaining the information; the request shall be reviewed by the person authorized for monitoring the ALPR system or designee, with any approved request and contact information for the requestor retained on file in access logs. We take steps to ensure that ALPR data will not be sold or disclosed for commercial marketing or promotional purposes, disclosed without authorization, or disseminated to those not authorized. Subject to and as required by applicable laws, we may provide ALPR data to law enforcement or a governmental agency upon legitimate inquiry such as with a warrant, or with valid court order or legal process.

System: ParkSmart is the owner of ALPR equipment. ALPR data is stored in the databases of our service provider, Route1/Genetec. Some data may be processed by us if applicable, such as if data is necessary to process a transaction for our Services, and may be combined with other data. For information about Route1/Genetec’s privacy practices, please visit their privacy policies.

Security: We and our service provider use administrative, operational, technical and physical safeguards to protect ALPR data from unauthorized access, use, destruction, and disclosure. For example, we use password-protected access to ALPR data. In addition, the database usage shall be monitored and audited. Operational measures include training authorized users on proper use 7 and secure practices of ALPR data. Physical controls include having network equipment and servers containing ALPR data being maintained and accessed only by authorized personnel. Technical measures include encryption where applicable and necessary updates/patches. If a data breach occurs, proper data breach notifications will be made in accordance with applicable law.

Retention: ALPR data will be retained or stored as necessary based on the parking facility location for the collection purposes and uses. Specifically, license plate information and images collected using the ALPR system will remain on file for a period of 365 days, unless otherwise authorized or required by applicable laws, such as if there is a court order or legitimate law enforcement or legal process request requiring a longer period. Parking facilities may set specific ALPR retention policies upon written request and subject to applicable laws. For information about how third parties, including our service provider, retain ALPR records, please refer to their privacy policies.

How do we protect and transfer information?

Consistent with others in our industry, we take efforts to employ security measures for personal information, taking into account reasonable security procedures and accessible technology. These data protection measures include engagement of a cybersecurity vendor and cybersecurity audit, access and operational controls on an as-needed basis, and review of our processes. However, no system can be completely secure; and we cannot promise, and you should not expect, that your personal information will always remain secure. Your provision of personal information and use of parking facilities is at your own risk. The safety and security of your information also depends on you. Take steps to safeguard your passwords and other data and notify us as soon as possible if you believe your account security or related information or device has been breached.

If you are visiting the Services from a location outside of the United States, your connection will be through and to servers located in the United States. By using the Services, you consent to the transfer of personal data to the United States and its storage and use as specified herein.

How long do we retain information?

We retain personal information for the length of time necessary to fulfill the purposes outlined in this Privacy Policy, unless a different retention period is requested by you or required or permitted by law. For example, we will retain your personal information for as long as it is needed to provide you with the Services or fulfill a legal or contractual obligation. We may also aggregate, deidentify, or anonymize personal information as applicable for use in analytics.

We use the following criteria to determine how long we retain personal information: (a) our relationship with you, such as if there is an open contract or account or a pending transaction or request; (b) legal obligations to retain personal information for certain purposes, such as to maintain transaction records; and (c) other obligations or considerations relating to the retention of data, such as contract requirements, litigation holds, investigations, or statutes of limitation. For more information about our retention policy for ALPR data specifically, please see above.

What are your privacy rights?

Although we are a small business that does not necessarily fall under certain privacy laws, we value consumer privacy rights and strive to provide flexibility with how your personal data is used and 8 disclosed. If you want to make a privacy request or have any questions, please contact us as outlined below with your name and email address or other identifier used in connection with our Services so that we can verify your request. You can make a privacy request to us by yourself or through your authorized agent; if an authorized agent is making a request on your behalf, the agent should provide its name and contact information, such as an email address, in addition to your information. There may be situations where we cannot grant your request; for example, if you make a request and we cannot verify your identity, or if you request deletion of data that we have a legal obligation to keep. Where we deny your request, we will take steps to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

Applicable privacy laws have different requirements and depend on various factors, such as where you live and the data at issue. If applicable, the following privacy rights may apply to you.

• Access. You can access and obtain your data and ask us for certain information, including: the categories of personal information collected and used; the categories of the sources of data; the business or commercial purposes for collecting, selling, or sharing data if applicable; the categories of third parties to whom data is disclosed; and the specific pieces of personal information collected. You also have a similar right to data portability.
• Amend. You can amend, correct, or rectify your data if it is inaccurate.
• Delete. You can have your data deleted subject to certain legal limitations.
• Limit. You can limit the processing of your data, in particular any sensitive data, and limit use of automated decision making, such as profiling if applicable.
• Opt-Out. You have the right to opt-out of certain data practices. For example, you can unsubscribe from marketing communications (if any) by following the opt-out instructions in each message or by contacting us. You may also opt out of certain practices if applicable.
• Complaints. You have the right to make certain complaints, including for privacy concerns. We value your feedback and seek the opportunity to work with you on any issues. You have the right to no discrimination for asserting your privacy rights.
• Specific Laws. Several states have enacted privacy laws that may apply to you, depending on the circumstances. Although our small business in the U.S. may not be covered by certain laws, we strive to inform you of your general rights. For example, the CCPA may apply to certain California residents, and there are privacy laws existing in other states. For more information about our privacy practices pursuant to these laws, please see the information throughout this Privacy Policy about the categories of data collected, the categories of sources for data, the purposes for such collection, and how we use and disclose personal information. Under California’s “Shine the Light” law, California residents may also request certain information regarding the sharing of personal information with third parties for their direct marketing purposes if applicable. Further, while our Services are designed for the U.S., residents of other countries have privacy rights, such as the right to access information; to ask that information be corrected, updated, or erased; and the right to object to, or request restriction of certain processing. Our legal basis for collecting and using your personal data is your consent, the fulfillment of our obligations pursuant to a contract, or where the collection and use is in our legitimate interests.

Do we collect information about children?

We do not knowingly collect personal information from children under the age of 13. Our Services are designed for adults. Our privacy practices are designed to fall outside of or otherwise comply with the Children's Online Privacy Protection Act (COPPA) and related laws

How do we use or disclose sensitive information?

We do not generally use or disclose “sensitive” personal information aside from with your consent, which may be given by entering or using a parking facility, using our website/app, or applying for a job, nor do we use sensitive information for purposes other than as reasonably necessary and proportionate to the use: (a) to perform certain services, such as verifying information or for analytics; (b) to verify or maintain the quality or safety of our Services; (c) to perform services or provide goods reasonably expected; (d) for short-term use where there is no disclosure or profiling; and/or (e) to resist malicious, fraudulent, or illegal actions or to ensure physical safety.

Do we respond to DNT Signals?

No, our website does not respond to DNT (short for Do Not Track) requests. DNT is a feature that, when enabled, sends a signal to websites to request that your browsing not be tracked.

How do we update this Privacy Policy?

We will update this Privacy Policy when our privacy practices or laws change or as otherwise required or permitted by applicable law. Each time you use the Services, the current version of this Privacy Policy will apply. Unless we receive your express consent, any materially revised Privacy Policy will apply only to information collected after the effective date of the revised Privacy Policy. You should review any updates. If you do not consent, you should cease using the Services.

How can you contact us?

Please contact us with any questions or concerns! We can be reached at: info@parksmartinc.com.

ParkSmart, Inc.
1630 North Main Street #372
Walnut Creek, CA 94596

Last Updated: February 3, 2025