California Civil Code Section 1798.90.51, titled “Collection of License Plate Information,” requires automated license plate recognition (“ALPR”) providers implement a usage and privacy policy with respect to the collection, use, maintenance, sharing, and dissemination of ALPR information. Although we primarily sell equipment or offer services with respect to ALPR systems, the following information is presented in the event, and to the extent, we operate an ALPR system in California:

1. The purpose for using the ALPR system and collecting ALPR information.

We may use an ALPR system in connection with our Services to track ingress and egress of vehicles into and out of properties that use our Services.

2. Access to the ALPR System:

We engage third-party independent contractors to install and maintain ALPR systems for our clients. Our Chief Technology Officer and the technology/product team reporting to them may, under certain circumstances, be able to access ALPR information. The parking operators in properties that contract our Services also have access to the ALPR system.

3. Monitoring for Security and Compliance with Applicable Privacy Laws:

We have taken all reasonable steps to safeguard the information technology systems utilized in the operation of our business, including the implementation of procedures to ensure that our systems are free from any disabling codes or other software routines or hardware components that would permit unauthorized access by a third party.

4. Restrictions on the Sale, Sharing or Transfer of ALPR Data:

ALPR information in our possession may be shared in accordance with this policy with our parking owners and operator customers for parking transactional purposes and to provide consumer motorists with the parking product or service requested. ALPR information may be shared with third party vendors of our customers in accordance with this policy and a Data Protection Agreement. In states where collection is permitted for unpaid parking citations, we may also share parking violation information with a third party collection agency.

5. Responsible Personnel:

Our Chief Technology Officer and the technology/product team reporting to them are responsible for the oversight and implementation of our ALPR compliance.

6. Information regarding ALPR Information accuracy and corrections:

Flash can review ALPR information captured by ALPR systems for accuracy. When requested by the end user to verify ALPR information in our possession, we will take reasonable measures to do so and to confirm such information and, if inaccurate, correct such information.

7. Retention of ALPR Information

ALPR information will be retained in accordance with our Privacy Policy and as long as required to verify the legitimacy of charges incurred in our facilities per parking operator auditors unless a shorter time is required by applicable law.