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FlashParking, Inc. (“Company,” “We” or “Us”) respects your privacy and is committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide to us through services accessible via www.FlashParking.com or any other website, IP address, social media account, iOS app, Android app, web app or other online product and service offered by FlashParking (collectively, the “Service”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect through the Service and in email, text, and other electronic messages between you and the Service.
It does not apply to information collected by us offline or through any other means, including on any other website operated by us or any third party or by any third party that may link to or be accessible from or on the Service.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:
In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number and other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, social security number, physical characteristics or description, address and telephone number.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law
Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability or sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).
D. Commercial information
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F. Geolocation data
We collect this information:
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (e.g., behavioral tracking).
The information we collect automatically is only statistical data. It helps us to improve the Service and to deliver a better and more personalized service, including by enabling us to:
Information We Collect Through Our App or Social Media
To enable our push notification and other mobile communication services, we may collect and store device IDs to identify each unique mobile device that registers for our service, including for example, device tokens from iOS devices, Live IDs from Windows devices, and other similar identifications from devices running on other platforms. These IDs cannot be tracked back to you, but are tied to a specific device which may only be used by one person. We may collect information including location-related information, internet protocol addresses, mobile device models, carrier information, the operating system of your mobile devices and other non-personally identifiable information.
Information You Provide to Us
If you contact us on or through the Service, the information we collect may include personal information such as name, e-mail address, telephone number, and any other information you provide to us, including records and copies of your correspondence.
We use information that we collect about you or that you provide to us, including any personal information, to:
In addition, we use the User-ID feature of Google Analytics to help us enhance your user experience. User-ID lets us associate a persistent ID for you with your engagement data from one or more sessions initiated from one or more devices. This ability to connect your contacts with us into a single thread also provides us with a more unified, holistic story about your relationship with our business. We will use information received through our use of User-ID in the manner described above. If you would like to opt-out of our use of this service, you may do so by following the instructions found under “Updating Personal Information” below.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may also disclose your personal information:
In the preceding twelve (12) months, Company has not disclosed or sold personal information.
With respect to your use of the mobile application portion of our Service (the “App”), the App may collect certain information automatically, such as the type of mobile device you use, the temporary or persistent unique device identifiers (sometimes called UDID) placed by us or our service providers, the unique identifier assigned by us to your device, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the App.
Additionally, the App collects precise information about the location of your device. You must first provide permission through your device before our App obtains such location information from technologies like GPS, Wi-Fi, or cell tower proximity (or a combination of these technologies). We, and our service providers, may use and store this information, in combination with other location-based information such as the IP address and billing or postal code provided by you at time of your App registration, to provide enhanced location based services, such as store specific services, search results, and other content. You can stop all collection of information by the App easily by uninstalling the App. Also, you may at any time opt-out from further allowing us to have access to your location data by adjusting the permissions in your mobile device.
The technologies we use for this automatic data collection may include:
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features of our Service.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from the Service is at your own risk. You should only access the Service within a secure environment.
Parents should always supervise their children while online. The Service is not designed nor intended to collect personal information from children under the age of thirteen. So that we may comply with the Children’s Online Privacy Protection Act, we ask that children under the age of thirteen not provide any personal information through the Service. If a child under the age of thirteen has provided us with personal information, we ask that a parent or guardian contact us at the email address provided below.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to object to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data protection/bodies/authorities/index_en.htm
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request through the contact information provided below. We will respond to your request within 30 days.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features of the Service.
If you are located in the European Union, your personal information will be transferred to and processed by our personnel located in the United States under the terms of the EU Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC. Please contact us through the contact information provided below if you would like to see a copy of the model contracts.
This Section 12 applies to applies to all visitors, users, and others who reside in the State of California and is adopted to comply with laws governing residents of the State of California, including the CCPA. This Section does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will disclose to you:
o sales, identifying the personal information categories that each category of recipient purchased; and
o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent please e-mail us at the email address provided below and provide your name and phone number as well as the authorized agents’ name and contact information (phone number or email address) and let us know what the scope of the authorized agents’ rights are to act on your behalf. If your authorized agent requests sensitive information about you then we may ask you to provide us with a sworn declaration to further verify your identity.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We attempt to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unreasonable. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out Rights
Because we do not sell personal information and we state in this policy that we do not sell personal information, pursuant to the CCPA we do not need to post a notice providing California residents with the right to opt-out of the sale of personal information.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
“Shine the Light” Law
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
Automated License Plate Recognition Law
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.
We engage third party independent contractors to install and maintain ALPR systems for our clients. Our VP of Operations and VP of Software Engineering and the technology/operations team reporting to the VP of Operations or VP of Engineering may, under certain circumstances, be able to access ALPR information. The parking operators in properties that contract our Services also have access to ALPR system.
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.
We do not sell, share or transfer any ALPR information in our possession.
Our VP of Software Engineering is responsible for the oversight and implementation of our ALPR compliance.
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.
ALPR information will be retained 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.
Last updated: August 24, 2020