PRIVACY POLICY

Effective as of July 2023

1. Introduction

PARKIMETER conducts business in several countries. In this privacy policy (the “Privacy Policy”), the terms “PARKIMETER”, “we” and “us” refer to the local group company Parkimeter Technologies, SLU which provides PARKIMETER parking and related services, including subscriptions and pay-per-use services (the “Services”).

In this Privacy Policy, we explain which categories of personal data PARKIMETER collects, why PARKIMETER collects such data, and what PARKIMETER uses the personal data for in connection with the Services, PARKIMETER's mobile application (the “Application”) or PARKIMETER's website (the “Website”). This in order for you to be able to exercise your rights.

PARKIMETER processes personal data in accordance with applicable data protection law. PARKIMETER is the controller for the processing of personal data described in this Privacy Policy.

Personal data is all such information that may be used to identify a specific individual (a natural person).

PARKIMETER provides the Services to both consumer customers (B2C) as well as business customers whose employees are users of the Services (B2B). This Privacy Policy applies to both types of customers.

2. Sources of personal data

Personal data collected from you

The personal data that may be processed consists primarily of such data that you, directly or indirectly, provide to PARKIMETER. For example, PARKIMETER collects your personal data when you:

Personal data collected from Credit Reporting Agencies

If you apply to pay by invoice, we will collect a person/credit report from credit reporting agencies.

3. Purposes and legal grounds for the processing of personal data

PARKIMETER processes personal data for the following purposes and on the basis of the following legal grounds. The tables below also provide information on what categories of personal data we process as well as storage periods.

Provision of Services

PARKIMETER processes your personal data in order to provide the Services.

Personal Data
Legal basis for the processing

Agreement. When you initiate an account registration with PARKIMETER, PARKIMETER will process personal data in order to take steps at your request prior to entering into an agreement with you (i.e. the terms of the Services).

When you use our Services and receive service-related messages, PARKIMETER will process personal data in order for PARKIMETER to fulfil its obligations to you in accordance with the terms of the Services. Moreover, if you have signed up for Automatic CameraPark, which consists of an Automatic Number Plate Recognition (also called the ANPR), a camera will read your vehicle registration number in order to start and end your parking. This processing of personal data is necessary in order for PARKIMETER to fulfil its obligations to you in accordance with the terms of the Services.

Additionally, if you choose our electric vehicle charging service, we will process personal data in order to provide this Service. This processing is necessary in order for PARKIMETER to fulfil its obligations to you in accordance with the terms of the Services.

If you are using the Services through your employer who is a business customer of PARKIMETER, we will process your personal data on the basis of our legitimate interest to fulfil our obligations to our business customer pursuant to our agreement with such customer. This includes any service-related messages that we may send to you.

If you are paying by invoice, your personal identification number is processed in order to ensure a secure identification of you.

If you apply to pay by invoice, we will also process your personal data in order to conduct a credit assessment, on the basis of our legitimate interest to check that there are financial prerequisites for approving this payment method.

The processing of location data is based – if the processing is not necessary for the Service in question – on your consent, which you give to us by activating location data in the Application on your mobile phone. You can withdraw your consent to PARKIMETER's collecting, using and sharing of such location data at any time. You can do so by turning off the function "allow access to location data" in your mobile phone.

Processing period

We will retain your personal data only for as long as is necessary for the purposes for which the personal data was collected, or as long as is required pursuant to law.

If you do not use our pay-per-use Services for more than 18 months, we will keep your account archived as inactive for 24 months from your last pay-per-use transaction, in the event that you wish to use our Services again in the future and thereby easily re-activate your account. Thereafter, we will remove or anonymize your account data except for information that we are obliged to keep pursuant to law or for our legitimate interest for defending, establishing or exercising any legal claims, in line with this Privacy Policy.

If you have a subscription, personal data will be retained for the duration of the subscription and after the termination of the subscription to the extent required pursuant to law, in accordance with this Privacy Policy. Thereafter, personal data will be removed or anonymized.

If you wish to terminate your account, please contact customer support. Upon termination, we will remove or anonymize your personal information, including your parking history data, without undue delay except for information that we are obliged to keep pursuant to law.

If you are a business customer user, your registered parking actions will be removed or anonymized twelve (12) months after the respective parking action, except for information that we are obliged to keep pursuant to law.

Personal data may be retained longer in cases where such retention is necessary due to law, or where it is used in relation to a legal claim, as stated in this Privacy Policy.

Marketing Communication and Offers

PARKIMETER processes your personal data in order to communicate with you regarding the Services, and to send you offers regarding PARKIMETER's services and products. Pursuant to Law 34/2002, of 11 July, on information society services and electronic commerce we may send our existing customers electronic marketing of our own products and services, that are similar to those initially contracted with the customer, on the basis of our legitimate interest to promote our business.

In the event that PARKIMETER enters into a collaboration or partnership that would entail sending marketing regarding such collaboration or partnership with third parties to you, we will ensure to obtain your consent to such marketing beforehand.

You have the right to unsubscribe from our mailing list at any time by following the instructions contained in the e-mail communication. If push notifications are available and, you no longer wish to receive push notifications in the Application, you may change your settings directly in the Application. You have the right to unsubscribe from SMS communications, if any, by following the instructions contained in the SMS communications.

PARKIMETER ensures that marketing directly targeting you complies with applicable laws, regulations, codes of conduct and ethical guidelines regarding marketing. PARKIMETER will only send marketing communication to you within 18 months from your last parking transaction or for as long as you have an active subscription, to the extent you have not previously opted out of such communication. If you have accounts for social media, you may see marketing from PARKIMETER.

PARKIMETER may use social media plugins on the Website in order to promote its communication channels. PARKIMETER is a joint controller with the respective third party to the extent that the plugins request content from the third party and transmits personal data to the third party. You can access these social media services using the corresponding icons wherever they appear on the Website. When you access these third-party websites and leave PARKIMETER's Website, the respective third parties are controllers for any personal data processing that occurs on such websites.

Personal Data
Legal basis for the processing

Legitimate interest. The processing of personal data is necessary in order to satisfy PARKIMETER's legitimate interest of communicating with you regarding the Services and giving you offers.

Some processing of personal data that occurs via cookies in accordance with our Cookie Policy is carried out for the purpose of displaying relevant advertising. This processing is based on your consent, pursuant to the Cookie Policy, as available on the Website.

Processing period

Personal data is processed during the customer relationship, e.g. for as long as you have an active subscription, an actively use our pay-per-use Services, or since the customer starts using the prebooking services and the booking has been confirmed and terminated.

If you have not used the pay-per-use Services for more than 18 months, or if you have terminated your subscription, PARKIMETER will no longer actively send you marketing communications or offers, to the extent you have not previously opted out of such communication but will keep your account archived and will send service-related messages when necessary.

The retention period for the relevant cookie-related information is stated in our Cookie Policy.

Conducting surveys

PARKIMETER processes your personal data in order to conduct surveys regarding PARKIMETER, the Application and the Services, for example by asking for feedback and reviews through the Application, by SMS or e-mail. Please bear in mind that you should not share personal data when you write your feedback in free-text fields. In the event that this is unavoidable, please do not share more personal data than what is necessary to provide the feedback you wish to provide.

Personal Data
Legal basis for the processing

Legitimate interest. The processing of personal data is necessary in order to satisfy PARKIMETER's legitimate interest of conducting surveys.

Processing period

The personal data is processed for this purpose during a period of three (3) months calculated from the time of the survey. Reports on a general level that do not contain personal data may be retained until further notice.

Follow-up and evaluation

PARKIMETER processes your personal data in order to create different reports and statistics in order to follow-up and evaluate the Services and our interactions with you.

Personal Data
Legal basis for the processing

Legitimate interest. The processing of personal data is necessary in order to satisfy PARKIMETER's legitimate interest to follow-up and evaluate our Services, the Website and the Application, and interactions with you.

Processing period

Personal data processed for this purpose will be retained for as long as necessary to fulfil the purpose of conducting follow-up and evaluation through e.g. reports and creating statistics on an aggregated level. Such statistics do not contain any personal data and will generally be retained until further notice.

Handling requests and customer service matters

PARKIMETER processes personal data in order to handle your requests in different channels, e.g. when you contact our customer service.

Consumer customer

Personal Data
Legal basis for the processing

Legitimate interest. The processing of personal data is necessary in order to satisfy PARKIMETER 's legitimate interest to handle your requests and provide customer service.

Processing period

The personal data is retained for this purpose during a period of six (6) months calculated from the time of the communication. Personal data in our customer service management system is anonymized thereafter and e-mail communication is deleted.

Personal data may be retained longer in cases where such retention is necessary due to law, or where it is used in relation to a legal claim, as stated in this Privacy Policy.

Business customer

Personal Data
Legal basis for the processing

Legitimate interest. The processing of personal data is necessary in order to satisfy PARKIMETER 's legitimate interest to handle your requests.

Processing period

The personal data is retained for this purpose during a period of six (6) months calculated from the time of the communication. E-mail communication is anonymized thereafter.

Personal data may be retained longer in cases where such retention is necessary due to law, or where it is used in relation to a legal claim, as stated in this Privacy Policy.

Compliance with legal obligations

PARKIMETER processes personal data in order to fulfil legal obligations relevant to PARKIMETER, e.g. accounting obligations.

Personal Data
Legal basis for the processing

Legal obligation. The processing of personal data is necessary in order for PARKIMETER to fulfil its legal obligations according to law or other regulations, such as the Spanish Commercial Code.

Processing period

The personal data is retained for such period as is necessary in order to comply with each legal obligation.

Establishment, exercise and defense of legal claims

PARKIMETER processes personal data in order to establish, exercise and defend legal claims, e.g. in connection with a dispute or judicial process.

Personal Data
Legal basis for the processing

Legitimate interest. The processing of personal data is necessary in order to satisfy PARKIMETER's legitimate interest to establish, exercise and defend legal claims.

The personal identification number is processed in order to ensure a secure identification of you.

Processing period

The personal data is retained for this purpose during the consumer customer relationship and during the necessary periods in order to comply with the relevant legal obligations and blocked for a period of 10 years thereafter in order to satisfy PARKIMETER's legitimate interest of defending, establishing or exercising any legal claims.

Maintenance, protection and development of the Services

PARKIMETER processes personal data in order to maintain, protect and develop the Services, the Application and Website included, e.g. to log, develop, test and improve our Services.

Personal Data
Legal basis for the processing

Legitimate interest. The processing of personal data is necessary in order to satisfy PARKIMETER's legitimate interest to maintain, protect and develop the Services and the Application.

The personal identification number is processed in order to ensure a secure identification of you.

Some processing of personal data that occurs via cookies in accordance with our Cookie Policy available on the Website is carried out for the purpose of ensuring the performance and functionality of the Website and to detect errors. The personal data processing for this purpose occurs on the basis of our legitimate interest to ensure the functionality and performance of the Website through the processing of personal data such as technical data.

Processing period

The personal data is retained for this purpose of maintenance and protection of the Services during the consumer and business customer relationship respectively. For development of the Services, personal data is only used in order to be anonymized for the purpose of using the data in PARKIMETER's test environment.

4. Security

PARKIMETER takes the matter of security of your personal data very seriously. PARKIMETER implements appropriate technical and organisational measures to protect your personal data from unauthorised access, alteration or destruction. Access to information is limited in various ways (e.g. by user authorisation and passwords being required, which are only assigned to employees who need access to such information to be able to perform their work duties). Other security measures include encryption, firewalls and physical limitations and restrictions when accessing buildings and files.

5. Recipients of personal data

PARKIMETER shares personal data collected with the following recipients for the following purposes. The receiver is the data controller for its own processing of the personal data we share with them, unless otherwise stated below.

Parking operators

We share data with parking operators in order to provide the Services, as well as for them to be able to carry out enforcement control of ongoing parking and verify parking carried out in their areas. The parking operator may also handle anonymized location data for statistical purposes.

Enforcement control and verification of parking

Personal Data
Legal basis for the processing

Legitimate interest. The processing of personal data is necessary in order to satisfy PARKIMETER's legitimate interest to fulfil the agreement with the relevant parking operators and parking operator's interest to check ongoing parking and to verify parking carried out in their areas.

Provision of Services

If you park in a garage, your registration number or the unique ID of the RFID card is shared between us and the parking operator in order to start and stop parking at PARKIMETER.

Personal Data
Legal basis for the processing

Agreement. The processing is necessary in order to for PARKIMETER to fulfil its obligations to you in accordance with the terms and conditions of the Services.

Payment receiver and payment service provider

If payment is made through e.g. card or digital payment methods (e.g. ApplePay and MobilePay), we only share the invoice number, booking id or ticket id and amount in order to complete the payment.

Personal Data
Legal basis for the processing

Agreement. The processing is necessary in order to for PARKIMETER to fulfil its obligations to you in accordance with the terms and conditions of the Services.

PARKIMETER Group companies

PARKIMETER 's technical platform may be provided, time to time, by the group company in Sweden to which personal data may be transferred in order for PARKIMETER to be able to provide the Services to you.

All group companies have entered into an internal data protection agreement which purpose is to protect your personal data when it is transferred within the group of companies.

Service providers

In order to fulfil the purpose of the processing of your personal data, PARKIMETER can share personal data with service providers. These service providers provide, among other, the following services to PARKIMETER: information services, phone services (PSMS), support services and IT services, such as marketing, support, operation, improvement, development and services for handling mailings and produce cards. These service providers are only allowed to process your personal data in accordance with PARKIMETER's explicit instructions and cannot use your data for their own purposes. They are also obliged to protect your data according to law and agreements.

Other recipients

In addition to the recipients mentioned above, PARKIMETER can, if necessary, share your personal data with the following recipients:

Public authorities
Purpose

We share your personal data with authorities to comply with legal obligations, or to establish, exercise or defend legal claims or to cooperate with authorities.

Legal basis for the sharing

The processing is necessary to fulfil legal obligations or for the legitimate interests of PARKIMETER. Specifically, such legitimate interests are to establish, exercise or defend legal claims or to cooperate with authorities.

Courts, external advisors and counterparties
Purpose

In case of a dispute, we may transfer data to other parties in order to establish, exercise or defend legal claims.

Legal basis for the sharing

The processing is necessary in order to satisfy our legitimate interest to establish, exercise and defend legal claims.

Law enforcement agencies, e.g. the Police
Purpose

We may share personal data with law enforcement agencies, e.g. the Police if we have a legal obligation to share your personal data or in order to contribute to an ongoing criminal investigation or to establish, exercise or defend legal claims.

Legal basis for the sharing

The processing is necessary in order to fulfil legal obligations or to satisfy our legitimate interest to contribute to an ongoing criminal investigation upon request or to establish, exercise or defend legal claims.

Potential buyers and sellers as well as their external counsel or advisors
Purpose

We may share information with potential buyers and sellers if we would transfer all or parts of our business or conduct a merger.

Legal basis for the sharing

The processing is necessary in order to satisfy our legitimate interest to carry out an acquisition or merger.

6. Where is my personal data stored?

To the extent PARKIMETER processes your personal data the data is stored on servers within the EU. We may transfer personal data to third parties who may be established or otherwise process personal data outside the European Union/European Economic Area (“EU/EEA”) in situations where our service providers are located outside the EU/EEA. In such cases, we will ensure that any such transfers comply with applicable data protection laws, including applying appropriate safeguards such as the EU Commission Standard Contractual Clauses and supplementary measures, as necessary. You have the right to request information regarding transfers outside the EU/EEA and a copy of the safeguards taken by PARKIMETER in order to protect your personal data. To do this, please use the contact details listed at the end of this Privacy Policy.

7. Cookies

PARKIMETER uses cookies to optimise the Services, to perform statistic evaluations, for analyses, and for marketing. A cookie is a text file stored on, for example your computer or mobile device, which enables identification of your computer or mobile phone. Cookies help PARKIMETER to adjust, for example, the Application and the Website based on your requests as a user of PARKIMETER's Services and the Website. See further information in our Cookie Policy available on the Website.

8. Your rights

Pursuant to applicable data protection legislation, you have a number of rights relating to the processing of your personal data. In order to exercise your rights, please contact PARKIMETER's customer service. See contact details below.

Right of access

You have the right to request to receive a confirmation from us on whether we process personal data which relate to you, and request access to the personal data we process that relate to you. Some of the data we store about you are available by logging in to your personal account in the Application and on the Website. A copy of your data can be requested through our customer service.

Right to rectification

If your personal data processed by PARKIMETER is inaccurate or inadequate you have the right to request that PARKIMETER corrects the personal data. You can correct some personal data by logging in to your personal account in the Application or on the Website.

Right to object to direct marketing

You have the absolute right to, at any time, object to PARKIMETER's processing of your personal data in terms of direct marketing and de-register from future marketing communications. To do so, please contact customer service through the contact details below.

Right to object to processing based on our legitimate interest

You have the right to object to processing based on our legitimate interest for reasons relating to your particular situation. We may continue to process your personal data, even if you have opposed to the processing, if we have compelling legitimate grounds that overrides your privacy interest.

Right to erasure ("the right to be forgotten")

Under some circumstances, you have the right to have your personal data erased, e.g. if you have objected to the processing and PARKIMETER does not have any compelling legitimate grounds for the processing to continue processing the data. This does not apply if we, for example, are required under law to store the data.

Right to request restriction of processing

Under certain circumstances, you have the right to request restriction of the processing of your personal data. If you request restriction, PARKIMETER may not be able to fulfil its obligations to you during the period when any such restriction is in place.

Data portability

Finally, you have the right to receive a copy of the personal data concerning you in a structured format and, if technically feasible, transfer the data to someone else (data portability). The right to data portability, compared to the right to access, only includes data that you have provided yourself and which we process based on certain legal grounds, e.g. the agreement with you (the terms of the Services).

Withdrawal of consent

Where a processing is carried out on the basis of your consent, you have the right to withdraw your consent at any time. To do so, please contact us via the contact details stated below. Please note that your withdrawal of consent does not affect the validity of the processing that occurred before the withdrawal.

Complaints

If you should have any complaints on PARKIMETER's processing of personal data, please do not hesitate to reach out to us so we can look into it. You also have a right to lodge a complaint with a supervisory authority. The supervisory authority in Spain is the Spanish Data Protection Authority (Sw. Agencia Española de Protección de Datos). You can find their contact information here: https://www.aepd.es//.

9. Amendments to PARKIMETER's Privacy Policy

PARKIMETER may amend the Privacy Policy from time to time. If any amendments are made to PARKIMETER's Privacy Policy which imply any amendment to the way PARKIMETER processes your personal data, e.g. collecting additional personal data for the stated purposes or processing of data for new purposes, PARKIMETER will inform you of such amendments via, for example, the Website, the Application or by email. PARKIMETER recommends that you regularly read PARKIMETER's Privacy Policy for the most recent information on how PARKIMETER processes your personal data.

10. Contact information

Should you have questions or comments regarding PARKIMETER's Privacy Policy, please contact PARKIMETER's at:

When you contact us to exercise your rights, please state your full name and provide contact details through which we can reach you. Please note that we may need to verify your identity before we proceed with your request.

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