PRIVACY POLICY

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

This policy is designed to comply with:

• Canada: The Personal Information Protection and Electronic Documents Act (PIPEDA) and the Alberta Personal Information Protection Act (PIPA).
• United States: The California Consumer Privacy Act (CCPA/CPRA), and other applicable state privacy statutes (e.g., Virginia, Colorado).
• European Union/UK: The General Data Protection Regulation (GDPR).

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

If the Company is involved in a merger, acquisition, or asset sale in which Your Personal Data may be transferred. Following the close of that business transaction, Your Personal Data may be transferred and become subject to a different Privacy Policy.

INTERPRETATION AND DEFINITIONS

INTERPRETATION

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

DEFINITIONS

For the purposes of this Privacy Policy:

COLLECTING AND USING YOUR PERSONAL DATA

TYPES OF DATA COLLECTED

PERSONAL DATA

While using Our Service, we may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, City, ZIP/ Postal Code
• Bank account information in order to pay for products and/or services within the Service
• Usage Data

When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:

• Date of birth
• Passport, Birth Certificate or National ID card
• Bank card statement
• Other information linking You to an address

USAGE DATA

Usage Data is collected automatically when using the Service.
information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

TRACKING TECHNOLOGIES AND COOKIES

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies here: All About Cookies by TermsFeed.

We use both Session and Persistent Cookies for the purposes set out below:

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

USE OF YOUR PERSONAL DATA

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

To manage Your Account: To manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionspanties of the Service that are available to You as a registered user.

For the performance of a contract: The development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news,other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

WE MAY SHARE YOUR PERSONAL INFORMATION IN THE FOLLOWING SITUATIONS

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.

For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a ThirdParty Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

With Your consent: We may disclose Your personal information for any other purpose with Your consent.

RETENTION OF YOUR PERSONAL DATA

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

TRANSFER OF YOUR PERSONAL DATA

Your information, including Personal Data, is processed on cloud and in any other places where the parties involved in the processing are located. It means that this information may be transferred to - and maintained on - the cloud.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

DISCLOSURE OF YOUR PERSONAL DATA

BUSINESS TRANSACTIONS

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

LAW ENFORCEMENT

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation.
• Protect and defend the rights or property of the Company.
• Prevent or investigate possible wrongdoing in connection with the Service.
• Protect the personal safety of Users of the Service or the public.
• Protect against legal liability.

SECURITY OF YOUR PERSONAL DATA

The security of Your Personal Data is important to Us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

DETAILED INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

ANALYTICS

We may use third-party Service providers to monitor and analyze the use of our Service.

PAYMENTS

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.

PRIVACY & THIRD-PARTY SERVICE PROVIDERS

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

1. Under GDPR (Data Processors): For the purposes of the GDPR, these Service Providers are "Data Processors" who process Personal Data only on Our documented instructions and are subject to a duty of confidentiality.
2. Under Canadian Law (PIPEDA & Law 25): For the purposes of the Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial laws:
   • Accountability: We remain responsible for Your Personal Information even when it is in the custody of a third-party Service Provider. We use contractual and other means to ensure that these providers provide a comparable level of protection to that which We are required to provide.
   • Foreign Transfers (Cross-Border): You acknowledge that some of our Service Providers may be located outside of Canada (including in the United States). While Your information is in another jurisdiction, it may be accessed by the courts, law enforcement, and national security authorities of that jurisdiction.
   • Privacy Impact Assessments (Quebec): For residents of Quebec, in accordance with Law 25, We conduct a Privacy Impact Assessment (PIA) before communicating Your personal information outside of the province to ensure the receiving jurisdiction provides adequate protection.
   • Service Provider Obligations: Our Service Providers are contractually prohibited from using Your Personal Information for any purpose other than to perform the specific services We have hired them for.

LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GDPR

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.

Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

YOUR RIGHTS UNDER THE GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.

Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

EXERCISING OF YOUR GDPR DATA PROTECTION RIGHTS

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA PRIVACY

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

FOR CANADIAN RESIDENTS

In addition to the rights described in our general Privacy Policy, residents of Canada are entitled to specific protections under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial legislation, including Quebec's Law 25, Alberta's PIPA, and British Columbia's PIPA.

• Accountability: We are responsible for personal information under our control and have designated a Privacy Officer to ensure compliance with these Terms.
• Meaningful Consent: By using SecurePark Tech Ltd., you provide meaningful consent to the collection and use of your data for the purposes identified at the time of collection. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.
• Transparency and Openness: We make specific information about our policies and practices relating to the management of personal information readily available to you.
• Cross-Border Transfers: Your personal information may be stored or processed outside of Canada (including in the United States). While in another jurisdiction, it may be accessed by local law enforcement or national security authorities under the laws of that country.
• Quebec Rights (Law 25): Residents of Quebec have enhanced rights, including the right to data portability, the right to de-indexing (requesting that your info not be linked to your name in search results), and the right to be informed of automated decision-making.

Categories of Personal Information Collected

For American Residents

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

For Canadian Residents (PIPEDA & Law 25)

In accordance with Canadian federal and provincial privacy laws, we collect "Personal Information," which includes any factual or subjective information about an identifiable individual. In the last twelve (12) months, we have collected the following types of information from Canadian users:

• Identifiers and Contact Information: Name, alias, postal address, unique personal identifier, online identifier, IP address, email address, or other similar identifiers.
• Technical and Usage Data: Information regarding your interaction with our Service, including device type, operating system, and browsing history.
• Geolocation Data: Precise physical location or movements, particularly as it relates to parking and enforcement services.
• Commercial Information: Records of services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Professional or Employment-Related Information: If you use our Service in a professional capacity, we may collect your business contact information.
• Sensitive Personal Information (Quebec): For residents of Quebec, we identify Geolocation Data and Financial/Payment Information as sensitive categories that receive enhanced protection and require express consent.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected.

For Canadian Residents (PIPEDA & Law 25): In addition to the CCPA standards above, the Company adheres to the following Canadian statutory requirements:

1. Identifying Purposes: In accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), we only collect personal information that is necessary for the identified purposes disclosed to you at or before the time of collection.
2. Limiting Collection: We do not collect personal information indiscriminately. The categories listed are intended to be transparent about potential data points; however, we limit the collection of your personal information to that which is necessary for the purposes we have identified (e.g., parking enforcement, payment processing, or account management).
3. Direct Collection and Consent: For residents of Quebec, under Law 25, we collect personal information directly from the "person concerned" unless you have consented to collection from third parties or such collection is permitted by law. Any information collected via technology that identifies, locates, or profiles you is subject to your express opt-in consent and is deactivated by default where required by law.
4. Actual Collection: Certain categories of personal information are only collected if You provide such information directly to Us or if your use of the Service necessitates such collection (e.g., your license plate for parking verification).

• Publicly available information from government records
• Deidentified or aggregated consumer information
Information excluded from the CCPA's scope, such as:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994'.

Under Canadian Privacy Laws (PIPEDA, PIPA, and Law 25), personal information does not include: Canadian Standard: Information that is "publicly available" as defined by the Regulations Specifying Publicly Available Information. This is strictly limited to:
• Information in telephone and professional directories (where the user has not opted out).
• Personal information appearing in a registry collected under statutory authority (e.g., land titles, corporate registries) where the use relates directly to the purpose of the registry.
• Records of judicial or quasi-judicial bodies (court records).
• Note: Information simply "available on the internet" (like social media) is NOT automatically considered "publicly available" in Canada.
• Information that is Anonymized or De-identified:
• Anonymized (Quebec): Information that no longer allows the person concerned to be identified, directly or indirectly, in an irreversible manner.
• De-identified (PIPEDA): Information that no longer allows an individual to be identified directly, but where a residual risk of re-identification exists.
• Canadian Personal Health Information Protection Act (PHIPA) and provincial health privacy statutes (e.g., Alberta's Health Information Act).
• Financial & Credit Data: Covered by the Canadian Bank Act and provincial Consumer Reporting Acts.
• Driver Data: Covered by the provincial motor vehicle acts (e.g., Ontario's Highway Traffic Act) regarding the protection of driver and vehicle registry information.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from You.
For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.

Indirectly from You.
For example, from observing Your activity on our Service.

Automatically from You.
For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.

From Service Providers.
For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes (American Standards):

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

• To operate our Service and provide You with our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Use of personal information (Canadian standards)

We collect, use, and disclose Personal Information only for purposes that a reasonable person would consider appropriate in the circumstances. In accordance with PIPEDA and Quebec's Law 25, these "Identified Purposes" include:

• To operate, maintain, and provide the core functions of the Service (e.g., managing parking sessions, verifying permits, and facilitating vehicle recognition).
• To respond to Your inquiries, provide technical support, and investigate concerns regarding Your account or parking transactions.
• To fulfill the specific reason You provided the information, such as processing payments, issuing digital receipts, or validating parking eligibility.
• To detect security incidents, verify identity, and protect against malicious, deceptive, fraudulent, or illegal activity. This includes protecting the integrity of our parking enforcement systems.
• To comply with Canadian federal and provincial laws, respond to lawful requests by public authorities (including for national security or law enforcement requirements), or comply with a court order or subpoena.
• For internal administrative purposes, such as auditing compliance with parking regulations, analyzing service performance, and ensuring the accuracy of our records.
• We may use information for statistical or research purposes, provided that for residents of Quebec, such data is anonymized (rendered irreversibly non-identifiable) or used in compliance with a Privacy Impact Assessment (PIA).

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If we decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes.

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) which includes a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Collected: Yes

Canadian Statutes (PIPEDA & Law 25): For users in Canada, encompasses all "Personal Information" maintained within our business and customer records as defined under the Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial acts such as Quebec’s Law 25. This includes:

• Customer Account Records: Any information about an identifiable individual that is recorded in any form, including name, mailing address, email address, telephone number, and communication preferences
• Financial and Transactional Records: Information relating to financial transactions, payment methods, or credit history as it pertains to the individual's use of SecurePark Tech Ltd.
• Identification and Registry Data: Any identifying number or symbol assigned to the individual (e.g., license plate numbers or internal customer IDs).
• Sensitive Records (Quebec): Under Law 25, any information in our records that is medical, biometric, or otherwise intimate in nature, or where the context of its use implies a high expectation of privacy, is classified as "Sensitive Personal Information." Collected: Yes.
• Category D: Commercial information
• Category F: Internet or other similar network activity.

Please note that the categories and examples of personal information listed above are those defined in the CCPA. This does not mean that all examples of that category were in fact disclosed but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

Canadian Statutory Compliance (PIPEDA & Law 25)

For residents of Canada, the Company adheres to the following additional disclosure standards:

• Identified Purposes: In accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), the Company only discloses personal information for the specific purposes identified to You at or before the time of collection. We do not disclose personal information for secondary purposes without obtaining Your further consent, unless required by law.
• Limiting Disclosure: We limit the disclosure of Your personal information to only that which is necessary to fulfill the identified business or legal purposes (e.g., processing a parking transaction or complying with a lawful warrant).
• Accountability for Third Parties: When we disclose information to third-party Service Providers, we remain accountable for that data. We use contractual and other means to ensure these parties provide a comparable level of protection and do not use Your information for any unauthorized purpose.
• Transparency (Quebec Law 25): For residents of Quebec, the Company ensures that any disclosure to third parties is clearly communicated, and we maintain a record of such disclosures. We do not "sell" Your personal information as defined by Law 25, and any communication of sensitive information requires Your express consent.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

U.S. Standard (CCPA): As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for monetary or other valuable consideration. This includes receiving a benefit in return for sharing information.

Canadian Standard (PIPEDA & Law 25): For the purposes of Canadian federal and provincial privacy laws, the Company recognizes the following standards regarding the communication of information for value:

1. Disclosure in Commercial Activity (PIPEDA): The Company is responsible for any personal information in its possession or custody that is disclosed to a third party in the course of commercial activities. This includes the bartering or exchange of user data for non-monetary benefits (e.g., service credits, analytics, or advertising advantages).
2. Transfers for Processing: In accordance with the "Accountability Principle," a transfer to a third-party Service Provider (e.g., a cloud host) for the purpose of providing the Service is not considered a sale or disclosure, provided the Company uses contractual means to ensure a comparable level of protection.
3. Communication for Value (Quebec Law 25): For residents of Quebec, the Company does not communicate personal information to third parties for their own commercial purposes without Your express, opt-in consent. We do not "sell" data as an asset except as part of a legitimate commercial transaction (such as a merger), which is subject to specific statutory safeguards.
4. No De-Facto Sales: The Company does not sell Your personal information in the traditional sense. However, any sharing of information that results in a benefit to the Company is disclosed here to ensure Meaningful Consent.

Clarification on Data Categories

Please note that the categories and examples provided in the list above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected or disclosed but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may have been collected or shared for value in return.

Canadian Statutory Compliance (PIPEDA & Law 25)

For individuals in Canada, the Company adheres to the following additional requirements regarding the use and disclosure of these categories:

1. Identified Purposes: In accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), we only disclose personal information for the specific, legitimate purposes identified to You at or before the time of collection. We do not use or disclose personal information for secondary purposes (purposes not integral to the Service) without obtaining Your further Meaningful Consent.
2. Reasonable Person Standard: The Company only discloses information for purposes that a reasonable person would consider appropriate under the circumstances.
3. Accountability for Transfers: When we share information with third-party Service Providers for processing (e.g., payment processors or cloud hosts), we remain accountable for that information. We use contractual agreements to ensure these parties provide a comparable level of protection to our own.
4. Privacy by Default (Quebec Law 25): For residents of Quebec, any collection or disclosure via technology that allows for identifying, locating, or profiling is deactivated by default. Such information is only shared if You provide express, opt-in consent.
5. Sensitive Information: We recognize that certain data—such as precise geolocation or financial details—requires enhanced security and a higher standard of express consent under Canadian law.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) which includes a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Canadian Statutes (PIPEDA & Law 25): For users in Canada, this category encompasses all "Personal Information" maintained within our business and customer records as defined under the Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial acts such as Quebec’s Law 25. This includes:
• Customer Account Records: Any information about an identifiable individual that is recorded in any form, including name, mailing address, email address, telephone number, and communication preferences.
• Financial and Transactional Records: Information relating to financial transactions, payment methods, or credit history as it pertains to the individual's use of SecurePark Tech Ltd.
• Identification and Registry Data: Any identifying number or symbol assigned to the individual (e.g., license plate numbers or internal customer IDs).
• Sensitive Records (Quebec): Under Law 25, any information in our records that is medical, biometric, or otherwise intimate in nature, or where the context of its use implies a high expectation of privacy, is classified as "Sensitive Personal Information." Collected: Yes.
• Category D: Commercial information
• Category F: Internet or other similar network activity.

Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

• Service Providers
• Payment processors
• Our affiliates
• Our business partners
• Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

The CCPA and Canadian privacy laws (PIPEDA and Quebec's Law 25) provide residents with specific rights regarding their personal information. Depending on where You reside, You have the following rights:

The right to notice.
You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

The right to request.
You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:

• The categories of personal information We collected about You.
• The categories of sources for the personal information We collected about You.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom We share that personal information.
• The specific pieces of personal information We collected about You
• If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You.
• For residents of Quebec, as of September 2024, You have the right to receive Your computerized personal information in a structured, commonly used technological format, or to have it transferred directly to another organization.
The right to say no to the sale of Personal Data (opt-out).
You have the right to direct Us to not sell Your personal information. You may withdraw Your consent to the collection, use, or disclosure of Your information at any time, subject to legal or contractual restrictions and reasonable notice. We will inform You of any consequences of withdrawal (e.g., inability to provide certain parking services).To submit an opt-out request please contact Us.

The right to delete Personal Data.
Personal Data, subject to certain exceptions. Once We receive and confirm Your request, 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 Providers to:

• Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 et. seq.).
• Comply with PIPEDA & Part 2: Electronic Documents
• The Personal Information Protection and Electronic Documents Act (PIPEDA) is the primary federal law. Specifically, Part 2 of the Act provides the legal framework for "Electronic Documents," ensuring that electronic communications are treated with the same legal weight and privacy protections as paper-based records.
• Consent for Access: We do not access Your electronic communications (such as private messages or internal account data) without Your knowledge and consent, except in specific legal circumstances.
• Comply with The Criminal Code of Canada (Part VI)
• Part VI of the Criminal Code (Section 184) prohibits the "Interception of Communications."
• Interception Protection: It is a criminal offense in Canada to knowingly intercept a private communication by means of an electromagnetic, acoustic, mechanical, or other device without the consent of at least one of the parties. We ensure our systems are designed to prevent unauthorized interception of Your data.
• Comply with Canada’s Anti-Spam Legislation (CASL)
• While CalECPA focuses on access, CASL focuses on the integrity of Your electronic communications and devices.
• Software Installation: CASL prohibits the installation of computer programs (including apps) on Your device without Your express consent.
• Alteration of Transmission Data: CASL prohibits the unauthorized alteration of "transmission data" (metadata) in an electronic message so that the message is delivered to a destination other than that anticipated by the sender.
• Comply with The Privacy Act (Public Sector)
• If SecurePark Tech Ltd. provides services to or on behalf of a Canadian government institution (e.g., a municipal parking authority), Your electronic communications are also protected under the federal Privacy Act, which limits how government bodies can collect and access digital records.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
• Comply with a legal obligation. Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
The right not to be discriminated against.
You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
• Denying goods or services to You.
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties.
• Providing a different level or quality of goods or services to You.
• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

By email: support@secureparktech.com

By visiting this page on our website: www.secureparktech.com

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative.
• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

We cannot respond to Your request or provide You with the required information if We cannot:

• Verify Your identity or authority to make the request.
• And confirm that the personal information relates to You.

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, we will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

Exercising Your Canadian Data Protection Rights

In order to exercise any of Your rights under the PIPEDA, or Quebec's Law 25, You can contact Us through the methods below.
Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will strive to respond to You as soon as possible and no later than the statutory deadlines (30 days for Canadian federal and provincial requests).

Contact Our Privacy Officer (Canada & General)

In accordance with Canadian law, We have appointed a Privacy Officer who is responsible for overseeing our compliance with privacy statutes and handling all data protection requests.

• By Email: privacy@secureparktech.com
• By Mail: 10558 115 Street NW, Edmonton AB, T5H 3K6, Attention: Privacy Officer
• By Phone: 1-800-835-6780

Specific Instructions for Canadian Residents

• Access & Correction: You have the right to request access to the personal information We hold about You and to request the correction of any inaccuracies. Most requests will be handled at no cost; however, if a request is complex, We may charge a minimal fee as permitted by law, provided We notify You of the cost in advance.
• Withdrawal of Consent: If You wish to withdraw Your consent for the collection or use of Your data, please contact our Privacy Officer. We will process Your request and inform You of any impact it may have on Your ability to use the Service.
• Quebec Portability Requests: If You are a resident of Quebec and wish to exercise Your Right to Data Portability, please specify that You would like Your data in a "structured, commonly used technological format."

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers We partner with (for example, our analytics or advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA, or constitutes "Profiling" and "Tracking" under Canadian statutes such as PIPEDA and Quebec's Law 25.

For Canadian Residents: In accordance with Canadian privacy principles, We ensure that any disclosure to these partners is limited to the identified purposes of providing and improving our Service. Please note:

• Privacy by Default (Quebec): For residents of Quebec, any technology used by our partners that identifies, locates, or profiles You is deactivated by default. These features will only collect Your information if You provide express, opt-in consent through our cookie banner or settings.
• Cross-Border Transfers: Some of our partners may store or process Your personal information outside of Canada (including in the United States). While Your information is in another jurisdiction, it may be subject to the laws of that jurisdiction, including access by local law enforcement.
• Right to Withdraw Consent: You have the statutory right to withdraw Your consent for interest-based advertising at any time. If You wish to opt-out of these disclosures or deactivate tracking functions, You may do so by following the instructions below.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA's opt-out platform: http://www.youronlinechoices.com/
• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

California Residents: If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Your California Privacy Rights (California's Shine the Light law). Under California Civil Code Section 1798.83, California residents who have an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581) California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account. Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Canada’s "Right to Know" (PIPEDA Principle 9): Upon request, You have the right to be informed of the existence, use, and disclosure of Your personal information and to be given access to that information

• Third-Party List: You have the right to receive an account of the use that has been made of Your information and a specific list of the third parties to whom it has been disclosed (not just for marketing, but for any purpose).
• Cost: We will provide this information at minimal or no cost to You, and within the statutory timeline of thirty (30) days

Canadian Residents: Under the Personal Information Protection and Electronic Documents Act (PIPEDA), You have a broader right to be informed of the existence, use, and disclosure of Your personal information. Upon request, We will provide You with an account of how Your information has been used and a specific list of the third-party organizations to whom it has been disclosed. We will respond to Your request within thirty (30) days at minimal or no cost to You.

How to Exercise These Rights
To request information or the removal of data, please contact Us using the information below. Please include the email address associated with Your account and specify whether You are making a request under California law, PIPEDA, or Quebec’s Law 25.

Note: While We will make every effort to remove requested content, the law may not require or permit removal in certain circumstances (e.g., if the data is required for legal compliance or parking enforcement records).

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email privacy@secureparktech.com