LICENSE PLATE RECOGNITION (LPR): Terms and Conditions and Privacy Policy
Effective Date: 6.1.2020
The “LICENSE PLATE RECOGNITION (LPR): Terms and Conditions and Privacy Policy (“LPR Policy”)” applies to properties that utilize license plate recognition hardware and software (“LPR”) for providing parking and access control services to tenants, employees of tenants and to guests/visitors/customers/event-goers visiting the property (collectively, “Visitors”). This LPR Policy describes how Property owners, managers, and operators (“Operators”) may collect, use, and disclose information collected in connection with the LPRs. By utilizing the services offered by ParqEx, you agree to, and agree to comply with, the terms of this LPR Policy.
Locations
LPR data is collected for vehicles accessing parking areas that use ParqEx Access+ Premium with License Plate Recognition (LPR) technology.
Data Collected
The LPR system captures two types of photos of observed vehicles: (1) a context photo of the vehicle and its immediate surroundings and (2) a photo of the license plate. Typically, these photos are taken from the front and/or rear of the vehicle depending if the LPR camera is pointing at the entry, exit or both. The photos are not of a resolution that allows identification of the vehicle occupants. Along with the photographic data, the system also records the global positioning system coordinates and date/time information of the observation. Further software processing of the license plate image generates an alphanumeric version of the license plate number which is also stored with the record. While no owner or driver information is stored directly with the LPR record, vehicle LPR data is linked to individual tenants renting parking at the property
Use of Data
The intended use of data collected by the LPR system is for parking access control, parking enforcement, and any law enforcement investigations. LPR data is used to determine a vehicle’s access permissions in a given parking area and support the issuance of a parking citation if needed. The data may be used by the Department of Public Safety in assisting immediate or ongoing safety concerns and in conducting specific investigations and complaints. In addition, the data may be used for compliance with applicable laws and regulations, and/or if needed in connection with litigation or other legal or administrative proceeding.
Operators may use and shares LPR Data for the following purposes:
- Security; Law Enforcement. Operators use LPRs and LPR Data to manage property security, including without limitation, to identify vehicles known to be associated with persons banned from the property or of interest to property security. In addition, Operators may use and share LPR Data with law enforcement to enable law enforcement to assist us in managing security at the property and to assist law enforcement in other valid law enforcement purposes, such as locating stolen cars or suspected criminals. Operators may also use and share LPR Data with other third parties as necessary to assist us in managing security.
- Parking Management. Operators use LPRs and LPR Data, in conjunction with other information, to monitor and prevent and remedy unauthorized use of our Parking Services, including to enforce parking restrictions with the goal of reserving preferred parking spaces for tenants and visitors. Operators may use and share LPR Data with law enforcement or other third parties to assist us in managing parking.
- Compliance with Laws. Operators may use and share LPR Data, including with law enforcement and other government entities, to cooperate with law enforcement agencies and to comply with laws, regulations, court orders and subpoenas, and other similar requests for information by authorities.
- Other Legitimate Uses. Operators may use LPR Data as necessary to maintain the ParqEx Access+ with LPR system and other Lacuna LLC systems. Operators may use and share LPR Data if we believe such use or disclosure is necessary to enforce Lacuna LLC’s rights, to protect the safety of Visitors or others when they access the property, and to assist us in fraud prevention or investigation.
Data Sharing
Personal data may be shared with third-party vendors (such as information technology, cloud storage providers and LPR solutions providers) for storage and other processing of personal data. Personal data may also be shared to comply with a valid legal process, governmental request, or applicable law, rule or regulation. Personal data will not be sold or licensed to any third parties for secondary commercial purposes.
AUTHORIZED USERS OF THE PARQEX ACCESS+ WITH LPR SYSTEM
Authorized users of the ParqEx Access+ with LPR system may include people working for, or supporting property management and/or employed by the Operators.
ParqEx, as the developer of the ParqEx Access+ with LPR system, may also access the ParqEx Access+ with LPR system. ParqEx is the official custodian of the LPR Data and is responsible for how it is used.
Operators who have a legitimate business need, are authorized to use and access the ParqEx Access+ with LPR system and LPR Data after they have been made aware of the policies that govern the ParqEx Access+ with LPR system. Operators trains Operator’s Employees who have access to the ParqEx Access+ with LPR system on how to best capture images and use the ParqEx Access+ with LPR system, and on the policies that govern the program. ParqEx trains Contractor Employees who have access to the ParqEx Access+ with LPR system on how best to capture images and use the ParqEx Access+ with LPR system, and on the policies that govern the program.
Data Retention
Data collected by the LPR system not resulting in parking enforcement action or not part of an ongoing law enforcement investigation is retained for 90 days. Data resulting in a parking enforcement action is retained with the citation records in the enforcement platform. Data associated with an ongoing law enforcement investigation is retained until the investigation is completed or as directed by investigators or courts. Data subject to a legal hold is retained until the legal hold has been lifted.
Access to Records
Access to records created and maintained by the LPR system is limited and restricted to authorized and trained ParqEx personnel performing their duties. All personnel with access to the system use unique identifiers and passwords to access records; and other activity is logged within the system. Access to records in the system by others is prohibited. Determining
Terms Updates
This notification will be updated periodically to reflect any changes in our programs and practices. These changes will be evident by a new “Effective Date” and are effective when they are posted below.