CITY SMART PARKING PRIVACY POLICY

City Smart Parking s.r.o. (“CSP”) is committed to transparency in the collection and use of your personal information. The Privacy Policy below describes how we collect and use personal information, and the circumstances under which we may share this information. This Privacy Policy applies to the privacy practices of: (a) our website located at www.eparkomat.cz/app a www.eparkomat.com  (the “CSP Websites”); (b) our platform (including APIs required to access the platform) that provides mobile services (the “CSP Platform”); (c) any mobile device software provided by us to you through the Apple App Store or Google Play, including, but not limited to, our mobile application titled eParkomat (the “CSP Mobile Application”); and (d) the Mojio hardware device for the vehicle (the “Mojio Hardware Device”) (together with the CSP Website, CSP Platform and the CSP Mobile Application, the “CSP Solution”).

  1. Collection of Information

CSP provides a smart parking service that allows you to gain access to information on the on-street and off-street parking especially with features like find, navigate, pay and park in order to enhance your parking experience. By using the CSP Application and / or the CSP Website, CSP may collect the following types of information:

  1. Account Information:

To access and use certain features of the CSP Solution, you may need to register for a My CSP Account (the “Account”) through the available CSP Solution interfaces, namely, the CSP Website or the CSP Applications. During the registration process, you may be asked to provide us with your full name, email address, plate number. You may also be asked to choose a username, password and security questions.

In registering for an Account (or after registration), you can choose to provide your social media login information and password through platforms such as Facebook. If you do so, you authorize us to access certain social media account information (consistent with your social media privacy settings), including but not limited to your profile information, full name, username, email address and full physical address. All such information is provided directly by the social media platform, whose use of your personal information will be subject to its own privacy policy and terms of use.

  1. Information from the Mojio Hardware Device (Chytré Auto T-Mobile)

We collect and use the information described below about the vehicle in which you installed the Mojio Hardware Device. We receive some of this information via a mobile service provider. See section 3(b) “Mobile Services Providers” for further information on how the Mojio Hardware Device interacts with a mobile network.

  1. Vehicle Related Information

We collect information about your vehicle’s operation to provide you with feedback on your parking habits..

  1. Vehicle Location Information

We collect information on the location of your vehicle, including the parked location of your vehicle.

If you access the Platform by mobile device, you may be asked to share your geo-location in order to make use of our geo-location services. You may also be asked to provide us with access to your device’s contact book and phone number in order to use some of the features of the CSP Solution, e.g. to communicate the location of your vehicle to your contacts.

  1. Payment Processing Information

When you pay for the CSP Solution, you will be disclosing your payment information to MPLA s.r.o., whose use of your personal information will be subject to its own Privacy Policy and Terms of Service. We do not have access to any payment processing information or any financial information such as credit card numbers.

  1. Information We Collect Automatically When You Visit Our Website or Use Our Applications

When you install one of the CSP Applications or use a computer, tablet, smart phone or other device to access the CSP Website, we may use automatic means to collect information about the device and how you use it. This information may include the type of device, your operating system, your browser (for example, whether you used Internet Explorer, Firefox, Safari, Chrome or another browser), your internet service provider, your domain name, your internet protocol (IP) address, your device identifier (or UDID), the date and time that you accessed our service, the website that referred you to the CSP Website, the web pages you requested, the date and time of those requests and your physical location. See section 7 “Cookies and Other Tracking Technologies” for further information.

  1. Use of Information

We use the information described above to:

  1. provide the CSP Solution to you;
  2. fix, maintain, enhance and modify the CSP Solution;
  3. communicate with you (e.g. in response to your inquiries or comments);
  4. comply with legal and regulatory requirements;
  5. promote our products and services;
  6. provide you with offers by our business partners that might interest you in accordance with your consent; and
  7. for other purposes in accordance with your consent.

We may use information for any purpose if we anonymize it so that it no longer will be able to identify you or your vehicle.

  1. Disclosure of Information

We may transfer or disclose information as follows:

  1. Service Providers Arrangements

Your information may be transferred (or otherwise made available) to our affiliates and other third parties who provide services on our behalf. Our service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose personal information for their own marketing or other purposes.

  1. Mobile Services Providers

For you to be able to access certain features using the Mojio Hardware Device, the Mojio Hardware Device needs to be connected to a mobile network through a mobile service provider (such as T-Mobile CZ, T-Mobile USA, Deutsche Telekom). When the Mojio Hardware Device is connected to a mobile network, the Mojio Hardware Device shares your information with the mobile service provider for the purposes of providing you with certain features of the CSP Solution. The information will be shared in accordance with the mobile service provider’s privacy policy and terms of use.

  1. Legal and Compliance

We and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization (e.g. law enforcement) for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable European, Canadian, US or other law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

  1. Sale of Business

Personal information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of CSP or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

  1. Anonymized Data

Information that is anonymized so that it will not be able to identify you may be shared with or sold to third parties.

  1. International Transfers

Your information may be stored and processed by us, our affiliates and our third party service providers in Europe, the Canada, the United States, or other jurisdictions that may not have data protection or other laws that are as protective as in your country of residence. In the event that personal information is transferred to Europe countries, the Canada, the United States, or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws. By using the CSP Solution, you consent to the transfer, processing and storage of your personal information in countries outside of your country of residence, including Canada, the United States, as described in this Privacy Policy.

  1. Safeguarding and Retention of Personal Information

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.

We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

  1. Access to Personal Information

You have the right to access, update and correct inaccuracies in your personal information in our control, subject to certain exceptions prescribed by law. You also have the right to object to the processing of your personal data for direct marketing purposes. You may request access, updating and corrections of inaccuracies in personal information we have in our control or object to the use of your personal information for direct marketing purposes by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

  1. Cookies and Other Tracking Technologies

We use cookies and other tracking technologies for the following purposes: (i) to operate the CSP Website (so-called “strictly necessary cookies”, which are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website); (ii) to provide you with offers that may interest you (including on third-party websites) (so-called “targeting cookies or advertising cookies”, which collect information about your browsing habits and are used to deliver adverts more relevant to you and your interests); (iii) to personalize the content we present you on the CSP Website (so called “functionality cookies”, which allow the Website to remember choices you make and provide enhanced, more personal features), (iv) to understand how the CSP Solution function and are used and to provide or improve the CSP Solution (so-called “performance or analytical cookies”, which are used to collect information about your use of the CSP Solution). Some cookies exist only during a particular session and some are persistent over multiple sessions over time.

You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the CSP Website, you may not be able to take advantage of all of the features on the CSP Website. If you want to delete any cookies that may already be on your computer or device, please refer to the instructions for your file management software to locate the file or directory that stores cookies.

We also use in-app tracking technologies to understand how the CSP Solution function and are used. You can stop all collection of data generated by the use of the CSP Applications by uninstalling the CSP Applications.

  1. Do Not Track

Most web browsers include a “do not track” setting. However, there is a lack of certainty or consistency with respect to what impact that setting should have on the information collected or on a user’s browsing experience. Accordingly, and consistently with respect to the operation of many websites, if you enable that setting, it will not change what information is exchanged with your computer, or how that information is used, when you visit the CSP Website.

  1. Third Party Websites

The CSP Website may contain links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our service and go to another site. During this process, another entity may collect personal information from you.

  1. Updates to the Privacy Policy

We may update this Privacy Policy to reflect changes to our privacy practices. If we make changes to this Privacy Policy, they will be reflected in an updated Privacy Policy that will be posted on this page and, where appropriate, notified to you by email, and all changes will be effective upon such posting or, where appropriate, notification by email, or at another specified time. We encourage you to periodically review this page for the latest information on our privacy practices.

  1. Contact Us

CSP welcomes your comments and questions regarding this Privacy Policy and the use of your personal information. To respond to your request, we may ask you for your full name, email address and phone number. If you have questions or concerns please contact our Privacy Officer:

By email:

privacy@eparkomat.com

By post:

Privacy Officer

City Smart Parking s.r.o.

Karviná – Fryštát, Vydmuchov 707/20, PSČ 733 01

Czech Republic

18.4.2017