Last Updated: January 1, 2023
PNF is a data controller with regard to any Personal Information collected from individuals accessing or using its Services. A “data controller” is an entity that determines the purposes for which and the manner in which any Personal Information is processed.
By using any of the Services and providing us with your Personal Information, you acknowledge that we will process your Personal Information in accordance with the terms of this Policy. If you do not want us to process your personal information, please do not use the Services or provide us with your Personal Information.
The “Last Updated” date provided above indicates the last time we made changes to this Policy. We may update this Policy from time to time to reflect changes in our personal information processing practices or in applicable laws. We encourage you to look for updates and changes to this Policy by checking this date when you access our websites and mobile applications. In the event of a material change to this Policy, we may also notify you directly via email.
- Personal information we collect
- How we collect personal information
- How we use personal information
- Legal bases for processing your personal information
- How we share your personal information
- Retention of personal information
- Privacy rights and choices
- Tracking technologies
- International transfers
- Third party links
- Contact information
- PERSONAL INFORMATION WE COLLECT
We collect the following categories of Personal Information:
- Identifiers, such as your name, address, email address, date of birth, phone number, IP address, Frequent Parker card number, Services account information, and IATA number.
- Commercial information, including reservation and travel information, and information provided in relation to customer service inquiries.
- Audio, electronic, visual, thermal, olfactory, or similar information, including audio recordings of your voice for quality assurance purposes in the event you call us; and surveillance and other security systems at our physical locations for safety and security purposes.
- Internet activity information, including IP address, internet service provider, operating system, browser information, device information, browsing history, your interactions with the Services.
- Financial information, such as credit card number or debit card number to pay for parking services.
- Geolocation information, to the extent you have configured your device to permit us to collect such information.
- Other information you voluntarily provide, including web form and poll responses and posts on the Services.
2. HOW WE COLLECT PERSONAL INFORMATION
We collect Personal Information in the following ways:
- When you provide it directly. We collect Personal Information directly from you when you: make an account; register for the App; enroll in our Frequent Parker Program; reserve and pay for a parking space; post on the Services; contact customer support; and complete web forms, polls, or surveys.
3. HOW WE USE PERSONAL INFORMATION
We will only use your Personal Information as described in this Policy or as disclosed to you prior to such processing taking place. We use your Personal Information for the following commercial and business purposes:
a)To personalize your experience;
b) To facilitate purchases and transactions;
c) To improve our Services;
d) To communicate with you about our Services;
e) To verify your identity;
f) To conduct or administer surveys and other market research for our business purposes;
h) To respond to requests, questions and comments;
i) To provide you with special offers, articles, announcements, invitations, and other information about our Services;
j) To provide customer support;
k) To share your Personal Information with third parties, as discussed below in our “How We Share Your Personal Information” section;
l) To administer the Frequent Parker program;
m) To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of us and our users, employees, or others;
n) To comply with legal requirements, judicial process, and our policies (e,g., to verify users’ identity in connection with access or correction requests);
o) To protect the safety and security of you, personnel, and our locations;
p) When it is necessary for other legitimate purposes, such as protecting our confidential and proprietary information; and
q) For any other purpose to which you consent.
We may also aggregate or de-identify any Personal Information that we collect in connection with our Services, such that the information is no longer personally identifiable or attributable to you. We may use such aggregated or de-identified information for our own legitimate business purposes without restriction.
4. LEGAL BASES FOR PROCESSING YOUR PERSONAL INFORMATION
For individuals who are located in the European Economic Area, the United Kingdom or Switzerland (collectively “EEA Residents’”) at the time their Personal Information is collected, our legal bases for processing your information under the General Data Protection Regulation (“GDPR”) will depend on the specific context in the which the Personal Information is collected and the purposes for which it is used. When we process your Personal Information, depending on the context, we may rely on a variety of different legal bases to process, including: (i) to perform a contract with you (or to take steps at your request prior to entering into a contract with you); (ii) necessity for our legitimate interests; (iii) to comply with our legal obligations and/or (iv) your consent. Below is a list of how we use your personal information, as described above in Section 3, with the corresponding legal bases for processing.
|Purpose of Processing||Legal Bases for Processing|
|b. To facilitate purchases and transactions; |
d. To communicate with you about our Services;
e. To verify your identity;
h. To respond to requests, questions, and comments;
j. To provide customer support;
k. To share your Personal Information with third parties; and
l. To administer the Frequent Parker program.
|Contract. Based on our contract with you or to take steps at your request prior to entering into a contract.|
|a. To personalize your experience; |
c. To improve our Services;
f. To conduct or administer surveys or other market research;
g. To enable our targeted advertising;
i. To provide you with special offers, articles, announcements, invitations, and other information about our Services;
k. To share your Personal Information with third parties;
m. To detect and protect against malicious, deceptive, fraudulent, or illegal activity;
o. To protect the safety and security of you, personnel, and our locations; and
p. When it is necessary for other legitimate purposes.
|Legitimate Interests. Based on our legitimate interests. When we process your personal data for our legitimate interests we always ensure that we consider and balance any potential impact on you and your rights under data protection laws.|
|n. To comply with legal requirements, judicial process, and our policies.||Legal Obligations. Based on our legal obligations, the public interest, or in your vital interests.|
|f. To conduct or administer surveys or other market research; |
g. To enable our targeted advertising;
i. To provide you with special offers, articles, announcements, invitations, and other information about our Services; and
q. For any other purpose for which you consent.
|Consent. Based on your consent.|
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Information” Section below.
We will not sell, share, or otherwise disclose your Personal Information for purposes unrelated to those detailed in this Policy. To that end, we will take reasonable precautions to allow access to your Personal Information to only our employees, agents, contractors, or similar entities to the extent necessary for the purposes set out in this Policy. We may share your Personal Information in the following ways:
- Between Affiliated Entities. Your Personal Information may be disclosed among our various affiliated entities for the purposes set out in this Policy.
- To Service Providers. We may share your Personal Information with service providers that perform services for us or on our behalf, including: to operate the Services; to assist us to perform business functions and operations; and to fulfill your requests. For example, service providers may include web hosting providers, app hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, and professional advisors like accountants, lawyers, and business consultants.
- With Our Third-Party Marketing Partners. We may share your information with our marketing service providers to provide targeted advertising services.
- With Your Consent. When you provide your consent to share your Personal Information, we will share it in the way(s) you specific, including when you request it be shared with others.
- As Necessary to Comply with Our Legal Obligations. We may also disclose personal information in order to assist with or otherwise enable our compliance with a legal or regulatory obligation, protect and defend our rights or property, protect the safety of our users or the public, and to exercise establish or defend our legal rights.
- As Part of a Corporate Transaction. We reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Policy. After such a sale or transfer, you may contact the recipient with any inquiries concerning the recipient’s privacy practices.
- Vital Interests. We may disclose information to any party where we believe it is necessary
We have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make reasonable efforts to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information.
Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers and other authentication information you use to access our Services.
7. RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy, unless we are otherwise required to retain it to: (i) comply with our own legal obligations; (ii) resolve a dispute; or (iii) enforce our legal agreements and policies. We may also retain de-identified, aggregate Services usage data for internal analysis purposes.
8. PRIVACY RIGHTS AND CHOICES
Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your Personal Information. If any of the rights listed below are not provided to you under the law that governs the processing of your Personal Information, we have absolute discretion in providing you with those rights. Please refer to the “What Rights Apply” section to determine the rights you have in your jurisdiction.
Your rights in relation to your Personal Information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or for other reasons.Right to Know/Access. You may have the right to obtain a copy, or a list of categories of the Personal Information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your Personal Information.
a) Right to Correct. You may have the right to correct any of your Personal Information in our records and systems. You may request us to rectify, correct or update any of your Personal Information held by us that is inaccurate.
b) Right to Delete. Under certain circumstance, you may have the right to request that we delete the Personal Information that we hold about you. This right is not absolute, and we may refuse such a request if there are compelling legitimate grounds for keeping your Personal information, for legitimate purposes, or as required by law. In addition, in the event your deletion request is honored, we may retain a record of your deletion request as required under applicable law.
c) Right to Portability. You have the right to receive a copy of the Personal Information we have collected about you in a structured, commonly used and machine-readable format.
To the extent the applicable law provides you with this right, you may exercise your right to opt-out by clicking here or by clicking the “Do Not Share My Personal Info” link in our Websites’ footer. You will need to submit a separate opt-out of sharing request on each device and browser you use to visit our Websites. For information about how to opt-out of sharing or selling on our mobile application, please see Mobile App Advertising section, in Section 9 of this Policy.
California residents may also opt-out of sharing and sales by using an opt-out preference signal for each participating browser system that you use. We will honor and process the opt-out preference signal in a frictionless manner. To start using an opt-out preference signal, please refer to the instructions provided here. You will need to submit a separate opt-out of sharing request on each device and browser you use to visit our Websites. Please note that you may still receive generalized ads after opting out of targeted advertising.
g) Right to Limit Use and Disclosure of Sensitive Personal Information. If you are a California resident, to the extent your Sensitive Personal Information, as that terms is defined under California privacy law, is used to infer characteristic about you, you have the right to object to our processing of your Sensitive Personal Information.
h) Right to Opt-Out of Automated Decision-making or Profiling. You may have the right not to be subject to a decision which significantly impact your rights that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement). No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.
i) Right Against Discrimination. You may have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your rights.
j) Right to Object. You may have the right to object to processing of your Personal Information for direct marketing purposes or if we are processing your Personal Information on the basis of our legitimate interest.
k) Right to Restrict. In some jurisdictions, applicable law may give you the right to restrict or object to us processing or transferring your Personal Information under certain circumstances. We may continue to process your Personal Information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
l) Right to Withdraw Consent. In certain jurisdictions, to the extent the processing of your Personal Information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.
m) Marketing Communications. You can opt-out of receiving marketing communications from PNF. Direct marketing includes any communications to you that are only based on advertising or promoting our products and services. We will only contact you by electronic means based on our legitimate interests, as permitted by applicable law, or your consent. If you do not want us to send you marketing communications, please go to your account settings to opt-out, submit a request via the opt-out method included in the communication, or submit an opt-out request as indicated in the “How to Make a Privacy Request” Section.
For users in the European Economic Area, the United Kingdom and Switzerland, to the extent we can rely on legitimate interest under the applicable law, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. We will contact you by electronic means for marketing purposes only if you have consented to such communication. You may raise such objections with regard to initial or further processing for purposes of direct marketing, at any time and free of charge.
n) Right to Appeal. In certain jurisdictions,you may have the right to appeal if we refuse to take action on your rights request. Instructions on how to appeal will be provided to you upon such a denial, but in any event, such instructions will be substantially similar to those provided below for submitting requests.
o) Right to Lodge a Complaint. You may have the right to lodge a complaint with your local data protection authority about our processing of your Personal Information. Contact details for data protection authorities in the European Economic Area are available here, and contact details for the United Kingdom’s ICO are available here.
p) Shine the Light. If you are a California resident, you have the right to ask us for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes. That notice will identify the categories of Personal Information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such Personal Information.
As noted above, depending on where you reside or are located at the time your Personal Information is collected, you may be able to assert certain rights with respect to your Personal Information. To determine which rights you have, please refer to the table below that references the rights as described above. U.S. States not listed either do not have a law providing such rights, or it does not apply to our operations. If your country is not listed, please reach out for more information about your rights under the applicable law.
|California (if you are a resident)||(a) Right to Know/Access; (b) Right to Correct; (c) Right to Delete; (d) Right to Opt-Out of Sale; (e) Right to Opt-Out of Sharing for Targeted Advertising; (f) Right to Limit Use and Disclosure of Sensitive Personal Information; (g) Right to Opt-Out of Automated Decision-making or Profiling (upon issuance of regulations by the California Privacy Protection Agency); (h) Right Against Discrimination.; (i) Right to Portability; and (p) Shine the Light.|
|Colorado & Connecticut (if you are a resident)||Starting July 1, 2023: (a) Right to Know/Access; (b) Right to Correct; (c) Right to Delete; (d) Right to Opt-Out of Sale; (e) Right to Opt-Out of Sharing for Targeted Advertising; (g) Right to Opt-Out of Automated Decision-making or Profiling; (h) Right Against Discrimination; (i) Right to Portability; and (n) Right to Appeal.|
|European Economic Area, United Kingdom, or Switzerland (if you are located in these jurisdictions at the time your pe resident)||(a) Right to Know/Access; (b) Right to Correct; (c) Right to Delete; (d) Right to Opt-Out of Sale; (e) Right to Opt-Out of Sharing for Targeted Advertising; (g) Right to Opt-Out of Automated Decision-making or Profiling; (h) Right Against Discrimination; (i) Right to Portability; (j) Right to Object; (k) Right to Restrict; (l) Right to Withdraw Consent; and (o) Right to Lodge a Complaint.|
|Any Location, including those listed above||(m) Marketing Communications.|
Submitting a Request to Exercise Your Rights. In addition to the methods specified above, you may exercise these rights by: (i) emailing us at [email protected] with the subject line “Consumer Rights Request”, or (ii) calling us toll-free at 1-800-404-7275. In addition, you may submit a written rights request to the appropriate address listed in the “Contact Information” section. In your request, please make clear which right you would like to exercise.
Before fulfilling your request, we are required by law to have you to verify the personal information we already have on file to confirm your identity. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
You may use an authorized agent to submit a rights request on your behalf. If you use an authorized agent to submit requests on your behalf, we will require you to directly verify your identity with us, or have you directly confirm with us that the authorized agent has been authorized to act on your behalf.
9. TRACKING TECHNOLOGIES
- Analyze our web traffic using an analytics package
- Identify whether you already visited our Sites
- Store information about your preferences
- To recognize when you return to our Sites
Cookies. When you visit our Services, we (or third-party data or ad networks we work with) may send one or more “cookies” to your computer or other devices. Cookies are alphanumeric identifiers stored on your computer through your web browser and are used by most websites to help personalize your web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third-party websites. Some features on the Services will not function if you do not allow cookies. The following types of cookies may be used on our Services:
- Essential Cookies. These cookies are essential because they enable you to use our Services as you reasonably expect. For example, strictly necessary cookies allow you to access secure areas on our Sites and provide necessary security functions. Without these cookies, some features cannot be provided. This category of cookies is essential for our Services to work and they cannot be disabled.
- Marketing Cookies. These cookies may be set through our Services by our marketing partners. Personal Information may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to your interests.
- Personalization Cookies. We use functional cookies to remember your choices so that we may tailor our Services to provide you with enhanced features and personalized content. While these cookies can be disabled, this may result in less functionality during your use of our Services.
- Analytics Cookies. These cookies allow us to collect passive information about your use of our Services, for example, count page visits and traffic sources so we can measure and improve the performance of our Services and our marketing activities.
Managing Cookies. You have the right to decide whether to accept cookies. If you do not want us to deploy cookies in your browser, you may exercise your preference through our cookie preferences manager or by modifying your web browser setting to either (1) refuse some or all cookies or (2) notify you and ask for your permission when a website tries to set a cookie. If you want to learn the correct way to modify your browser settings, please use the “Help,” “Tools” or “Edit” menu in your browser or review the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser. If you choose to disable cookies in your browser, you can still use our Sites, although your ability to use some of the features may be affected. If you want to exercise your rights regarding Personal Information collected via cookies and similar tracking technologies, please see the “Your Privacy Rights” section above.
Mobile App Advertising: When you use our mobile application, we or our Third Party Marketing Partners may use one or more of several different identifiers for your mobile device, including Apple Identifier For Advertising (IDFA) or Android Advertising ID (AAID), to target and deliver ads to you in our app or other apps. This means that your device identifier may be accessed by third-party ad networks and used to (a) help manage the number and types of ads you see; (b) track the source of installs related to ads seen in other apps; and (c) identify your interests and behavior and target advertising to you based on those interests and behavior.
Apple requires app developers to ask for permission before they can track your activity across apps or websites they do not own in order to target advertising to you, measure your actions due to advertising, or to share your information with data brokers. If you previously gave our mobile app permission to track, you can tell our app to stop tracking your activity. On iOS or IPadOS, go to Settings, tap on our app, then tap to turn off Allow Tracking. You can also reset your IDFA from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to your previous IDFA.
If you have an Android device, and are running Android 12 or above, you can delete your AAID permanently by opening Settings, navigating to Privacy > Ads, tapping “Delete advertising ID,” then tapping it again on the next page to confirm. This will prevent any app on your phone from accessing it in the future. Please note that if you do so, you will still see advertisements, but they will not be tailored to your inferred interests.
You may also access industry-provided opt-out tools, although they are not tailored to our mobile applications. For instance, to opt-out of data collection by the Digital Advertising Alliance’s participating member companies for interest-based advertising across mobile applications, download the DAA’s App Choices mobile application opt-out offering at https://youradchoices.com/appchoices.
Website Interest-Based Advertising. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1.
Do Not Track. Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
Our Services are not directed to, and we do not knowingly collect Personal Information from, children under the age of 18. If you are under 18, please do not attempt to fill out our forms or send any Personal Information about yourself to us. If we become aware that a child under 18 has provided us with Personal Information, we will take steps to delete such information from our files.
11) INTERNATIONAL TRANSFERS
If the processing of your Personal Information is subject to the EU or UK General Data Protection Regulation, we will ensure that any international or onward transfer is consistent with applicable law, including: (i) through the use of standard contractual clauses approved by an appropriate regulatory authority, such as the European Commission or the U.K. Information Commissioner’s Office; (ii) an Article 49 derogations in specific situations; or (iii) any other compliant transfer mechanism. We may also rely on an adequacy decision of the European Commission confirming an adequate level of data protection in the jurisdiction of the party receiving the information.
12) THIRD PARTY LINKS
Please note that our Services may contain links to third-party websites, such as delivery services and social media pages. These links are intended for your convenience only. These third-party websites and services are not related to us and may have separate privacy policies and data collection practices. We have no responsibility for these websites or their privacy practices and encourage users to read the privacy policies of all websites they visit.
13) CONTACT INFORMATION