Introduction

This GDPR Privacy Addendum (the “GDPR Privacy Addendum”) supplements the information contained in Parking Revenue Recovery Services, Inc.’s (“PRRS” or “we” or “us”) Privacy Policy (our “Privacy Policy”) and applies solely to the users of our Website, App and Services who are located in the European Economic Area. We adopt this GDPR Privacy Addendum to comply with the European Union’s General Data Protection Regulation, and any laws implementing the foregoing by any member states of the European Economic Area (the “GDPR”). Unless otherwise defined in this GDPR Privacy Addendum, any terms defined in the GDPR or our Privacy Policy have the same meaning when used in this GDPR Privacy Addendum. When this GDPR Privacy Addendum is applicable to you, it takes precedence over anything contradictory in our Privacy Policy.

Data Controller, Data Protection Officer, and Representative

PRRS is the data controller of your Personal Data. At this time, PRRS is not required to appoint a Data Protection Officer or representatives in the European Union, and has elected not to do so. PRRS may be contacted in any manner set forth below in the “Contact Information” Section of this GDPR Privacy Addendum.

Information We Collect About You and How We Collect It

The Personal Data we collect is identified in Appendix A. The ways in which we collect it are described in our Privacy Policy.

We collect Personal Data from you in order to provide you with our Services. By entering or exiting a participating parking facility with which we partner to provide our Services, or otherwise using our Services, you consent to our processing of Personal Data. If you do not consent, you must not enter the facility or utilize our Services.

Lawful Basis for Processing Your Personal Data

The processing of your Personal Data is lawful only if it is permitted under the GDPR. We have a lawful basis for each of our processing activities:

• Consent. By using our Website, App or Services, you consent to our collection, use, and sharing of your Personal Data as described in our Privacy Policy and this GDPR Privacy Addendum. If you do not consent to the terms of our Privacy Policy and this GDPR Privacy Addendum, please do not use the Website, App or Services;
• Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your interests and rights and freedoms and we do not process your Personal Data if your interests or rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: fulfil our obligations under a contract to you, to comply with a legitimate interested legal obligation that we are subject to, and meet the legitimate interests pursued by us or by a third party and such processing is not considered to be harmful towards you, such as our interests in developing, evaluating, marketing and selling our products and services, pursuing, developing and maintaining business relationships with our customers, suppliers and other business relations, facilitating communication between PRRS and you, detecting and correcting bugs and to improve our Website, App or Services; safeguarding our IT infrastructure and intellectual property; and detecting and preventing fraud and other financial crime.
• As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

Special Categories of Information

PRRS does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data, such as race or ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, genetic/biometric data, sexual orientation, and/or health, from you.

Automated Decision Making

PRRS does not use your Personal Data with any automated decision-making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.

How We Use Your Information

We use your Personal Data as described in our Privacy Policy.

Disclosure of Your Information

We share or otherwise disclose your Personal Data with the entities and for the purposes described in our Privacy Policy. If we share your Personal Data with third parties that carry out services on our behalf, we enter a written Data Processing Agreement that requires that the third parties only process the Personal Data for the purpose it was provided, in accordance with our instructions, and as otherwise permitted by the agreement.

Your Rights Regarding Your Information and Accessing and Correcting Your Information

The GDPR provides you with certain rights with regards to our processing of your Personal Data. These rights replace the similar rights provided in our Privacy Policy or are supplemental to such rights.

• Access and Update. You can request to review your Personal Data by contacting us via the email listed under Contact Information below. If you believe of any information is incorrect, please let us know. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
• Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
• Portability. To the extent the Personal Data you provide PRRS is processed based on your consent and that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
• Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
• Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
• Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
• How You May Exercise Your Rights. You may exercise any of the above rights by contacting us via the email listed under Contact Information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We shall respond to your request no later than one (1) calendar month, starting from the day we receive the request. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.

Consent to Processing of Personal Data in Other Countries Outside the European Economic Area

In order to provide our Website, App, and Services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your information may be processed and stored in the United States and United States federal, state, and local governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of the United States. By using our Website, App and Services, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States.

Your Personal Data is transferred by PRRS to another country only if it is required or permitted under the GDPR, to the extent applicable, and provided that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with our Privacy Policy and this GDPR Privacy Addendum when we transfer it to a third party, PRRS uses Data Processing Agreements between PRRS and other recipients of your data where required by GDPR and, where applicable, are based upon the standard contractual clauses adopted by the European Commission (collectively, the “Standard Contractual Clauses”). You may request a copy of the Data Processing Agreement by contacting us through the Contact Information below.

Data Retention Periods

PRRS will retain your Personal Data for the entire time that you keep your account open / until you request us to delete your Personal Data (subject to above). After this period, we may retain your Personal Data for up to one (1) year, or for any of the reasons listed below, whichever is longer:

• for as long as necessary to comply with any legal requirement;
• on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
• for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
• for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

Changes to This GDPR Privacy Addendum

We may change this GDPR Privacy Addendum at any time. It is our policy to post any changes we make to our GDPR Privacy Addendum on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you by posting a notice on the Website’s home page. The date this GDPR Privacy Addendum was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this GDPR Privacy Addendum to check for any changes.

Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or this GDPR Privacy Addendum, or have any requests related to your Personal Data, please contact us at:

Parking Revenue Recovery Services, Inc.
12381 East Cornell Ave, Aurora, CO 80014, USA
Phone: (877) 302-7275
Email: Privacy@prrsparking.com