Privacy Policy (full version)

15 March 2019

We”, “our” or “us” means Parkflow UK Limited, a company incorporated in accordance with the laws of England and Wales with company number 11561580 and registered office at 4 More London Riverside, London, SE1 2AU.

This privacy policy (the “Policy”) has been prepared in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and the Data Protection Act 2018 (collectively, the "Data Protection Laws").

This Policy sets out how we use your personal data when you use the Parklook App, which is an online platform through which you may notify other users about the upcoming availability of parking spaces within a specified location at a specified time and/or may have the convenience of knowing when and where a parking space will become available from other users within a particular location (the “Service”, “Services” or the “App”). Further information about our App can be found in our Terms of Service (the “Terms of Service”).

Please contact us if you have any questions about this Policy or the personal data we hold about you. You can contact us by messaging us on our website www.parklook.com or via your user area in the App or by email to info@parklook.com.

1. Executive summary

1.1We operate the App and in order for us to provide the Service to you, it is necessary for us to track your location through GPS technology.

1.2If you wish to use our Service, you will need to turn on location tracking at all times whilst using the Service.

1.3If you turn off the location tracking system on your device, this will make the Services unavailable for further use.

1.4If you turn off location tracking whilst using the Service, this will mean we cannot comply with our obligations under our Terms of Service and may disadvantage you if there is any dispute related to your location during the performance of the Service.

1.5We may use online maps, routing and navigation service providers (such as Google Maps google.com/maps and/or Mapbox www.mapbox.com) to display the maps and various locations in our App, create your routes, track your location data and share your estimated arrival and/or departure times with other users to whom you may offer, or from whom you may book, a parking spot. Those service providers are not processing personal data on our behalf and may (through your use of our Service) collect and track your location and other data.

1.6Our App allows you (unless you turn off the “call function” in our App) to call other users and enable other users to call you directly. This may help you and other users to communicate directly and ask for assistance with finding the location of the relevant parking place and/or the user’s vehicle.

1.7We do not record any user-to-user voice calls. While making and/or receiving calls to/from other users through our App your mobile phone number will not be disclosed, or otherwise made available, by us to any other users and the mobile phone numbers of the other users will not be disclosed, or otherwise made available, by us to you.

1.8You can turn off the “call function” in our App at any time if you do not want to receive calls from other users. However, the unavailability of direct voice communication with other users may make it difficult or inconvenient for you and other users to find the relevant parking spot and/or yours or the other user’s vehicles and therefore may increase the risk of unsuccessful exchanges of parking spots.

2.Information we collect and how we use that information

2.1Information you give us or we collect when you use our Service. If you use our Service then you will complete your user account registration form and provide, or we will collect, the following personal information about you:

  • (a)your full name;
  • (b)mobile phone number;
  • (c)e-mail address;
  • (d)language preferences;
  • (e)information about your vehicle including type, colour and 3 last characters of registration number;
  • (f)GPS location data;
  • (g)IP address;
  • (h)information about your use of the Service for example, order details, date and time the Service was provided, amount charged, distance travelled, location chosen;
  • (i)username and password;
  • (j)technical information, including the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface), mobile network information, your mobile operating system, the type of mobile browser you use, the time zone setting; and
  • (k)traffic data and other communication data that is collected as part of the use of the Service; and
  • (l)such other information which you may provide additionally at your own choice during your account registration (such as model or brand of your vehicle) or communications with our customer support (either via the App or our website online chat).

2.2We obtain the above personal information when you register to use our Service, download or register the App, search for an App or the Service, make or receive payments while using the Service, use our Service, share user feedback via the App, enter a promotion or survey and when you report a problem with our Service. If you contact us, we will keep a record of that correspondence.

2.3Cookies. We also collect information about you using cookies when you visit our web site. For more information on the cookies we are using, please see our cookie policy.

2.4Information we receive from other sources. We may receive information from other users of the Service in connection with you as part of their use of the Service.

3.Why do we process your personal data

3.1If you are using our Service, then we use your personal information to:

  • (a)create, update and manage your user account;
  • (b)provide the Service and track your location using GPS technology;
  • (c)contact you about the contract we have with you;
  • (d)facilitate your use of our Service;
  • (e)connect you with other users and/or connect them with you;
  • (f)respond to a query or complaint that you have sent to us about the Service;
  • (g)resolve disputes between users of our Service and for these purposes we may access your GPS location data;
  • (h)collect user feedback about our Service and about your rating as a participant in the Service;
  • (i)understand how our Service is being used by our users so we can improve the Service;
  • (j)share your feedback about our Service in our App, web site or our social networks profiles (e.g. Facebook, Instagram, Twitter etc.); and
  • (k) make any payments and appreciation awards to which you may be entitled by using our Service; and
  • (l)improve your experience in using our Service.

3.2Please ensure when using our Service that you do not submit any personal data that you do not want to be seen, collected or used by us or other users. Please note however that unless you submit all necessary information which is required by our Terms of Service, certain (or even all) functions of our App may become unavailable for your further use.

3.3When you register to use our Service, we will ask you if you want to receive direct electronic marketing information from us. We will only send you direct electronic marketing mail if you expressly opt in to receive it. You can change your mind about receiving marketing from us at any time by messaging us on our website parklook.com or via your user area in the App or by email to info@parklook.com.

3.4If you do not disable location data tracking when you are not using the Service, then we may collect personal data and aggregate it on an anonymous basis with anonymous personal data from other users to assist marketing companies to display generic marketing material on social media platforms like Facebook and Instagram.

3.5We do not disclose information about identifiable individuals to advertisers, but we may provide them with anonymous aggregated information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day).

3.6We only use such aggregated anonymous information to help advertisers reach the kind of audience they want to target (for example, women in SW1) and may aggregate the personal data we have collected from you to place you within a targeted audience albeit on an anonymous basis.

3.7Our web site uses cookies. A cookie is a small text file which is placed onto your computer (or other electronic devices) when you use our website. We use cookies and other similar tracking technologies on our website. We do this for the following purposes: for example, we may monitor how many times you visit the website, which pages you go to and the originating domain name of a user's internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

4.How we process your personal data lawfully

4.1Under the Data Protection Laws, we must have a legal ground for processing your personal data. We have set these out below:

  • (a)where you are using our Service or are providing us with sign up information as outlined above, GPS location data, or other information required to create or manage your account so you can use our Service, our legal basis for using your personal data is that it is necessary in relation to taking steps prior to entering into a contract with you or for performing our contract with you. Failure to provide your personal data may mean we are unable to fulfil our contract with you and provide the Service to you;
  • (b)we may provide a forum for other users of the Service to rate you as a user of the Services. The legal basis for our use of this information is that it is in our legitimate interests and the legitimate interests of other users of the Service to share feedback about other users using the Service. We have considered our legitimate interests carefully and have balanced them against your rights under the Data Protection Laws. We consider that this is a proportionate use of your personal data because it is important for the integrity of the Service that users can give feedback. If there is a dispute over any feedback provided, then we will investigate the case and share our findings with the complainant;
  • (c)our legal basis for using the personal data we collect when you use our website is that it is in our legitimate interests to understand how our website is being used and to be able to improve the user experience of our website. We have considered our legitimate interests carefully and have balanced them against your rights under the Data Protection Laws. We consider that this is a proportionate use of your personal data because we collect minimal information about you and will only use it to review our Service use and help improve our Service;
  • (d)if you agree to receive direct electronic marketing information from us then our lawful ground for processing is consent. You may withdraw your consent to receive direct marketing at any time.

5.How long we will keep your personal data

5.1We will not keep your personal data for longer than we need it for the purposes we have explained in this Policy.

5.2We will keep the personal data that you provide and that we collect or receive in relation to your account and your contract with us for six years from the date our contract with you ends.

5.3We will keep any personal data you provide or we collect or receive other than where you are a user of our Service for two years after our communication with you ends.

5.4Where we have collected your personal data for marketing, we will keep it for two years from the date you give your opt in consent to receiving marketing from us, or until you withdraw your consent to receiving marketing from us.

5.5Where we have collected location data, we will keep it for one year to resolve any disputes that may arise during this period.

5.6If a dispute arises between us, we will continue to retain your personal data for the purposes of responding to and dealing with any such dispute.

6.Who will have access to your personal data

6.1Your personal data may be collected by or shared with the following third parties for the following reasons when you use our Service or register for an account:

  • (a)we will share some categories of the information you give us and that we collect from you with other users of the Service to enable them to see, check, compare accept or reject your offers and requests and to communicate with you in respect of the Service;
  • (b)we will share your data with our accountants, auditors, marketing support providers (such as agencies which manage our social media accounts) and/or other third-party advisors and providers to the extent that they may need to access your personal data in the context of providing their services to us (only to the extent necessary to provide these services to us);
  • (c)our marketing support providers (such as agencies which manage our social media accounts) may use Google Analytics or similar solutions to customize, monitor and analyse your data (read more here) to the extent that they may need to do so in the context of providing their services to us;
  • (d)we use reputable third parties to provide us with user (help desk) support, support for our internal IT systems, our web hosting, SMS sending and other services. We will share your personal data with them to the extent that they need to access our systems and website to be able to provide their support and other services;
  • (e)online maps, routing and navigation service providers (such as Google Maps google.com/maps and/or Mapbox www.mapbox.com) may have access to your personal data .Those service providers are not processing personal data on our behalf but may (through your use of our Service) collect and track your location and other data for their own purposes and in accordance with their own terms and policies. We cannot prevent them from doing this as it forms part of their service terms so you should read their terms and privacy notices carefully to understand what they may do with your personal data;
  • (f)it is illegal in your country to use hand-held mobile devices while driving or riding your vehicle, unless you have a hands-free access, which may include a voice command. To allow you using a voice command function in our App while driving or riding your vehicle we use voice/speech recognition solutions provided by Google Voice Actions (read more here) for Android mobile devices and Apple Speech (read more here) for IOS mobile devices. Those service providers may (through your use of our Service) collect or monitor your voice commands or other data for their own purposes and in accordance with their own rules and policies. We do not have any influence over which data these providers collect from you and we are also not aware of the extent of their data processing;
  • (g)we may use plugins on our website from social media networks such as Facebook, Instagram and Twitter. We may also use plugins for the embedded video players which may become available on our website. If you click on those plugins, they are activated and automatically transmit data to the relevant plugin provider. We do not have any influence over which data these providers collect from you and we are also not aware of the extent of their data processing, You should read their terms and policies carefully to understand what they may do with your personal data;
  • (h)we may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries where they provide services to us and need to access our systems and web site to be able to provide such services;
  • (i)in the event that we sell all or part of our business, or merge with another organisation, we may transfer personal data that we have collected as described in this Policy, along with our other business assets, to the organisation that we are selling to or merging with; and
  • (j)we will also share your personal data with entities, organisations or individuals outside Parkflow UK Limited where this is necessary to comply with any law, legal procedure or governmental request that is applicable to us, obtain legal or tax advice, enforce the terms of our contracts, prevent or detect fraud or otherwise as permitted or required by law.

7.Transfer of personal data outside the European Economic Area

As a general rule, the data that we collect from you will not be transferred to, or stored at, a destination outside the UK or the European Economic Area (“EEA”) or processed by staff operating outside the UK or EEA. Any transfer of your personal data will be subject to a legally compliant contract that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach or will be transferred under another similar approved mechanism.

8.How is your personal data secure

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

9.Your rights over your personal data

9.1the Data Protection Laws give you certain rights over your personal data that we hold:

  • (a)you have a right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK authority for data protection issues (read more here);
  • (b)you have a right to ask us what personal data we hold about you and to have a copy of the personal data that we hold about you. This includes:
    • (i)details of the purpose for which it is being or is to be processed;
    • (ii)details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
    • (iii)the period for which it is held (or the criteria we use to determine how long it is held);
    • (iv)any information available about the source of that data;

      Requests for your personal data must be made to info@parklook.com in writing and a copy will be retained on your personnel file. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person if possible. There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations.

  • (c)you have a right to request that we correct any errors in your personal data. When exercising this right please provide us with your details and how the information needs to be corrected. Please contact us at info@parklook.com to exercise this right;
  • (d)you have a right to ask us to delete your personal data where:
    • (i)you believe that we do not need your personal data anymore;
    • (ii)you have objected to our processing and we do not have a legitimate interest to continue processing your personal data;
    • (iii)our use of your personal data is illegal;
    • (iv)we have to delete your personal data to comply with our legal obligations; and
    • (v)you have given us consent to process your personal data, you withdraw that consent and we cannot otherwise legally process your personal data.
  • (e)where we have your personal data on the basis of your consent or because we need it to perform our contract with you, you provided your personal data to us and we process your personal data by automated means, you have the right to ask us to give you a copy of your personal data in a commonly used, electronic format;
  • (f)where our use of your personal data is based on your consent, you have the right to withdraw that consent at any time;
  • (g)you have the right to ask us to stop processing your personal data temporarily where:
    • (i)you do not think the personal data we have about you is correct, so that we can check if it is correct;
    • (ii)what we are doing with your personal data is illegal, but you would prefer we stop using your personal data rather than delete it;
    • (iii)we do not need your personal data anymore, but you need us to keep it so that you can exercise any legal rights; and/or
    • (iv)you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing.

9.2If you would like to exercise any of these rights, please contact us by messaging us on our website parklook.com or via your user area on the App or by email to info@parklook.com. We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.

9.3We have summarised your rights above and please note that such rights can only be exercised to the extent permitted under the Data Protection Laws.

10.Changes to our Policy

We keep our Policy under regular review. Any changes we may make to it in the future will be posted on our website, our App and, where appropriate, notified to you by e-mail or when you next use our Service. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Service.

11.How to contact us

Please contact us if you have any questions about this Policy or the personal data we hold about you by messaging us on our website www.parklook.com or via your user area on the App or by email to info@parklook.com.

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