PARKING CORPORATION OF VANCOUVER

PRIVACY POLICY

THIS PRIVACY POLICY CONTAINS LEGAL OBLIGATIONS. PLEASE READ THIS PRIVACY POLICY BEFORE USING THE EASYPARK PLATFORM OR ANY OF OUR SERVICES.

Last Update: [*], 2015

1. Purpose

The Parking Corporation of Vancouver (“EasyPark”, “we”, “us” or “our”) values your privacy and uses this application or website and all of its related webpages and websites (including without limitation any mobile optimized website) to provide you with access to EasyPark’s products and services (collectively, the “EasyPark Platform”). The purpose of this privacy policy (the “Privacy Policy”) is to describe how EasyPark collects, protects, uses and discloses Personal Information that is collected by EasyPark or provided by you as you use the EasyPark Platform.

This Privacy Policy is hereby incorporated into: (a) our Website Terms and Conditions; (b) our Mobile Payments Terms of Use Agreement; and (c) any other agreements with EasyPark into which you may enter from time to time (collectively, the “EasyPark Agreements”).

This Privacy Policy may change from time to time, so please check periodically for updates.

2. Information Collection, Use And Disclosure

Personal Information

For the purpose of this Privacy Policy, “Personal Information” means information about an identifiable individual (including any “Personal Information” as such term is defined in the Personal Information Protection and Electronic Documents Act, Canada or the Personal Information Protection Act, British Columbia), that is collected by us or supplied to us through the EasyPark Platform in order to operate and use the EasyPark Platform. See “Information We Collect” below for a more detailed list of the various reasons why EasyPark collects Personal Information.

Information We Collect

To take advantage of some of the features of the EasyPark Platform you will have to provide us with your Personal Information. You are responsible for ensuring that all information created through your use of the EasyPark Platform and any of our services is accurate, reliable and complete.

We collect, receive, and may store Personal Information. Personal Information may include your full name, user name, phone number, email address, residential address, billing address, shipping address, credit card information (including the credit card number, expiration date, and the full name on the credit card), billing history, trip history, geographic and location information gained through the use of the EasyPark Platform.

We may also collect other supplemental information from various third parties. For example, if you incur a debt to EasyPark, we may conduct a credit check by obtaining additional information about you from a credit bureau, as permitted by law; or, if the information you provide cannot be verified, we may ask you to send us additional information, such as your driver license, credit card statement, or utility bill, to confirm your address, or we may ask you to answer additional questions on our website, via email, or through our customer service centers or programs.

If you do not wish to have EasyPark collect your Personal Information through the EasyPark Platform, you can choose not to provide us with your Personal Information, but that may impair your ability to access and use the EasyPark Platform.

When you download, access and use the EasyPark Platform, information that does not identify you may be collected by EasyPark or our service providers to customize and improve user experience, improve our applications and services, understand usage and navigation trends in the aggregate, determine the relevance of content, and for other planning and evaluation purposes. The information automatically collected is not linked to your Personal Information. In particular, we may collect:

(i) Website Details: Google Analytics or other analytics providers may also collect information about the parts of the EasyPark Platform you use or third party websites you visit when you leave the EasyPark Platform;

(ii) App Usage Details: When you access and use the EasyPark Platform, we may automatically collect certain details of your access to and use of the EasyPark Platform, including location data and other communication data and the resources that you access and use on or through the EasyPark Platform; and

(iii) Other information: We may collect information about your IP address, operating system, browser type, mobile network information. Note that IP addresses may also be linked to Personal Information, to improve your experience while you are using the EasyPark Platform.

Information may be collected by using cookies or mobile cookies, or related technologies. A cookie is a small file placed on your computer, smartphone or other device. It may be possible to refuse to accept cookies or location-based capabilities on your device by activating the appropriate settings. However, if you select these settings you may be unable to access certain parts of the EasyPark Platform.

In installing or operating the EasyPark Platform, the application or operating system may display default notices indicating or requesting access to photos, media, files or contact lists. Please note that EasyPark does not access any such information on your device. EasyPark does not access any files on your device except a local log file that documents your activity within the EasyPark Platform only. This log file is stored on the same memory space as your photos and music, and the operating system and therefore may require such notices to indicate that we have access to that general memory space. Additionally, this log file does not track your activity in any other application, nor does it contain data pulled from any other function on your device. We access the log file when you submit a bug report. The data in the log file allows us to reproduce, and ultimately fix, bugs that you may encounter during your use of the EasyPark Platform.

How We Use Collected Information

We may use any Personal Information provided by you to serve you and to operate and maintain our services. For example, we may use Personal Information to manage the products and services we provide to you, manage your account with us, respond to your requests and inquiries, to customize your future use of the EasyPark Platform, to troubleshoot problems with the EasyPark Platform, to improve the EasyPark Platform, to enforce the EasyPark Agreements, to conduct marketing (including promotional activities), to conduct surveys, to communicate with you and to take any other action required or permitted by law. Note that we do not use Personal Information that identifies you for any marketing purpose unless we have given you the opportunity to consent or withhold consent to such use, in which case we will honor your choice.

By providing Personal Information through the EasyPark Platform, you acknowledge and agree that we may use the Personal Information for the purposes set out above.

When We May Disclose Information

We may use third party companies to provide us with back-end support for the EasyPark Platform and our services, including, but not limited to, our mobile parking payments service, data storage and processing, web hosting and credit card processing. We reserve the right to partner with any third party service providers, and we may share Personal Information with those third parties to allow them to provide services. We also may exchange information with other companies and organizations for fraud protection and credit risk reduction. We will not transfer Personal Information to such third party service providers, except for our business partners who have agreed to comply with legally required privacy standards and who will use the information only for the purposes disclosed at the time of collection or for a use consistent with that purpose. Note that your Personal Information is not disclosed to parking enforcement officers who enforce parking bylaws.

We reserve the right to and may also disclose Personal Information that we believe is necessary or appropriate: (i) to enforce our rights under the EasyPark Agreements, or any other agreements; (ii) to investigate or defend against any allegation or claim against EasyPark or involving the EasyPark Platform or our services; (iii) to assist governmental enforcement agencies or if we reasonably believe that we are required to do so by law or legal process or if we are otherwise requested by any law enforcement officer or agency acting under colour of law; and (iv) to protect the property rights and safety of anyone (e.g., if you are in an accident and are unable to communicate Personal Information to the appropriate authorities, we may provide Personal Information to the authorities). We also may release Personal Information if required to do so by agreement, or if in good faith it is necessary to comply with any agreement.

We may also share Personal Information, in our discretion, to the extent that such information is not readily personally identifiable, including, without limitation, with researchers or the public, such as data challenges or other public disclosures of data that is not readily identifiable.

Retention of Personal Information

We may keep Personal Information obtained through the EasyPark Platform for so long as is necessary or appropriate to carry out the purpose(s) for which such information was collected or for such longer period as may be required or permitted by applicable laws and regulations and your consent to such purpose(s) remains valid after termination of our relationship with you.

Although we have no obligation to do so, we also may retain any email, letter, or other correspondence from you, to ensure quality control.

3. Safeguarding Your Information

We take reasonable security precautions to protect your Personal Information. When we ask users to enter sensitive information (such as a credit card number), that information is encrypted. We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Your PIN protects your mobile pay parking account information from unauthorized access and you are responsible for keeping this information confidential. We ask you not to share this information with anyone. Specific security features include: (i) your account locks after three failed attempts to access it; (ii) only your parker identification is retained on your mobile device, and all other information stays on our service providers’ dedicated servers; (ii) all communications are encrypted; and (iv) we have required our providers to ensure that payment transactions are protected to Payment Card Industry Data Security Standards (PCI DSS).

If you have any question about the security of the EasyPark Platform or about our services, you can send an email to info@easypark.ca. Although we intend to use reasonable security safeguards to protect the security of Personal Information, WE HAVE LIMITED CONTROL AND WE CANNOT PROVIDE OR GUARANTEE COMPLETE SECURITY OF ANY PERSONAL INFORMATION, INCLUDING, BUT NOT LIMITED TO, ANY PERSONAL INFORMATION THAT IS PROVIDED TO THIRD PARTIES, THEREFORE, YOUR POSTING OR TRANSMITTING OF ANY PERSONAL INFORMATION IS DONE AT YOUR SOLE RISK. If there is a serious breach in the security of our services, then we will attempt to contact you using some or all of the Personal Information you have provided to us, to allow you to take further steps that may be necessary to protect your information. We will also take steps to promptly notify the appropriate governmental agencies.

4. Links To Other Sites

The EasyPark Platform may contain links to other websites. Please be aware that we are not responsible for the privacy practices of any other website. We encourage our users to be aware of when they leave the EasyPark Platform and to read the privacy policy of every website that collects personally identifiable information. This Privacy Policy applies solely to Personal Information collected by EasyPark.

5. International Use

Our services are provided in Canada and are intended solely for the use of users in Canada; however, if you use and access the EasyPark Platform or our services from outside of Canada, then be aware that Canadian laws apply to EasyPark, the EasyPark Platform and our services.

6. Policy Regarding Children

We do not knowingly collect or maintain any Personal Information from any person under 16 years of age, and no part of our services or the EasyPark Platform is communicated directly to any person under 16 years of age, except through the person’s parents or legal guardians. If we learn that Personal Information of any person under 16 years of age has been collected without parental or guardian consent, then we may take appropriate steps to delete that Personal Information. If you are under 16, you may use the EasyPark Platform and our services only with the involvement of a parent or guardian.

7. EasyPark Changes

As we continue to develop our activities, we might sell or buy assets, subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets. If we are restructured, or otherwise change our legal or ownership structure, we reserve the right to assign or transfer any Personal Information that we have collected provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

8. Updates and Changes to Privacy Policy

At any time and from time to time, we may unilaterally amend, modify, or change this Privacy Policy in our sole discretion. Notice that this Privacy Policy is amended, modified or changed by EasyPark will be given to you by either: (i) a posting of a notice on the EasyPark website; (ii) an e-mail to you; or (iii) by in-app notification. By continuing to use the EasyPark Platform or any of our services after any amendment, modification, or change notice was provided, you have agreed to be bound by all such amendments, modifications, and changes. Therefore, please carefully check the EasyPark website and provided e-mail address on a regular basis to maintain awareness of all amendments, modifications, and changes to this Privacy Policy. If you choose to use the EasyPark Platform or any of our services, your use and any dispute over privacy is subject to this Privacy Policy and the EasyPark Agreements.

9. Contact Us

For more information or if you have questions or concerns regarding this Privacy Policy, please contact us at the address, telephone number, or email address below:

EasyPark Vancouver
209-700 West Pender Street
Vancouver, BC
Canada V6C 1G8
Phone: (604) 682-6744
Email: info@easypark.ca

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