PERSONAL DATA PROCESSING AND PRIVACY POLICY - MR.PARKIT s.r.o.

This personal data processing and privacy policy has been written to inform you of how we process (use) and protect your personal data. When we say “you”, we mean:

• ou as our customers, to whom we provide parking services, i.e. if you have reserved a parking spot in any of the garages/parking lots we offer, or
• ou as garage/parking lot operators, with whom we have a contract placing your garage/parking lot in our portfolio. We also consider you garage/parking lot operators if you own independent parking spots that we offer for our customers’ use

PERSONAL DATA PROTECTION BASICS

Personal data means all information that identify you or can be used to identify you, as well as information about you (your personality, activities, property, etc.). We consider your personal data confidential and always handle it with care.

Processing personal data means any operation or set of operations with personal data or sets of personal data, performed with or without the use of automated processes, such as collecting, recording, organizing, structuring, saving, adapting or changing, searching, viewing, using, disclosing by transfer, disseminating or any other disclosing, classifying or combining, restricting, erasing or destroying. Processing means fully or partly automated processing of your personal data and non-automated processing only if personal data is held or supposed to be held on record.

We uphold the following basic rules under all circumstances when processing personal data:

• Legality, propriety and transparency: We process your personal data legally, properly and transparently.
• Purpose restriction: We collect your personal data exclusively for certain, explicitly stated and legitimate purposes, and we do not process your personal data in any way that is incompatible with these purposes.
• Minimization: We process personal data only in the appropriate, relevant and restricted scope, and only in relation to the purpose for which we are processing it.
• Accuracy: We make sure that the personal data we process is accurate and updated as necessary. We take any and all reasonable measures to ensure that inaccurate personal data is erased or corrected immediately – considering the purposes for which we process it.
• Restricting saving: We save your personal data in a form that can identify you for no longer than necessary for the purposes for which we process it.
• Integrity and confidentiality: We make sure that the personal data we process on you is secure. We process your personal data in a way that ensures it is properly secured, including technical and organizational measures taken against unauthorized or unlawful processing and against random loss, destruction or damage. We use advanced physical and electronic security measures.
• Localization: We store all your personal data in the Czech Republic and do not send them to countries outside the European Union.

Road map

If you are our customers, please focus on the section on personal data in providing parking services. If you are a garage/ parking lot operator, go to the section on personal data of garage/parking lot operators. In both cases we may also process your personal data for marketing and commercial purposes (see the section on personal data processing for marketing and commercial purposes).

Some data that can under certain circumstances be tied to a specific natural person is the product of using cookies and web beacons (see the section on cookies and web beacons), so we have also included the rules that apply to these technologies. A separate section is devoted to online accounts (see the section on online accounts) that you may have set up to use our services.

Finally, this policy will inform you of the conditions under which we may disclose your personal data and to whom (recipients) and of your rights in connection to the data processing.

PERSONAL DATA IN PROVIDING PARKING SERVICES

If you have ordered parking services from our company using the mrparkit. com website or in any other manner, please be aware that we process your personal data associated with that. This involves especially your identification and contact data, the subject of the parking services and course of the contractual relationship (billing, etc.), including communication with you. We typically process: billing information, email address, driver’s first and last name, driver’s phone number (especially, but not exclusively, for activating access to the garage/parking lot) and vehicle license plate number and color.

We process personal data for the purposes of due provision of services. In a situation (a typical case) where we are brokering parking services for the garage/ parking lot operator, we issue accounting documents and accept payments on their behalf. In such a case we also process personal data in the interest of settling the contractual relationship between us and the garage/parking lot operator. If the vehicle driver is not the person who ordered the parking services directly, we process – with regard to our legitimate interests in due provision of services – the driver’s first and last name, phone number and email address; the same applies to the vehicle license plate number and color if the person who ordered the services is not the owner/operator of the vehicle. The person who ordered the services must ensure that the driver and owner (operator) of the vehicle are made familiar with our privacy policy.

If you pay for our services by card, the payment is made through a secure portal operated by Československá obchodní banka, a.s.; we have no access to the personal data or any other data used to authorize the payment transaction. If you pay for our services by PayPal, the payment is made through PayPal’s secure web interface; we do not use any additional personal data sent to us by PayPal in connection with the payment (address) for any purposes other than to identify the payment.

We process (store) personal data for the period for which it is legally relevant for performing under the contractual relationship (parking services), i.e. until the applicable periods have passed (limitation, preclusive, warranty, storage and other periods as stipulated by legal regulations or by agreement of the parties, until the last of these periods has passed. The period for assessing the relevant contractual relationship is different from case to case, but usually not more than 10 years after performing the contractual relationship, i.e. the end of the reservation. We store personal data entered concerning orders that were not finalized on your part for five months after you enter them, and then we anonymize them.

PERSONAL DATA OF GARAGE/PARKING LOT OPERATORS

If you are a garage/parking lot operator, we process the personal data in the agreements you have made with us (agency agreements) and the personal data arising from performance under those agreements. This involves especially (but not exclusively) your identification and contact data, the subject of the agreement and course of the contractual relationship (invoicing, etc.), including commercial communication with you. Naturally, we also have to process this personal data in order to uphold our contractual obligations and exercise the rights under these agreements and meet the legal obligations associated with them.

We acquire personal data of this nature primarily from you, but depending on the circumstances we may also obtain them from other sources (e.g. from customers we arrange parking for in your garage/ parking lot). We always proceed with the utmost transparency in this regard.

We may also process your personal data before entering into an agreement so that the agreement can be duly made. If the agreement is not concluded because the parties do not reach an accord or for any other reason, we will continue to process your personal data in the scope necessary in order to resolve any precontractual issues and the associated liability, including performance of the associated legal obligations.

We process (store) personal data for the period for which it is legally relevant for performing under the contractual relationship, i.e. until the applicable periods have passed (limitation, preclusive, warranty, storage and other periods as stipulated by legal regulations or by agreement of the parties, until the last of these periods has passed. The period for assessing the relevant contractual relationship is different from case to case, but usually not more than 10 years after performing (ending) the contractual relationship. In the case of contractual relationships prepared but not performed, personal data is processed until the relevant limitation periods related to precontractual liability have passed.

PERSONAL DATA PROCESSING FOR MARKETING AND COMMERCIAL PURPOSES

We also process your personal data for marketing and commercial purposes, for two reasons:

• first, so we keep our customers and garage/parking lot operators informed of new developments and what we have on offer and so we can give them information upon request about what we have on offer; and
• secondly, so we can personalize our approach to you if we work together (history of parking services, commercial history, etc.).

We process personal data in order to contact you with news and what we have on offer if there is a reasonable expectation that you are interested in what we offer; this expectation exists especially if you are or have been our customers or garage/ parking lot operators we work or have worked with in the past. We process personal data in order to personalize our approach if you have had commercial contact with us, i.e. if you have used our parking services or if you are or have been garage/parking lot operators working with us.

We respect the fact that your email address can only be used to send commercial messages if you have given it to us as our customer or as a garage/ parking lot operator or if you have given your consent for us to use your email address for this purpose. You can withdraw your consent at any time; for ways to do this, see the section called “Your rights”. Every email we send includes a simple, clear opportunity to reject further commercial messages in the form of an electronic opt-out.

We process the following personal data for marketing and commercial purposes (not all types of personal data are necessarily processed for every person):

• identification and contact information (first and last name, postal address, email address, phone number, etc.);
• profile personal data in relation to our cooperation (order history, business relationship, services ordered, participation in MR.PARKIT events, reviews, etc.);
• data letting us personalize communication with you (communication history, last contact, etc.)

We may combine any or all of the personal data we process to create profiles of data subjects that we will use for the purposes described above.

We acquire personal data for marketing and commercial purposes primarily from the contractual relationships we have formed with you (including parking services you have ordered) and the messages you send us through online forms, social media, phone, etc.

The legal basis for our processing of your personal data is our legitimate interest in using the data for marketing and commercial purposes in the interest of maintaining and developing commercial contacts and conducting our business. You have the opportunity to object to the processing of your personal data for marketing and commercial purposes. If you object to the use of your personal data for sending commercial messages or other forms of direct marketing, we will immediately stop processing your data for those purposes. If you object to the use of your personal data for personalizing our communication with you, we will assess the reasons for your objection (given your specific situation) to see whether we have serious, legitimate grounds for continuing to process your data outweighing your interests or rights and freedoms. We will then inform you of whether we will accept your objection or, if we cannot accept it, then our grounds for not doing so. For ways to make an objection, see the section called “Your rights”.

We process (store) personal data for contacting you with news or what we have on offer for as long as you can be reasonably expected to be interested in our offers, unless you have previously objected to such processing or withdrawn your consent to such processing. We process personal data for personalizing our communication with you for no longer than 10 years after the last business contact with you.

COOKIES AND WEB BEACONS

On mrparkit.com we use cookies, which are small text files containing data about accessing the website through the web browser saved on your computer, which then sends the data to our web server the next time you visit our website. Cookies help personalize website settings and improve user experience, including saving user preferences. We may also use cookies to adapt advertisements and monitor web traffic.

We may also use web beacons on our website or in the emails we send. Web beacons are small graphic elements (data files, pixel tags) downloaded from our web server for tracking emails, web traffic and user behavior, and then optimizing electronic services for users (including personalized ads).

The circumstances described above (personalizing settings and monitoring web traffic, personalizing ads, monitoring interest in our messages) represent our legitimate interests in connection with improving the services we provide. In our opinion, these activities are also of benefit to you. However, if you do not want us to use cookies and web beacons, you can opt out. When you first visit the website on a particular web browser, you will be asked for your consent to the use of cookies, which will only be used if you express your consent. You can cancel your consent to the use of cookies at any time. The most practical way of doing so is by deleting the cookies on your web browser. You can also stop your computer from saving cookies or sending requests to download web beacons by deactivating the appropriate settings in your web browser.

We do not use personal data acquired using cookies and web beacons to identify you.

ONLINE ACCOUNTS

We allow customers and garage/parking lot operators to manage their cooperation with us if they wish (orders and reservations, complaints, communication, etc.) using MR.PARKIT online accounts.

You can use your online account to manage your identification and contact information and certain other data. If you delete certain data through your online account or replace it with different data, this is equal to withdrawing your consent to processing the deleted or replaced personal data, if that data was processed only on the basis of your consent. If the data is processed on a legal basis other than consent, we continue processing deleted or replaced personal data under the conditions applying to the relevant legal basis for processing. Deleting or replacing the data is considered updating the status.

HANDING PERSONAL DATA OVER TO THIRD PARTIES (RECIPIENTS)

With the exceptions described in the following points, we do not hand personal data over to any third parties, directly or indirectly (by granting access). We do not buy or sell personal data.

We may disclose personal data to subjects that process personal data for us or provide us with services that require the disclosure of personal data. This involves, in particular, IT services (server hosting or web hosting), database services, accounting services, tax advisory services and legal services. Our work with these subjects always remains on a purely operational level. The recipients do not process the personal data independently, but only strictly in accordance with our instructions. We are responsible for ensuring that recipients do not misuse the personal data disclosed to them and that they are bound by integrity and confidentiality clauses regarding personal data and other obligations pursuant to valid legislation.

We disclose our customers’ personal data in the scope necessary to the relevant garage/parking lot operators in order to provide the parking services. Garage/ parking lot operators are independent data controllers and we are not responsible for them. The rules for processing personal data by garage/parking lot operators are given in the rules of operation for individual garages/parking lots or in the related operator documentation. If such documentation is not available, then processing personal data by garage/ parking lot operators is governed by valid legal regulations.

Your personal data can also be disclosed to third parties if necessary for meeting our legal obligations (this primarily applies to public authorities) or if necessary based on the nature of the matter, in particular in order to perform under a contractual relationship to which you are party.

YOUR RIGHTS

You have the right to receive confirmation from us on whether we process your personal data or not. If we do, then you have the right to access the personal data we process and receive detailed information on the processing and sources of your personal data. If you provided us with your personal data on the basis of your consent or in connection with performing contractual obligations, and if the personal data is processed automatically, you have the right to receive said data in a structured, commonly used and machine- readable format.

You have the right to have us correct any inaccuracies in your personal data without delay; this also applies to filling in incomplete personal data. You also have the right to require that we erase your personal data if we do not have sufficient legal basis to process it (e.g. if you objected to processing your personal data for the purposes of direct marketing). If you so request, instead of erasing your personal data, we will simply restrict the processing, i.e. the personal data will only be stored and not processed in any other way without your consent.

You have the right to object at any time to the processing of your personal data for the purposes of direct marketing, and your personal data will no longer be processed for that purpose. If you object to the processing of your personal data in other cases where we process the personal data on the basis of our legitimate interests, we will first assess the reasons for your objection (given your specific situation) to see whether we have serious, legitimate grounds for continuing to process your data outweighing your interests or rights and freedoms. We will then inform you of whether we will accept your objection or, if we cannot accept it, then our grounds for not doing so.

You are entitled to exercise your rights in any form that clearly communicates the content of your request, notification or objection, in particular in electronic form by sending an email to info@mrparkit. com. If you request that we take a certain measure, we will inform you of the measures taken without undue delay, no more than one month after receiving your request. This time frame can be extended by an additional two months if necessary, and if so then you will be informed in a timely manner.

If you feel that your rights are being infringed in connection with how we are processing your personal data, you can file a complaint with the Office for the Protection of Personal Data (www.uoou.cz).You also have the right to file a civil suit in court and seek judicial protection.

The English version of the Operation Rules of the garage is a translation of the original Czech version. It is only of an informative nature. In the event of any discrepancy between the English and Czech versions, the Czech version takes precedence.