California Privacy Policy

Effective April 3rd, 2020

This Privacy Notice for California Residents supplements the information contained in ACE Parking Management, Inc.’s and its subsidiaries (“ACE’s” “Company’s”) privacy policy and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”).  We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Consistent with the CCPA, job applicants, current and former employees and independent contractors (collectively, “Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered “Consumers” for purposes of this California Privacy Notice or the rights described herein.  However, our Personnel may obtain a separate privacy notice that is applicable to them by contacting their local Human Resources department. Publicly available information is also not treated as Personal Information under the CCPA, so this notice is not intended to apply to that data and your Consumer privacy rights do not apply to that data.

INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”).  In particular, ACE has collected (or not collected, if indicated below) the following categories of personal information from its consumers within the last twelve (12) months:

CategoryExamplesCollected
A. Identifiers.A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, address, telephone number, education, employment, employment history, credit card number, debit card number, or any other methods of payment for our products, or medical information.
Some personal information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law.Age (40 years or older), medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status. NO
D. Commercial information.Records of products or services purchased, obtained, or considered.YES
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NO
F. Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.YES
G. Geolocation data.Physical location or movements.YES
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.NO
I. Professional or employment-related information.Current or past job history or performance evaluations.YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NO
K. Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NO

HOW WE COLLECT YOUR INFORMATION

ACE obtains the categories of personal information listed above from the following categories of sources:

  • Direct interactions. You may give us your information by filling in forms or by corresponding with us by mail, phone, fax, email or in-person. This includes, but may not be limited to, personal data you provide when you:
    • fill out a form, use or access our website or our mobile app, such as when you make a reservation or make a purchase;
    • create a user account on our website;
    • use any of our services, including when you stay with us or visit one of our partners’ parking or other facilities in which we manage or provide services.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Parking lot, parking garage, and other facility owners.
    • License Plate Recognition Systems.
    • Technical data from the following parties:
      (a) Analytics providers such as Google;
      (b) Advertising networks such as Google Adwords, Bing Adcenter, Amazon ads, Criteo sponsored ads, and IPromote display ads; and
    • Data from providers of technical, payment and delivery services such as PayEezy, PayTrace and USAePay.

USE OF PERSONAL INFORMATION

We may use and/or disclose the personal information we collect for one or more of the following business purposes:

  • To Fulfill or meet the reason you provided the information.  For example, if you provide your name, address, phone number and employer name in order to park in one of the facilities we manage.
  • Fulfillment of reservations and other purchases. Completing your parking reservation or transaction; supplying the purchased goods and services; customizing our services to your preferences; and keeping proper records of those transactions.
  • Customer support. Notifying you of any changes to our services; responding to your inquiries via email, phone, or writing; investigating and addressing concerns raised by you; and monitoring and improving our customer support responses.
  • Improving our services. Conducting data analysis and audits; developing new products and services; enhancing our website and mobile app; improving our services; identifying usage trends and visiting patterns; conducting customer satisfaction, market research, and quality assurance surveys; determining the effectiveness of our promotions and meeting contractual obligations.
  • Marketing and promotions. Sending you emails and messages about news and new promotions, features, products and services, and content.
  • Parking violations; legal proceedings and requirements. Investigating or addressing claims or disputes relating to your use of our services; or as otherwise allowed by applicable law; or as requested by regulators, government entities, and official inquiries.

ACE will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

SHARING PERSONAL INFORMATION

ACE may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we require that the recipient both keep that personal information confidential and not use it for any purpose except performing the contract.

We do not sell your name or other personal information to third parties.  However, we may share your personal information with the following categories of third parties:

  • Within the ACE Family of Companies. We share information within the ACE family of companies to help us provide our services or conduct data processing on our behalf.
  • With ACE service providers and business partners. We may provide information to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This may include, for example:
  • Payment processors and facilitators
  • Cloud storage providers
  • Marketing partners and marketing platform providers
  • Data analytics providers
  • Research partners
  • Consultants, lawyers, accountants and other professional service providers
  • Insurance and financing partners
  • With our clients. We may share your information with our clients (for example, property owners) where we have a contractual agreement to do so in order to provide services to you.
  • With your consent. We may share your information other than as described in this policy if we notify you and you consent to the sharing.
  • For legal reasons or in the event of a dispute. We may share your information with third parties for legal reasons or in the event of a dispute. This may include, for example:
  • In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company
  • To comply with a court order, search warrant, subpoena, or other legal process
  • To comply with legal, regulatory, or administrative requirements of any government or law enforcement authority
  • To establish or exercise our legal rights and to protect and defend us in connection with any threatened or actual legal action, claim or dispute

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category D: Commercial information.
  • Category I: Professional or employment-related information.

In the preceding twelve (12) months, Company has not disclosed the following categories of personal information for a business purpose:

  • Category C: Protected classification characteristics under California or federal law.
  • Category E: Biometric information.
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data.
  • Category H: Sensory data.
  • Category J: Non-public education information.
  • Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

Within the ACE Family of Companies. We share information within the ACE family of companies to help us provide our services or conduct data processing on our behalf.

  • With ACE service providers and business partners. We may provide information to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This may include, for example:
  • Payment processors and facilitators
  • Cloud storage providers
  • Marketing partners and marketing platform providers
  • Data analytics providers
  • Research partners
  • Consultants, lawyers, accountants and other professional service providers
  • Insurance and financing partners
  • With our clients. We may share your information with our clients (for example, property owners) where we have a contractual agreement to do so in order to provide services to you.


SALES OF PERSONAL INFORMATION
In the preceding twelve (12) months, Company had not sold any categories of personal information (for both minors and non-minors).  ACE does not sell personal information to third parties.

DATA RETENTION

ACE will retain your personal information for as long as reasonably necessary to fulfill the purposes for which we collected it, and to satisfy any applicable legal, regulatory, or reporting requirements.  To determine the appropriate retention period, we evaluate the intended use, amount, and sensitivity of the personal information.

YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights.  You have the right to request that ACE disclose certain information to you about our collection and use of your personal information over the past 12 months.  Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.

Deletion Request Rights.  You have the right to request that ACE delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it

Exercising Access, Data Portability, and Deletion Rights.  To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format.  We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination.  We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you through a notice on our website.

CONTACT INFORMATION

If you have any questions or comments about this notice, the ways in which ACE collects and uses your information described in this privacy policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

ACE Parking Management, Inc.
Attn: Chris Lynch
645 Ash Street
San Diego, CA 92101

Phone: 1.855.ACE.PARK
Email: personaldatarequests@aceparking.com