This Automated License Plate Recognition (“ALPR”) Policy (the “Policy”) describes the methods and practices employed by UPP Global (“UPP,” “We,” “Us,” “Our”) to efficiently monitor and effectuate its Services. The purpose of this Policy is to ensure the collection methods, usage, maintenance, and dissemination of ALPR data respects consumer’s rights to privacy and is compliant with applicable law. This Policy pertains only to UPP and its corporate affiliates and its/their officers, directors, employees and agents (collectively, also, “UPP”). For more information on how UPP interacts with users through this Website, including any collection or processing of data or other identifiable information, please see our Privacy Policy and Terms of Use.

Applicability Of This Policy. This Policy pertains only to UPP interaction with and use of ALPR deployed at one of our physical locations. This Policy may also be applicable to any third-party ALPR related information received from other third parties (e.g., law enforcement). Whether UPP releases such ALPR information or data is dependent on applicable law and this Policy. This Policy does not apply to ALPR data in the possession or control of others. Please carefully review the ALPR policies for how third-parties use and collect ALPR data.

What is ALPR? Automated License Plate Recognition (ALPR) technology utilizes cameras equipped with character recognition software and various processes to capture and retain digital images of vehicle license plates to create a searchable computerized database resulting from the data collected by fixed and/or mobile cameras located at UPP’s various locations. ALPR data includes your license plate number and state information, as well as the date, time and geolocation of when and where the image or information was collected for the purposes outlined in this Policy.

1. Why UPP Utilizes ALPR Data. ALPR utilization is an efficient means to streamline business services and provide a more efficient customer experience at applicable locations. This is achieved through digital capturing, analysis, and retention of license plate data to enable the expeditious identification of vehicles to support parking operations, compliance, and enforcement activities. ALPR is also an efficient method to supplement and/or replace the use of proximity access cards and permit stickers for subscription-based services as well as paper tickets that log the times/fees related to when a vehicle either enters or exits one of our physical locations.

2. How We Use ALPR Data. UPP may use ALPR data to:

· Determine correct parking fees for lost ticket transactions;

· Identify and track abandoned vehicles;

· Verify the number of vehicles parked in our locations;

· Verify overnight vehicle parking;

· Respond to inquiries from law enforcement agencies;

· Identify open parking spaces and availability;

· Permit automated entry/exit of vehicles without utilizing personnel or traditional entry/exit gates;

· Issue fees, tickets, or notices to consumers;

· Collection of unpaid debts;

· Generate internal parking data and metrics for UPP’s locations.

3. What Types of ALPR Data Is Collected. The following information may be collected by our ALPR system(s):

· Vehicle license plate image captured;

· Vehicle license plate number;

· Vehicle license plate state;

· Date;

· Time;

· Geolocation data;

· Payment information/method; and,

· Parking device information.

4. Release of ALPR Data. UPP will not share collected ALPR data with any individual or entity, except as may be necessary to effectuate UPP business and operations. ALPR data collected and retained will not be:

· Sold, published, exchanged, or disclosed for commercial purposes;

· Disclosed or published without authorization except as may be required for law enforcement purposes; or

· Disseminated to persons or entities without a right to know/not authorized to access or use the data.

5. Requests from Third Parties. ALPR data will not be disclosed to the public or in a civil matter unless such disclosure is required by law or court order. Additionally, UPP may disclose ALPR data if requested by a federal, state, or local law enforcement or other governmental agency by legitimate inquiry, or, if a warrant or other court order is issued and served to compel disclosure of such information. Any specific request for ALPR data UPP receives from any third party is subject to UPP conditional review and approval. If a request is approved, UPP would seek to require that such third-party certify compliance with all applicable laws and/or ensure confidentiality of such information consistent with UPP’s policies and practices.

6. ALPR Data Storage & Retention. This section applies only to how UPP stores and retains ALPR data: Please consult the ALPR policies of our independent service providers for information about how long these providers retain ALPR data. ALPR data is typically transmitted to and stored by the databases of independent third-party service providers. ALPR data accessible by UPP may be stored in our databases for purposes of processing parking related transactions. For example, data may be used to allow customers to enter and exit UPP locations with a valid permit without needing to provide payment, or, to effectuate other legitimate business purposes, e.g., to supplement or replace access cards, parking tags/decals/stickers, and other related materials.

ALPR data retention periods may vary depending on location. Additionally, such data may be destroyed or overwritten under certain circumstances, including, but not limited to, when a facility’s data storage capacity is reached/exceeded. To ensure that data is not lost, we may centrally store and maintain your data by utilizing internal business processes as a safeguard. ALPR data stored in our systems does not include:

· Photographs of individuals;

· Photographs of you;

· Photographs of the vehicles;

· Close-up photographs of license plates;

Instead, ALPR data is stored only in a numerical format that may include an accompanying date and time of capture, and geolocation data related to the location of capture, none of which directly identify an individual.

7. Restricted Uses. The sale and unauthorized dissemination of ALPR information is strictly prohibited by company policy. Violations will include disciplinary action up to and including termination of employment. We only use ALPR to collect license plate data from within public view. We do not use any ALPR data to harass, intimidate or discriminate against any consumer, individual, or groups afforded constitutional/statutory protections.

8. Quality Assurance Measures. UPP shall take appropriate measures to ensure accuracy, correct license plate translation errors when identified, and confirm any inadvertently collected or accessed information will be removed and/or not used in the event UPP discovers any such issues related to the collection of ALPR data.

9. Security Measures. UPP and its third-party service providers utilize safeguards to protect your ALPR data from unauthorized access, disclosure, and usage. Specifically, UPP employs administrative, operational, and physical safeguards to protect ALPR data, including, but not limited to, limiting access to sensitive data to only authorized personnel, creating password protected accessibility to our ALPR system, and training our authorized uses on proper usage and security protocol. Access to ALPR is primarily limited to the following individuals/entities:

· Parking supervisors;

· Parking facility managers and/or their designees;

· Assistant parking managers;

· Auditors;

· Information technology (“IT”) personnel and contractors;

· Designated financial personnel for recordkeeping purposes.

Additionally, UPP utilizes trustworthy third-party service providers to safeguard ALPR data within their possession and control.

10. Changes To This Policy. We reserve the right to make changes to this Policy at any time and for any reason. Any changes will be reflected in a revised policy posted on our website: UPP Global and we will alert you that there has been a change by updating the “Updated” date displayed on this Policy. If UPP determines that such changes materially affect your privacy rights, we will provide additional notice to you.

Applicable Law. Various state laws in the United States govern whether an ALPR system may be used by business organizations or law enforcement authorities. We may incorporate ALPR at physical locations we own or manage. We do not employ the use of ALPR where prohibited by state law.

Contact Us. If you have additional questions or comments about this Policy, please send us an email at support@uppglobal.com. If you prefer, you may also contact us via physical mail at: 496 Congress Street, Suite 3, Portland, Maine 04101.

Updated 11/12/2024

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Automated License Plate Recognition (ALPR) Policy UPP Global