Automated License Plate Recognition (ALPR) Usage and Privacy Policy

Wayleadr ("Wayleadr") uses Automated License Plate Recognition ("ALPR") technology, which consists of a system of cameras and associated software that capture and process license plate information ("ALPR System"). The ALPR System is installed at entrances and exits of Wayleadr's clients' parking facilities.

DATA COLLECTION

The following data may be collected using Wayleadr's ALPR System (collectively, "ALPR Data"):

• License plate numbers and license plate state;
• Still images of vehicles (and surroundings); and
• Date, time, and geographic location associated with each of the categories of data listed above.

PURPOSE

ALPR Data may be accessed and used for the following purposes:

• To manage parking operations and enforce parking policies, including administering the reservation of parking places and access to parking facilities;
• To be used in capacity-planning analytics for parking facilities; and
• To cooperate with law enforcement agencies, government requests, subpoenas, court orders, or valid legal process.

AUTHORIZED PARTIES

Access to ALPR Data is limited to Wayleadr's Customer Service Managers, Technical Solutions Experts, Project Coordinators, Director of Implementations, Director of Customer Service, Full Stack Engineers, Senior Software Engineers, and Lead Engineers ("Authorized Users").

Authorized Users are required to complete privacy and information security training before they may access ALPR Data, which addresses the handling of ALPR Data to protect privacy interests and comply with applicable laws.

DATA RETENTION

ALPR Data is retained for 90 days, except as required to comply with legal obligations, in connection with active investigations, or in connection with managing parking operations and enforcing parking policies. After the retention period expires, we take steps to securely delete or anonymize the ALPR Data.

DATA SHARING

Wayleadr does not sell, lease, or otherwise commercially distribute ALPR Data. ALPR Data may be shared with third parties in limited circumstances, including:

• With our service provider, Amazon Web Services (AWS), which provides our secure storage environment, subject to the confidentiality agreement between Wayleadr and AWS.
• To law enforcement or other governmental authorities in response to lawful requests, to comply with legal process, or in other cases if we believe the disclosure is required or appropriate to comply with legal or regulatory requirements.
• To third parties in connection with or anticipation of an asset sale, merger, bankruptcy, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of all or some of our assets; or as needed support for external auditing, compliance, legal, and corporate governance functions.

DATA SECURITY

Wayleadr implements reasonable security measures designed to protect ALPR Data, including:

• Encryption and secure storage on Amazon Web Services;
• Network and system access controls; and
• Monitoring, with roles-based access control, for unauthorized access to ALPR Data.

Wayleadr also conducts periodic audits of the ALPR System to examine whether ALPR Data is collected and used in compliance with Wayleadr's procedures and applicable laws.

Wayleadr uses commercially reasonable operational, administrative, technical, and physical safeguards and procedural and personnel security measures to monitor and secure the ALPR System and ALPR Data. These safeguards are designed to protect ALPR Data from unauthorized access, use, modification, disclosure, or destruction. We also identify and record who has accessed ALPR Data based on individual access credentials, the date and time of access, the data elements in the search query, and purpose for access. Wayleadr also conducts periodic audits of the ALPR System to check the security of the ALPR Data, and that the ALPR Data is used only for the authorized purposes described in this Policy.

DATA ACCURACY AND CORRECTION

Wayleadr enables drivers to input their license plates during the onboarding process. Drivers may update their license plates at any time through the Wayleadr app or online.

Any concerns regarding the accuracy of ALPR Data may be submitted using the contact information below.

OFFICIAL CUSTODIAN

The official custodian and owner of ALPR Data and Wayleadr's ALPR System is Wayleadr's Chief Technology Officer.

UPDATES

Changes to this ALPR Usage and Privacy Policy may be made from time to time by Wayleadr. Any changes to the Policy will take effect upon posting, and will apply to all ALPR Systems and ALPR Data in accordance with applicable law.

CONTACT INFORMATION

For questions or concerns about this policy, please contact: [email protected].