Processing of personal data and GDPR information
Last updated: 2020-03-11
1. The following sections show the guidelines applied by ApParkingSpot for personal data processing. The purpose of the guidelines is to ensure that We always process personal data in accordance with applicable personal data laws and with respect for privacy.
2. The use of the Service includes the processing of personal data for various purposes. ApParkingSpot is the data controller for all processing of personal data that ApParkingSpot, or supplier/partner on behalf of ApParkingSpot, performs within the framework of the Service.
3. "Personal data" means any kind of information that can be directly or indirectly attributed to a person, such as his name and address. Encrypted data and different types of electronic identities, such as IP numbers, are counted as personal data if they can be linked to natural persons.
4.1. We strive to ensure that personal data is processed with the consent of the User concerned. A consent has always been withdrawn. If a consent is revoked, We will not process the personal data further and will not update previously provided information. However, it should be noted that despite the withdrawal of consent, some processing may be necessary to complete the law or concluded contract.
5. Collection of personal data
5.1. In the first instance, we receive your personal data directly from you when you create a user account in the App or contact us by email and/or phone. We also retrieve some information from publicly available information services, e.g. we regularly associate your social security number with public records to ensure that your information is up-to-date and accurate. Examples of information that we retrieve from publicly available information services are names and contact details. We can also collect information on creditworthiness from credit rating agencies, banks or information companies.
6. Purpose of collecting personal data
6.1. By accepting the Terms, you agree to:
-that the processing of your personal data is in accordance with this personal data policy, and
-that we can send you direct marketing, e.g. by mail, telephone, electronic communications (such as sms or e-mail) or otherwise (You may opt out of any additional offers at any time).
6.2. By accepting the Terms, you further agree that We treat:
-Contact details such as name, e-mail, telephone number, address and social security number,
-Payment details such bank account for payment,
-Geographical position such as coordinates,
-Detailed order history including, but not exclusive, receipts and timing of booking,
-Feedback provided by the User,
-Technical data including, but not limited to, mobile OS version, application usage, IP address and,
-User information about Users for the purposes listed under section 6.4 below.
6.3. Personal data is collected only for specific purposes. The general purpose is usually to provide the service requested by the Affected User. ApParkingSpot does not process personal data for purposes that are incompatible with the original purpose.
6.4. ApParkingSpot may use, compile, process and analyse the information described above in section 6.2 above to administer user's account with Us, to promote ApParkingSpot and our potential partners products and services, to analyse Users' use of the Service, to ensure the technical functionality of the Service and to comply with legal or regulatory obligations.
-Contact information is used to create an account with Us and to create a rental ad. We may contact you and/or share your contact information with relevant parties in case of complaints.
-Payment details are used to be able to issue an invoice to the Tenant, to receive payment for a rented parking space or to be able to make a payment to the Lessor in case of a rented parking space.
-Geographical location is used to be able to view parking spaces closest to you or the nearest desired address.
-Order history is used to present the history to the User and to calculate response rates and average response times.
-Feedback, contact information and technical information about the OS version and application usage are collected to improve the Service.
-Technical data is used to ensure the technical functionality of the Service and for analysis purposes with the aim of improving the Service.
7. Transmission of personal data
7.1. Personal data may be passed on to partners, for example to provide the service requested by the affected User. In cases where we transfer your data to another company that processes your personal data on our behalf as a data processor, we have agreements in place with strict instructions on the processing of personal data, confidentiality and security.
7.2. We share your personal data with:
-The police and/or other authorities in the investigation of criminal offences,
-Paynova for payment solution.
-APCOA, housing associations and other parties whose customers/members offer and provide their parking spaces for rent via ApParkingSpot.
-IT consultants that we use from time to time to manage server environments such as databases and applications and development of our systems.
-Suppliers that We use from time to time to provide cloud computing platform for our systems.
-Suppliers that We use from time to time to provide analytical services.
-Supplier that We use from time to time to handle e-mails such as booking process and welcome letters.
-Supplier that We use from time to time to manage SMS notifications.
-Affected parking companies on bookings and relevant information about the booking including, but not exclusively, the registration number of the vehicle in question and the time of start and termination of the rental period;
7.3. Partners who may receive personal data may be located outside the EU/ESS as described above. In the case of a transfer to a country outside the EU/ESS, appropriate safeguards are taken as are required by binding corporate rules, standard contractual clauses decided by the European Commission, approved codes of conduct or certification mechanisms, and legally binding instruments between authorities. In the case of such a transfer to a third country, the relevant data is encrypted, and by agreement, access is given only to certain specific individuals in the receiving organization.
8. Storage times
8.1. ApParkingSpot saves the data as long as you have a user account with us. Please note that your user account will not be terminated if you simply uninstall our App from your equipment.
8.2. We will retain your personal data for the period necessary to pursue the purposes described in this policy, unless required or permitted by law that we retain the data for a longer period of time. Thereafter, we will delete or de-identify your personal data.
8.3. ApParkingSpot stores your personal data for the time specified in the list below. The defined storage period begins on the day of deregistration.
-Contact information (first name, middle name, last name, email, full address, mobile phone number and date of birth), Max 10 years
-Payment information (account number), Max 10 years
-Vehicle data (registration number and other non-personal vehicle information, etc.), Max 10 years
-Rental details (contact details of the Tenant and the Lessor, the vehicle's registration number and information about parking space, etc.), Max 10 years
-Communication/Review information (communication with other registered users, uploaded reviews and experiences, usernames, car details, profile picture and reviews), Max 2 years
-Information on rental/rental behaviour (reviews, experiences, rental and rental tasks and occurrence, etc.), Max 2 years
-Marketing information (personal data collected through tracking cookies), Max 2 years
-Booking details (contact details and payment details), Max 10 years
-Fraud detection information (account activities, payment settings, account settings, payment details and history, contract length, services received, contact history, website visits, registration behavior, and fraud detection results), Max 7 years
9.1. ApParkingSpot takes technical and organizational measures to protect the personal data processed, so that the data is not lost, destroyed, manipulated or made available to unauthorized persons. The measures aim to achieve a level of safety that is sufficiently high in view of the technical possibilities available.
10. Right to receive information and rectification
10.1. You have the right, in accordance with applicable personal data legislation, to request a so-called register extract with information about what personal data about you we process. You are entitled to this information free of charge and without giving reasons. You have to obtain information about what personal data is processed, from which it has been collected, for what purpose the processing is carried out and to whom the data is disclosed. Requests for information relating to the processing of personal data are made to firstname.lastname@example.org.
10.2. You have the right to request rectification, blocking or deletion of your own personal data that is incorrect or that is processed in violation of applicable law. We are then obliged to take such measures. If We are required by law to store your data, the data can only be blocked.