Privacy Notice
Introduction
The protection of Your privacy is of utmost importance to us.
This privacy notice applies to the personal data that we process. It is created to help You understand how we are processing Your personal data whilst You have access to the Services and the Platform.
APCOA Group Ltd., a company incorporated and organised under the laws of Germany, having its registered office at Flughafenstrasse 34, 70629 Stuttgart, Stuttgart, Germany under the registration number HRB 726 108, is the data controller for the personal data collected in connection with the access to the Platform and APCOA Services, whilst the Third Party Providers, including Your APCOA, are the data controllers for the personal data collected in connection with the access and use of Third Party Provider Services. By way of consequence, You acknowledge that when having access to or use Third Party Provider Services, related Third Party Provider privacy statements shall apply.
Some pages on the Platform include links to third party websites. These third party sites are governed by their own privacy statements, and APCOA are not responsible for their operations, including but not limited to their information practices. You should review the privacy statement of those third party sites before providing them with any personally identifiable information.
Be aware that all capitalized terms that are not defined within this Privacy Notice have the meaning specified in the Terms.
APCOA practices are subject to applicable laws in the countries and locations in which they operate. This means that APCOA engage in the practices described in this Privacy Notice in a particular country or region only if permitted under the laws of those locations.
Please contact us at dpo@apcoa.eu regarding our practices in a particular country or region.
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1. Definitions
1.1. You or User: means you as an individual using the Platform for Your own private or business needs.
1.2. Platform: means the complete technological solution provided by APCOA that enables You to have access to the Services.
1.3. Local Service Centre: means the local entity by which the Platform is locally made available, promoted, commercialised and supported. You can find the list of Local Service Centre here: https://www.apcoa.com/business-lines/.
1.4. Third Party Provider: means third party providers, including the Local Service Centre, with which APCOA cooperate in order for You to be allowed to request Third Party Provider Services via the Platform.
1.5. Services: means services provided through the Platform, including business services.
2. Scope of this Privacy Notice
This Privacy Notice describes how APCOA collect, use and process personal data when You access the Platform and all of the Services offered by APCOA and/or commercialised by a Local Service Centre. Services provided by Third Parties Provider are directly managed by those third parties. In this regard, their privacy notice shall apply concerning Your personal data and information.
This notice applies to all Users of the Platform anywhere in the world, unless covered by a separate privacy notice.
This Privacy Notice does not apply to:
- the data processing of other companies and organisations that advertise or display the Services.
- Third Party Services, or any services offered by other companies or individuals, including websites that may include, refer to and/or display APCOA Services and/or the Platform.
3. Processing of Your personal data
3.1. Which data are collected?
APCOA collect personal data:
- provided by Users to APCOA, such as during account creation
- created during the use of the Services and/or the Platform, such as location, the Platform usage, and device data,
- during support interaction between the User and the Local Service Centre
- from other sources, such as other Users or account owners, business partners (e.g. automotive companies, Your employer in case of Business Services subscription, service providers), vendors, Third Party Providers (e.g. public and private operators of parking, transit network, charge points and mobility services) and governmental authorities.
Most of our data processing is based on contractual or legal obligations, with some exception for consent-based processing. APCOA uses personal data to enable reliable and convenient Services. APCOA also use personal data:
- to provide, enhance and personalise the Services
- to deliver customer support
- to conduct maintenance services and research & development
- to send marketing and non-marketing communications to Users
- to propose to You benefits such as, but not limited to, promotional codes, discounts, promotional campaigns, challenges, benefits, rewards, cash back.
- for legal or regulatory reasons
APCOA do not sell or share Your personal data to/with third parties for the purpose of direct marketing, unless you provide Your consent.
If the processing is based on Your consent, You may revoke that consent at any time through Your account.
The following personal data is collected by or on behalf of APCOA and/or the Local Service Centre:
3.1.1. Data that You provide to APCOA
This includes:
- Your profile:
APCOA collect personal data when Users create or update their accounts. This may include their name, title, email, phone number, login name and password, address, payment or banking information (including related payment verification information), license plate and other government identification documents (which may indicate document numbers as well as date of birth, gender, and photo). This also includes vehicle information, User settings, and evidence of fitness to get the proper fare applied.
As the case may be, in some specific location, You might use our “Guest mode” service without creating an account. However, we do collect some of Your personal data in order to process Your transactions, such as, as the case may be, Your vehicle registration number, Your location and information on Your transaction (e.g. start and end time) and if You request to receive a transaction receipt, Your email address.
- Social Media account identification:
If you sign up using one of the social media plugin (e.g. AppleID, GoogleID, or FacebookID), You grant APCOA permission to use the public key and personal data of said services to authenticate You and/or have access to the Platform and related Services as per above mentioned.
- APCOA for Business:
Company details, director’s details such as name, IDs, government identification documents (which may indicate document numbers as well as date of birth, gender, and photo), employee’s name, email, phone number, position, login name and password, address, profile, picture, company payment or banking information, carfleet license plates.
- Your content
As per specified within the Terms, APCOA collect the data submitted by Users within the Platform and/or when they contact APCOA and/or the Local Service Centre to provide ratings, feedback. This may include feedback, photographs or other recordings collected by Users, including audio or video recording submitted by Users in connection with customer support. This also includes metadata relating to the method(s) You use to communicate with APCOA and/or the Local Service Centre.
Without this personal data it is not possible to verify who You are and whether You should have access to the account in question. Without them, APCOA won’t be able to provide You access to the Platform and to the related Services. Therefore, this processing is based on the contract you are entering into with APCOA or, as the case may be, the Local Service Centre, when you are accepting APCOA Terms.
3.1.2. Data created and collected whilst You are using the Platform and/or the Services
When You are using the Platform, personal data might be collected and processed such as Your location, Your transaction details, information related to Your device, or browser.
- Location data
APCOA collect User specific or approximate location data in order for APCOA to give Users access to Services available in their location or define the relevant journey to get the Services (e.g. get to the cheaper parking zone or parking lot, eV charging spot, or find your way back to Your car) or propose benefits.
APCOA collect location data thanks to Your device if you have authorised it through Your device settings. You may decide not to enable Your device to provide location data whilst using the Platform. However, this may affect the User experience and the Platform features. For instance, You might need to enter or search Your location manually in order to access the Services available in Your specific location, or You may not be able to access Services at all.
In both cases, however, Your location data may be shared with third parties:
- to ensure the Service You request is properly delivered e.g. eV charging
- in application of the local law and regulation, to enable the enforcement of applicable regulations e.g. on-street parking control by the authorised enforcement agency
- to provide You with the Services and/or discounts, promotions
- Transaction details
All information and potential personal data allowing You to get Third Party Provider Services are created, collected and processed for this purpose such as date and hour, license plate, geographical area, address. Those personal data might, if required for You to access the Services You ordered, be shared with Third Party Provider. Those data may include Your chosen payment method and information related to the payment processing.
- Usage of the Platform or the Products & Services
APCOA collect data about Your activity in the Platform in order to improve Your User experience and to propose You the most appropriate offers, discounts, Services. APCOA may process personal data such as time, frequency and duration of Your activities, features You use and how You use it, addresses, or crash reports.
- Device & Access Interfaces data
APCOA collect data related to the device and Access Interfaces You use such as unique identifiers related to Your device, browser, connection, network, device attribute, signals, settings and operations, IP address. APCOA might share the above-mentioned data with Third Party Providers, if they are required for You to access the Services.
3.2. Whom do we share personal data with?
In application with the present Privacy Notice, Your personal data might be shared with third parties such as Third Party Provider, Local Service Centre, public authorities, suppliers and subcontractors (e.g. hosting, customer support, online marketing), Your employer, and other partners. Who we share Your personal data with, depends on the Services and specific location.
3.3. How do APCOA process personal data?
In order to deliver the Services to You, personal data may be processed by APCOA and shared with Third Party Provider and/or Local Service Centre and/or the relevant payment service provider and, as the case may be, Your employer for Business Services.
You shall refer to the privacy statement of related Third Party Provider.
3.3.1. For User support
Collected personal data (which may include call recordings, social media conversation) may be processed by APCOA and/or Local Service Centre and shared with Third Party Provider and/or Local Service Centre to provide customer support, including to investigate and address User concerns, and to monitor and improve our customer support responses and processes.
3.3.2. For maintenance, research & development
APCOA may use personal data for testing, research, analysis, services maintenance, product and services development, and machine learning to improve the User experience. This helps us make our services more convenient and easier-to-use, enhance the safety and security of our services, and develop new services and features.
3.3.3. For communications with You
APCOA may use personal data to generate and provide Users with receipts, commercial and marketing information, discounts and promotion, related to APCOA and/or Third Party Provider, inform Users of changes to Terms, Services, or policies, or send other communications that aren’t for the purpose of marketing the services of APCOA or Third Party Provider.
In addition, when You send us an e-mail or chat with us online or via social media (e.g. WhatsApp), we register Your messages. If You call us, our customer service will register Your questions or complaints in our database. We may also record telephone calls for training purposes or to prevent or combat fraud.
3.3.4. For legal or regulatory reasons
APCOA might share personal data with third parties, including public authorities to meet any applicable law, regulation, legal proceedings, investigation, transaction enforcement or enforceable governmental request or any complaint or claim management, or even detect, prevent or otherwise address fraud, security or technical issues.
3.4. Where is your personal data processed?
Your personal data is kept and processed in the European Union. Your personal data is mainly processed by our staff.
4. Personal data retention
Except if You decide otherwise and notify APCOA in this regard, APCOA retains User personal data for as long as necessary for the purposes described above. This means that APCOA retain different categories of data for different periods of time depending on the type of data, the category of User to whom the data relates, and the purposes for which we collected the data.
Users may request deletion of their account at any time through their account.
Following an account deletion request, APCOA anonymise the User’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the User’s account such as an outstanding credit or an unresolved claim or dispute. In addition, should Your account be inactive for a certain amount of time and after several notifications from APCOA, Your Account would be deactivated. Anonymisation means that Your record is made unrecognisable to humans & computers alike.
5. Your Privacy Controls
Except if required to have access to the Platform, You have options regarding the data APCOA collect and how it is used in Your account.
Please ensure that You control with whom You share data through Your account.
6. APCOA may occasionally update this Privacy Notice
APCOA may update this Privacy Notice from time to time. If we make significant changes, we will notify Users in advance of the changes through the Platform or through other means, such as email. APCOA encourage Users to periodically review this notice for the latest information on our privacy practices.
Use of the Platform and Services after an update constitutes consent to the updated notice to the extent permitted by law.
6.1. Accessing Data
Users can access their personal data including their profile data and transaction or order history through the Access Interfaces and their account.
6.2. Receiving data
Users can request a copy of their personal data at dpo@apcoa.eu
6.3. Changing or updating data
Users can edit, update and correct the account content e.g. name, phone number, email address, payment method, license plate etc. directly through their account.
6.4. Deleting data
Users may request deletion of their account at any time through the Platform and their account settings.
6.5. Objections, restrictions, and complaints
You may request that APCOA stop using all or some of Your personal data, or that APCOA limit their use of Your data. This includes objecting to APCOA’s use of personal data that is based on APCOA legitimate interests. APCOA may continue to process data after such objection or request to the extent required or permitted by law.
