Last Update: 26.06.2021

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1. General Information

The privacy of your personal data is one of the main concerns of VA SOLUTIONS LAB SRL (we will reffer to it as "Parking Spotter"), located in Cluj-Napoca, Str. Buna Ziua no. 34-36, registered with the Trade Register Office under no. J12 / 4099/2017, with fiscal code RO 37835604. In this respect, Parking Spotter is constantly pursuing and ensuring that the processing of personal data strictly complies with the principles and legislation on the protection of personal data.

This privacy policy addresses the personal data of Parking Spotter Clients and other Users of www.parking-spotter.com through which personal data is collected, including the Integrators as defined herein.

1. Definitions

"Parking Spotter" means a computer program (software), including its graphical interface, on which Parking Spotter owns all copyright or computer software designed to be run on a phone, smartphone and / or tablet, and / or on a computer, and is made available to Users by Parking Spotter, including Parking Spotter business policies, through the parking-spotter website www.parking-spotter.com. com "or" Site ").

"Client" means the individual or legal person who is guided to the chosen parking spot using the Parking Spotter application.

"Personal Data" means any information relating to an identified or identifiable natural person ("the data subject"); an identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or one or more specific elements of his physical, physiological, genetic, psychic, economic, cultural or social identity.

"Partner" - means any professional, a company that owns a parking lot that is integrated into Parking Spotter software.

"Integrator" means any professional, a company that integrates a parking owned by a third party and which he manages using Parking Spotter’s software.

"Processing" (and its derivatives, including without limitation "processing") means any operation or set of operations performed on Personal Data, including without limitation the collection, recording, preservation, modification, use, disclosure, access, transfer or destruction;

"User" - any person accessing or using Parking Spotter.

The other terms used in capitals that have not been defined in this Privacy Policy will have the meaning assigned according to the Terms and Conditions of Parking Spotter - More Details https://www.spotus.space/terms-and-conditions

• Categories of Processed Personal Data

III.1. Parking Spotter will process the following Customer’s Personal Data:

(i) name and last name, email address, signature, geolocation data (provided by the IT equipment on which Parking Spotter is installed / running, and any other data the Customer provides directly through Parking Spotter (eg such as User-Provided Content as defined in the Terms and Conditions).

(ii) if the Park Spotter User account is registered through the Google account, Parking Spotter will process the following public profile data displayed by the respective applications: username, email address;

(iii) Parking Spotter may also process data on how Parking Spotter is used, such as parking spotter behavior / preferences / habits, Park Spotter's previous orders.

III.1. Parking Spotter will process the following Personal Data of Customers:

(i) name and forename, email address, signature, geolocation data (provided by the IT equipment on which Parking Spotter is installed / running, and any other data the Customer provides directly through Parking Spotter (eg such as User-Provided Content as defined in the Terms and Conditions).

(ii) if the Park Spotter User account is registered through the Google account, Parking Spotter will process the following public profile data displayed by the applications: username, email address;

(iii) Parking Spotter may also process data on how Parking Spotter is used, such as parking spotter behavior / preferences / habits, Park Spotter's previous commands.

1. The Processing Purposes

IV.1. User and Customer Personally Identifiable Information, provided when creating a User Account or otherwise using Parking Spotter, may be processed by Parking Spotter directly and / or through Employees for the following purposes:

(i) to conduct the contractual relationship between the User / Client and Parking Spotter, as defined in the Terms and Conditions;

(ii) to meet Park Spotter's legal obligations in the context of services provided through Parking Spotter, including financial, accounting, tax, and archiving obligations;

(iii) for direct marketing activities - name and surname, e-mail address, postal address can be collected and processed for marketing, advertising, and advertising purposes. For this purpose, the data will be processed to transmit, via remote communication, such as e-mail, telephone, including Parking Spotter and push notifications*, about news about the services offered through the platform Parking Spotter;

* Note: A push notification is a message that appears on a mobile device that can be sent at any time without the need for users to be in the app or use their devices to receive such messages.

When you have agreed to such processing, you have the right to withdraw your consent or to oppose you at any time. Withdrawal of consent will not affect the lawfulness of Park Spotter's processing prior to the withdrawal of the agreement. Also, unsubscribtion can also be done by accessing the links indicated in the text of the e-mails received or the options available in your account.

(iv) for the purpose of conducting various analyzes, reporting on the way the Services function, making consumer preference profiles, mainly with a view to improving the services provided by Parking Spotter. Parking Spotter will also be able to transmit the statistical data to its Partners. However, please note that all such information submitted to Third-party Partners will be provided in aggregate form, without including data that could lead to the identification of the data subjects (directly or indirectly).

(v) to resolve complaints, requests submitted through Parking Spotters and also in order to improve the Services offered by Parking Spotter to its Users / Customers - the name and surname, e-mail address, telephone number and any other data provided by User / Client.

 

1. The duration of Personal Data processing

V.1. As a principle, Parking Spotter will process Personally-identifiable Data for the duration of the contractual relationship and subsequently personal data will be stored for the periods applicable to the different types of Personal Data established under Park Spotter's policy of storing and archiving data and documents, respectively for the time required to meet the legal obligations of Parking Spotter.

If you withdraw your data processing agreement and there are no other legal grounds for processing (such as the existence of a legal obligation, the existence of a contractual relationship, Park Spotter's legitimate interest), or you oppose the processing, and there are no legitimate and compelling reasons for the processing to prevail, Parking Spotter will cease processing your Personal Data.

Also, users' data on their navigation on Parking Spotter, such as those resulting from the monitoring of geolocation data, will be processed until the data subject requests deletion of these data under the law. Subsequently, Parking Spotter may have anonymization of these data, thus depriving them of personal character and continue processing anonymous data for statistical purposes.

 

V.2. If the User / Customer, as the case may be, wants to close / delete the account, it will not be automatically deleted or automatically delete its Personal Account Data from the account by clicking on the "Delete Account" button. To prevent situations where the User / Client would accidentally click on the account deletion button, Parking Spotter will display a pop-up message to the User / Customer requesting the user to confirm that he / she wants to delete the account.

 

If the User / Customer confirms that he wishes to delete the account, Parking Spotter will reasonably believe that such request implicitly (i) deleting the data and (ii) withdrawing the User / Client's consent to data processing for direct marketing purposes .

 

Within one month of the date of registration of the application, Parking Spotter shall communicate to the User / Customer the manner of solving the request, unless the statutory response time is extended according to the law.

 

1. Persons who can access Personal Data

Personal Data is mainly processed by Parking Spotter through its employees or collaborators authorized to process personal data.

Personal Data may also be disclosed to the following categories of persons:

(i) Parking Spotter attorneys who may process the data in the name and on behalf of Parking Spotter for any of the above purposes;

 (ii) to public authorities in response to a request for information made in compliance with the law, or in any case for Parking Spotter to carry out a legal obligation to do so;

(iii) Third parties, in connection with or during the negotiations involving a merge, a sale of Parking Spotter assets, the consolidation or restructuring, financing or acquisition of Parking Spotter or a portion of it by other entities;

(iv) to the general public in the case of User-Submitted Content.

 

• Person's Rights

Under the applicable legal provisions, with respect to the processing of Personal Data provided in this Policy, you have the right to request access to your personal data, rectification or erasure thereof, or restriction of processing, your right to object to processing within the limits and conditions by law, the right not to be the subject of an individual automatic decision, and the right to data portability.

Also, if you choose to give your consent, you have the right to withdraw it at any time. In addition, you have the right to file complaints with the National Supervisory Authority for Personal Data Processing, as well as the right to appeal to the courts.

Parking Spotter has the obligation to inform the operator within 4 hours of a security incident occurring.

Please note that in case of withdrawal of your consent under the applicable legal provisions, when such an agreement has previously been made for marketing activities, Parking Spotter will, after notifying you, send you any commercial messages.

However, please note that in such a situation, although you will no longer receive direct mail, Parking Spotter may process your Personal Data legally on other grounds and for other purposes.

In order to exercise the above mentioned rights, you can address us with the following contact details:

Address: Buna Ziua 34-36, Cluj-Napoca, Romania

E-mail: office@parking-spotter.com

Atn: Parking Spotter Marketing Department

Parking Spotter does not respond to anonymous requests. Therefore, if you write to us by e-mail, please give us your name and surname and email to identify and respond to your request.

Depending on the request, if it is justified and formulated in accordance with applicable law, Parking Spotter will:

(i) confirm to the applicant whether or not to process his / her Personal Data;

(ii) rectify, update, block, delete or transform into anonymous data, free of charge, his Personal Data whose processing does not comply with the provisions of the law;

(iii) terminate the processing of the Applicant's Personal Data.

If the data subject asks for a deletion of the data under the terms of the law, including as a consequence of closing / deleting the account, Parking Spotter may still process certain Personal Data on the basis of:

(i) the legal obligation

(ii) the contract between Parking Spotter and the User / Client / Integrator, including the Terms and Conditions document;

(iii) Parking Spotter's legitimate interest (for example, to handle requests that can be received from competent authorities to verify commercial transactions or to perform any legitimate verification, including online fraud).

Also, at any time, the User has access to his / her contact details and can edit / modify/ delete them directly in Parking Spotter in the "My Account" section. For unsubscribing from commercial communications, the User may use the option at the end of each email containing commercial communications. To disable geolocation services, the user can access the settings of the Informatic Device used at any time.