ALPR Privacy Policy

1. Overview

Modern Parking Inc. ("MPI," "we," "us," or "our") uses Automated License Plate Recognition ("ALPR") technology at select parking facilities we manage. This technology captures and processes license plate data to facilitate parking operations, enforce parking rules, and enhance security.

This ALPR Privacy Policy explains how we collect, use, store, and protect license plate data collected through our ALPR systems. This policy is provided in accordance with applicable California privacy laws, including the California Consumer Privacy Act (CCPA) and any relevant local ordinances.

2. What Data We Collect

Our ALPR systems capture the following data when a vehicle enters or exits a monitored facility:

• Vehicle license plate number (plate image and converted text)
• Date and time of entry/exit
• Location of the ALPR camera (facility name and entry/exit point)
• Photograph of the vehicle and surrounding area
• Vehicle make, model, and color (as detected by the system)

We do not collect or process the following through ALPR:

• Driver or occupant facial recognition data
• Personally identifiable information (PII) beyond what is displayed on the license plate
• Vehicle tracking across non-MPI facilities

3. How We Use ALPR Data

MPI uses ALPR data solely for legitimate parking management purposes, including:

• Access Control: Granting or denying entry to authorized parkers (monthly tenants, permitted vehicles, registered guests)
• Enforcement: Identifying vehicles in violation of parking rules, including unauthorized parking, expired permits, or vehicles on tow lists
• Revenue Collection: Matching vehicles to parking sessions for payment verification and gateless entry/exit systems
• Security: Investigating incidents, theft, vandalism, or other security events at managed facilities
• Operational Analytics: Aggregate, anonymized data on facility usage, occupancy trends, and traffic patterns

We do not use ALPR data for:

• Selling or licensing data to third parties
• Mass surveillance or tracking of individuals
• Marketing or advertising purposes
• Immigration enforcement or unrelated law enforcement dragnet searches

4. Data Sharing

MPI may share ALPR data in the following limited circumstances:

• Property Owners/Managers: With the property owner or management company for the facility where the data was collected
• Law Enforcement: Only when responding to a valid subpoena, court order, or specific, documented law enforcement request
• Towing Companies: License plate data may be shared with authorized towing partners for vehicle removal
• Service Providers: Third-party vendors who process data on our behalf under strict data processing agreements

5. Data Retention

ALPR data is retained according to the following schedule:

• Active enforcement data: Up to 90 days from the date of collection
• Authorized parker data: Retained for the duration of the parking agreement plus 30 days
• Incident-related data: Up to 1 year if associated with a documented security incident or legal matter
• Aggregate/anonymized analytics: Indefinitely (no personally identifiable data)

Upon expiration of the applicable retention period, ALPR data is permanently deleted from all MPI systems and backups.

6. Data Security

MPI implements industry-standard security measures to protect ALPR data, including:

• Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
• Role-based access controls limiting ALPR data to authorized MPI personnel only
• Audit logging of all data access and queries
• Secure data centers with physical and network security controls
• Regular security assessments and vulnerability testing

7. Your Privacy Rights

Under California law, you may have the following rights regarding your personal information:

• Right to Know: Request disclosure of the personal information we have collected about you
• Right to Delete: Request deletion of your personal information (subject to legal retention requirements)
• Right to Opt-Out: Request that we not sell or share your information (we do not sell ALPR data)
• Right to Non-Discrimination: You will not be discriminated against for exercising your privacy rights

To exercise any of these rights, please contact us using the information in Section 9 below. We will respond to your request within 30 days.

8. Signage and Notice

MPI posts clear, visible signage at all facilities where ALPR technology is in use. Signage is placed at facility entrances and in prominent locations to ensure that drivers are informed of ALPR data collection before entering the facility.

9. Contact Us

If you have questions about this ALPR Privacy Policy or wish to exercise your privacy rights, please contact us:

• Phone: (213) 482-8400
• Fax: (213) 482-7600
• Email: CustomerService@modernparking.com
• Mail: Modern Parking, Inc., 303 S. Union Ave., First Floor, Los Angeles, CA 90017-1932
• Website: modernparking.co

10. Updates to This Policy

MPI may update this ALPR Privacy Policy from time to time to reflect changes in technology, legal requirements, or our practices. We will post the updated policy on this page with a revised "Last Updated" date. We encourage you to review this policy periodically.

11. California Civil Code Section 1932.5 Notice

Pursuant to California Civil Code Section 1932.5, MPI provides notice that ALPR technology may be in use at our facilities. This technology captures license plate images and associated data for the purposes described in this policy. By entering an MPI-managed facility where ALPR signage is posted, you acknowledge this data collection.