Privacy

Last Updated: June 15, 2017

We at HotSpot Parking Ltd. (“we”, “us”, “our”, “HotSpot”) love our customers and want to provide the best user experience possible. To offer and constantly improve our products, we often need to collect, use, and sometimes share your data, including personal information. We wrote this privacy policy to help you understand how we use your personal information so you can make an informed choice.

By visiting www.htsp.ca (the “Site”) or signing up for any of the products or services HotSpot offers (collectively, the “Services”, as more fully described in our Terms of Service) you are agreeing to the terms of this privacy policy (the “Privacy Policy”) and the HotSpot Terms of Service, which incorporates by reference this Privacy Policy.

We made an effort to write this Privacy Policy in language as plain as possible, but it is a legally binding agreement between you (your employer, client, or any entity you if you are acting on their behalf) and HotSpot. If you disagree with the way that we collect, use, or share information, or anything else in this Privacy Policy please do not use our Services.

Technology changes often and we may need to update this Privacy Policy, in which case we will do our best to notify you of the change. By continuing to use the Services you are agreeing to the updated Privacy Policy. The date of the latest update will always be posted at the top.

When we use the term “Personal Information” in this policy, it means any information related to an identifiable individual, but does not include the name, title, business address, or telephone number of an employee of an organization.

  1.  PERSONAL INFORMATION FROM MERCHANTS

This section covers Personal Information we collect from those businesses (“Merchants”) who sign up for and use a HotSpot merchant account (the “Merchant Services”), which includes the merchant app, web dashboard, and Bluetooth beacons. Also remember: as a business, if you are collecting information about your customers you need a privacy policy too!

1.01 WHAT WE COLLECT FROM MERCHANTS AND WHY

We collect this information about merchants:

  • your name,
  • company name,
  • street address,
  • email address,
  • phone number, and
  • credit card details.

We need this information to provide you with the Merchant Services, keep you informed about your account, and process transactions (e.g. billing, contact you, invoice you).

We also collect information about how you interact with and use our website and business app, including:

  • IP address,
  • your browser and device,
  • what pages you visit,
  • when you access your account,
  • what and if you post.

This information is used to improve our products and provide you with customer service relating to your account.

We collect Personal Information about your customers while they are in your store, in accordance with the terms below, in order to provide you with the Merchant Services. This information is core to the Services we provide you.

  1.  PERSONAL INFORMATION FROM APP USERS

This section covers Personal Information we collect about HotSpot Mobile App (the “Mobile App”) users.

2.01 INFORMATION WE COLLECT FROM MOBILE APP USERS AND WHY

When you sign up we collect the following Personal Information (“User Information”):

  • your name,
  • photo (if provided),
  • email address,
  • date of birth,
  • phone number,
  • physical address,
  • license plate, and
  • car make and year.

We need this information to verify your identity, set up your account, allow you to use the parking and transit functions in the app, as well as provide functionality to Merchant Services (as described in section 2.02).

If you want to buy parking credits or bus fares, we will collect your credit card details so we can process payment transactions for those purchases.

When you park and when you walk into businesses using our Merchant Services, we collect location information (collectively, “Location Information”), including:

  • when you enter or leave a city,
  • when you enter or leave a business,
  • rough location inside the business, and
  • location of your parked car (if you park with our app).

This information, which is connected to certain User Information, as described below,  is used to provide Mobile App functionality (for example, Parking Extender) as well as provide insights to Merchants on how you interact with their businesses. Some or all of this Personal Information may be shared with Merchants and third party apps that you use, as identified in section 2.02.

2.02 MOBILE APP USER INFORMATION WE SHARE AND WHY

In order to provide the functionality in our Mobile App we need to share some of your User Information and Location Information with our Merchant Services users and certain third party apps.

Users may disable the collection of location information at any time by turning off location services on your mobile device. However,  disabling location services will cause you to lose your ability to use most of the Parking Services, including  Parking Extender and Designated Driver.

When you enter a Merchant business, we share your name, photo, and age range as well as certain stats about how you may have interacted with their ads, information we get from third party apps (described in section 3.), and location information including how far away you park, how often you visit the Merchant’s location, how long you stay in the store, etc.

We may also share some or all of this Personal Information with third party apps that you use in order to improve your experience both while visiting stores and while using those apps. Third party app developers are responsible for the information they collect and share; please see their privacy policy for more on what and how they collect your Personal Information.

  1.  PERSONAL INFORMATION FROM PARTNERS

Partners are individuals or businesses that have developed their own applications and use the HotSpot Application Interface (API) or Software Development Kit (SDK).

3.01 INFORMATION WE COLLECT FROM PARTNERS AND WHY

By integrating our API or SDK into their apps, third-party apps may allow us to collect Personal Information about Users that includes:

  • names,
  • photos,
  • app usage statistics (depends on the app, for example, how you interact with reviews of a local business),
  • and other information that depends on the app.

We use this information to improve our Services and to provide information to the third party app so that the third party can improve their app and services.

All information provided to us from third parties is collected and shared pursuant to their privacy policy.

  1.  PERSONAL INFORMATION FROM THE SITE

When you visit our website, we  collect information about the device and browser you use, your network connection, your IP address, and any information you provide us with voluntarily (depending on the form you fill out this may include your name, email address, company name, etc.).

We also assign a unique cookie to each website visitor (a small piece of data stored on your device that includes a unique identifier).

We use this information to recognize you when you return, personalize your service, service your account, enhance our services, and answer any questions you may have.

We may also use this information to send you marketing material and updates on our Services; we will not send you this unless you have opted-in to receiving it.

  1.  CONSENT

Whenever you access or use the Services or voluntarily provide information you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy

  1.  NON-PERSONALLY IDENTIFIABLE INFORMATION

Non-personally identifiable information means any information that cannot be associated with a specific individual, including aggregate or otherwise anonymized information about users.  We may use or share this information to:

  1. analyze trends and usage of resources through aggregated data;
  2. improve the features and functionality of the Services;
  3. better understand your needs and interests;
  4. better understand the needs and interests of other users of our Services.

For example, a Merchant may want to compare itself to other businesses and we may provide aggregated data on how often customers return to similar businesses.

  1.  OTHER INSTANCES WE MAY DISCLOSE YOUR INFORMATION

We may share Personal Information identified in this Privacy Policy to the following entities, for the following purposes:

  1. to our service providers and suppliers to perform a business, professional, or technical support function for us like processing payments and website hosting;
  2. as necessary if we believe that there has been a policy violation such as those published on our site, or some violation of terms you signed, or some other violation of our rights or the rights of any third party;
  3. to respond to judicial process and provide information to law enforcement agencies, or in connection with an investigation on matters related to public safety, as permitted by or otherwise required by law; and
  4. otherwise with your consent.

Additionally in the event of a

  • merger,
  • acquisition,
  • reorganization,
  • sale of our company or assets, or
  • in the event of our bankruptcy

your Personal Information may be one of the transferred or acquired assets. We may also share your personal information where you have granted us permission to do so, and we reserve the right to use and disclose any information collected via the Site that is not in a personally identifiable form.

  1.  HOW WE PROTECT YOUR PERSONAL INFORMATION

We recognize the importance of keeping your information safe and we use commercially reasonable efforts to ensure our Services and Site is as secure as possible.

We have taken physical, electronic, contractual, and managerial steps to secure the information we collect from Site visitors and Service users. However, no method of transmission over the Internet or method of electronic storage is ever 100% secure; therefore while we endeavor to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

It is your responsibility to protect the security of your Account, and any end-users you are providing services to through our Services and your Account. Don’t share your account information with anyone and notify us if you believe there has been a breach.

  1.  INTERNATIONAL TRANSFER OF INFORMATION

Your Personal Information may be transferred to, maintained on, and processed on computers located outside of your jurisdiction where the privacy laws may not be as protective. You acknowledge and agree that your Personal Information may be accessible to law enforcement or other governmental agencies under the laws of those jurisdictions.

We have taken reasonable measure to ensure compliance with the privacy laws of the United States of America and Canada, and we are always working to maintain and/or improve compliance in the future.

The protections given to you by this Privacy Policy still apply regardless of jurisdiction. By using the Services or providing us with any information discussed in this policy you agree to that transfer.

  1.  WHAT WE DON’TDO WITH YOUR INFORMATION

Other than as disclosed in this Privacy Policy, we do not and will never share, disclose, sell, rent, or otherwise provide Personal Information to other companies for the marketing of their own products or services.

We do not use the Personal Information we collect from you or your customers to contact or market to your customers or directly compete with you. However, HotSpot may contact or market to your customers if we obtain their information from another source, such as from the customers themselves.

  1.  CHILDREN’S INFORMATION

The Site and our Services are not directed to children under the age of 13, nor do we knowingly collect any Personal Information from or about them.

  1.  THIRD PARTY WEBSITES AND LINKS

The Site and Services may offer links to other websites. You should be aware that operators of linked websites might also collect your Personal Information (including information generated through the use of cookies) when you link to their websites.

HotSpot is not responsible for how such third parties collect, use or disclose your Personal Information, so it is important to familiarize yourself with their privacy policies before providing them with your Personal Information.

  1.  MODIFYING OR DELETING YOUR INFORMATION

You may review, update, correct, or delete any information in your HotSpot Account by contacting us, or by making the appropriate modifications in your Account profile or preferences. Upon receipt of a written request, we will provide you with access to your Personal Information unless we are required or permitted by law to withhold it.

If you completely delete all such information then your account may become deactivated.

We will keep your Personal Information for as long as it is necessary for the identified purpose or as required by law (which may extend beyond termination of our relationship with you). We may also retain some data to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law.

All retained Personal Information will remain subject to the terms of this Privacy Policy.

If you would like us to delete your Account and/or remove your records from our system, please contact us and we will delete your account within 30 days if we do not have any legal obligation to retain the record. It may not be possible to completely delete all your Personal Information due to technological and legal constraints but we will do our best.

You retain all rights to your information and can access it anytime. If you have any questions about your Personal Information or this policy, please contact:

privacy@htsp.ca

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