California Consumer Privacy Act Notice
Effective Date: January 1, 2020
Last Revised on: June 22, 2020
Passport provides software platforms that, where available, enable you to manage and pay for parking, parking citations, transit tickets, permits, tolling fees, and ancillary services through our mobile applications or websites and applications or websites of affiliates or partners with whom we integrate, such as in-dash applications in vehicles and map applications (collectively, “Services”). We partner with transit agencies, local governments and interlocal agencies or partnerships, tolling agencies, colleges, universities, hospital systems, and other public and private operators (our “Partners”) when they provide the above services, to improve their operations and to simplify and personalize your interactions with such services. Our collection and use of your information are designed with these purposes in mind.
- Notice at Collection–Notice at or before the point of collection, about the categories of personal information to be collected from you and the purposes for which the personal information will be used
- Your “Right to Know” about personal information collected, used, and disclosed including
- Our commitment that we do not and will not sell your personal information
- Your right to request deletion of (“Right to Delete”) your personal information
- How to submit a verified consumer request for your Right to Know or Right to Delete
- How to use an authorized agent to submit a verified consumer request
- Your “Right to Non-Discrimination” for the exercise of a privacy right
- Other California privacy rights
- Changes to our privacy notice
- Our contact information
Notice at Collection
The purpose of this Notice at Collection is to provide you with timely notice, at or before the point of collection, about the categories of personal information to be collected from you and the purposes for which the personal information will be used.
Categories of Personal Information We Collect
- Identifiers: For example, a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, or other similar identifiers.
- Personal Information Categories from Cal. Civ. Code § 1798.80(e): For example, a name, signature, address, telephone number, driver’s license or state identification card number, education, employment, or employment history (if needed to validate your eligibility for certain Services), and credit card or debit card number.
- Commercial Information: For example, records of products or Services purchased, obtained, or considered from Passport or its Partners.
- Internet or Other Similar Network Activity: For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
- Geolocation Data: For example, information that can be used to determine a device’s physical location, where enabled for certain Services.
- Professional or Employment-Related Information: For example, current employment information only if and when needed to establish eligibility for certain Services.
Please note that Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (CalFIPA), and the Driver’s Privacy Protection Act of 1994.
We use the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided
- For our internal operation purposes
- For auditing relating to consumer transactions including ad impressions and compliance with regulations
- Fraud and security detection
- Debugging to identify and repair errors
- Short-term data use for the current interaction that is not used to build a profile
- Servicing transactions and accounts (e.g., customer service, maintaining and servicing accounts, customer verification, payment processing) and providing services on behalf of business or service provider (e.g., financing, advertising or marketing, analytics)
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us is or is contemplated to be among the assets transferred
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business
- To share the personal information with service providers to carry out business purposes that are related and necessary for the provision of the Services.
We will not use your personal information for a purpose materially different from those disclosed in this Notice at Collection unless we directly notify you and obtain explicit consent to use it for the new purpose.
What we Sell and Right to Opt-Out
Passport does not and will not sell personal information.
Your Right to Know
You have the right to request that we disclose what personal information we collect, use, disclose, and sell. You can do this through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request.”
We collect personal information, which means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). The following table includes disclosures for the preceding 12 months of: categories of personal information we have collected about consumers, the categories we have disclosed for a business purpose, and categories of third parties with whom we shared the personal information during that period.
|Category||In the preceding
12 months this category was:
|Categories of third parties to whom the information was disclosed where reasonably necessary to perform our Services as intended|
|Personal Information Categories from Cal. Civ. Code § 1798.80(e)||☒||☒|
|Internet or Other Similar Network Activity||☒||☒||
|Geolocation Data||☒||☒||Our Partners|
|Professional or Employment-Related Information||☒||☒||Our Partners|
Your Right to Request Deletion of Your Personal Information
You have the right to request that Passport delete any of your personal information collected or maintained by Passport, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request.”
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Submitting a Verified Consumer Request
You have the right to submit verified consumer requests to know information or for deletion. The request to know can be for any or all of the following about you:
(1) Specific pieces of personal information that Passport has;
(2) Categories of personal information Passport has collected;
(3) Categories of sources from which the personal information is collected;
(4) Categories of personal information that Passport sold or disclosed for a business purpose;
(5) Categories of third parties to whom the personal information was disclosed for a business purpose; and
(6) The business or commercial purpose for collecting or selling personal information.
The request to delete is to delete any of your personal information collected or maintained by Passport, subject to certain exceptions.
Please note that we are not required to provide personal information to you more than twice in a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You can submit requests by calling 866-477-9773, clicking here, or as set forth below in the “Contact Us” section.
Your request will be verified by matching the information you provide to information that we have collected, including your name and telephone number or email address. We might request additional information to the extent necessary for verification, including, for example, your account PIN, the last four digits of your credit or debit card used to transact with us, or the date or location of your last transaction.
Once we receive your verifiable consumer request, we will send you an acknowledgement within 10 days which will describe our verification process. We will respond to your request within 45 days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Please note that, in responding to our request, we are not permitted to disclose or provide you with your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics.
Using an Authorized Agent to Submit a Request
Only you, a person registered with the California Secretary of State, or a person you authorize to act on your behalf, may make a verifiable consumer request related to your personal information by following the procedures specified above. You may also make a verifiable consumer request on behalf of your minor child. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to verify your identity directly by submitting a verified consumer request according to the procedures in the section “Submitting a Verified Consumer Request.” If anyone purporting to be an authorized agent for a consumer contacts us, we will require proof that the authorized agent has been authorized to act on the consumer’s behalf.
Your Right to Non-Discrimination for the Exercise of a Privacy Right
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note, however, that our provision of some or all of the Services as intended, or any portions thereof, may be impeded or made impossible if we do not possess the minimum information required to perform the Services on your behalf.
Other California Privacy Rights
Passport does not respond to Web browser “do not track” signals or other mechanisms.
Other parties who provide common information-gathering tools to collect data when you are using our Services, such as cookies and other tracking technologies, to remember settings, track activities within the Services, and analyze trends–may collect personally identifiable information about your activities over time and across different Web sites when a consumer uses our Web site or service. We may obtain reports based on the use of these technologies on an individual and aggregated basis.
If you have any questions or comments about this notice, the ways in which Passport collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at firstname.lastname@example.org, call us at 866-477-9773 or write to us at:
Passport Labs, Inc.,
Attention: Privacy Officer,
128 S. Tryon Street, Suite 2200,
Charlotte, NC 28202