This policy applies to:

• Our Website and its visitors (“Visitors”).
• Our Digital Platforms.
• Individuals who use Digital Platforms for their own parking, permits, and payments (collectively, “Consumers”), including our mobile-app users and individuals who receive citations by our Customers (as defined below).

Our Digital Platforms are used by municipalities, parking enforcement officers, departments of motor vehicles, parking lot owners/managers, and other entities to help manage parking and enforcement (“Customers”). If you are an employee, contractor, or agent of a Customer (“Customer Employee”), we may process your personal information as part of Customer’s use of the Services (e.g., to create accounts, authenticate access, or provide support.)

Our role in relation to your personal information depends on how you interact with us and with our Customers.

When we act as a service provider / processor.

In many cases, we provide our Services to municipalities, transit agencies, universities, parking operators, and other organizations (“Customers”). This typically includes parking enforcement, citation issuance/processing, permit administration, and related collections workflows; in these contexts, the relevant municipality or parking authority determines the purposes and means of processing, and we process personal information only on the Customer’s instructions. In those situations, the Customer decides what personal information to collect and how to use it, and we process that information only on the Customer’s instructions. The Customer is the “business” or “controller” (or similar term under applicable law), and Passport is a “service provider” or “processor.” If you want to exercise privacy rights regarding information we process on a Customer’s behalf, you should contact that Customer directly. Where required, we will support the Customer in responding to your request.

When we act as a business / controller.

We act as a “business” or “controller” when we decide how and why your personal information is used—for example, when you create or use a Passport account or app directly with us, when you visit our Websites or Digital Platforms, when we provide certain Passport Payments services (such as when we act as merchant of record), and when we use information to operate, secure, improve, and market our Services. In these situations, you may be able to exercise your privacy rights directly with us as described in the U.S. State Privacy Rights supplement.

For avoidance of doubt, when your parking, permits, citations, enforcement, or collections are administered by a Customer (such as a municipality or parking authority), that Customer is typically the business/controller for those program activities, and requests about those activities should be directed to the Customer.

The following chart describes the categories of personal data we collect from you and the uses of such data:

In addition to the uses described above, we may use the information for the following purposes:

For Marketing. To send promotional and marketing materials, support contests and other promotions, notify you about incentives and rewards, support business development, research, marketing and promotional purposes, press inquiries or aggregate statistical analysis and site customization.

For providing Services. To maintain, analyze, customize, and improve your experience on our Services; provide customer/technical support; and respond to requests and inquiries. To communicate with you about our Services, including receipts, technical notices, security alerts, and support and administrative messages. To provide technical support, including notices about accounts and subscriptions and changes to our service

For CRM. To communicate with Visitors/Customers/Consumers about the Services, manage subscriptions/accounts, personalize experiences, estimate audience size/usage patterns, and analyze trends.

For Compliance. To comply with law and satisfy our regulatory and compliance obligations. Additionally, to support compliance efforts on behalf of others and ourselves that support our provision of Services to you.

For Corporate Operations. To operate our business, including support for transactions impacting our company as a whole (such as mergers, acquisitions, reorganizations, underwriting or asset purchases). Also, to monitor and enforce our contracts, legal terms, acceptable use or other policies or similar terms, and to address existing or anticipated disputes and to protect our legal interests.

For Security. To help detect and prevent fraudulent use of our Services and other prohibited, illicit or illegal activity; to compare information for accuracy and monitor information security, manage and protect our technical infrastructure (servers, networks, etc.). To detect and prevent fraud and other prohibited, illicit or illegal activity, and to protect the rights and vital interests of you, others, and ourselves.

For Other Disclosed/Consented Purposes. We collect information to fulfill the purpose stated at collection, for purposes disclosed in connection with the Services, or for other uses permitted by law or with your consent.

We may process data for any other purpose disclosed to you in connection with the Services from time to time. If we intend to process your personal information for a purpose other than that set out above and which is not compatible with the original processing purpose, we will provide you with relevant information prior to such processing and will obtain your consent where necessary.

To enhance our Services, we may also retain and use your information in an anonymized or de-identified format where your identity is not recognizable. Such information is not subject to the same usage restrictions as personal information and can be used to improve our products and services, conduct research, or for our other business purposes.

As permitted by law, we may combine the information we gather about you in identifiable form, including information from third parties. We may use this information, for example, to improve and personalize our Services, content and advertising.

When you use our Services, we may collect information through cookies, web beacons, and similar technologies. This information includes IP address; browser type; operating system; device type and unique identifiers; mobile network information; language preferences; dates/times of access; pages/content viewed; files downloaded; links clicked (including within our emails); referring and exit websites; error logs and information about how you interact with our Website or Digital Platforms (collectively, “Usage Data”).

Third-party collection via our Website and Services. When you visit our Website (and, where applicable, use our Digital Platforms), we and certain third-party service providers may collect information from your browser or device through cookies, pixels, SDKs, and similar technologies (for example, IP address, device and browser information, and cookie identifiers). We use these technologies to operate and improve our Website, maintain security, and measure traffic and conversion related to our own marketing and communications. Our Website and Digital Platforms may also include third-party features or embedded content (for example, widgets or social media tools). If you interact with those features, the third party may collect information directly from you in accordance with its own privacy practices.

Information we receive from third parties. We may receive information from analytics providers, marketing service providers, and other service providers that help us understand Website performance and measure the effectiveness of our communications and campaigns (for example, traffic and conversion metrics). We use this information to support our operations, improve the Services, and understand how visitors engage with our Website and communications.

Do Not Track and your choices. We do not respond to browser “Do Not Track” signals. You can manage cookies and similar technologies through our cookie preference tools (see our Cookie Policy for details).

We are committed to maintaining measures to protect the security of your personal information maintained in our systems. However, no network or system is ever entirely secure, and we cannot guarantee the security of networks and systems that we operate or that are operated on our behalf. If we face a security breach, we may notify you as required by law via email or conspicuous posting on this site.

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unlawful or unauthorized access, loss, destruction, or alteration.

The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. You should not share your password with anyone.

We share personal information only to operate our business, provide Services to you, comply with law, or when you direct or authorize us to.

Customers. We may share your information with Customers to facilitate our Services, allow you to pay for permits and settle parking fines, provide insights as to how you interact with Customer content, support Customer marketing efforts, confirm individual identities and issue citations, and other purposes. If you are a Consumer and have questions about (or want to exercise rights relating to) a Customer’s parking program, including permits, citations, enforcement activities, or collections, you should contact the relevant Customer directly.

Third Party Verification and Collections. Enforcement authorities who use our Services may seek to verify driver’s license, license plate, vehicle registration, or similar information to confirm identity, issue citations, process citations, and take other enforcement actions. Accordingly, we may share relevant information with third parties that provide, verify, or facilitate access to such information, including state departments of motor vehicles, National Law Enforcement Telecommunications Systems (“NLETS”), TransUnion Locator Services (“TLO”), and other identity/information verification providers used in connection with Customer-directed enforcement workflows. Where required by the relevant Customer/jurisdiction, we may also share limited information with collections service providers for collections and enforcement of unpaid citations or fees.

Payment Processors. We may share your information with payment processors and facilitators when necessary to provide our Services.

Affiliates. We may share some or all of your information with our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control with us.

Operational Support. We work with third parties to help us provide our Services and to support internal operations. They process personal information on our behalf and under contract, limited to providing services to Passport and subject to appropriate safeguards. We work with different types of third parties, presently including:

• Third parties that verify individual identities out of a Customer’s state to issue citations;
• Data hosting, storage and cloud service providers;
• Platform and/or application security service providers;
• Technical and customer support providers;
• Marketing and analytics providers; and
• Other third parties.

Professional Advisors, Law Enforcement and Regulators. We may share information with our legal, compliance, audit, accounting, banking, and other professional advisors, and with regulators, law-enforcement, and government authorities to: (i) comply with laws and regulatory obligations; (ii) protect our rights, Customers, users, and the public; (iii) respond to subpoenas, court orders, and other lawful requests; and (iv) prevent fraud or harm and to establish, exercise, or defend legal claims, including enforcing our terms.

Corporate Transaction. We may disclose information in connection with, or in anticipation of, a merger, acquisition, financing, reorganization, divestiture, sale of assets or equity, dissolution, or similar transaction.

Other Disclosures. We may also disclose information as needed to provide our Services, as described at the time of collection, as permitted or required by law, or with your consent or direction.

We may disclose aggregated or deidentified information that does not identify any individual without restriction.

When provided for by applicable law, you have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this information to another controller. See Your U.S. State Privacy Rights Notice for your additional rights based on applicable data privacy laws in your jurisdiction.

Update personal information. If you have an online account, you may update certain profile details in your account settings or by emailing support@passportinc.com. Where permitted by law, we may decline changes that would violate legal requirements, make records inaccurate, or impair our Services. Some updates must first be made with relevant third parties before appearing in our systems.

Marketing communications. You may opt out of receiving certain emails from us by following the unsubscribe or stop instructions in the email or by contacting us at privacy@passportinc.com. Please note that you may continue to receive non-marketing emails from us after you opt out. We do not control communications sent by third parties, including Customers. If you are a Consumer, please contact the relevant Customer directly to learn about and manage any communication choices they offer.

Cookies. You may exercise choice regarding your cookie preferences by clicking here. The choices you make are both browser and device specific. You may also set your cookie preferences through your browser settings. You can learn more about how to manage your cookie preferences here.

We may direct you to, or provide you with an option to, visit third-party websites or platforms. Third-party platforms operate independently from us and we are not responsible for the personal information that you choose to submit to those platforms. We encourage you to review the privacy policies and settings of the third-party platforms that you interact with as they will govern your interactions with those platforms.

Our Services are not intended to interact in any way with minors. Any access to or use of the Services by anyone under the age of 13 is unauthorized. If you are under 13, and you provide any information on or through our Services, we may contact your parent or guardian about your communications. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you are a parent or guardian or otherwise believe we might have any information from a child under 13, please contact us at privacy@passportinc.com.

We may update this Privacy policy from time to time in order to provide clarification or notice of changes to our practices. If we make changes, we will revise the Effective Date at the top of this Privacy policy. Changes to this Privacy policy will be effective once they are posted unless otherwise indicated. We may choose to notify you by email to the email address in our records. We encourage you to periodically review our privacy policy to be sure you are familiar with the most current version.

If you have any questions or concern about this Privacy policy or the privacy practices at Passport, please contact us at privacy@passportinc.com or write to us at 5960 Fairview Road, Suite 250 Charlotte, NC 28210 USA.