Privacy Policy

zero5, Inc. ("zero5" or "we" or "zero5") respects your privacy and is committed to protecting it through our compliance with this policy

This Privacy Notice (our "Privacy Notice") describes the types of information we may collect from you or that you may provide when you visit the website zero5.co or subdomains thereof (each, a "Website") and/or when you use our mobile applications that you download from an official mobile application store, such as the Apple App Store® or the Google Play Store® (each, an "Application") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• on our Websites and Applications;
• in email, text, and other electronic messages between you and our Websites and/or Applications;
• when you visit a parking facility that uses our services, which may include information collected automatically through cameras and other recording devices as well as information manually entered by the operator of the parking facility; and
• when you interact with our advertising on third-party websites, applications, or services, if those advertisements include links to this policy.

It does not apply to information collected by:

• through any other means, including on any other website or application operated by zero5 or any third-party or when you otherwise interact with us offline (other than when you visit a parking facility);
• us related to your or any other individual's employment or potential employment with us; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Websites and Applications.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites or Applications. By accessing or using these Websites or Applications, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of these Websites or Applications after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.

Our Websites and Applications are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Websites or Applications. We do not knowingly collect Personal Data from children under 13. If you are under 13, do not use or provide any information on our Websites or Applications or on or through any of its features, register on the Websites or Applications, make any purchases through the Websites or Applications, use any interactive or public comment features of our Websites or Applications, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 13 without verifiable parental consent, we will delete that information. If you believe we might have any information directly from a child under 13, please contact us at team@zero5.co.

(A) Generally

We collect several types of information from and about users of our Websites and Applications ("Personal Data"):

• by which you may be personally identified, such as name, date of birth, postal address, e-mail address, telephone number, license plate number, vehicle identification number (“VIN”), images or video of your vehicles;
• if you are an employee of a parking facility that uses our services, we may collect information that allows you to access our Application or Website and manage the operations of the parking facility, such as your job title and employee ID
• that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites or Applications, error information, clickstream data, and other communication data and the resources that you access and use on the Websites; and/or
• about your internet connection, the equipment you use to access our Websites and Applications, and usage details.

We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through the Websites or Applications. Information collected automatically may include usage details, IP addresses, information collected through cookies, and other tracking technologies; and
• from third parties, for example, the operators of the parking facilities that use our technology and services.

(B) Information You Provide to Us

The information we collect on or through our Websites and Applications are:

• information that you provide by filling in forms on our Websites or Applications. This includes information provided at the time of registering to use our Websites or Applications, subscribing to our service, or requesting further services. We may also ask you for information, when you enter a contest or promotion sponsored by us, and when you report a problem with our Websites or Applications;
• records and copies of your correspondence (including email addresses), if you contact us;
• your responses to surveys that we might ask you to complete for research purposes;
• details of transactions you carry out through our Websites or Applications and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Websites or Applications;
• your search queries on the Websites or Applications; and
• information you provide or is collected in order to deliver services to you.

(C) Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Websites or Applications, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:

• details of your visits to or use of our Websites or Applications. We collect traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites and Applications, error information, clickstream data, and other communication data and the resources that you access and use on the Websites and Applications;
• Information about your computer or mobile device and internet connection, i.e., your IP address, operating system, and browser type; and
• Images of your vehicle and other information about your stay at a parking facility that uses our services, including an image of your vehicle and license plate, and your entry and exit times at the parking facility. We use this information to assist the parking facility in understanding the use of their facility as well as to allow you to use the "auto pay" feature of our services.

The information we collect automatically is statistical data may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Websites and Applications and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Websites and Applications according to your individual interests;
• speed up your searches; and
• recognize you when you return to our Websites or Applications.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies).

  A cookie is a small file placed on the memory of your computer or mobile device. Our Websites may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Websites. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Websites. You can find more information about cookies at http://www.allaboutcookies.org.

• Session Cookies.

  Our use of cookies may also include "session cookies." Each time you access the Website, a session cookie containing an encrypted, unique identifier is placed on your browser. These session cookies allow us to uniquely identify you when you use the Website and track which pages of the Website you access. Session cookies are required to use the Website

(D) Information We Collect From Third Parties

We may also collect information from third parties, such as the operator of a parking facility at which you park your vehicle. This may include information about your vehicle and your stay at a parking facility, including when you use a valet to park your vehicle. We use this information to assist the parking facility in understanding the use of their facility, assist the facility in providing valet services, as well as to allow you to use the "auto pay" feature of our services.

We use information that we collect about you or that you provide to us, including any Personal Data:

• to present our Websites and Applications and their contents to you;
• to provide you with information, products, or services that you request from us and to personalize or develop those products or services (including for example, auto-pay services that you may sign up for);
• to provide you with notices about your account;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to our Websites and Applications or any products or services we offer or provide through them;
• to allow you to participate in interactive features on our Websites and Applications;
• to maintain, customize, and secure your account;
• to help maintain the safety, security, and/or integrity of our business, website, products, services, databases, and other technology assets;
• to provide you with support and to respond to your inquiries (including to investigate and address concerns and monitor/improve responses)
• for internal testing, research, analysis, and product development, including to develop and improve our websites and application, and to develop, improve, or demonstrate our products and services including by training machine learning models;
• to undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us;
• to assist the operator of a parking facility that uses our services to help manage the parking facility, obtain payment for parking services, and improve to their services;
• to process your payment for parking or validation for parking;
• if you are an employee of a parking facility, so you may manage parking operations at the facility, including to enter and track information about valet tickets;
• in any other way we may describe when you provide the information;
• to fulfill any other purpose for which you provide it; and
• for any other purpose with your consent.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Privacy Notice:

• to the operator of the parking facility that you park your vehicle in;
• to contractors, service providers, and other third parties we use to support our business. Our payment processors' privacy policies may be found at http://stripe.com/us/privacy;
• to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of zero5's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by zero5 about our Websites' and/or Applications' users is among the assets transferred;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of zero5, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies.

  You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Websites may then be inaccessible or not function properly.

You can review and change some of your Personal Data by logging into the Websites or Applications and visiting your account profile page. You may also contact us through any of the contact information below to request access to, correct or delete some types of Personal Data that you have provided to us. We cannot delete your Personal Data except by also deleting your user account. We may not always be able to accommodate a request to delete or change information, including if we believe the deletion or change would violate any law or legal requirement or cause the information to be incorrect. If you are an employee of a parking facility, you may need to make your request through the operator of the parking facility.

California residents may have additional rights and choices related to the use of their Personal Data. Please see State-Specific Privacy Rights for more information.

Your California Privacy Rights

In addition, California residents are entitled to certain information about our use of Automated License Plate Recognition Systems ("ALPR System") as described in the California ALPR System Addendum.

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they "do not track" your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites or Applications, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to use a password on our Websites and Applications that is different from passwords you use on other websites and applications.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Websites or Applications. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Websites or Applications.

We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page or on the main screen or as a pop-up in our Application. If we make material changes to how we treat our users' Personal Data, we will notify you by email to the email address specified in your account. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and/or Applications and this Privacy Notice to check for any changes.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you must contact us at the contact information below or through the "Contact" page on our Websites.

To Contact zero5:

zero5
3 E. 3rd Ave
Suite 221
San Mateo, CA 94401
USA
team@zero5.co

Effective Date: 09/08/2021

This California Automated License Plate Recognition System Addendum (the "Addendum") governs the ALPR System operated by zero5, and applies to our employees, customers, and camera affiliates who have access to or use our ALPR Systems. Our services may include the use of an Automated License Plate Recognition System ("ALPRS" or "ALPR System") when deployed at a parking facility by that facility's operator. Our ALPR System contains a searchable computerized database resulting from the operation of one or more mobile or fixed cameras combined with computer algorithms to read and convert images of registration plates and the characters they contain into computer-readable data. The information contained in the system includes images of license plates, plus the date, time and location when the images were collected, and the license plate characters and numbers associated with the image.

The images stored in the system are collected from areas visible to the public where there is no reasonable expectation of privacy. The data collected by the ALPR System and stored in our system may contain Personal Data (as defined in our Privacy Notice), such as the information which relates the license plate image to the driver when you provide us this information.

PII contained in vehicle registration information is protected by federal law (Driver's Privacy Protection Act, Title 18, US Code, Section 2721 et seq.) and state laws. Law enforcement and other users may have access to vehicle registration information, and other sources of PII, which they may correlate with data collected and stored in the ALPR System to create vehicle hotlists in accordance with the above referenced federal law.

(A) Use and Collection of ALPR System data

zero5 authorizes collection of ALPR System data for use by zero5, the parking facility operators, and other customers of zero5's products and services consistent with this policy. The authorized uses of the ALPR system are:

• By zero5 and the operator of a parking facility for parking enforcement and management, including to identify or ascertain the location and identity of a specific vehicle when there is a legitimate commercial interest in doing so (for example, for billing and collections purposes or to prepare a vehicle for pickup from the parking facility);
• By law enforcement agencies for law enforcement purposes.
• By zero5 to make data collected by the ALPR System available to customers and law enforcement agencies for the purposes described above, to provide market research information to parking facility operators and other similar parties based on aggregated data collected by the ALPR System data, and to debug and improve our ALPR System and other products and services.

Some examples of the permitted users of the ALPR System include:

• zero5's personnel;
• The operator of the parking facility;
• Law enforcement personnel; and
• Entities to which information collected by the ALPR System or our Applications maybe disclosed as permitted under the Driver's Privacy Protection Act, 18 U.S.C. 2721 et seq.

We do not make the ALPR System or the data collected or stored by it available to individuals for personal, non-commercial purposes or for any purposes not described above.

(B) Users and Training

zero5 personnel are only permitted to use the ALPR System for the following limited purposes: (a) to demonstrate the system to parking facility operators who use our products and services, or who are interested in potentially using our products and services; (b) provide customer support, (c) to identify and repair errors that impair existing intended functionality in our products and services; (d) for internal testing, research, analysis, and product development, including to develop and improve the ALPR System and our other products and services; and (d) collect data for purposes authorized by this policy. All authorized personnel that use or access information collected from the ALPR System are required to read and understand our training manuals and other documentation for the ALPR System. Additionally, we require that all personnel of the operators of the parking facilities to attest that they have read and understood all applicable training materials provided either by zero5 or the parking facility operator.

(C) Monitoring and Compliance

The ALPR System sends status updates to zero5, and these status updates are monitored 24 hours a day for information anomalies and system disruptions. zero5 also monitors the information collected by the ALPR System to ensure the accuracy of charges to drivers using the parking facility, and zero5 promptly investigates any reports of incorrect ALPR System data and rectifies such data as appropriate.

zero5 maintains usage logs, and periodically audit such logs, to ensure the security of our data assets and compliance with this policy. The usage logs include the following information:

• The date and time data in the ALPR System is accessed.
• The IP address and other information about the device from which the ALPR System is accessed, such as the version of the zero5 Application, and make and model number of the device.
• The license plate number or other data elements used to query the system.
• The username of the person who accessed the information and, as applicable, the organization or entity with whom the person is affiliated.
• The purpose for accessing the information.

(D) Sale, Sharing or Transfer of ALPR System Data

zero5 collects data for commercial purposes. We do not collect ALPR System data on behalf of law enforcement agencies, and we do not share, sell, or transfer ALPR System data to other third-parties other than as described in this Addendum. We license the information from the ALPR System to parking facility operators and other similar entities solely for the purposes described in this Addendum. We share the results of specific queries for use by its customers consistent with this Addendum and pursuant to the parking facility operator's license agreement. All parking facility operators and other appropriate users are required to establish an account pursuant to an agreement with us that limits the use of the ALPR System data for authorized purposes only. We will also disclose the ALPR System data for the purposes described in our Privacy Notice, including to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

(E) Custodian or Owner of the ALPR System

zero5 is the custodian and owner of the ALPR System and is responsible for implementing this Addendum.

(F) Accuracy the Data Collected and Processed by the ALPR System

The collection data by the ALPR System is automated so that the license plate images, and the details of when they are collected, are included in the system without review, along with the computer translation of the license plate number. Although very infrequent, the license plate translation is sometimes inaccurate or incomplete. To avoid mistaken use of ALPR System data, zero5 recommends that you, as well as our parking facility operators customers, confirm the computer translation before taking any action as a result of information automatically collected and processed by the ALPR System. zero5 and/or the parking facility operator may correct errors in translation to license plate numbers and other database errors when identified.

(G) Retention

The company retains the data collected by the ALPR System as long as it has commercial value, which is generally one (1) year. The company periodically evaluates the use of historical data collected and stored by the ALPR System to determine if the cost to maintain the data exceeds its value, and may adjust its retention period. We may keep the data collected by the ALPR System for a longer period of time as follows: (a) as long as necessary to comply with any legal requirement (including any legal hold; (b) on our backup and disaster recovery systems in accordance with our backup and disaster recover policies and procedures; (c) for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; (d) if reasonably requested by the parking facility operator, for as long as they reasonably request. Note that we may retain any data collected from the ALPR System that has been aggregated or otherwise rendered anonymous in a manner that you are no longer identifiable for an indefinite period of time.

(H) Revisions to This Privacy Notice

zero5 reserves the right to amend this Addendum at our discretion and at any time. When we make changes to this Addendum, we will post the updated Addendum on our Website and in our Application and update the Addendum's effective date. Your continued use of our products and services following the posting of changes constitutes your acceptance of such changes.