Last Updated: June 15, 2017
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.
1.01 WHAT WE COLLECT FROM MERCHANTS AND WHY
We collect this information about merchants:
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:
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.
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”):
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:
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.
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:
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.
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.
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:
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.
Additionally in the event of a
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.
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.
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.
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.
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.
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.
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.
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: