Privacy

Last Updated: February 18, 2018

This website (the “Site”) is owned, operated and provided by HotSpot Parking Inc., in conjunction with and on behalf of our subsidiaries, affiliates, related corporations and business names (collectively “HotSpot”).

We at 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 the Site, or signing up for any of the products or services HotSpot offers (collectively, the “Services”, and each a “Service” as defined in our Terms of Service) you are agreeing to the terms of this privacy policy (the “Privacy Policy”), including but not limited to the collection, use and disclosure of your information as described below, and the HotSpot Terms of Service, which incorporates by reference this Privacy Policy.

In this Privacy Policy “you” and “your” refer to any person or entity who downloads, views, uses, accesses, or browses any content or material from the Site or the Services. “We”, “us” and “our” refer to HotSpot.  Any capitalized terms not defined in the Privacy Policy shall have the meaning given to them in the HotSpot Terms of Service.

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 other entity 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 the Site or 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, but we are under no obligation to do so. 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 of our Privacy Policy.

When we use the term “Personal Information” in the Privacy 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 HOTSPOT MOBILE APP USERS

This section covers the Personal Information we collect about HotSpot Mobile App users.

1.1 INFORMATION WE COLLECT FROM HOT SPOT MOBILE APP USERS AND WHY

When you sign up for a HotSpot Account or the HotSpot Mobile App, we collect the following Personal Information (“User Information”), voluntarily and directly from you:

  • your name;
  • email address;
  • phone number;
  • license plate; and
  • car make and year.

We need this information to verify your identity, communicate with you about the Site or the Services, contact you about HotSpot promotions, set up your HotSpot Account, and allow you to use the HotSpot Parking Services and HotSpot Transit Services.

You may also set up your HotSpot Account by linking it to your Facebook account.  If you sign up using your Facebook account, Facebook will ask your permission to share certain information from your Facebook account with HotSpot.  This includes your name, email address, and profile picture.  Facebook has its own privacy policy which will govern how Facebook uses, collects, and shares your Personal Information.  You can control the information we receive from Facebook using the privacy settings on your Facebook account.

If you want to buy Parking Tokens or Transit Tokens, you must link a valid and authentic credit card to the HotSpot Account through Stripe Payments Canada, Ltd. (“Stripe”), a third party software platform used to accept payments in connection with web and mobile applications.  Stripe will collect Personal Information from you in order to accept your payments.  Stripe has its own privacy policy which will govern how Stripe uses, collects and shares your Personal Information. 

If you have location services enabled on your mobile device, when you park with the HotSpot Mobile App and when you walk into businesses that are using our HotSpot Merchant Parking Validation Services, we collect location information (collectively, “Location Information”), including:

  • when you enter or leave a business;
  • approximate time spent inside the business; and
  • location of your parked car.

This information, which may be connected to certain User Information, is used to provide you with certain functionality within the HotSpot Mobile App, including Parking Extender, Designated Driver, Find-your-Car (as these functions are defined in the HotSpot Mobile App), and parking validation on behalf of a merchant.  Some or all of this information may be shared with merchants who use our HotSpot Merchant Parking Validation Services.

1.2 HOTSPOT MOBILE APP USER INFORMATION WE SHARE AND WHY

In order to provide you with parking validation on behalf of a merchant, we need to share some of your User Information and Location Information with our HotSpot Merchant Parking Validation Services users.  When you enter a business that is using our HotSpot Merchant Parking Validation Services, we share your name and time spent in store with that merchant. 

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 HotSpot Parking Services.

2. PERSONAL INFORMATION FROM THE SITE

When you interact with us via the Site, we use various technologies to collect certain anonymous information from you (the “Site Usage Information”).  The Site Usage Information we collect may include information about the device and browser you use, your network connection, your IP address and the date and time you visited the Site.  We also assign a unique cookie to each website visitor (a small piece of data stored on your device that includes a unique identifier). 

In addition to the Site Usage Information, we also collect any information you provide us with voluntarily (this may include your name and email address).

We use the Site Usage Information and the personal information voluntarily collected from you when you visit the Site to recognize you when you return, personalize your Services, service your HotSpot Account, enhance the Services, and answer any questions you may have.  We may also use this information to send you marketing material and updates on our Services; but we will not send you this unless you have opted-in to receiving it.

HotSpot may share the Site Usage Information with its third party advertisers, marketing agencies and/or media partners, who, along with HotSpot, may use the Site Usage Information in order to tailor the advertising you see on other participating third party websites.

3. 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:

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

4. 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:

  • to participating municipalities as part of our resolve parking ticket function, when you elect to use this function;
  • to our service providers and suppliers to perform a business, professional, or technical support function for us like processing payments and website hosting;
  • as necessary if we believe that there has been a breach of this Privacy Policy, the Terms of Service, or some other violation of our rights or the rights of any third party;
  • 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; or
  • 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 further reserve the right to use and disclose any information collected via the Site that is not in a personally identifiable form.

5. 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.  You may withdraw your consent to the collection, use or disclosure of your information at any time, recognizing that we will need some reasonable notice in order to accommodate your request, and that it may be subject to any specific contractual obligations you may have toward us.

6. 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 HotSpot Account, and any end-users you are providing services to through our Services and your HotSpot Account. Don’t share your HotSpot Account information with anyone and notify us immediately if you believe there has been a breach.

7. WHAT WE DON’T DO 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.

8. 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.

9. 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.

10. MODIFYING OR DELETING YOUR INFORMATION

Your Personal Information is stored, maintained on, and processed on computers or servers located within Canada. 

You may review, update, correct, or delete any information in your HotSpot Account by contacting us, or by making the appropriate modifications in your HotSpot Account profile or preferences.  If you completely delete all of your information then your HotSpot Account may become deactivated.

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.

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 HotSpot Account and/or remove your records from our system, please contact us and we will delete your HotSpot 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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