1. Purpose and Scope
This policy governs the collection, access, use, maintenance, sharing, disclosure, retention, and destruction of automated license plate recognition information by Dos Parking LLC. It is intended to protect privacy and civil liberties and to satisfy the requirements applicable to ALPR operators and end-users under California Civil Code sections 1798.90.5 through 1798.90.55.
This policy applies to Dos Parking personnel and independent contractors who operate, administer, access, maintain, or support an ALPR system or ALPR information on behalf of Dos Parking. A facility owner or other customer may have additional responsibilities and policies.
2. Definitions
"ALPR System" means a searchable computerized database resulting from one or more mobile or fixed cameras combined with computer algorithms that read images of registration plates and convert the characters into computer-readable data.
"ALPR Information" means information or data collected through an ALPR System, including license plate images or characters and associated date, time, location, direction, lane, event, and equipment information.
"Authorized User" means a Dos Parking employee or approved independent contractor whose assigned duties require access to the ALPR System or ALPR Information and who has completed required training.
3. Authorized Purposes
Dos Parking may use ALPR Systems and ALPR Information only for legitimate, documented business, operational, safety, security, or legal purposes, including:
• Facilitating authorized vehicle entry, exit, parking, and access-control functions.
• Associating a vehicle with an authorized user account or facility credential.
• Verifying parking or access events and resolving customer-support questions or disputes.
• Protecting the safety and security of people, vehicles, facilities, equipment, and systems.
• Detecting, preventing, documenting, or investigating suspected fraud, misuse, security incidents, or unlawful activity.
• Testing, maintaining, troubleshooting, auditing, and improving ALPR accuracy and system performance.
• Preparing aggregated or de-identified operational analytics that are not used to track an identifiable person.
• Complying with applicable law, lawful process, contracts, insurance obligations, or documented legal holds.
ALPR Information will not be used for facial recognition, immigration profiling, discriminatory surveillance, personal purposes, employee curiosity, targeted advertising, or any purpose unrelated to an Authorized Purpose.
4. Authorized Personnel and Training
Access is limited according to role and least-privilege principles. The following roles may be authorized when access is necessary for assigned duties:
• Operations managers and designated facility operations personnel responsible for access, parking, incident response, or customer support.
• Information security, systems administration, engineering, and technical-support personnel responsible for security, maintenance, audit, troubleshooting, or accuracy.
• Designated privacy, legal, compliance, or risk personnel responsible for requests, investigations, claims, audits, or legal obligations.
• Approved contractors and service providers that require access to host, maintain, secure, or support the ALPR System under written confidentiality, security, and use restrictions.
Before receiving access, Authorized Users must receive training appropriate to their role covering this policy, permitted and prohibited uses, account security, privacy and civil liberties, accuracy limitations, access logging, incident reporting, retention, disclosure restrictions, and applicable law. Refresher training is required periodically and when material policies or systems change.
5. Access Controls and Monitoring
• Access must use unique user credentials and appropriate authentication. Shared accounts are prohibited except for a documented technical necessity with compensating controls.
• Permissions must be role-based, limited to the minimum necessary, reviewed periodically, and promptly removed when no longer needed.
• Dos Parking maintains records of access to ALPR Information. Records will include at least the date and time of access and the license plate number or other data elements used to query the system. Where technically available, records also include the user, organization, and business purpose.
• ALPR Information may be used only for the Authorized Purposes in this policy. Access logs and user activity may be reviewed to detect misuse and verify compliance.
• Suspected unauthorized access, disclosure, alteration, loss, or misuse must be reported promptly to the Privacy and Security Officer and handled under incident-response procedures.
6. Security Safeguards
Dos Parking maintains reasonable operational, administrative, technical, and physical safeguards designed to protect ALPR Information from unauthorized access, destruction, use, modification, or disclosure. Safeguards may include encryption in transit and at rest where appropriate, secure hosting, firewalls, monitoring, authentication, least-privilege access, logging, backups, vulnerability management, vendor controls, secure disposal, training, and incident response.
7. Sharing, Disclosure, Sale, and Transfer
Dos Parking does not sell ALPR Information and does not disclose it for advertising or a recipient’s independent marketing. ALPR Information may be shared only when reasonably necessary for an Authorized Purpose and subject to applicable law, including with:
• A facility owner, operator, manager, employer, hotel, municipality, or other business customer responsible for the location where the information was collected, when necessary for authorized operations, security, support, or investigation.
• A contracted service provider that hosts, secures, maintains, troubleshoots, or supports the ALPR System, under written restrictions on use, confidentiality, security, retention, and onward disclosure.
• Law enforcement, regulators, courts, insurers, counsel, or other parties when required by valid legal process or when disclosure is permitted by law and reasonably necessary to protect rights, property, safety, or security.
• A party to a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, subject to appropriate confidentiality and continued legal obligations.
• Another party at the direction or with the valid consent of the person to whom the information relates, when legally permitted.
Before a discretionary disclosure, personnel must verify the recipient, document the purpose and authority, limit the information to what is necessary, and apply appropriate safeguards. Requests from government agencies should be referred to designated privacy or legal personnel unless an emergency makes immediate disclosure lawful and necessary.
8. Accuracy and Correction
ALPR technology may produce inaccurate or incomplete reads because of lighting, plate condition, angle, weather, speed, obstruction, equipment limitations, or other factors. An ALPR result must not be treated as conclusive without appropriate review when it may materially affect a person.
Where reasonably available, Dos Parking may compare an ALPR image and timestamp against account information, access records, equipment data, or other reliable evidence. A person may report a suspected error to info@dosparking.com. Dos Parking will review a sufficiently specific request, correct associated account or operational records when appropriate, and document material corrections. Raw historical images may be preserved where needed to maintain evidentiary integrity, subject to retention rules.
9. Retention and Destruction
The retention period for ALPR Information is the duration reasonably necessary and proportionate to complete the specific Authorized Purpose for which the information was collected or retained. Information associated with an active safety, security, fraud, customer-support, legal, insurance, or other documented investigation may be retained until that matter is finally resolved and any applicable legal-preservation period ends.
When the Authorized Purpose or investigation is complete, Dos Parking will delete or de-identify the information within a reasonable operational period, unless continued retention is required or permitted by law, contract, litigation hold, safety need, or another documented Authorized Purpose. Dos Parking periodically reviews retained ALPR Information and destroys or de-identifies information that no longer has a valid retention basis. Destruction must be performed using methods reasonably designed to prevent reconstruction or unauthorized recovery.
10. System Oversight and Auditing
The Privacy and Security Officer oversees implementation of this policy, coordinates with operations and technology personnel, and is the official custodian for Dos Parking’s ALPR program. Dos Parking will periodically review access permissions, access logs, disclosures, retention, security controls, training, and compliance. Material violations may result in access removal, disciplinary or contractual action, notification to affected customers or authorities where required, and remediation.
11. Public Requests and Complaints
Questions, privacy requests, correction requests, or complaints concerning ALPR Information may be submitted to:
Dos Parking LLC
Attn: Privacy and Security Officer
724 Oak Grove Ave #100
Menlo Park, CA 94025
Email: info@dosparking.com
Phone: +1 551 340 9717
Dos Parking may verify identity, vehicle association, and authority before disclosing or changing ALPR Information. Requests may be limited or denied where disclosure would compromise security, another person’s privacy, an investigation, privilege, legal obligations, or where an exception applies.
12. Policy Review and Changes
Dos Parking will review this policy periodically and update it when systems, practices, or legal requirements materially change. The current version will be made publicly available in writing and conspicuously posted on dosparking.com. The effective date appears at the top