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PRIVACY POLICY - UNITED STATES AND CANADA

Last Updated: December 30, 2022

Last Reviewed: December 30, 2022

SpotHero, Inc. and its affiliates (“SpotHero,” “we,” “us,” or “our”) offers
marketing services (“Marketing Services”) regarding the location and potential
availability of certain parking spots (“Parking Spots”) to users (“Users”) of
www.spothero.com and associated software application(s) (“App”) (collectively,
the “Site”). In so doing, we market the Parking Spots on the Site and facilitate
the reservation (“Reservations”) of Parking Spots between Users of the Site and
owners, lessors, managers or operators of Parking Spots (“Licensors”)
(collectively, Users and Licensors of the Site may be referred to as “you” or
“your”).

SpotHero values individual privacy rights and wants to give you and other
visitors to our Site the opportunity to understand the kind of information that
we collect and how you can limit the use of personal information to those
purposes for which it has been authorized, as detailed in this privacy policy
(“Privacy Policy”). By using the Marketing Services or the Site, you agree that
you have read and understood the Privacy Policy. The Privacy Policy describes:

 * the information that SpotHero collects from you;
 * how that information is used, transferred, and disclosed by SpotHero; and
 * the rights and options available to you.

This Privacy Policy is incorporated as part of the SpotHero Terms and
Conditions, available at https://spothero.com/legal/terms-of-use. This Privacy
Policy does not apply to workforce-related personal information collected from
job applicants. You can view our Applicant Privacy Notice here or via our
Careers page.

Important note for former Parking Panda users: Thank you for visiting SpotHero!
If you are looking for the last version of the Parking Panda Privacy Policy
prior to the shut down of the Parking Panda website, please follow this
link: https://spothero.com/legal/parking-panda-privacy.

Thank you for reading our Privacy Policy. We hope you enjoy using SpotHero!


1. INFORMATION WE COLLECT

We collect, transmit, and store information that you provide directly to us
through (i) the use of the Site, (ii) creation or modification of an account,
(iii) requesting of Marketing Services, (iv) contacting of customer support or
other similar communications, and (v) requesting of SpotHero’s Marketing
Services for Parking Spots as a Licensor. The type of information we collect,
transmit, and store is described below:

 * Identifiers. When you create a SpotHero account as a User or Licensor, we
   store and use information you provide during the account creation process as
   a User or account onboarding process as a Licensor, such as first and last
   name, email address, phone number, postal address, login and password
   information, vehicle information such as, license plate information and
   make/model/year of a vehicle, and other similar account information (“Account
   Information”)
 * Payment Information. When you use our Site as a Licensor, we may collect
   financial information, such as bank account or wire transfer information to
   facilitate payments directly to you. If you are using our Site and services
   to create Reservations, limited credit card and bank account information may
   be collected by SpotHero and more detailed credit card or bank account
   information may be collected by our payment processor, Stripe
   (https://stripe.com/en-ca/privacy). We never have access to your full credit
   card number, but, to administer your account and prevent fraud, we may have
   limited access to the following: the type of credit card you used (Visa,
   AmEx, etc.), the last four digits of the card number, and the card's
   expiration date;
 * Internet or Other Similar Network Activities. The IP address from which you
   access the Site; cookie data; network connection type; browser type; the name
   of the domain from which you access the internet; the type of device, browser
   and operating system used to access the Site; the date and time you access
   the Site and the duration and stop time of such access; the information about
   any person or entity from whom you were referred; the pages, files, documents
   and links that you visit; the internet address of the website from which you
   linked to the Site;
 * Commercial Information and Inferences. Information about your visit to the
   Site or your usage of the Marketing Services generally; information you
   provide voluntarily when participating in surveys or product improvement
   interviews; and
 * Geolocation Information.Geolocation information including, with your consent,
   precise geolocation information.


2. HOW WE USE THE INFORMATION WE COLLECT

Consistent with the permission you give us to collect personal information from
you, SpotHero may use such information for the following legitimate business
purposes:

 * To provide, personalize, and improve your experience with the Marketing
   Services and our advertising made available on or outside the Site;
 * To ensure technical functionality of the Marketing Services, develop new
   products and services, and analyze your use of the Marketing Services,
   including your interaction with applications, advertising, products and
   services that are made available, linked to, or offered through the Marketing
   Service;
 * To communicate with you for Marketing Service-related or research purposes
   including via e-mails, notifications, text messages, or other messages, which
   you agree to receive;
 * To communicate with you, either directly or through one of our partners, for
   marketing and promotional purposes via e-mails, notifications, or other
   messages consistent with any permissions you may have communicated to us;
 * To facilitate payment processing through our third party payment processor,
   Stripe, or prevent or detect fraud;
 * To facilitate payments directly to you as a Licensor;
 * With your consent, to calculate distance to available Parking Spots and show
   you Parking Spots near your location;
 * To enforce this Privacy Policy, the Terms and Conditions, and any other terms
   that you have agreed to, including to protect the rights, property, or safety
   of SpotHero, Users, Licensors, or any other person, or the
   copyright-protected content of the Marketing Services;
 * To fulfill the purpose for which you submitted the information and for other
   uses consistent with that purpose; and
 * As otherwise stated in this Privacy Policy.


3. HOW WE DISCLOSE YOUR INFORMATION

We may disclose the information we collect, transmit, and store with third
parties for a business purpose, as described below. Otherwise, we do not sell,
rent, lease, or “share” personal information, and will not disclose Users’
personal information to third parties for purposes of their direct marketing
without your consent.

With Licensors. If you are a User, we share your information with Licensors for,
among other things, facilitating Reservations, confirming your Reservation
on-site, and otherwise for the Licensors’ own business uses, including marketing
to you.

With Users. If you are a Licensor, we share your information with Users for,
among other things, facilitating Reservations and providing customer support.

With our Service Providers. We share your information with third-party service
providers to support or provide services for us in connection with your use of
the Site and our Marketing Services, such as services related to communications
and hosting, security and fraud prevention, technical and customer support,
tracking and reporting usage, marketing, payment processing and other functions.
SpotHero shares personal information with its service providers subject to
obligations consistent with this Privacy Policy, and on the condition that
personal information is only used on SpotHero’s behalf and pursuant to our
instructions.

With Payment Processors. We share your information with our third party payment
processor, Stripe, so that Users can pay for Reservations made on our Site. If
you are a Licensor, we share your information with banks and other financial
institutions in order to make payments to you.

To Complete Business Transfers. We share information from or about you with our
subsidiaries or other companies under common control, and require them to also
honor this Privacy Policy. If another company acquires SpotHero, or all or
substantially all our assets, that company will possess the same information,
and will collect, use, and disclose the information only as described in this
Privacy Policy.

With Marketing, Advertising, and Analytics Service Providers. We may share
information about you with our data analytics and advertising service providers,
such as Google Analytics and Rakuten Advertising, to help us measure traffic and
usage trends for the Site and to understand more about the demographics and
behaviors of our Users. These companies may collect personal information when
you interact with our digital property, including IP addresses, digital
identifiers, information about your web browsing and app usage and how you
interact with our properties and ads for a variety of purposes, such as
personalization of offers or advertisements, analytics about how you engage with
websites or ads and other commercial purposes. To learn more about Google's
privacy practices, click here. To access and use the Google Analytics Opt-out
Browser Add-on, click here. To learn more about Rakuten’s privacy practices,
click here. To learn more about your rights with respect to Rakuten, click here.

To Protect Rights and Property.  We may disclose your information to third
parties when we believe in good faith that disclosure is necessary to protect
our rights, our property, personal safety, or the interests of you or any other
person, and to detect, prevent and/or otherwise address fraud, risk management,
security or technical issues.

To Comply with and as Required by Law. We may disclose your personal information
to government authorities or other relevant third parties in order to comply
with applicable legal requirements, judicial proceedings, court orders, legal
process, or lawful requests from governmental authorities. We may also disclose
your personal information in the good-faith belief that such action is necessary
to protect our rights, interests, or property, or to protect your safety or the
safety of others.

Aggregate or Anonymous Information. We share User information in the aggregate
with third parties, such as Licensors that use our Marketing Services. For
example, we may disclose the number of Users that have booked a Reservation in a
particular city or a particular location.

At Your Request. We also share your information as directed or requested by you,
or subject to your consent.


4. DEIDENTIFIED INFORMATION

We may collect deidentified information from you and aggregate information that
may not by itself reasonably identify you as the source when you navigate the
Site (“Deidentified Information”). Deidentified Information may include: (i)
device type, (ii) device operating system, (iii) internet browser type, (iv)
internet service provider, (v) referring/exit pages, (vi) date/time stamp, and
(vii) clickstream information. We will take reasonable measures to ensure that
Deidentified Information we collect is not personally identifiable and may not
later be easily used to identify you as required by applicable law. When we
receive or use deidentified information, we maintain it in deidentified form and
do not attempt to reidentify the information.


5. LOCATION INFORMATION

When you use the Site or Marketing Services, we may collect and store general
location information, such as an IP address. If you permit us to access location
services through the permission system used by your mobile operating system or
browser, we may also collect the precise geolocation of your device when our App
is running in the foreground or background of your device. This information may
be used to help you locate parking spots near you. You do not have to enable
precise geolocation data to use our App, but its functionality may be affected
by your choice.


6. TEXT MESSAGING

SpotHero may use the mobile phone number or similar contact information that you
provided to us to send text messages to provide you with the Marketing Services
and to facilitate your use of Reservations. For example, SpotHero may send you a
text message containing a parking pass or other information allowing you to
access a Parking Spot or garage. Additionally, SpotHero may send you a text
message containing a link to download a copy of its software application, based
on your request. Each text will contain instructions permitting you to “opt-out”
of receiving future text message communications. However, you cannot revoke your
authorization for fraud related communications or legally required
communications.


7. USE BY CHILDREN

The Marketing Services and Site are not intended for use by persons under the
age of 16 in the United States (or under the age of majority in Canada, as
applicable). We do not seek or knowingly collect information from individuals
under the age of 16, and we request that such individuals do not provide such
information.If you are under 16 and a resident of the United States (or under
the age of majority in your respective Canadian jurisdiction), you may not use
either the Marketing Services or the Site. If we learn we have collected or
received personal data form a child under the age of 16, we will promptly delete
the information.


8. COOKIES AND INTEREST BASED ADVERTISING

Cookies and similar tracking technologies, such as beacons, scripts, web beacons
and tags, are small bits of text, that are stored on browsers or devices by
websites, apps, online media and advertisements. We use cookies and similar
tracking technologies for purposes such as: authenticating Users, remembering
Users’ preferences and settings, and understanding the behaviors and interests
of Users who visit the Site or interact with the Marketing Services.

You can learn more about our use of cookies by visiting our Cookie and
Interest-Based Advertising Policy.


9. YOUR RIGHTS AND CHOICES

SpotHero provides ways for you to access and delete your personal information as
well as exercise applicable data rights that give you certain control over your
personal information. Your Rights and Choices include:

Email Subscriptions. We may, from time to time, communicate with you via email.
If you no longer wish to receive promotional emails from us, please let us know
by clicking unsubscribe in those messages or by emailing us at
support@spothero.com.  Please note that, although you can opt not to receive
promotional emails, we reserve the right to send you informational emails about
any administrative notices regarding the Site or important information about
your account, as permitted under the CAN-SPAM Act (15 U.S.C. §7701 et seq.).

Text Messages. You can opt-out of receiving text messages by texting STOP from
the mobile device receiving the messages. Opting-out of receiving text messages
may limit your ability to take advantage of our full range of features and
services.

Location Information. You can prevent your device from sharing location
information through your device’s system settings. If you do, this may limit our
ability to provide you our full range of features and services.

Cookie Tracking. You can modify your cookie settings in your browser. You can
also update your cookie settings by using our “Cookie Preference Center” tool
available in our Site footer. You may also enable online, where available, a
universal opt-out preference tool (such as the Global Privacy Control (GPC)
signal) that automatically communicates your opt-out preferences, which we
intend to respect.

Accessing Your Account. You can access or correct your account information at
any time by logging into your account or by contacting support@spothero.com (if
you are a User) or sellersupport@spothero.com (if you are a Licensor). If you
wish to close your account, please contact support@spothero.com (if you are a
User) or sellersupport@spothero.com (if you are a Licensor).

Deleting Your Account. You can delete your User account through the SpotHero iOS
mobile app by opening the SpotHero app, clicking Account --> Privacy --> Delete
My Account. Please note that in some cases we may retain certain information
about you as required by law, or for legitimate business purposes to the extent
permitted by law. Please note that deleting your account is permanent and cannot
be undone.

State and Country Specific Rights. Some states provide specific, additional
rights to their residents regarding personal information. For more information
about these rights and how to exercise them, see the State and Country Specific
Rights section below.


10. LINKED SITES AND THIRD PARTY USE OF INFORMATION

Other websites that you visit, including any such sites linked from or to our
Site (such as websites of Licensors), may have separate privacy policies or none
at all. Other websites may use personal information differently than our policy
permits so we strongly encourage you to review the privacy policies of any site
before you provide your personal information on the internet or explore such
third-party sites. You agree that we are not responsible for unauthorized
third-party use of your information.


11. DATA INTEGRITY AND SECURITY

We utilize information technology security to keep the information that you
provide to us via our Site secure. We also attempt to have privacy protection
controls in place with our vendors in order to ensure that your personal
information is protected from unauthorized access or disclosure. Only authorized
employees are permitted to access your personally identifiable information or
that of other visitors touring the Site. Notwithstanding, as effective as our
reasonable security measures may be, no security system is impenetrable nor is
any method of transmission over the Internet or via mobile device, or method of
electronic storage, 100% secure. Therefore, while we strive to use commercially
acceptable means to protect your personal information we cannot guarantee its
absolute security.


12. INTERNATIONAL USERS

SpotHero is based in the United States of America (“U.S.”), and, regardless of
where you use our Site from or otherwise provide information to us, the
information may be transferred to and maintained on servers located in the U.S.
Please note that any information we obtain about you will be stored in
accordance with U.S. privacy laws, regulations and standards, which may not be
equivalent to the laws in your country of origin or residence. By using the Site
or by providing us with your information, you consent to this collection,
transfer, storage, and processing of information to and in the U.S. SpotHero
only offers Marketing Services in the U.S. and Canada.


13. RETENTION

We will retain your personal information while you maintain an account with
SpotHero or to the extent necessary to provide the services through the Site.
Thereafter, we will keep personal information for as long as reasonably
necessary: (i) to respond to any queries from Users; (ii) to demonstrate we
treated Users fairly; (iii) for ordinary business continuity procedures; or (iv)
to comply with any applicable laws. We delete personal information within a
reasonable period after we no longer need the information for the purposes set
out in this Policy.


14. MODIFICATIONS TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in our sole discretion
without prior notice to you. The most current version of the Privacy Policy will
govern our collection, use, and disclosure of information about you. You are
responsible for ensuring we have an up-to-date, active, and deliverable email
address for you, and for periodically visiting our Site and this Privacy Policy
to check for any changes. We will indicate at the top of the Privacy Policy when
it was most recently updated. Accordingly, please refer to this Privacy Policy
frequently as it may change.

If we make material changes to the Privacy Policy, we will notify you by email
and/or by positing a notice on the Site prior to or on the effective date of the
changes. By continuing to access or use the Marketing Services after those
changes become effective you acknowledge the revised Privacy Policy.


15. CONTACT INFORMATION

If you have questions about this Privacy Policy or wish to contact us regarding
our privacy practices, we can be reached via any of the following:

SpotHero, Inc.
125 S. Clark St., Ste. 1300
Chicago, IL 60603

Privacy Contact: legal@spothero.com


16. STATE AND COUNTRY SPECIFIC RIGHTS

Pursuant to certain state laws, you may have additional rights that you may
exercise with respect to SpotHero’s collection, use, and sharing of your
personal information, as further described below.

SpotHero will not discriminate against you for exercising your rights under any
state law.

A. CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS

California Rights Regarding Your Personal Information. If you are a California
resident, the California Consumer Privacy Act of 2018 (“CCPA”), as amended by
the California Privacy Rights Act (“CPRA”), grants you certain data privacy
rights. Your rights include the:

 * Right to Access: You have the right to request a copy of the specific pieces
   of personal information that we have collected about you in the previous
   twelve (12) months. The information will be delivered by mail or
   electronically. Upon receipt of a Verifiable Consumer Request, described
   below, we will disclose: (i) The categories of personal information we have
   collected about you; (ii) The categories of sources from which personal
   information is collected; (iii) Our business purpose for collecting personal
   information; (iv) The categories of third parties with whom we share personal
   information, if any; and (v) The specific pieces of personal information we
   have collected about you.
 * Right to Data Portability: You have the right to receive your personal
   information in a portable, readily usable format that allows you to transmit
   your information to another entity without hindrance.
 * Right to Correct Inaccurate Information: You have the right to request that
   we correct inaccurate information about you that we maintain.
 * Right to Deletion: You have the right to request that we delete your personal
   information.
 * Right to Be Free from Discrimination: You have the right to not be
   discriminated against by us for exercising any of your rights under the CCPA.
   Unless permitted by the CCPA, we will not: (i) Deny goods or services to you;
   (ii) Charge different prices or rates for goods or services, including
   through the use of discounts or other benefits or imposing penalties; (iii)
   Provide a different level or quality of goods or services to you; or (iv)
   Suggest that you will receive a different price or rate for goods or services
   or a different level or quality of goods or services.

To exercise your rights, please use the Verifiable Consumer Request method
described below. Please be aware that your rights (including those enumerated
elsewhere in this Policy) are limited to the extent permitted by applicable law.

To opt-out of the “sharing” of your personal information for personalized or
targeted advertising purposes, follow the instructions here or visit our Cookie
Preference Center in the footer of our website.

Categories of Information Collected, Disclosed, and Shared. The categories of
personal information we collect and the sources from which we collect such
information are described in Section 1 of our Privacy Policy; the business
purposes for which we use this information are described in Section 2 of our
Privacy Notice; and the categories of third parties to whom we may disclose this
information are described in Section 3 of our Privacy Policy. We have not sold
consumers’ personal information in the preceding twelve (12) months.

As further described in our Privacy Policy, in the preceding twelve (12) months,
we or our service providers may have collected the following categories of
personal information, as defined in the CCPA, for a business purpose:

 * Identifiers
 * Financial Information
 * Commercial Information
 * Internet or Other Electronic Network Activity Information
 * Geolocation Data Sufficient to Identify a Precise Physical Location
 * Inferences About Preferences and Characteristics Based on Other Personal
   Information

Sensitive Personal Information. SpotHero does not use or disclose sensitive
personal information other than to provide you the Site and Marketing Services,
as permitted by California law. SpotHero does not sell or share sensitive
personal information for the purpose of cross-context behavioral advertising.

California’s “Shine the Light” Law. Separate from the CCPA, California’s “Shine
the Light” law permits Users of the Site that are California residents to
request certain information regarding our disclosure of personal information to
third parties for their direct marketing purposes. We do not disclose your
personal information to third parties for the purpose of directly marketing
their goods or services to you unless you request such disclosure. If you have
any questions regarding this policy, or would like to change your preferences,
you may contact us at the address listed above in Section 15 (Contact
Information).

B. OTHER STATE PRIVACY RIGHTS

Residents of certain states, such as California, Nevada, Colorado, Virginia, and
Utah may have additional personal information rights and choices.

Colorado, Connecticut, Virginia, and Utah each provide their state residents
with rights to:

 * Confirm whether we process their personal information;
 * Access and delete certain personal information
 * Data portability;
 * Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with
rights to:

 * Correct inaccuracies in their personal information, taking into account the
   information's nature processing purpose;
 * Opt-out of profiling in furtherance of decisions that produce legal or
   similarly significant effects.

Nevada provides its residents with a limited right to opt-out of certain
personal information sales.  SpotHero does not sell your personal information to
third parties as defined in Nevada law, and will not do so in the future without
providing you with notice and an opportunity to opt-out of such sale as required
by law. If you have any questions regarding our data privacy practices or our
compliance with Nevada data privacy law, please contact us at
legal@spothero.com.

To exercise your state-specific privacy rights, please use the Verifiable
Consumer Request method described below.

To opt-out of the “sharing” of your personal information for personalized or
targeted advertising purposes, follow the instructions here or visit our Cookie
Preference Center in the footer of our website.

C. CANADA RESIDENTS: YOUR CANADIAN PRIVACY RIGHTS

Under applicable Canadian privacy legislation, you have the following rights:

 * Access. SpotHero permits the reasonable right of access to your Personal
   Information. Upon written request and authentication of identity, we will
   provide you with access to your Personal Information under our control,
   subject to any legal requirements and applicable exceptions to the right of
   access. We will make the information available within thirty days or provide
   written notice where additional time is required to fulfill the request.
   Where an access request is refused, we will notify you in writing and provide
   our rationale for refusal along with a list of next steps available to you.
 * Accuracy. If you demonstrate the inaccuracy or incompleteness of Personal
   Information, we will amend the information as required. If appropriate, we
   will send the amended information to third party service providers to whom
   the information has been disclosed.
 * Complaint. You may also have the right to complain to the Office of the
   Privacy Commissioner of Canada or the appropriate provincial Information and
   Privacy Commissioner if you have concerns related to our privacy practices.

If you are a resident of Canada and would like to exercise any of the
aforementioned rights, please click on this link and complete the webform.

Depending on your use of our Site and Marketing Services, you may have the
following choices:

 * Cookies Settings and Preferences. You may disable cookies and other tracking
   technologies through the settings in your browser. While doing so may
   negatively affect your experience with the use of our Site and Marketing
   Services, it will not prevent us from transacting with you. You can also
   update your cookie settings by using our “Cookie Preference Center” tool
   available in our Site footer.
 * Marketing e-mails. You may sign up for our mailing list in order to receive
   promotional and other materials that may be of interest to you. If you no
   longer wish to receive marketing e-mails from us, you may choose to
   unsubscribe at any time by clicking on the “unsubscribe” link in our emails
   or by contacting us at support@spothero.com.
 * Opt-Outs. You may contact us to opt out of the use or sharing of your
   Personal Information, including for marketing or advertising purposes, and/or
   the provision of your Personal Information to our business partners for such
   purposes.
 * Online behavioural advertising. As outlined further below, we use Google
   Analytics on our Site. For more information on how Google Analytics collects
   and processes information, as well as how you can control the information
   sent to Google, please review Google’s site “How Google uses data when you
   use our partners’ sites or apps” located at
   www.google.com/policies/privacy/partners/. You may control your advertising
   preferences or opt-out of certain Google advertising products (i.e. the
   Google Analytics cookies) by visiting the Google Ads Preferences Manager,
   currently available at https://google.com/ads/preferences.


17. VERIFIABLE CONSUMER REQUEST

You can exercise your legal rights by submitting a Verifiable Consumer Request
to us by:

 * Visiting us at our webform (Preferred);
 * Emailing us at legal@spothero.com;
 * Calling us at (844) 707-7682.

Please note that we reserve the right to ask for information verifying your
identity and residency prior to disclosing any information to you or acting on
your request.  Should we ask for verification, the information you provide to
verify your identity and residency will be used only for that purpose, and all
copies of this information in our possession will be destroyed when the process
is complete. An agent may submit a request on your behalf, but you must verify
that your agent is authorized to do so.

If you make a request to exercise your rights, we will strive to respond or act
on your request within 45 days of receiving your verifiable request. Notably,
however, we reserve the right to extend the time to respond to 90 days when
reasonably necessary. You may only make a Verifiable Consumer Request for access
to personal information twice in a 12-month period.

If you wish to appeal SpotHero’s decision to deny a request, please contact us
via email within fourteen (14) days at the address listed above in Section 15
(Contact Information) using the subject line: Data Subject Rights Appeal.

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