REEF Mobile Privacy Notice

Effective Date: March 17, 2020

This REEF™ Mobile Privacy Notice (“Notice”) applies to those individuals that download and use the REEF™ Mobile App (“Users”) of REEF™ (“REEF”). We adopt this notice in alignment with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

For a complete description of REEF’s data handling practices, please review our full privacy policy found here.

Information We Collect

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User or device (“Personal Information”). In particular, we may have collected the following categories of Personal Information from those Users who are subject to this privacy notice within the last twelve (12) months:

Categories of Personal Information which are collected

  • Identifiers and demographic data. This includes data like name, address, mobile phone number, vehicle license plate, and email.
  • Sensitive Data. This includes financial account numbers necessary to process payments.
  • Transactional Data. This is data related to any parking services you may have paid for.
  • Internet or other similar network activity. Our app requires the use of an internet connection, either over Wi-Fi, or via your cellular network. The network activity necessary for you to connect to our services is the kind of data we collect. It can include information like device ID, operating system, and other related technical information necessary for us to provide the services in the app.
  • Geolocation data. This is location data we collect as part of the functionality of the app.
  • Inferences REEF based on Personal Information. This information relates to your ongoing usage of the app, the places where you park, and any additional services you may obtain from REEF while using the app or parking in facilities we own or manage.

Personal Information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated information.
  • Information excluded from the CCPA’s scope

REEF obtains the categories of Personal Information listed above from the following categories of sources:

·      Directly from you. For example, from forms you complete or products and services you use.

·      Indirectly from you. For example, from observing your actions as a User, from records of your use of REEF information technology, or from location-tracking enabled devices with the REEF app installed.

·      From independent third parties related to your eligibility for doing business with REEF. For example, your credit card issuer.

Use of Personal Information

We may process or disclose the Personal Information we collect for one or more of the following business purposes:

·      To fulfill or meet the reason you provided the information. For example, to pay for parking.

·      To provide you with support and to respond to your inquiries.

·      To enhance our services by, among other methods, obtaining assistance with providing more personalized services to you through analytics and other technologies.

·      To protect the security or integrity of the app, and any services you might obtain via the app.

·      To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

·      As described to you when collecting your Personal Information.

·      Disclosures made in an effort to prevent or halt violations of REEF policies, illegal activities, or as required by law.

·      Disclosures that we reasonably believe are necessary to defend against or prevent us from incurring liability to third parties.

·      To evaluate or conduct a fundraising, merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

REEF is an international group of companies where certain services are provided by one or more affiliates for the entire group or a part of it. We, therefore, reserve the right to share personal information with our direct and indirect affiliates for all purposes described above. Whenever we share Personal Data with affiliates, we request from them that they commit themselves to process Personal Data in line with this Privacy Notice.

We may disclose your Personal Information to a third party for our business purpose. These third parties are generally “Service Providers” as defined by applicable law. When we disclose Personal Information for our business purpose, we enter into a contract with our Service Providers that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

However, sometimes, we are the Service Provider to these third parties. When REEF is the Service Provider, these third parties are considered “businesses” by applicable law. Where REEF is a business’ Service Provider, our client’s handling of your personal information is not covered by this notice or REEF’s privacy policy.

We may also disclose your Personal Information to another company as part of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets to that company; or where required by REEF policy, law, or in response to valid legal process compelling disclosure.

Disclosures of Personal Information

In the preceding twelve (12) months, REEF has disclosed all of the categories of Personal Information as noted above, for the business purposes described above.

We disclose your Personal Information for a business purpose only to Service Providers, businesses, or, where required by law, or in response to valid legal process compelling disclosure.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold Personal Information. The Company does not and will not sell Personal Information of Users.

Changes to Our Privacy Notice

REEF reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date.

Contact Information

If you have any questions or comments about this notice, the ways in which REEF collects and uses your information, please do not hesitate to contact REEF at:

1+ (888) 561-7333

or

privacy@reeftechnology.com