SULLY PARKING PRIVACY POLICY

The personal information we collect depends on how you interact with Sully Parking, the Services you use, and the features available to you.

A. Contact and Identity Information

We may collect information such as:

• First and last name
• Email address
• Telephone number
• Mailing or billing address, when applicable
• Other information you voluntarily provide to identify yourself or communicate with us

B. Account Information

If you create or maintain a Sully Parking account, we may collect:

• Account username or email address
• Authentication information
• Account preferences
• Saved vehicle information
• Reservation history
• Account activity
• Communication preferences

Passwords are intended to be stored using appropriate security protections, such as cryptographic hashing, rather than in plain text.

C. Vehicle and Parking Information

When you make or use a parking reservation, we may collect:

• Vehicle make and model
• Vehicle color
• License plate number
• License plate state or jurisdiction
• Parking location
• Assigned parking space or parking area
• Arrival and departure information
• Entry and exit activity
• Reservation status
• Check-in and validation records

Certain Sully Parking locations may use cameras, license plate recognition systems, access-control systems, QR codes, or similar technologies for parking management, security, access verification, operational purposes, and enforcement.

D. Reservation and Transaction Information

We may collect information relating to your transactions with Sully Parking, including:

• Event or destination
• Parking facility or lot
• Reservation date and time
• Parking package or service selected
• Reservation reference number
• QR code or other access credential
• Backup or verification code
• Amount charged
• Discounts or promotional codes
• Payment status
• Refund status
• Transaction identifiers
• Receipt information
• Check-in status
• Cancellation information

E. Payment Information

Payments may be processed through third-party payment processors.

Depending on the payment method and service being used, the payment processor may collect payment card information, digital-wallet information, billing information, and other information necessary to complete the transaction.

Sully Parking does not intend to directly store complete payment-card numbers or card security codes when transactions are processed through our third-party payment providers.

We may retain transaction-related information such as:

• Transaction amount
• Transaction identifier
• Payment status
• Refund status
• Receipt information
• Payment method type
• Date and time of transaction

Payment information handled by a third-party payment processor is also subject to that provider's privacy and security practices.

F. Communications and Customer Support Information

If you communicate with Sully Parking, we may collect and retain:

• Emails
• Customer-support inquiries
• Contact-form submissions
• Survey responses
• Feedback
• Complaints
• Refund requests
• Reservation questions
• Other correspondence with us

We may use these communications to respond to you, maintain records, resolve disputes, improve our Services, train personnel, and protect Sully Parking and its customers.

G. Website, Device, and Technical Information

When you use our website or other digital Services, we and our service providers may automatically collect information such as:

• Internet Protocol address
• Browser type
• Device type
• Operating system
• Device identifiers
• Referring website or source
• Pages viewed
• Features used
• Links clicked
• Approximate geographic information derived from an IP address
• Date and time of access
• Session information
• Website interactions
• Diagnostic information
• Error logs
• Security logs
• Advertising or analytics identifiers, where permitted

H. Location Information

We may collect or infer approximate location information based on information such as your IP address, parking facility, reservation destination, or device information.

If a feature requests precise device location, we will collect such information in accordance with applicable permissions and law.

I. Camera, License Plate Recognition, and Facility Security Information

Certain parking facilities may use security cameras, license plate recognition (“LPR”), gate systems, access-control technology, or other security and operational systems.

Where used, these technologies may process information such as:

• Images of vehicles
• License plate numbers
• Entry and exit times
• Access attempts
• Facility activity
• Security events

We may use this information to verify reservations, manage parking access, maintain security, investigate incidents, prevent fraud or unauthorized use, enforce applicable parking rules, resolve disputes, and improve parking operations.

The specific technologies deployed may vary by facility.

J. Information From Third Parties

We may receive information from third parties involved in providing or supporting the Services, including:

• Payment processors
• Property owners and parking facility partners
• Transportation partners
• Event partners
• Technology providers
• Analytics providers
• Advertising and measurement providers
• Customer-support providers
• Security and fraud-prevention providers

We may combine information received from these sources with information collected directly from you, subject to applicable law.

We may collect personal information:

• Directly from you
• When you create an account
• When you make or modify a reservation
• When you enter or use a parking facility
• When your reservation or access credential is verified
• When you make a payment or request a refund
• When you contact customer support
• When you participate in a survey or promotion
• Automatically through our websites and technology
• Through cookies and similar technologies
• From service providers and business partners
• From property owners or operators
• From transportation or event partners
• From security or access-control systems

Sully Parking may use personal information for legitimate business and operational purposes, including to:

Providing the Services

• Process and manage parking reservations
• Allocate parking spaces
• Generate reservation confirmations and access credentials
• Verify customer access
• Facilitate parking entry and exit
• Coordinate transportation or related services
• Process cancellations and refunds
• Maintain customer accounts

Communications

• Send reservation confirmations
• Provide parking instructions
• Send service-related notices
• Communicate operational changes
• Respond to customer inquiries
• Provide customer support
• Send marketing communications where permitted

Safety, Security, and Fraud Prevention

• Protect customers, employees, partners, property, and facilities
• Authenticate reservations
• Detect unauthorized access
• Prevent fraudulent transactions
• Investigate suspicious activity
• Enforce parking rules and applicable agreements
• Maintain security records
• Protect the integrity of our Services

Analytics, Research, and Product Improvement

We may analyze information to:

• Understand how customers use our Services
• Evaluate parking demand
• Measure parking utilization
• Understand arrival and departure patterns
• Analyze reservation behavior
• Evaluate website and marketing performance
• Identify operational inefficiencies
• Improve facility operations
• Develop new products and features
• Improve pricing and capacity planning
• Improve customer experience
• Conduct research and statistical analysis
• Evaluate business performance

Advertising and Marketing

Where permitted by law and consistent with your privacy choices, we may use information to:

• Measure advertising effectiveness
• Understand marketing attribution
• Create or measure audiences
• Personalize marketing
• Conduct remarketing
• Improve advertising campaigns
• Measure conversions

Business Administration

We may use information to:

• Maintain business and accounting records
• Conduct audits
• Perform financial analysis
• Manage business relationships
• Evaluate potential partnerships
• Conduct strategic planning
• Support financing or investment activities
• Protect or enforce our contractual and legal rights

Legal and Compliance Purposes

We may process information when reasonably necessary to:

• Comply with applicable laws and regulations
• Respond to valid legal process
• Cooperate with governmental or regulatory authorities
• Establish, exercise, or defend legal claims
• Investigate violations of our agreements
• Protect the rights, property, safety, or security of Sully Parking, our customers, or others

Sully Parking may create aggregated, statistical, anonymized, de-identified, or otherwise non-identifying information from information collected through the Services.

This information may include insights concerning:

• Parking demand by location
• Event parking demand
• Occupancy and utilization
• Average parking duration
• Reservation conversion
• Arrival and departure patterns
• Vehicles served
• Unmet parking demand
• Traffic and customer-flow patterns
• Facility performance
• Operational performance
• Geographic demand trends
• Transportation demand
• Customer behavior in aggregate
• Parking-market trends

To the extent permitted by applicable law, Sully Parking may use, retain, disclose, license, commercialize, publish, or otherwise process aggregated or de-identified information for legitimate business purposes, including analytics, research, product development, transportation and parking insights, planning, benchmarking, marketing, business development, facility-owner reporting, operational improvement, and commercial partnerships.

Sully Parking does not intend to use de-identified information to identify an individual where prohibited by applicable law.

Nothing in this Privacy Policy restricts Sully Parking's use of information that does not constitute personal information under applicable law.

Sully Parking and our service providers may use cookies, pixels, tags, software development kits, local storage, analytics technologies, advertising identifiers, and similar technologies.

These technologies may be used to:

• Keep our Services functioning
• Maintain reservation sessions
• Remember preferences
• Authenticate users
• Protect against fraud
• Measure website traffic
• Understand user behavior
• Diagnose technical problems
• Measure conversions
• Analyze advertising performance
• Create or measure audiences
• Support marketing and remarketing
• Improve our Services

Depending on applicable law, certain technologies may require consent or may be subject to an opt-out right.

Our Privacy Choices tools may allow you to control certain non-essential technologies.

Sully Parking may use Google Analytics and related Google measurement and advertising technologies to understand use of our Services, measure performance, improve our products, and evaluate marketing.

Depending on our configuration, these technologies may include Google Analytics, Google signals, User-ID functionality, user-provided data functionality, conversion measurement, advertising integrations, audience functionality, advertising personalization, and remarketing.

Google Signals

Where enabled, Google signals may allow Google Analytics to associate information collected from our Services with information from users who are signed into their Google accounts and have permitted Google to associate their web and application browsing activity with their accounts.

This may provide Sully Parking with aggregated cross-device, demographic, interest, and audience insights.

User-ID

We may use internal account or customer identifiers to better understand interactions across sessions, devices, or Services.

Where User-ID functionality is used, Sully Parking does not intend to use directly identifying information, such as an unmodified email address, as the Google Analytics User-ID where prohibited by Google's requirements or applicable law.

User-Provided Data

Where implemented, permitted by law, and subject to applicable consent requirements, first-party information provided by users may be processed through Google or other measurement providers to improve conversion measurement, attribution, audience matching, advertising effectiveness, and related functionality.

Such information may include information such as an email address or telephone number and may be transformed or hashed before transmission.

Hashing information does not necessarily remove that information from the scope of applicable privacy laws.

Advertising and Audience Features

Where permitted, Google advertising integrations may be used to create or measure audiences, conduct remarketing, measure conversions, understand advertising effectiveness, or support personalized advertising.

Your ability to control these activities may depend on your location, applicable law, browser settings, Google account settings, and the privacy choices we make available.

We may disclose personal information as reasonably necessary for the purposes described in this Privacy Policy.

Service Providers

We may disclose information to companies that perform services on our behalf, such as:

• Payment processing
• Website hosting
• Cloud infrastructure
• Email delivery
• Customer support
• Analytics
• Advertising measurement
• Security
• Fraud prevention
• Database management
• Reservation technology
• Access-control technology
• Communications

These providers may process information according to their agreements with us and their own legal obligations.

Property Owners and Parking Partners

We may provide information to property owners, parking facility operators, or authorized personnel when reasonably necessary to:

• Validate reservations
• Coordinate facility access
• Manage parking operations
• Address customer issues
• Maintain safety and security
• Resolve incidents or disputes
• Provide operational reporting

Transportation and Service Partners

When a reservation or service includes transportation or another partner-provided service, we may provide information reasonably necessary to coordinate and deliver that service.

Analytics, Advertising, and Measurement Providers

We may disclose or make information available to analytics, advertising, attribution, audience, and measurement providers where permitted by law and consistent with applicable privacy choices.

Professional Advisors

We may disclose information to attorneys, accountants, auditors, insurers, financial institutions, consultants, and other professional advisors where reasonably necessary.

Legal, Safety, and Governmental Disclosures

We may disclose information when we reasonably believe disclosure is necessary to:

• Comply with applicable law
• Respond to subpoenas, court orders, warrants, or other legal process
• Cooperate with governmental authorities
• Protect our legal rights
• Prevent fraud or illegal activity
• Protect the safety of customers, employees, partners, or the public
• Investigate or respond to security incidents

Business Transactions

Personal information may be disclosed or transferred in connection with a merger, acquisition, financing, investment, reorganization, bankruptcy, sale of assets, corporate restructuring, due diligence process, or similar business transaction.

At Your Direction

We may disclose information when you request, direct, authorize, or consent to the disclosure.

Where available, our Privacy Choices interface may allow you to manage categories of cookies and similar technologies, including:

• Strictly Necessary
• Functional
• Analytics
• Advertising or Targeted Advertising

Strictly necessary technologies may remain active because they are required to provide the Services, maintain security, process reservations, or perform other essential functions.

Where required by law, we will request consent before using certain non-essential technologies.

Where required by applicable law, Sully Parking may recognize qualifying browser-based opt-out preference signals, such as the Global Privacy Control (“GPC”), as a request to opt out of certain sales, sharing, or targeted advertising activities associated with the browser or device from which the signal is received.

Where we can reasonably associate an authenticated user with the signal and applicable law requires us to do so, we may apply the preference more broadly to that user's account.

You may submit a privacy-related request by contacting:

Please include enough information for us to understand and respond to your request.

For your protection, we may request information reasonably necessary to verify your identity or authority to make the request.

Do not send passwords, complete payment-card numbers, card security codes, Social Security numbers, or other highly sensitive information through an ordinary email request.

Authorized agents may submit requests on behalf of another person where permitted by applicable law. We may require appropriate documentation confirming the agent's authority.

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected and for legitimate business, security, accounting, contractual, dispute-resolution, and legal purposes.

Retention periods may depend on:

• The nature of the information
• The purpose for which it was collected
• Whether you maintain an account
• Applicable contractual obligations
• Fraud and security considerations
• Applicable statutes of limitation
• Tax, accounting, and financial requirements
• Legal or regulatory requirements
• Pending or reasonably anticipated disputes

When information is no longer reasonably necessary, we may delete, anonymize, de-identify, or aggregate it, subject to applicable law and technical limitations.

As of the effective date of this Privacy Policy, Sully Parking's Google Analytics event-data and user-data retention settings are configured for two months. These settings may change as our systems, legal requirements, and business needs evolve.

Information may remain temporarily in backups, archives, fraud-prevention systems, security records, or other systems after deletion from active systems.

Sully Parking uses reasonable administrative, technical, and physical safeguards designed to protect personal information.

Depending on the information and system involved, safeguards may include:

• Access controls
• Authentication controls
• Encryption
• Secure hosting
• Restricted administrative access
• Logging and monitoring
• Vendor-management practices
• Security procedures
• Employee or contractor access limitations

No website, application, network, database, or electronic transmission can be guaranteed to be completely secure. Accordingly, Sully Parking cannot guarantee absolute security.

Customers are responsible for maintaining the confidentiality of passwords, reservation links, QR codes, backup codes, and other access credentials.

If you believe your account, reservation, or personal information has been compromised, contact us promptly through our Contact Us form.

If Sully Parking becomes aware of a security incident involving personal information, we may investigate the incident, take appropriate containment and remediation measures, work with relevant service providers or authorities, and provide notifications when required by applicable law.

The Services are not directed to children under the age of 13, and Sully Parking does not knowingly seek to collect personal information directly from children under 13.

If we learn that we have collected personal information from a child in circumstances prohibited by applicable law, we will take reasonable steps to delete or otherwise appropriately handle the information.

A parent or legal guardian who believes a child has provided personal information to us may contact us through our Contact Us form.

Our Services may contain links to, integrations with, or functionality provided by third parties.

Those third parties may maintain their own privacy policies and practices. Sully Parking is not responsible for the privacy practices of unaffiliated third parties, except to the extent otherwise required by law.

We encourage you to review the privacy policies of third-party services before providing personal information to them.

If you interact with Sully Parking through a social-media platform, the platform may collect information independently from Sully Parking.

Information collected by the platform is subject to the platform's privacy policies and settings.

We may receive information concerning your interaction with Sully Parking's social-media pages, advertisements, or content.

We may send transactional and operational communications concerning reservations, payments, facility access, security, transportation, service changes, or your account.

Because these messages are necessary to provide or administer the Services, you may not be able to opt out of all service-related communications while maintaining an active reservation or account.

Where permitted, we may also send promotional or marketing communications.

You may unsubscribe from marketing emails using the unsubscribe mechanism provided in the communication or through our Contact Us form.

Unsubscribing from marketing communications will not necessarily prevent us from sending transactional, security, legal, or service-related communications.

Sully Parking may use automated systems, algorithms, rules, analytics, or software to assist with business operations, including:

• Parking allocation
• Capacity management
• Demand analysis
• Fraud detection
• Security monitoring
• Pricing analysis
• Operational forecasting
• Customer-experience improvements
• Marketing measurement

Where applicable law provides rights relating to certain automated decision-making activities that produce legal or similarly significant effects, Sully Parking will honor those rights as required.

Sully Parking may generate business intelligence and operational insights concerning parking demand, occupancy, availability, customer flows, facility performance, reservation patterns, transportation demand, event traffic, and operational efficiency.

To the extent such information does not identify an individual or has been lawfully aggregated or de-identified, Sully Parking may use and disclose it for legitimate business purposes, including:

• Business operations
• Research
• Analytics
• Strategic planning
• Product development
• Commercial partnerships
• Property-owner reporting
• Transportation analysis
• Market analysis
• Investment or financing discussions
• Marketing and business development
• Benchmarking and forecasting

Nothing in this Privacy Policy is intended to restrict Sully Parking's lawful use of information that does not constitute personal information under applicable law.

As Sully Parking grows, we may enter into transactions involving investors, lenders, strategic partners, purchasers, affiliates, or other parties.

Information may be reviewed, disclosed, or transferred as part of due diligence, financing, investment, acquisition, merger, restructuring, asset sale, bankruptcy, or similar transactions, subject to appropriate legal and contractual protections where required.

Residents of certain U.S. states may have additional rights concerning personal information.

Depending on applicable law, these may include rights to:

• Know or access personal information
• Correct inaccuracies
• Delete certain personal information
• Obtain a portable copy of information
• Opt out of targeted advertising
• Opt out of certain sales of personal information
• Opt out of certain sharing of personal information
• Limit certain uses of sensitive personal information
• Appeal the denial of a privacy request

Sully Parking will respond to qualifying requests as required by applicable law.

If the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), applies to Sully Parking's processing of your personal information, California residents may have specific rights regarding their personal information.

These may include rights to know, access, correct, delete, and obtain information concerning certain disclosures, sales, or sharing of personal information.

Where applicable, California residents may also have the right to opt out of the sale or sharing of personal information and to limit certain uses or disclosures of sensitive personal information.

Sully Parking does not intend to exchange customer personal information directly for money. However, as explained above, certain advertising and analytics activities may be considered “sharing” or “selling” under California law even where no money is exchanged.

Qualifying requests may be submitted through our Contact Us form or through any Privacy Choices mechanism we make available.

Sully Parking is based in the United States.

If you access the Services from outside the United States, information may be processed, transferred, or stored in the United States or other countries in which our service providers operate.

Privacy and data-protection laws in those jurisdictions may differ from the laws of your jurisdiction.

Where required by applicable law, Sully Parking will implement appropriate measures concerning international transfers and processing of personal information.

Some browsers offer a “Do Not Track” setting.

Because there is not a universally accepted standard governing responses to traditional Do Not Track signals, our Services may not respond to all such signals.

This is separate from legally recognized opt-out preference signals, such as Global Privacy Control, which we address as required by applicable law.

You may choose not to provide certain personal information.

However, some information is necessary to provide particular Services. For example, we may be unable to complete a parking reservation without sufficient contact, vehicle, reservation, or payment information.

We may update this Privacy Policy periodically to reflect changes in:

• Our Services
• Our technology
• Our business practices
• Our partnerships
• Our data practices
• Applicable law
• Regulatory guidance

When we update this Privacy Policy, we will revise the “Last Updated” date above.

Where required by applicable law, we may provide additional notice or obtain consent before materially changing how certain personal information is processed.

Your continued use of the Services following an update will be governed by the updated Privacy Policy to the extent permitted by applicable law.

Questions, concerns, complaints, or requests relating to this Privacy Policy or Sully Parking's privacy practices may be directed to:

When contacting us about a privacy matter, please include enough information for us to identify the nature of your request. Please do not send passwords, complete payment-card information, or other unnecessary sensitive information by email.