Newpark Security Ltd (We) are committed to protecting and respecting your privacy.
- Trust version 2.0 (iOS) and Trust version 2.2 (Android) mobile application software (App) and any updates or supplements to it available on Apple Inc’s App Store and Google Play (Appstore), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
- Any of the services accessible through the App (Services). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Please note that the Trust App operates across a number of different car parks which are not owned or controlled by us. We recommend that you read the Terms & Conditions and any other Privacy Notice brought to your attention at your chosen car park.
This policy is provided in a layered format so you can click through to the specific areas set out below.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- DESCRIPTION OF CATEGORIES OF PERSONAL DATA
1. Important information and who we are
Newpark Security Ltd is the controller and is responsible for your personal data (collectively referred to as “Newpark”, “we”, “us” or “our” in this policy).
Our full details are:
- Full name of legal entity: Newpark Security Ltd
- Name of data privacy manager: Matilda Cook-Wescott
- Email address: email@example.com
- Postal address: Unit 4, Unicorn Business Park, Whitby Road, Bristol, BS4 4EX
- Telephone number: 0117 301 2540
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated on 26/01/2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
2. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data
- Contact Data
- Financial Data
- Transaction Data
- Device Data
- Profile Data
- Usage Data
- Marketing and Communications Data
- Location Data
We explain these categories of data below.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How is your personal data collected?
We will collect and process the following data about you:
- Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions, enter a competition, promotion or survey, and when you report a problem with an App or our Service. If you contact us, we will keep a record of that correspondence.
- Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work, for instance where a parking location needs to be verified. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
- Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- We will receive certain Identity and Transaction Data from car park operators where such car parks have ANPR systems installed. In these cases we will receive your vehicle registration number, time and date of use of the car park, details of the location of the car park and an image of your vehicle
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Cardstream based inside the EU;
- Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
4. How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data
|Purpose/activity||Type of data||Lawful basis for processing|
|To install the App and register you as a new App user||IdentityContactFinancialDevice||Your consent|
|To process in-App purchases and deliver Services including managing parking payments and collecting money owed to us||IdentityContactFinancialTransactionDeviceMarketing and CommunicationsLocation||Your consentPerformance of a contract with youNecessary for our legitimate interests (to recover debts due to us)|
|To manage our relationship with you including notifying you of changes to the App or any Services||IdentityContactFinancialProfileMarketing and Communications||Your consentPerformance of a contract with youNecessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)|
|To enable you to participate in a prize draw, competition or complete a survey||IdentityContactDeviceProfileMarketing and Communications||Your consentPerformance of a contract with youNecessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)|
|To administer and protect our business and this App including troubleshooting, data analysis and system testing||IdentityContactDevice||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|To deliver content to youTo make recommendations to you about goods or services which may interest youTo monitor trends so we can improve the App||IdentityContactDeviceProfileUsageMarketing and CommunicationsLocation||ConsentNecessary for our legitimate interests (to develop our products/Services and grow our business)|
5. Disclosures of your personal data
We share your personal data with certain third parties set out below for the purposes set out in the table above. Who we share your personal data with will depend on the location of the Services which you use via the App:
- Car park operators and owners who we partner with to enable use of our App and Services in the parking facilities which they control.
- Parking control bodies for the purpose of parking enforcement. If you have not paid for your parking transaction we may also share your personal data with a debt collector.
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue and Customs, regulators and other authorities and law enforcements agencies who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5).
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of 12 Months then we will treat the account as expired and your personal data may be deleted.
9. Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
- Request access to your personal data.Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data.Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data.Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data.Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing your personal data.Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer or your personal data.Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent.Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at firstname.lastname@example.org.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
11. Description of categories of personal data
- Identity Data: first name, last name, username or similar identifier, vehicle registration number.
- Contact Data: billing address, email address and telephone numbers.
- Financial Data: payment card details.
- Transaction Data: includes details about payments to and from you and details of in-App purchases, including details of where and when you have parked using our services.
- Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting.
- Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
- Usage Data: includes details of your use of our App including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data: includes your current location disclosed by GPS technology.