ALPR Usage and Privacy Policy

AUTOMATED LICENSE PLATE RECOGNITION (ALPR) USAGE AND PRIVACY POLICY

VF Mall, LLC (“Owner”) utilizes automated license plate recognition (“ALPR”) technology at Westfield Valley Fair shopping center (the “Center”).

A. Purpose

ALPR information may be collected, accessed, and used to:

Help customers find their vehicles;
Assist customers with vehicle-related inquiries;
Register employees for parking at the Center;
Prevent customers from paying an incorrect fee;
Prevent people from parking in unauthorized or restricted parking stalls;
Reduce customer wait time when entering and exiting the property;
Notify Center management when a flagged vehicle comes onsite;
To assist with investigations and insurance claims related to Center property damage;
Assist with emergencies including fires, floods, or accidents; and
Assist with law enforcement investigations.

B. Access and Use of the ALPR System(s)

The following parties are authorized to collect, access, and use the ALPR System(s):

SKIDATA, Inc./Sentry Control Systems (“Skidata”) Personnel, specifically Skidata System Engineer(s), who provide technology support services for the ALPR technology;
LAZ Parking Management (“LAZ”) Personnel, specifically the Operations Manager, Assistant Operations Manager, Office Supervisor, and Customer Service Agents, who manage parking services at the Center;
Park Assist (“Park Assist”) Personnel, specifically Park Assist Client Services Coordinator(s), who provide technology support services for the ALPR technology;
Vice President, Center Management, Assistant General Manager, and Manager on Duty at the Center, who have day-to-day responsibility for the Center and its services, including the parking and the ALPR system(s); and
Center Security Personnel, specifically the Security Director and the Assistant Security Director, who assist customers with parking and security questions and services.

All personnel with access to ALPR information undergo training on the operation and proper use of the ALPR system(s) prior to being provided access to the ALPR system(s), including review of the Center ALPR policy and on-the-job training.

C. System Monitoring

Owner, Skidata, LAZ, and Park Assist utilize physical access controls, digital permission controls, and other technological, procedural, and operational security measures to protect ALPR information from unauthorized access, destruction, use, modification, or disclosure. These measures include username(s) and password(s) for access, and IT security controls to protect ALPR information. In addition, ALPR system vendors conduct routine maintenance and periodic audits of the ALPR system(s) in order to ensure accuracy of the system(s).

D. Information Sharing

Owner and the authorized users identified above do not sell ALPR information. They do not share ALPR information except for the purposes stated above, or as obligated by law such as by search warrant or subpoena.

E. Official Custodian

The official custodian of the ALPR information is the Vice President, Center Management. For additional information please contact the Vice President, Center Management at valleyfair@urw.com.

F. Data Accuracy

Reasonable technical measures, including regular testing and maintenance, are utilized in order to ensure the accuracy of ALPR information and correct errors.

G. Data Retention

ALPR information is retained for up to 30 days. Some ALPR information may be purged daily. After 30 days, ALPR information is automatically destroyed unless the retention period must be increased due to legal obligations. Examples of legal obligations include administrative or judicial proceedings such as search warrants, subpoenas, and litigation. ALPR information retained as a result of legal obligations will be destroyed after the legal obligation to retain it ends, at which point the 30-day retention schedule will resume.

H. Changes to this Policy

This ALPR Usage and Privacy Policy may be revised from time to time by Owner. Any changes to the policy will take effect upon posting.