LPR Privacy Policy


Edited: March 11, 2026

ALPR PRIVACY POLICY

This policy governs the usage and privacy practices regarding automated license plate recognition (ALPR)
systems, as required by California Civil Code 1798.90.51 et seq.

A. Purpose and Scope

AirGarage Inc. (AirGarage) uses ALPR systems to help ensure security, prevent theft and fraud, assist with
parking enforcement, and help maintain the safety of individuals and properties. The purpose of this policy
is to ensure that the collection, use, maintenance, sharing and dissemination of ALPR information is
consistent with respect for individuals’ privacy and civil liberties and to comply with applicable law.

B. Administration

At some AirGarage Locations, vehicle inventories are conducted using automated license plate recognition
technology. This data may be used to (i) determine correct parking fees for time-based parking sessions; (ii)
identify and track abandoned vehicles; (iii) automatically activate and/or deactivate parking sessions; (iv)
verify vehicle counts; (v) collect unpaid parking fees; and/or (vi) respond to inquiries of law enforcement
agencies.

C. Usage

All access to, and retention of, ALPR data shall be managed by the Chief Technology Officer (“CTO”) or the
CTO’s designee (the “ALPR Custodian”), who shall be responsible for overall implementation of and
compliance with this policy.

1. The ALPR Custodian shall ensure that only authorized personnel with a legitimate business need
shall be granted access to ALPR data.

2. Authorized personnel include:

i. Lot Enforcers – When auditing location occupancy, it is necessary for lot enforcers to
review and enter license plate information into the ALPR system. Lot enforcers must verify
all images being recorded are accurate.

ii. AirGarage Employees – Employees run reports on a regular basis in to flag unpaid or
possibly abandoned vehicles. Employees also use the inventory numbers to determine
location occupancy levels. Employees are responsible for handling inquiries made by law
enforcement agencies.

iii. Maintenance Technicians – Camera maintenance technicians provide service and
maintenance to the ALPR system and have access to all reports within the system.
All personnel authorized to access or use ALPR information must first receive training to ensure the
responsible and ethical use of personal information, including ALPR data. This training ensures personnel
understand how to protect personal information, comply with relevant privacy laws and regulations, and
follow proper procedures when handling security incidents, breaches, or unauthorized access events.

D. Security and Monitoring

1. AirGarage uses reasonable information security measures, including physical, administrative, and
technical safeguards to protect your information, including information gathered through our
ALPRs. AirGarage routinely monitors its ALPR system for accuracy. The ALPR Custodian shall also be
responsible for the correction of data errors of which the ALRP Custodian becomes aware.

2. AirGarage monitors the use of ALPR data through access logs to prevent unauthorized access. The
access logs include, among other things, the date and time the information is accessed; the license
plate number or other data elements used to query the ALPR system; the username of the person
who accesses the information; and the purpose for accessing the information.

E. Data Sharing

AirGarage may share ALPR data with our customers for whom we provide ALPR services, where disclosure
is necessary to deliver such services. We may also disclose ALPR data to vendors and service providers that
support the operation, maintenance, hosting, or analysis of our ALPR systems. In addition, we may disclose
ALPR data to law enforcement or other government authorities when required by law, pursuant to valid
legal process, or where reasonably necessary to investigate fraud, security incidents, or threats to safety.
We do not sell ALPR data for unrelated commercial marketing purposes.

F. Data Retention

The ALPR Custodian is responsible for ensuring all locations are operating the ALPR system within the
parameters of the law.

License plate information collected using the ALPR system will remain on file for a period of 30 days, it may
be automatically purged from the ALPR system upon the expiration of this period. Photos without a visible
license plate in frame will be deleted by the system within 30 days. However, if ALPR information is
required for legal proceedings or other lawful purposes, it may be preserved for a longer duration as
necessary to comply with applicable laws and regulations.

Parking Facilities may set specific ALPR retention policies upon written request, for example to request an
expedited deletion or modified retention period.

ALPR system audits shall be conducted on a regular basis.

Contact

This policy is posted on our website. If you have any questions on this policy, would like to request a copy
via email or in writing, or would like to request data deletion, contact us at privacy@airgarage.com