Privacy Policy

This privacy policy will inform you as to how we look after your personal data when you interact with Cumbria Parking Services and tell you about your privacy rights and how the law protects you.

Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and processes your personal data when you interact with us, including any data you may provide to us.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller
We are a car park management and infrastructure company called Cumbria Parking Services Limited and we are the data controller.

Contact details

Post: Cumbria Parking Services Ltd, Unit 3A, Threlkeld Business Park, Threlkeld, Keswick, Cumbria, CA12 4SU

Email: dpo@cumbriaparkingservices.co.uk

Telephone: 03333 110 225

Changes to the privacy notice and your duty to inform us of changes

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Third-party links

Our website may include links to third-party websites, plug-ins and applications in order to make payments. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

THE DATA WE COLLECT ABOUT YOU

If you are providing us with your personal data when enquiring, purchasing, registering or subscribing to one of our services or when appealing a Parking Charge Notice, then we will only use this data to process your request and communicate with you.

To do what we need to do to run our business and pursue our legitimate interests we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data including first name, maiden name, last name, title, your association with a vehicle, vehicle registration mark, images of your vehicle registration plate and your vehicle.
• Contact Data including address, email address and telephone numbers.
• Transaction Data including details about payments to and from you and other details of parking time and services you have purchased from us.
• Technical Data through our website which includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
• Profile Data including your username and password.
• Usage Data including information about how you use our website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect Special Categories of Personal Data about you, however, if you provide this data to us when appealing a Parking Charge Notice we will ensure it is kept secure.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect personal data from and about you through:

• Direct interactions. This includes personal data you provide when you:
• contact us about our products or services;
• appeal a Parking Charge Notice;
• pay a Parking Charge Notice; or
• give us some feedback or request information on our services.

• Automated and other technologies or interactions. This includes personal data we or third parties acting on our behalf collect when you:
• interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies;
• visit car parks managed by us when we may automatically or manually directly or via third parties collect your vehicle registration mark and photographs of your vehicle.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
1. website analytics providers.
2. parking management equipment providers.
3. website administrators.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as:
• parking management equipment providers.
• payment service providers.
• collection agents.
• Solicitors.

• Identity and Contact Data from publicly available sources such as:
• the driver vehicle licence agency;
• the Parking on Private Land Appeals (POPLA).

HOW WE USE YOUR PERSONAL DATA

All personal data collected by us is only used in accordance with the UK General Data Protection Regulations (GDPR). Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into 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.
• In response to requests by government or law enforcement authorities.

The processing of your personal data for the collection of Parking Charge Notices is necessary for a contract which has been entered into and there is a legitimate interest to do so. We are entitled to pursue a motorist for an unpaid parking tariff or an unpaid parking charge.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at dpo@cumbriaparkingservices.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Unless you tell us otherwise we may contact you by post, email, or telephone about the product or service you have requested from us.

COOKIES

When someone visits www.cumbriaparkingservices.co.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make any attempt to find out the identities of those visiting our website.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties such as:
1. the International Parking Community (IPC) for the purpose of audit of our car park management service.
2. the driver vehicle licence agency (DVLA) for the purpose of audit of our car park management service.
3. the Independent Appeals Service (IAS) Service for the purpose of reviewing and your appeal.
4. print and mail service providers for issuing Parking Charge Notice and responding to your correspondence.
5. email service providers for responding to your correspondence.
6. collection agents for recovery of debts due to us.
7. solicitors for the purpose of enforcing the parking contract or responding to queries of a legal nature.
8. any other duly authorised sub-contractors.

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.

DATA SECURITY

We look after your personal data by putting security procedures in place which is appropriate for its nature. Although we will do our best to protect your data we cannot guarantee the security of your data transmitted to our website. Once received all personal data is held in a secure environment. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will keep your personal data for no longer than is necessary to carry out the purposes explained above. 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.

YOUR DATA RIGHTS

In relation to the personal data which we may hold about you, you have the following rights, to:

• Access the information we hold about you; you can do this by making a subject access request.

• Ask us to:
  • Rectify information about you that is incorrect or incomplete.
  • Delete (erase) information about you.
  • Restrict how we process your information.
  • Transfer your data in an accessible electronic format.
  • Object to our processing of your information.
  • Complain to us via our contact details below.

Complain to the data regulator the Information Commissioner’s office (ICO) via www.ICO.org.uk or you can contact the Information Commissioner’s Office on 0303 123 1113.

Please contact us using the details below if you wish to assert your rights ensuring you provide proof of your identity with any request. Under data protection law we must verify your identify before carrying out your request or supplying any information and provide you with an explanation if we do not agree with your request. Once your identity has been confirmed we will respond to your request within one calendar month.