DIBS Parking Inc. Privacy Policy

1. Who Controls My Personal Information

1.1 Controller

Where this Policy mentions "DIBS Parking," "we," "us," or "our," it refers to DIBS Parking Inc.

2. Personal Information We Collect

2.1 Information Needed to Use the DIBS Parking Platform

We collect personal information about you when you use the DIBS Parking Platform. Without it, we may not be able to provide all services requested. This information includes:

2.1.1 Contact, Account, and Profile Information

Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.

2.1.2 Identity Information

Where appropriate, we may ask you for an image of your government-issued ID document(s), passport, national ID card, tax ID, or driving license (in accordance with applicable laws) or other verification information, such as your date of birth, address, email address, phone number, or digital identity, and/or a selfie when we verify your ID, if applicable. If a copy of your ID is provided to us, we will obtain information from your ID.

2.1.3 Payment Transaction Information

Such as payment account, credit card information, bank account information, payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address, and other related transaction details.

2.1.4 Parking Space Information (for Parking Hosts)

Such as address, location details, Parking Space photos and descriptions, and access instructions.

2.1.5 Vehicle Information (for Parking Guests)

Such as license plate number, vehicle make and model, and vehicle size and capacity.

2.2 Information You Choose to Give Us

You can choose to provide us with additional personal information, including:

2.2.1 Additional Profile Information

Such as gender, preferred language(s), city, personal description, and any additional profile information you provide.

2.2.2 Information About Others

Such as a payment instrument or contact information belonging to another person or information about a co-guest. By providing us with personal information about others, you certify that you have permission to provide that information to DIBS Parking for the purposes described in this Privacy Policy and you have shared the DIBS Parking Privacy Policy with them.

2.2.3 Biometric Information

Such as facial recognition data derived from photos and identification documents you submit for verification, where offered and with your consent where required by applicable law.

2.2.4 Communications Information

Such as email, call, message, SMS, and text information where delivery is enabled on or through the DIBS Parking Platform. Communication information may also include call recordings and transcripts consistent with the requirements under applicable law, and other log information like your phone number, calling-party number, receiving-party number, account name, email address, forwarding numbers, time and date of communications, duration of communication, routing information, and the types and volumes of communications.

2.2.5 User-Generated Content

Such as any photos, videos, and other content you choose to provide.

2.2.6 Support Information

Such as call recordings and transcripts consistent with the requirements under applicable law, chat information, and messages collected to provide customer support services, including investigating and responding to user concerns and monitoring and improving our support processes.

2.2.7 Other Information

Such as when you fill in a form, add information to your account, respond to surveys, participate in research, post to community forums, participate in promotions, import or manually enter address book contacts, provide your address and/or geolocation, provide business information, or share your experience with us.

2.3 Information Automatically Collected by Using the DIBS Parking Platform and Our Third Party Provider's Payment Services

When you use the DIBS Parking Platform and Payment Services, we automatically collect certain information. This information may include:

2.3.1 Geolocation Information

Such as precise or approximate location determined from your IP address, mobile or other device's GPS, or other information you share with us, depending on your device settings. We may also collect this information when you're not using the app if you enable this through your settings or device permissions.

2.3.2 Usage Information

Such as searches for Listings, bookings you have made, additional services you have added, access dates and times, the pages you've viewed or engaged with before or after using the DIBS Parking Platform, and other actions on the DIBS Parking Platform, including the pages or content you view and links you click to third-party applications. We may collect this information even if you haven't created a DIBS Parking account or logged in.

2.3.3 Device Information

Such as IP address, hardware and software information, device information, device event information, unique identifiers, crash data, read receipts, mobile network information, browser type and language. We may collect this information even if you haven't created an DIBS Parking account or logged in.

2.4 Information We Collect from Third Parties

We may collect personal information from other sources, such as:

2.4.1 Third-Party Applications

If you choose to link, connect, or login to the DIBS Parking Platform with a third-party service, such as Google or Facebook, you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service. If you choose to connect a smart lock to your DIBS Parking account, we may collect information about the smart device, such as log or event information and device information.

2.4.2 Background Information Providers

To the extent permitted by applicable laws, we may obtain, for example, reports of criminal records, sex offender registrations, and other information about you and/or your background. We may use your information, including your full name and date of birth, to obtain such reports.

2.4.4 Referrals and Co-Guests

If you are invited to the DIBS Parking Platform, for example, as a co-guest for an event, the person who invited you can submit personal information about you.

2.4.5 Complainants

If a Parking Host, Parking Guest, or any third party submits a complaint about you, we may receive information relating to the specific complaint made in order to understand and, where relevant, address the complaint.

2.4.6 Financial Institutions

If you elect to pay with funds from your bank account, we may receive certain information from your financial institution, such as bank account details and account balance.

2.4.7 Other Sources

To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data, and information to help detect fraud and safety issues from (i) third-party service providers, other third parties, and/or partners, or (ii) Members and any other individuals, entities, and authorities, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention, security investigation, and risk assessment efforts. We may receive information about you and your activities on and off the DIBS Parking Platform, including from users of DIBS Parking, members of the public, governmental, public, or tax authorities, certain publicly-available information including social media posts or profiles, or about your experiences and interactions from our partners.

3. How We Use Information We Collect

We use personal information as outlined in this Privacy Policy.

3.1 Provide the DIBS Parking Platform

We may process this information to:

• enable you to access the DIBS Parking Platform and make and receive payments,
• enable you to communicate and engage with others,
• process and respond to your request,
• provide you with support,
• send you messages, updates, security alerts, and account notifications,
• determine your state of residence based on automated review of your account information and your interactions with the DIBS Parking Platform, and
• enable your use of our products and parking booking services.

3.2 Improve and Develop the DIBS Parking Platform

We may process this information to:

• perform analytics, debug, and conduct research,
• improve and develop our products and services, and
• provide customer service training.

3.3 Personalize and Customize the DIBS Parking Platform

We may process this information to:

• personalize and customize your experience based on your interactions on the DIBS Parking Platform, your search and booking history, your profile information and preferences, and other information you choose to give us, and
• tailor your experience with DIBS Parking.

3.4 Safeguard the DIBS Parking Platform and Community

We may process this information to:

• study and combat discrimination on the DIBS Parking Platform,
• detect, prevent, assess, and address fraud and security risks,
• protect our community from illegal activities or other behaviors,
• verify or authenticate information provided by you, including identity information,
• conduct checks against databases and other information sources, including background checks,
• comply with our legal obligations, protect the safety and well-being of our Parking Guests, Parking Hosts, Parking Hosts' employees, and members of the public,
• resolve disputes with our Members, including sharing information with your co-Parking Host(s) or additional Parking Guests about disputes related to your role as a co-Parking Host(s) or additional Parking Guests,
• enforce our agreements with third parties,
• determine eligibility for certain types of bookings,
• comply with law, respond to legal requests, prevent harm, and protect our rights,
• enforce our Terms of Service ("Terms") and other policies, and
• assess or evaluate your interactions with the DIBS Parking Platform and information obtained from third parties.

In certain cases, automated processes, which analyze your account and activities on the DIBS Parking platform as well as information in relation to activities on and off the DIBS Parking platform that can be associated with you, could restrict or suspend your access to the DIBS Parking Platform if such processes detect activity that may pose a safety or other risk to DIBS Parking, our community, or third parties. If you would like to challenge decisions based on automated processes, please contact us at support@dibs-parking.com.

3.5 Provide, Personalize, Measure, and Improve our Advertising and Marketing

We may process this information to:

• send you promotional, advertising, and marketing messages, and other information,
• show, personalize, measure, and improve our advertising on advertising platforms,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by DIBS Parking or its third-party partners,
• analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you, and
• invite you to events and relevant opportunities.

3.6 Analyze Your Communications

3.6.1 Purpose

We may review, scan, or analyze your communications on or enabled through the DIBS Parking Platform for purposes disclosed in this Privacy Policy, including safety, support, product enhancement Subject to applicable law, we scan and analyze all images uploaded by users to the DIBS Parking platform in message threads, profiles, listings, and experiences for certain illegal or inappropriate activities for the purpose of identifying and reporting content violations to appropriate authorities.

3.6.2 Methods

We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for investigations or customer support.

3.6.3 Non-Sale

We will not sell reviews or analyses of these communications.

3.7 Enable Payment Processing Services

Personal information is used to enable payment processing services provided by Stripe, Inc. (as defined in the Terms), such as to:

• process payments,
• perform the contract with you,
• verify your identity,
• detect and prevent money laundering, fraud, abuse, and security incidents,
• conduct security investigations and risk assessments,
• comply with applicable legal and compliance obligations, such as anti-money laundering regulations and sanctions enforcement, and
• enforce our Terms and other payment policies.

If you are not an DIBS Parking user, we may receive payment information relating to you, such as when an DIBS Parking user provides your payment card to complete a booking.

4. Sharing and Disclosure

4.1 Sharing With Your Consent or at Your Direction

Where you provide consent or direct us to share your information, we share your information as described at the time of consent or choice, such as when authorizing a third-party application or website to access your DIBS Parking account, processing an insurance claim, applying for flexible payment and financing products, or participating in promotional activities by DIBS Parking partners or third parties.

4.2 Who We Share With

We may share your information with:

4.2.1 Other Members

To help facilitate bookings, connections, or other interactions between Members (who may be located in, or use service providers located in, jurisdictions with varying levels of data protection), we may share information in certain situations.

4.2.2 Members' Service Providers

Parking Hosts may use third-party services to help manage or deliver their services, such as a parking attendant. Parking Hosts may use features on the DIBS Parking Platform to share information about the Parking Guest with such third-party service providers. Other Members may use services other than DIBS Parking to process your data, including email or reservation management software. Such services are outside of DIBS Parking's control and will be subject to applicable law.

4.2.3 Building Management

We may share personal information of Parking Hosts and Parking Guests with the owner(s) of Parking Spaces, a homeowners' association, and/or their agent, such as a building operator or property management company ("Building Management"), including booking information and information related to compliance with applicable laws, in order to facilitate programs with Building Management. Parking Guest booking and personal information, including guest contact information, may be shared with the Building Management of the building, complex, or community where the listing is located to facilitate hosting services, compliance with applicable laws, security, billing, and other services.

4.2.4 Service Providers

We share personal information with affiliated and unaffiliated service providers (including their service providers) to help us run our business and for their compliance purposes, including those that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background checks, fraud prevention, security investigations, and risk assessments, (iv) perform product development, maintenance, and debugging, (v) allow the provision of the DIBS Parking Services through third-party platforms and software tools, (vi) provide customer service, advertising, or payments services, (vii) offer additional services you select, (viii) process, handle, or assess insurance claims or similar claims, (ix) review, scan, and analyze communications on the DIBS Parking Platform for certain purposes, or (x) offer flexible payment plans and financing provided by a third-party credit provider. These providers are contractually bound to protect your personal information, have access to your personal information to perform these tasks, and may also disclose your information where required by law.

4.3 Why We May Share Your Information

We may share your information in order to:

4.3.1 Build Your Public Profile

Information you share publicly on the DIBS Parking Platform may be indexed through third-party search engines. In some cases, you may opt-out of this sharing in your account settings. We may make certain information publicly visible to others, such as:

• your profile and account information and information derived from them,
• listing pages that include information such as the Parking Space's approximate or precise location description, calendar availability, profile photo, aggregated demand information, and additional information you choose to share,
• reviews, ratings, and other public feedback, and
• content in a community or discussion forum, blog, or social media post, and content you make available to the public, including Parking Space Listing details on third-party sites, platforms, and apps.

4.3.2 Comply with Law, Respond to Legal Requests, Prevent Harm, and Protect Our Rights

4.3.2(i) Disclosure

As we reasonably deem appropriate, we may disclose your information or communications to courts, law enforcement, governmental or public authorities, tax authorities, authorized third parties, or other Members, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request, such as a subpoena or court order, or to respond to claims asserted against DIBS Parking, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) enforce and administer our agreements with Members, including our Terms, this Privacy Policy and any other policies published on our website, www.dibs-parking.com, (v) investigate potential violations of applicable law, including emergency situations which may involve the risk of death or serious physical harm, (vi) respond to requests for or in connection with current or prospective legal claims or legal proceedings concerning DIBS Parking and/or third parties, in accordance with applicable law, or (vii) protect the safety, security, rights, or property of DIBS Parking, its employees, its Members, or members of the public.

4.3.2(i)(a) To Tax Authorities

Where legally required or permissible according to applicable law, we may disclose Parking Hosts' and/or Parking Guests' information to relevant tax authorities or other governmental agencies, depending on where you are based, for the purpose of the tax authorities' determination of proper compliance with relevant tax obligations.

4.3.2(i)(b) To Governmental Authorities for Registrations, Notifications, Permits, or License Applications or Numbers

In jurisdictions where DIBS Parking facilitates or requires a registration, notification, permit, or license application or number of a Parking Host with a governmental authority, we may share information of participating Parking Hosts, including registration numbers and Parking Host contact information, with the relevant authority, during the application process, when the Parking Space Listing is published, and periodically thereafter.

4.3.2(ii) Notification

Where appropriate and/or legally required, we may notify Members about legal requests, unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to DIBS Parking, our Members, or expose DIBS Parking to a claim of obstruction of justice.

4.3.3 Effectuate Business Transfers

If DIBS Parking undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction, such as due diligence. In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

5. Third-Party Partners and Integrations

5.1 Linking Third-Party Services

You can link your DIBS Parking account with certain third-party services, such as social networks. When you direct the data sharing by creating this link:

• some of the information provided to us from linking accounts may be published on your public profile,
• information you provide to us from the linking of your accounts may be stored, processed, and transmitted for fraud prevention, security investigations, and risk assessment purposes,
• we share information about your reservation with third-party travel partners and reward programs, and
• publication and display of information that you provide to the DIBS Parking Platform through this linkage is subject to your settings and authorizations on the DIBS Parking Platform and the third-party service.

5.2 Third-Party Service Terms

Parts of DIBS Parking may link to third-party services. DIBS Parking does not own or control these third parties. When you interact with these third parties and choose to use their service, you are providing your information to them. Your use of these services is subject to the privacy policies of those providers, including Google Maps/Earth Additional Terms of Use, Google Privacy Policy (see here for more information on how Google uses information) and Stripe Privacy Policy.

7. Your State Privacy Rights

7.1 Application

If you reside in California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Vermont, Virginia, or Washington, or are otherwise protected by privacy laws in those jurisdictions, this Section 7 applies to you and is a supplement to our Privacy Policy.

7.2 Online Contact Information

Consistent with applicable law, you can exercise any of the rights described in this section by contacting us by email at support@dibs-parking.com. If you have any questions, you may also contact us at support@dibs-parking.com with the subject "Privacy Contact."

7.2.1 Verification

Please note that you may need to verify your identity and request before further action is taken. As a part of this process, you may be required to provide personal information, such as your name, state of residence, phone number, email address associated with your account, and government identification.

7.2.2 Authorized Agent

Consistent with applicable law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, we may require that: (i) you or your authorized agent provide a valid power of attorney, (ii) the agent provide proof that you gave the agent signed, written permission to submit the request, (iii) you verify your identity with us, and (iv) you directly confirm with us that you provided the authorized agent permission to submit the request.

7.3 Your Rights

7.3.1 Right to Access

Consistent with applicable law, you may submit a verifiable consumer request to access, in a portable and (if technically feasible) readily-usable form, the personal information that we have collected about you as well as more information about our data practices.

7.3.2 Right to Delete

Consistent with applicable law, you may submit a verifiable consumer request to delete your personal information.

7.3.3 Right to Correct

Consistent with applicable law, you may submit a verifiable consumer request to correct inaccuracies in your personal information held by DIBS Parking.

7.3.4 Right of Non-Discrimination

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the service may change or no longer be available to you. Any differences in the services are related to the information provided.

7.3.5 Appeal of Consumer Rights Request

To appeal a refusal to take action on your request, please see the instructions in our response to your request or submit your appeal in writing by contacting support@dibs-parking.com with the subject "Appeal of Consumer Rights Request."

7.4 Opt-Outs

7.4.1 Personalized Advertising Opt-Out

We do not sell personal information. However, we do process personal information for purposes of displaying advertisements that are selected based on users' online activities over time and across different sites, services, and devices. We also engage in automated processing that could affect you. Consistent with applicable law, you may opt out of such processing.

7.4.2 Opt-out Signals

We strive to honor opt-out preference signals where required by applicable law. When we detect an opt-out preference signal, we will make reasonable efforts to honor such opt outs for jurisdictions that require them. Please note that your opt-out preference signal might only apply to the particular browser, device, or technology that you use to opt-out. The opt-out preference signals are offered by a third party that we do not control.

7.4.3 Right to Opt-Out for the Purposes of Profiling for Decisions That Produce Legal or Similarly Significant Effects

Consistent with applicable law, you may have the right to opt-out of processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects.

7.4.4 Opt-Out of Processing or Limit Use and/or Disclosure of Sensitive Personal Information

Certain categories of personal information that we collect and use might be "sensitive" under data privacy laws. Consistent with applicable law, you may have the right to limit certain uses or disclosures of your sensitive personal information or opt-out of processing of your sensitive personal information.

7.5 Other Information

7.5.1 Withdrawing Consent

If we are processing your personal information based on your consent you can withdraw your consent at any time by changing your account settings or, consistent with applicable law, by emailing support@dibs-parking.com specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

7.5.2 Sensitive Data Inferences

We may process inferences from your sensitive data for the purposes discussed in our Privacy Policy. In the event that we do, we will retain the inferences until we have fulfilled the purpose for which we collected them. We will delete such inferences in accordance with our Privacy Policy.

7.5.3 De-Identification

Consistent with applicable law, we commit to maintain and use information in de-identified form and not to attempt to re-identify the information. We may use such information in de-identified form or otherwise as consistent with applicable law.

7.5.4 Third-Party List

Consistent with applicable laws, you may request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties.

7.6 California Residents

If you live in California, or are otherwise protected by privacy or consumer data laws in California, this section applies to you and is a supplement to our Privacy Policy.

7.6.1 Sale and Sharing of Data

We do not sell personal information to third parties; we are not data brokers and do not put personal information on the open market. We do not knowingly sell or share the personal information of individuals who are younger than 16. We do allow third parties to collect personal information through the DIBS Parking Platform and share personal information with third parties for the business purposes described in this Privacy Policy including, without limitation, advertising and marketing on the DIBS Parking Platform and elsewhere based on users' online activities over time and across DIBS Parking, services, and devices. Consistent with applicable law, you may opt out of such processing by emailing us at support@dibs-parking.com.

7.6.2 Information Pertaining to California Consumer Requests

We have not received and processed any consumer requests under the California Consumer Privacy Act during the previous calendar year.

7.7 Nevada and Washington Residents

If you live in Nevada or Washington, or are otherwise protected by privacy or consumer data laws in Nevada or Washington, this section applies to you and is a supplement to our Privacy Policy.

7.8 Vermont Residents

If you live in Vermont, or are otherwise protected by privacy or consumer data laws in Vermont, only this section applies to you and is a supplement to our Privacy Policy. DIBS Parking will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state's law or with your consent.

7.9 Managing Your Information

You can access and update some of your personal information through your Account settings. You are responsible for keeping your personal information up to date.

8. Retention

8.1 Retention Periods

We retain personal information for as long as needed or as permitted in light of the purpose(s) for which it was obtained and further processed and consistent with applicable law. The criteria used to determine our retention periods include:

• the length of time we have an ongoing relationship with you and provide the DIBS Parking platform services to you, whether you are a Parking Guest or a Parking Host (for example, for as long as you have an account with us or keep using DIBS Parking) and the length of time thereafter during which we may have a legitimate need to retain your personal information, such as to manage and protect our business, to address issues or defend claims that may arise,
• whether there is a legal, tax, reporting, or auditing obligation to which we are subject, such

8.2 Shared Information

Information you have shared with other Members, such as Reviews and forum postings, may continue to be publicly visible on DIBS Parking, even after your DIBS Parking Account is canceled.

8.3 Residual Copies

Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

9. Security

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unlawful or unauthorized access, loss, destruction, or alteration.

10. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the "Last Updated" date at the top. In case of material changes, we will also provide you with notice of the modification by email. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account, you will be required to accept the revised Privacy Policy prior to your continued access to or use of the DIBS Parking Platform and such access or use will be subject to the revised Privacy Policy.

11. Contact Information and Responsible DIBS Parking Entities

For questions or complaints about this Privacy Policy or DIBS Parking's handling of personal information, contact DIBS Parking Inc., Legal Privacy, 1430 NW 200th Street, Miami Gardens, Florida 33169 or by emailing us at support@dibs-parking.com.

12. Definitions

Undefined terms in this Privacy Policy have the same definition as in our Terms.