Crescent Carwash, Inc., with all associated companies and subsidiaries (collectively, “Crescent Carwash”) has created this Automated License Plate Recognition (ALPR) Policy to provide necessary disclosures about why we use ALPR technology and what we do with ALPR information.
1. What are the authorized purposes for using the ALPR system and collecting ALPR information?
We collect ALPR information via our system to determine if a vehicle is a subscriber to our Monthly Wash Club program and to determine whether your account is current and the visit is within the usage limit (for example, for a private vehicle, up to ten washes per month). Our system does this by reading the license plate number and seeing (a) if it matches a license plate number that a subscriber has already registered and (b) how recently it last visited one of our locations.
2. What is authorized to use or access our ALPR system or to collect ALPR information and how are they trained?
Our employees are authorized to access the ALPR database at each location are the Manager and Assistant Manager, and the ALPR data may occasionally be accessed onsite for troubleshooting purposes by our equipment and software vendors. Our employees have access to process registrations or cancel memberships. All of these personnel are trained to use the ALPR system only for its approved purpose, not to divulge ALPR information to third parties, and to utilize the system only in ways consistent with the law.
3. How do we monitor the ALPR system to ensure the security of the information and compliance with applicable privacy laws?
We maintain access control, including password protection. Employees who have access to the database are instructed to keep it secure and not to share its contents.
4. What are the purposes of, process for, and restrictions on, the sale, sharing, or transfer of ALPR information to other persons?
We do not sell, share, or transfer ALPR information in the ordinary course of business. We do not sell or share ALPR data related to our customers or non-customers. We may, however, disclose this data to third parties where required by legal process (subpoena, search warrant, etc.). If part or all of our business is sold, the ALPR data may be transferred to the new owner, who will then have the responsibilities we have now.
5. What is the title of the official custodian, or owner, of the ALPR system responsible for compliance?
The title of the official custodian responsible at each location is the Manager.
6. What reasonable measures will we use to ensure the accuracy of ALPR information and correct data errors?
We periodically check the equipment to make sure that it is working, and when it does not retrieve a record that it should, we perform a manual lookup against customer records (including an image of the plate taken at the time of registration) and make sure that the hardware and software are working properly.
7. How long will we retain ALPR information, and how do we decide when/if to destroy it?
For subscribers to our Monthly Wash Club, we maintain their license plate numbers and an image of their plates through the term of their subscriptions and a reasonable period after that to accommodate seasonal renewals. Otherwise, we delete license plate information when a customer asks us to.
If data read from license plates does not match subscribers on our systems, the system overwrites it when the system reaches a certain number of records. If the data read does match a Monthly Wash Club subscriber, the license plate number becomes part of a sales record.
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