Privacy Notice
Last updated: December 2023
Prior versions of this Privacy Notice can be found at
https://pumbaparking.com/old-privacy-policy/

  About this Privacy Notice This Privacy Notice is meant to give you information about what personal data we collect about you, how we use it, why we use it, and how you control the data processing.

Table of Contents

 

• The Basics: Who We Are, Our Role, and Definitions

     

• Personal Data We Collect, How We Use It, and Why

     

• Our Marketing Activities

     

• Sharing the Personal Data We Collect

     

• International Transfers

     

• Security

     

• Your Rights – How to Control Our Use of Your Personal Data

     

• Data Retention

     

• Cookies and Similar Technologies

     

• Third-Party Services

     

• Children

     

• Changes to the Privacy Notice

     

1. The Basics

• • 1.1. Who We Are
    • 1.1.1. Pumba Parking Ltd. offers a mobile app through which use can optimize the on-street parking searching experience and receive additional parking services, including ‘VIP Services’ services. Our offices are located at 48 Yehuda Halevi St., Tel Aviv – Yafo, Israel, and our registration number is 516292729.
    • 1.1.2. If you have questions about our company or your privacy, or want to exercise your rights, you can contact us at info@pumbaparking.com.
  • 1.2. Our Role: Controller and Processor. Certain data protection laws, including the laws in the EU, differentiate between a party that determines why and how personal data is processed (called a “controller”) and a party that processes personal data solely on the controller’s behalf and according to the controller’s instructions (called a “processor”). We are the controller with respect to the processing described in this Privacy Notice.
  • 1.3. Definitions and Recommendations
    • When we refer to “services“, we mean the parking services available on our website or through our mobile app, including the ‘VIP Service’ in which a driver will park your car for you.
    • When we refer to “personal data“, we mean information that is defined as personal data under law. This includes information that identifies you directly or indirectly, including unique identifiers like IP addresses or cookie IDs.
    • When we refer to “you“, we mean any user of our app and services or a visitor to our website.
    • This Privacy Notice is meant to be read together with our Terms of Service, which you can find at https://pumbaparking.com/terms-of-service/. In general, we recommend that you routinely review this privacy notice and your preferences on our app.
  • 1.4 A Note on Legal Bases. Certain jurisdictions only allow the processing of personal data where a legal basis has been established. Under the EU’s General Data Protection Regulation (“GDPR“), the possible legal bases include (but are not limited): your consent, the processing is necessary to perform a contract with you, the processing is necessary to fulfill our legal obligations, or a company has a legitimate business interest to process your personal data. Where we are a controller, we only collect and process data where we have established a legal basis. Below you can find more details about specific legal bases.

2. Personal Data We Collect, How We Use It, and Why. Below is a description of the types of personal data we collect, how we use it, and the reason why we consider each use lawful. You have no legal obligation to provide us with personal data, but if you don’t provide us with certain information, we may not be able to provide you with the associated services.

 

• • 2.1. Contact Information – When you send us a message via email or through any contact form on the app or on our website, we will collect any data you provide, such as your name, email address, and the content of your message.
    • How We Use this Data: To respond to your message.
    • Legal Basis: We process this personal data based on the performance of a contract with you.

• • 2.2. Data Collected Automatically through the Site. When you visit our site, we automatically collect data about your computer or mobile device, including personal data such as your IP address, device ID, browsing history (e.g. the other sites you’ve visited before ours), and your activity on our site (e.g. what pages you visited, for how long, and what links you clicked on). For more information about the cookies we use and how to adjust your preferences, see the Cookies and Similar Technologies section below.
    • How We Use this Data: We mainly use this data to generate aggregated analytics data about the use of our site so we can maintain and improve the site and develop new products or services. We also use statistical data to prevent fraud and protect the security of our site. One of the tools we use to collect and analyze this data is “Google Analytics”. For more information about how Google collects information and how you can control such use, see: www.google.com/policies/privacy/partners/.
    • Legal Basis: We process this personal data based on our legitimate interests to develop and improve our products and services, and to prevent fraud.

• • 2.3. Ordering Sensors. When you order one of our sensors through the website, we collect your name, email address, phone number, and mailing address.
    • How We Use this Data: We use this data in order to provide you with a sensor.
    • Legal Basis: We process this data in order to perform a contract with you, in this case our Terms of Service.
    • Note that sensors do capture images of the street where they are placed, and this may also incidentally capture images of individuals passing by and license plates or cars. Due to the low resolution used for the images, individuals cannot be recognized, and license plates cannot be identified. In any event, to the extent required, images are immediately anonymized and are not retained by Pumba or used by Pumba on a personalized basis.

• • 2.4. Data Collected Upon Installation of App. When you install our app, we will set up a user account associated with the mobile device on which the app is installed and will assign it a unique identifier that we generate. We also collect certain device information, such as your device ID, device type, operating system (including version and settings), as well as certain settings relating to your device.
    • How We Use this Data: We use this unique user ID along with the device information for the purpose of provision of the app and services to you. We may link this information with your account information.
    • Legal Basis: When we process your registration data to provide you with our services, we do so to perform a contract with you, in this case our Terms of Service.

• • 2.5. Registration Data. In order to access our app, you must first create an account. When creating an account, you will be asked to provide your name, email address, car model, and residence address. If you access our app using a third-party login service (such as Facebook or Gmail), we also receive personal data about you from that service, such as Facebook Access Token, Google Sign-In Token, advertiser ID and information from your public profile, which may include your name, gender, profile picture, age group, and residency. You can control the information to which we have access through your settings on the applicable platforms.
    • How We Use this Data: We use your registration information to allow you to access our app, save your preferences, protect the security of our app, prevent fraud, and address any issues that arise. We use your contact details to communicate with you about our app and to send you informational newsletters about our products and services. information about our marketing activities and how you can control your preferences, see the section on Our Marketing Activities below.
    • Legal Basis: When we process your registration data to provide you with our services, we do so to perform a contract with you, in this case our Terms of Service. When we process your registration data to maintain our app, including to prevent fraud, protect the security of and/or address issues with our app, we do so on the basis of our legitimate interest to maintain our assets. When we use your contact details to send you informational materials, we do so based on our legitimate interest in marketing our products and services.

• • 2.6. Payment and Transactional Data. If you make a purchase through the app, such as when purchasing a plan or VIP Services, we receive information related to such purchase, such as the type of payment method, and history of transactions.
    • How We Use this Data: To process your payments and to manage your orders.
    • Legal Basis: We process your payment data to perform a contract with you, namely, our Terms of Service.

• • 2.7. Activity and Usage Data. When you use our app we automatically collect data about your mobile device, including personal data such as your activity on our app (e.g. what features you have used, where you have clicked, your driving and parking searches, and your app settings). You may also choose to input and save certain destinations and points of interest, such as your home address, work address, and other favorite destinations.
    • How We Use this Data: We use data about your use of the app in order to provide you with the service and to enhance your experience and to personalize it for you. For example, saving a record of your successful parking activities, routes, and favorite destinations can improve your experience of the services. In addition, we use certain data about your usage to generate aggregated analytics data about the use of our site so we can maintain and improve the site and develop new products or services. We also use statistical data to prevent fraud and protect the security of our site. One of the tools we use to collect and analyze this data is “Google Analytics”. For more information about how Google collects information and how you can control such use, see: www.google.com/policies/privacy/partners/.
    • Legal Basis: When we use this data to provide you with the services and to enhance your experience, we do so in order to perform our contract with you, namely, our Terms of Service. We process this personal data based on our legitimate interests to develop and improve our products and services, and to prevent fraud.

• • 2.8. Geo-Location. If you consent, we will collect your (geo)location when you use our app, including your route and travel information, such as how long it takes you to travel from one point to another. You may be asked to enable the collection of location data both while the app is open as well as in the background after you have closed the app. Our collection of location data is subject to your consent. You are free to configure your settings at your discretion and may choose whether any location data will be collected, the type of location data (precise or approximate), and whether it will be collected only while the app is running or while the app is closed as well.
    • How We Use this Data: We use your location to provide you with location-based services, such as allowing you to navigate toward available parking spots, and providing you with a detailed location history of your parking trips. We use location data even when the app is closed in order to personalize the services, to maximize your user experience, and to develop and enhance our services.
    • Legal Basis: We process your location based on your consent. You may withdraw your consent at any point by changing your device settings. Please note, however, that certain functionalities of the app will not function if you do not provide consent.

• • 2.9. Android’s App Set ID. We collect Android’s App Set ID from your device when you use our app.
    • How We Use this Data: We use the App Set ID for the essential purposes of analytics and fraud prevention. We do not connect the App Set ID to any Android advertising identifiers (for example, AAIDs) or any personal data for advertising purposes. We process the App Set ID in accordance with Google Play’s User Data Policy.
    • Legal Basis: When we process your App Set ID to prevent fraud, we do so based on our legitimate interest to protect ourselves and our customers. When we process it for analytics purposes, we do so based on our legitimate interests to improve our services.

3. Our Marketing Activities. As described above, we may use personal data we collect for advertising and marketing purposes. We try to limit the marketing material we send to a reasonable and proportionate level. Below we describe how you can control the marketing material you receive from us.

• • 3.1. We use your contact details to send you informational newsletters and other materials about our products and services. You may request not to receive these notices at any time by emailing us at info@pumbaparking.com.

• • 3.2. You can stop the delivery of all marketing emails by following the “unsubscribe” link in any messages we send you. Alternatively, you can contact us at info@pumbaparking.com to request to unsubscribe.

• • 3.3. Note that if you are a registered user, we may need to contact you about administrative or service-related issues as part of the services we provide to you. Similarly, we may contact you through the app, via text message, or via push notifications with messages relating to your use of the app or services. This is not marketing communication and you will continue to receive these messages even if you opt-out of marketing emails.

4. Sharing the Personal Data We Collect. We share your personal data as follows:

• • 4.1. Service Providers. Below is a list of the types of service providers we use, the service each provides, and the types of data shared with each. All service providers have agreed to confidentiality restrictions and have undertaken to use your personal data solely as we direct.

Type of Service	Description	Personal Data Shared
Cloud Computing	We use service providers that offer cloud computing services. They offer us space on their servers for us to store our files and programs, including your personal data.	All personal data that we collect from you is stored on third party servers.
Email Marketing	We use an independent vendor to send out marketing emails on our behalf.	your name and email address
Payment Processors	When you make a payment through our services, the transaction is processed by an independent vendor.	The details of your credit card number or other payment method
Analytics Providers	We use a service provider to assist us with analytics services.	Data collected automatically through our site, including IP addresses, device IDs, and cookie information.
Geo-location data	We use service providers to assist us in translating geo-coordinates to addresses and addresses to coordinates and to provide driving/walking time estimations between geographic points.	Geo-location data, addresses

• • 4.2. Change of Ownership. If we are looking to sell our company, liquidate assets, or merge with another, we may share your personal data with other interested parties as part of negotiations toward that transaction. In such case, or where we do sell our company, your personal data shall continue to be subject to the provisions of this Privacy Notice.

 

• • 4.3. Law Enforcement Related Disclosure. We may share your personal data with government agencies or other relevant parties, such as a law office or independent auditor: (i) if we believe that such disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Notice) or those of a third party; (ii) if required by law or court order; or (iii) as is necessary to comply with any legal and/or regulatory obligations, such as audit requirements.

 

5. International Transfers. Some of our service providers are located in countries other than your own. When we transfer your personal data internationally, we will do so safely and securely and in accordance with applicable law.

• • 5.1. If you are located in the EU, when we share your personal data with third parties based outside of the European Economic Area (“EEA“), we will ensure that they sign on agreements that require them to comply with applicable law, keep your data secure at similar levels to the level described in this Privacy Notice, and make sure that your data protection rights are protected. We will also implement the following safeguards:

• • • 5.1.1. When we transfer your personal data to Israel or certain other jurisdictions, we rely on the decision by the European Commission that says that those countries are considered to provide an adequate level of data protection.

• • • 5.1.2. Where we transfer your personal data to other countries, we (i) take additional security measures to protect the data and (ii) use specific contracts approved by the European Commission, known as the Standard Contractual Clauses, to give your personal data the same protection it has in the EEA.

• • • 5.1.3. Please contact us at info@pumbaparking.com if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Security. The security of your personal data is our highest priority. We work hard to make sure that your personal data will be held securely and that it will not be shared or lost accidentally. However, it is impossible to guarantee absolute security. The security of your data also depends on the security of the devices you use and the way in which you protect your user IDs and passwords. The measures we take include:

• • 6.1. Technical Measures. The electronic safeguards we employ to protect your personal data include secure servers, firewalls, and antivirus protections.

• • 6.2. Access Control. We limit access to your personal data only to authorized personnel who have a need to know, including customer support staff, and software developers. We review these permissions regularly and revoke an employee’s access immediately after his/her termination.

• • 6.3. Internal Policies. We maintain and regularly review and update our privacy related and information security policies.

• • 6.4. Personnel We require employees to sign non-disclosure agreements according to applicable law and industry customary practice.

• • 6.5. Database Backup. Our databases are backed up and verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity.

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7. Your Rights – How to Control Our Use of Your Personal Data. Depending on which laws apply, you have certain legal rights over your data. Below is some general information about rights that may apply to you, but we recommend checking the law or consulting with a lawyer to understand what applies in your specific case. To exercise your rights, please contact us at info@pumbaparking.com. We may ask for reasonable evidence to verify your identity before we can comply with any request.

• • 7.1. Right of Access. You may have a right to know what personal data we collect about you. We may charge you a fee to provide you with this information, if permitted by law. If we are unable to provide you with all the information you request, we will do our best to explain why. See Article 15 of the GDPR for more details, if your personal data is subject to GDPR.

• • 7.2. Right to Correct Personal Data. You may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data. See Article 16 of the GDPR for more details, if your personal data is subject to GDPR.

• • 7.3. Deletion of Personal Data (“Right to Be Forgotten”). If you are located in the EU, you may have the right to request that we delete your personal data. Note that we cannot restore information once it has been deleted. Even after you ask us to delete your personal data, we may be allowed to keep certain data for specific purposes under applicable law. See Article 17 of the GDPR for more details, if your personal data is subject to GDPR.

• • 7.4. Right to Restrict Processing. If you are located in the EU, you may have the right to ask us to stop processing your personal data. See Article 18 of the GDPR for more details, if your personal data is subject to GDPR.

• • 7.5. Right to Data Portability. If you are located in the EU, you may have the right to request that we provide you with a copy of the personal data you provided to us in a structured, commonly used, and machine-readable format. See Article 20 of the GDPR for more details, if your personal data is subject to GDPR.

• • 7.6. Right to Object. If you are located in the EU, you may have the right object to certain processing activities. See Article 21 of the GDPR for more details, if your personal data is subject to GDPR.

• • 7.7. Withdrawal of Consent. If we are processing your data based on your consent, you are always free to withdraw your consent, however, this won’t affect processing we have done from before you withdrew your consent.

• • 7.8. Right to Lodge a Complaint with Your Local Data Protection Authority. If you are located in the EU, you have the right to submit a complaint to the relevant data protection authority if you have any concerns about how we are processing your personal data, though we ask that as a courtesy you please attempt to resolve any issues with us first.

8. Data Retention.

• • 8.1. We retain your personal data as long as necessary to fulfill each of the purposes we described above. Once we’re done with your data, we delete it.

• • 8.2. When deciding how long to store personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized access, the purposes for which the personal data was collected, as well as applicable legal requirements. Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business’s retention policy.

• • 8.3. Please contact us at info@pumbaparking.com if you would like details about the retention periods for each type of personal data we process.

 

9. Cookies and Similar Technologies.

 

• • 9.1. What are Cookies? A cookie is a small piece of text that is sent to your browser by a website you visit. This piece of text acts as a sort of tag, letting the website know that it’s you (really, your device) that’s visiting. There are other technologies that act similarly, like web beacons, pixel tags, and Device IDs for apps, but for simplicity’s sake we’ll refer to them all as “cookies”.

 

• • 9.2. Websites can place their own cookies (called “first-party cookies”) but can also place cookies from other sites (called “third-party cookies”). If your browser holds both first and third-party cookies for a given website, both the website and the third party are notified when you visit the site. We may place both first and third-party cookies on our site.

• • 9.3. How We Use Cookies. While the specific names and types of cookies we use may change from time to time, they generally fall into one of the categories listed below. We will not place any cookies on your browser that are not strictly necessary unless you have first consented to receive them.

Cookie Type	Function
Necessary	These cookies allow the site to work correctly. They enable your access to the site, move around, and access different services, features, and tools. These cookies cannot be disabled.
Functionality	These cookies remember your settings, preferences, and other choices you make (like placing an item in a shopping cart) in order to help personalize and streamline your experience.
Security	These cookies help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information.
Performance/Analytics	These cookies collect analytical information to help us understand how you use our site, for example whether you have viewed messages, clicked on links, and how long you spent on each page. This helps us improve our site to better suit your needs.

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• • 9.4. Third Party Cookies. In addition to our first-party cookies, we place cookies from the following third parties:

• • • Mixpanel cookie – third party analytics service.

 

• • 9.5. How to Adjust Your Preferences. Most web browsers are initially configured to accept cookies, but you can change the settings so that your browser refuses all cookies or certain types of cookies. In addition, you are free to delete any existing cookies at any time. Please note that some features of the services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit.

10. Third-Party Services. You may have access to third-party services through our services. Please note that all use of third-party services is at your own risk and subject to such third party’s terms and privacy policies. We do not take any responsibility for the performance of other services.

11. Children. We do not knowingly collect personal data from children under the age of eighteen (18). In the event that you become aware that an individual under the age of eighteen (18) has registered without parental permission, please advise us immediately.

12. Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business. We will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version.

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