Processing of personal data of users of the Apcoa Flow Application
Please read carefully and carefully this document, which applies to the data processed in Apcoa Flow. Information about Apcoa Flow is available at www.apcoa.pl/apcoa-flow and in the Terms and Conditions of Apcoa Flow available when installing Apcoa Flow on your mobile device.
The administrator of your personal data is APCOA Polska Sp. z o.o. (previous name APCOA Parking Polska Sp. z o.o.) with its registered office in Warsaw, Rondo ONZ 1, registered in the National Court Register under number 0000129400 (Apcoa).
In order to install the Application, it is not necessary for the user to provide personal data. However, you must create a User Account before you can use Apcoa Flow. When you create a user account, Administrator processes the following personal data:
- your name and surname,
- e-mail address.
Providing this data is voluntary, but not providing it will prevent the creation of an Account of the User.
In connection with the use of the Apcoa Flow Application, the Administrator also collects data:
- regarding the user's geolocation and historical parking spaces on the basis of the user's consent; consent to geolocation is necessary for the use of the Apcoa Flow Application;
- vehicle registration number, payment or credit card number, including details of their use in specific locations in connection with your use of the Application, based on your consent;
- phone number, based on your consent, which is provided voluntarily and not required for use of the Apcoa Flow Application.
We only collect, process and store personal data about you when you use the Application:
- to create your Apcoa Flow Application User Account and use the Application in accordance with its purpose, including in particular the location of available parking spaces, the ability to make electronic payments;
- to enter into and perform a lease agreement for a parking space if personal data is provided for the purpose of performance of the agreement, including invoicing (including invoicing), internal and external debt collection, enforcement proceedings and the handling of complaints;
- in other cases in which data processing takes place on the basis of the consent of the data subject - in the scope and purpose of which it results from the content of the consent granted;
- for legally justified purposes of the data controller, in particular direct marketing of products and services and customer satisfaction surveys.
The Administrator may also conduct analyses of statistical data established on the basis of personal data obtained, after their prior anonymisation.
Personal data of the user will not be passed on to third parties, unless it is necessary to provide a service or perform a contract. However, personal data will be transferred to the entity administering the Application System of Apcoa Flow and the entity providing maintenance and development services for this system. In this case, data may be transferred outside the EEA, but only to entities that provide adequate safeguards and enforceable data subjects' rights, as well as effective legal remedies, as set out in a contract concluded in accordance with standard contractual clauses.
Personal data may also be transferred to third parties for the purpose of conducting external debt collection or enforcement of claims, as well as to suppliers responsible for the operation of IT systems, accounting services providers, non-cash payment operators, marketing agencies (with respect to marketing services) and entities related to the Administrator, including companies from its capital group. Your Application Flow User Data will also be passed on to authorities and public authorities entitled to access it and as part of the Administrator's legal obligation to disclose it or the obligation to disclose it by court order.
Employees and subcontractors of the Administrator are obliged to maintain confidentiality and comply with data protection regulations, and access to data is restricted to persons who have appropriate authorisations or concluded personal data processing outsourcing agreements.
User rights of Apcoa Flow
The User may obtain information about the processing of his or her personal data free of charge at any time and without stating any reason, as well as exercise his or her right to access, rectify, supplement and amend the data processed by us about him or her. The User may at any time demand the deletion of all stored data concerning him/her (right to be forgotten) and demand a limitation of data processing. These rights shall be exercised immediately by the Administrator in the event that the implementation of the demands is permitted by law.
Each User also has the right to transfer data and the right to object to the processing of his/her data for justified purposes of Apcoa as the Administrator, including direct marketing of its products and services and profiling, as well as the right not to be subject to the decision, which is based solely on automated processing.
The User may also, at any time and without giving any reason, withdraw the consent to the processing and use of data concerning him/her, if the data were processed on the basis of the consent granted. Consent may not be revoked if:
- the data subject does not identify himself sufficiently,
- the legal provision allows data to be processed despite the revoked consent.
If you withdraw your consent to data processing in connection with your use of the Application, you must delete your user account and stop using the Application. Withdrawal of consent to the processing of data does not affect the possibility of concluding parking space rental agreements outside of the Application.
We also reserve the right to do so:
- the data subject has the right to access his or her data collected directly from the Application and the right to information about the data at any time, however, this right may be actively exercised no more than once every 6 months;
- the data subject have the right to request the deletion of your personal data, in particular if the data are no longer necessary for the purposes for which they were collected. However, this request will not be met if the processing of data is necessary for:
o exercise of rights and freedoms of expression and information,
o on the fulfilment of a legal obligation to process under EU or Polish law, or to perform a task carried out in the public interest, in particular the Accounting Act,
o for archival purposes in the public interest, for scientific or historical research or statistical purposes,
o to establish, enforce or defend claims.
Please note that data protection and data processing rules, including those of third parties, in particular mobile device software providers on which the Application is installed, may be subject to continuous change. Therefore, it is recommended and necessary to familiarise yourself with changes in the laws and regulations adopted by individual companies, which is the responsibility of the data subject. The Administrator will only inform Users of the Apcoa Flow Application of any change in the personal data protection policy of the Apcoa Flow Application.
The period of time for which personal data is stored in the Application is dependent on the data being processed, and so on:
- data required to create and maintain a user account for the Application - until the user deletes the user account for the Application,
- data concerning the concluded rental agreements of the parking space, including data necessary for the collection and enforcement of claims - until the time of determination, enforcement or defence of claims, but not longer than the statute of limitations provided for by law,
- data processed on the basis of consent - until its withdrawal,
- other data - no longer than 2 years.
Final information
If the Administrator finds that the personal data has been processed in violation of law, the data subjects have the right to lodge a complaint with the President of the Office for Personal Data Protection with the registered office in Warsaw, ul. Stawki 2.
In order to ensure the highest level of security of personal data processing processes, Apcoa has appointed an Inspector for Personal Data Protection, who you can contact at daneosobowe@apcoa.pl or in writing to Apcoa.
