Parkpnp Limited T/A WAYLEADR and WAYLEADR Inc. (“WAYLEADR”, “we”, “us” or “our”) is committed to protecting customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This privacy notice (“Notice”) has been developed to ensure our Clients and End Users (each defined below) feel confident about the privacy and security of personal data and to meet our obligations under Irish Data Protection Legislation, the European Union General Data Protection Regulation and United States of America Data Protection laws" (“Data Protection Law”). Under Data Protection Law, personal data is information that identifies you as an individual or is capable of doing so (“Personal Data”).
We must comply with the data protection principles set down in Data Protection Law and this Notice applies to all personal data collected, processed and stored by us. By providing us with information, you accept and agree to the practices described in this Notice. This Notice sets out the following:
- What Personal Data we collect and process about you in connection with your relationship with us as, or on behalf of, a Client using WAYLEADR or as an End User (“you” and/or “your”) and through your use of our website, mobile applications and online services;
- Where we obtain the Personal Data from;
- What we do with that Personal Data;
- How we store the Personal Data;
- Who we transfer/disclose that Personal Data to;
- How we uphold your data protection rights; and
- How we comply with the Data Protection Law.
All personal data is collected and processed in accordance with Data Protection Law and is used to help us with the provision of our online parking booking services, including WAYLEADR (our “Services”).
For the purposes of Data Protection Law, “WAYLEADR” is the data controller of your Personal Data. You will find our contact details in the “Contact us” section below.
WAYLEADR’s Clients and End Users
Our “Clients” are businesses, companies and institutions that have opted for our WAYLEADR service. Our “End Users” are either (i) customers who choose to use the “WAYLEADR'' service in their individual capacity, or (ii) our Clients’ employees, contractors, agents and any other third party that our Client permits to utilise its subscription to WAYLEADR.
Depending on the nature of the Services being provided, “WAYLEADR” may act as either a data controller or a data processor with respect to the Personal Data of End Users. This Notice applies to the processing of End Users’ Personal Data to the extent to which “WAYLEADR” acts as a data controller of that Personal Data.
For all other service offerings, “WAYLEADR” is the data controller of the Personal Data that is collected and used about “WAYLEADR” customers, under Data Protection Laws.
We have appointed a Privacy Officer to oversee compliance with this Notice. You have the right to make a complaint at any time to a supervisory authority.
What types of Personal Data do we collect?
There are a number of types of Personal Data that “WAYLEADR” collects.
- Personal information from End Users required to provide the Service such as: contact information (including email); name; and occasionally billing details, in the case of Wayleadr Revenue where "Clients" choose to charge "End Users" for parking.
- Personal information from employees, contractors or other agents of Clients with whom “WAYLEADR” liaises in providing the services to the Client (who may or may not also be End Users), such as: contact information (including email and telephone number); and name.
- Information which is collected from our website(s) or generated by our systems (or those of third parties) to track the traffic of our website(s) (e.g. IP addresses).
- Information given to us through surveys, subscriptions, etc.
The specific types of Personal Data that “WAYLEADR” collects depends on the type of services that you opt for on our website, on the phone and through sales. The reason we ask you for personal details is to help administer your online parking bookings and ensure you get the best service possible.
“WAYLEADR” does not collect sensitive information or any information that may constitute special category Personal Data for the purposes of Data protection Law.
How we collect Personal Data
“WAYLEADR” may collect Personal Data directly from End Users, such as when End Users use our website, over the phone app or through email when you use our services. In the event that Clients do not provide sufficient information for us to provide the WAYLEADR service, we may also collect the missing personal data directly from End Users.
“WAYLEADR” may also collect Personal Data from Clients, either for the purposes of providing the Services to End Users (including registering End Users) or in arranging for Clients to subscribe to our Services.
Information may also be collected when End Users correspond with “WAYLEADR” over the phone, through the website chat bot or via email, or through any other form of communication. “WAYLEADR” may also collect data provided to us through our partners, listed in the table below.
End Users may be able to access third party social media services through our website or app or before coming to our website or app. When End Users are registered with a social service account, we will obtain the Personal Data that End Users choose to share with us through these social media services pursuant to their privacy settings in order to improve and personalise the use of our website or app.
How we use this Personal Data
“WAYLEADR” may use this data for any or a combination of reasons.
- Facilitating and processing contracts in order to deliver our Services
- Facilitating registration to our products and services
- Communicating with you – End User and/or Client - (over phone, email, newsletters, etc.) – including for as part of customer service.
- Aiding our marketing activities.
- Informing you (End User and Client) of our products/services/etc.
- Improving our services, including analysing the data on the “WAYLEADR” website.
- For purposes which are reasonably expected as part of running our business. These purposes are necessary as part of the Services we provide and do not materially impact your rights, freedom or interests.
Disclosure of Personal Data to third parties
Except as stated in this Notice, we will not disclose Personal Data that we collect to any parties other than those without your consent. Except as disclosed below, we will not sell, share, trade, rent, or give away your Personal Data.
We shall disclose your Personal Data to third parties only when it is necessary as part of the Services (for example, we share the Personal Data (and other data) that we collect in WAYLEADR on behalf of a particular Client with that Client and to such other parties as instructed and agreed with the Client), business practices or when there is a legal or statutory obligation to do so. Whenever we disclose your Personal Data to third parties, we will only disclose that amount of your Personal Data necessary to meet such business need or legal requirement. Third parties that receive your Personal Data from us must satisfy us as to the measures taken to protect the Personal Data such parties receive, in accordance with Data Protection Law and as stated in this Notice. Appropriate measures will be taken to ensure that all such disclosures or transfers of your Personal Data to third parties will be completed in a secure manner and pursuant to contractual safeguards.
Please find below a list of the third party processors and external links to their respective data privacy and security policies
Heroku for Application Management, Deployment, Server & Database Hosting
Intercom for Customer Interaction
SendGrid for Email Delivery Services
Stripe for Payment Processing
“WAYLEADR” may disclose information provided by you (End User or Client) to our third party partners. This may facilitate parking, or aid in the delivery and advances of our Services.
Personal Data may be shared with other companies within the “WAYLEADR” group. We may transfer your Personal Data to another company that is affiliated with us, with which we have merged, or which has acquired all or some of our assets. We will advise you if such a change of ownership or change of corporate structure takes place and we will update this Notice accordingly.
We may provide your Personal Data when obliged to do so under Data Protection Law and in response to properly made requests, for example, for the purpose of the prevention and detection of crime, and the apprehension or prosecution of offenders. We may also provide your Personal Data for the purpose of safeguarding national security. In the case of any such disclosure, we will do so only in accordance with Data Protection Law.
We may also provide your Personal Data when required to do so by law, for example under a court order, and may transfer data to legal counsel where same is necessary for the defence of legal claims.
We may also use social media plugins on our website or App. As a result, End Users’ information may be shared with your social media provider and possibly presented on your social media profile to be shared with others in your network. Please refer to the privacy notices of these third-party social media providers to find out more about these practices.
No mobile phone number information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
International transfer of Personal Data
The processing of Personal Data by “WAYLEADR”, or the disclosure of Personal Data to third parties as set out above, may include overseas transfers outside the EEA to countries whose data protection laws are not as comprehensive as those within the EEA. In accordance with Data Protection Law, we shall only transfer personal data to recipients offering an adequate level of data protection. This may include the transfer of data in accordance with the EU-US and Swiss-US Privacy Shield frameworks (for transfers to the US) or pursuant to data transfer agreements that incorporate the Standard Contractual Clauses approved by the EU Commission. “WAYLEADR” continues to monitor all developments regarding the legal bases for the international transfer of Personal Data and shall update its processes as necessary.
Lawful basis for processing Personal Data
We rely on the following legal bases under GDPR in processing Personal Data:
- consent (when engaging with Clients and/or End Users in registering for the Services);
- performance of a contract with you (specifically to administer End Users and/or Clients’ parking requirements);
- compliance with legal obligations (e.g. lawful law enforcement requests);
- legitimate interests (e.g. in the event of a complaint or legal action being taken against “WAYLEADR”).
For the first two uses in the above section, we rely on the legal basis that the processing of the personal data is necessary for the performance of a contract, specifically to administer End Users and/or Clients’ parking requirements. If the required personal data is not provided, we cannot finalise the parking facility, nor can we provide customer service. For uses 3 to 7 above, we rely on Article 6(1)(f) of GDPR, which provides that we can process personal data where processing “is necessary for the purposes of the legitimate interests pursued by us, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data“.
If necessary and where applicable, we also rely on compliance with legal obligations (such as lawful law enforcement requests).
Note that we may process your personal data in reliance on different lawful grounds depending on the specific purpose for which we are using your Personal Data at that time. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data in a particular instance.
We will also obtain your consent where required under applicable law prior to processing your Personal Data for direct marketing purposes. You have the right to withdraw consent to marketing at any time by contacting us.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data for purposes other than which we collected it where this is required by law.
Failure to provide Personal Data
Where we need to collect personal data in order to provide the Services to you or to the Client, and you do not provide or agree to provide that data when requested, we may not be able to provide the Services and/or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service that you have with us.
Security and storage of your Personal Data
“WAYLEADR” takes all necessary steps to ensure the protection and privacy of Personal Data in accordance with the requirements of Data Protection Law. “WAYLEADR” regularly reviews and implements new security and encryption technologies and has put in place suitable physical, electronic and managerial procedures to safeguard and secure the information collected.
While all necessary steps are taken to ensure the safety of your information, unfortunately, no data transmission over the internet can be guaranteed total security. While we do strive to protect all information, we cannot ensure or warrant the security of any information you give to “WAYLEADR” or obtain from our online services and products. Therefore, the transmission of data as part of the Services is at your own risk. However, once your information does come into our possession – we take all reasonable actions to protect your information from unauthorised access, loss or misuse. We also strive to protect that information from modification or disclosure. If we find that a security breach has occurred, we have procedures to minimise the effects and we may liaise with you (Client and End User) as appropriate in accordance with the requirements of Data Protection Law.
How long do we keep your Personal Data?
The period for which we retain Personal Data varies according to the use of that information. In some cases, there are legal requirements to keep Personal Data for a minimum period of time. Unless specific legal requirements dictate otherwise, we will retain Personal Data no longer than is necessary for the purposes for which the Personal Data were collected and processed (as described above). The following are the terms of our data retention policies and procedures:
Your Personal Data will be retained for no longer than is necessary for the purposes for which it was collected. “WAYLEADR” will retain your Personal Data for as long as we continue to provide our Services to you. Following termination of the provision of the Services, your Personal Data shall be retained for as long as is necessary and permissible in accordance with statutory limitation periods.
Links to external sites
“WAYLEADR”’s website contains links to other websites for convenience purposes. While we may link to third party websites, it does in no way indicate an endorsement of their site, policies or practices – unless stated. If you are concerned about your privacy on those sites, please check their privacy policies.
Changes to this Notice
On occasion, “WAYLEADR” may review and update this Notice from time to time to consider changes in the law and the experience of the Notice in practice. Any and all changes will be advised to you and, if necessary, we will obtain your consent prior to applying any changes to any Personal Data collected from you prior to the date the change becomes effective Any changes to the Notice will be communicated to you by way of an e-mail or a notice on our website. We advise our Clients and End Users to periodically review our policies.
“WAYLEADR”s website: How we use aggregate data & collect and share information
How we use aggregate data
“WAYLEADR” collects non-personal information as aggregate data such as how website users utilise our website. For example, we monitor the number of visits to our site, we track the number of visits to certain pages on our site, and the domain names of our users’ internet service provider.
This aggregate data allows us to examine trends and gather insights that would not be readable if the elements of data were viewed in isolation. It is a means that allows us to understand the workings of our website and services, and in turn, this allows us to improve and enhance our services. We may also use this data with our partners to improve our educational and employment services.
This information does not constitute Personal Data for the purposes of Data Protection Law.
IP (Internet Provider) Address
Your IP address is supplied to “WAYLEADR” through our web servers. This aids us in diagnosing problems or support issues with our servers.
For more information about cookies and how to stop cookies being installed visit the following website: http://www.allaboutcookies.org.
We use tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of the websites. This software does not enable us to capture any Personal Data.
When acting as data controller, “WAYLEADR” seeks to ensure that the information we hold is accurate, correct and up to date. If the information we hold about you is inaccurate or out of date, or if you would like your details removed from our website, please contact [email protected]. This will allow us to take reasonable steps to address or discuss alternative options with you.
Your Data Protection Rights
Subject to certain limited exceptions, you have the right to the following from “WAYLEADR”:
Request information about whether we hold Personal Data about you, and, if so, what that Personal Data is and why we are holding/using it.
Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate Personal Data we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
Object to automated decision-making including profiling, that is not to be subject to any automated decision-making by us using your Personal Data or profiling of you.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request transfer of your Personal Data in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically usable format and to be able to transfer your data to another party in an electronically usable format.
Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. In circumstances where we act as data controller over the personal data and we receive notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please contact our Privacy Officer at [email protected].
Note that in circumstances where Services are provided under WAYLEADR, the above requests should be directed to our Client, as data controller.
Where we act as a data controller, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
Questions regarding this Notice
We welcome questions and feedback regarding this Notice and our website. We may use said feedback to better our services, products and websites. It may also be shared with our partners in aggregate form or with identifying characteristics removed.
Ireland & Europe: +353 1903 6083
USA & North America: +1 845 720 4279
Registered Address for Parkpnp T/A Wayleadr:
77 Camden Street Lower, Dublin 2, D02 XE80, Ireland.
Registered Address for Wayleadr Inc.:
18 E 50th Street, New York, NY, 10022, Floor 8
Contact our Data Protection Officer
To contact Wayleadr's Data Protection Officer in respect of the processing of your personal data by Wayleadr please email [email protected]