Personal data processing policy.

Data controller

Controller	BonzPatrol s.r.o.
Reg. no. / VAT no.	22199357 · CZ22199357
Registered office	U Výstaviště 1286/21, Holešovice, 170 00 Prague 7, Czech Republic
Court registration	Municipal Court in Prague, section C, file 412302
Data protection contact	gdpr@bonzpatrol.cz

BonzPatrol s.r.o. is the operator of the car parks and a party to the parking agreement. It does not act towards you as an intermediary or as a processor on behalf of a third party — it determines the purposes and means of the processing itself, and is therefore the controller within the meaning of Art. 4(7) GDPR.

Contact point

Address any questions about the processing, requests to exercise your rights and objections to gdpr@bonzpatrol.cz or in writing to our registered office.

Other contacts: support@bonzpatrol.cz (car park operations, verifying that a payment demand is genuine), reklamace@bonzpatrol.cz (complaints about the service or a payment).

When the data arises

By driving a vehicle into the car park you enter into a lease agreement with BonzPatrol s.r.o. Its terms (the rules of operation) are posted at the entrance and published in the car park overview. To perform that agreement it is necessary to establish which vehicle was present in the car park and for how long.

A camera system with licence plate recognition therefore records the vehicle registration number on entry and on exit. From those two moments the system calculates the duration of presence and the corresponding price. You pay online at pay.bonzpatrol.cz. If you do not comply with the terms of the agreement, we assert a contractual penalty under the car park’s rules of operation, together with any outstanding parking fee where applicable.

What data we process

Camera system data

• the vehicle registration number and its country of registration;
• the time of entry and the time of exit, direction of travel and camera identifier;
• the confidence level of the plate recognition;
• vehicle attributes recognised by the camera: colour, make, model, vehicle type;
• images: a crop of the registration plate and a photograph of the vehicle at the moment of passage.

The cameras are aimed at the vehicle and its registration plate. It cannot be ruled out that a person standing near the vehicle is captured in an image. We do not use such images to identify persons; we use neither facial recognition nor any other biometric identification, and we do not organise the records by person.

Parking data

• the record of the parking period (start, end, duration of presence);
• the calculated price, the rate applied and the price list version used;
• the payment status.

Payment data

• the amount, currency, time, transaction identifier and its result;
• the type of payment instrument used, the card brand, the last four digits of the payment card number and the result of the 3-D Secure check;
• your e-mail address, if you enter it at payment in order to receive a tax document;
• for bank transfers, the data from the bank transaction (the payer’s name and account number, the variable symbol, the message for the payee).

We do not process, and have no access to, the full payment card number, its expiry date or the security code (CVC/CVV) — those are processed exclusively by the payment gateway provider. Nor do we process the issuer identification number (BIN) or any part of the card number beyond the last four digits.

Data used when asserting a claim under the agreement

• the description of the breach, the date and time it arose, the case reference and payment identifiers;
• supporting evidence (camera and photographic records under the rules of operation);
• identification of the vehicle operator: given name and surname or business name, address, date of birth, and where applicable the identification number of the person; contact details, where available;
• correspondence in the matter and the record of its dispatch and delivery.

List of vehicles holding a parking permit

At some car parks, preferential terms apply to the vehicles of the tenants of the building and their employees: such a vehicle is not charged and no contractual penalty is applied to it. To make that exemption work, we keep a list of permitted vehicles and, for each of them:

• the vehicle registration number and the validity period of the permit;
• details of the permit holder — name, e-mail address, telephone number and, where applicable, address — so that we can verify and administer the permit and, in the event of a dispute, evidence to whom and at whose request it was granted.

This data is passed to us by the operator of the building or by the holder’s employer; we do not obtain it from you. We do not use it to contact holders or for any purpose other than administering the parking permit.

Technical and security data

• IP address, browser identification, the time and address of the request, the result of the operation — in the operational and security logs of the payment portal and the information system.

Data of business partners’ contact persons

• the name, work e-mail address, telephone number and job title of persons acting on behalf of our contractual partners.

We process neither special categories of personal data under Art. 9 GDPR nor data relating to criminal convictions under Art. 10 GDPR.

Purposes and legal bases

Purpose	Legal basis
Establishing the parking duration, calculating the price, recording the parking period	performance of a contract — Art. 6(1)(b) GDPR
Receiving and matching a payment, issuing and sending a tax document	performance of a contract — (b); for the tax document also a legal obligation — (c)
Handling a complaint or an objection to a payment or the service	performance of a contract — (b); legal obligation — (c)
Keeping the list of vehicles holding a parking permit and exempting them from charges and from the contractual penalty	performance of the contract with the operator of the building — (b); legitimate interest in administering the permit — (f)
Checking compliance with the parking terms and producing supporting evidence	legitimate interest — (f)
Asserting and recovering the contractual penalty, outstanding parking fees and other claims under the agreement (e.g. compensation for damage or towing costs), including establishing the vehicle operator	legitimate interest — (f)
Defending against an unjustified challenge to a payment and preventing misuse of payment instruments	legitimate interest — (f)
Securing the information system, resolving technical faults, preventing attacks	legitimate interest — (f)
Bookkeeping and meeting tax obligations	legal obligation — (c), in particular Act No. 563/1991 Coll. and Act No. 235/2004 Coll.
Cooperation with public authorities and asserting claims in proceedings	legal obligation — (c); legitimate interest — (f)
Communication with business partners’ contact persons	legitimate interest — (f)

Our legitimate interests

Processing based on Art. 6(1)(f) GDPR is carried out for the following specific interests:

• Protection of property and proper operation of the car park. The car park is self-service and unattended. Without a record of which vehicle entered and when, it is impossible to establish occupancy, to evidence that the service was provided, or to prove a breach of the terms.
• Provability. Camera and photographic records serve as evidence that the service was provided, of how long the vehicle was present, and of a breach of the terms. Without them we would be able neither to substantiate our own claim nor to refute an unfounded complaint.
• Debt recovery. Without establishing the vehicle operator, a claim arising from a breach of the agreement cannot be asserted.
• System and payment security. Operational logs serve to detect attacks, misuse of payment instruments, and erroneous or duplicate transactions.

For each of these processing operations we have weighed our interest against your privacy. We therefore process only data about the vehicle and the course of the parking, not about persons as such; we keep images for a short time and process them further only where a specific breach case has been opened; and we establish the identity of the vehicle operator only at the moment we actually assert a claim, and only to the extent necessary for delivering the payment demand and for possible court recovery.

You have the right to object to processing based on legitimate interest — see below.

Where we obtain the data

We obtain most of the data directly from the operation of the car park and from the payment: the camera system records the vehicle, the payment gateway tells us the result of the payment.

Data we do not obtain from you:

• The register of road vehicles. Where we assert a claim under the agreement, we ask the competent municipal authority with extended powers to provide data about the vehicle operator. We thereby obtain the given name and surname or business name, the address, the date of birth and, where applicable, the identification number of the person. We base this processing on our legitimate interest in asserting and recovering the debt (Art. 6(1)(f) GDPR); the information under Art. 14 GDPR is provided to you by this document and also in the payment demand delivered to you.
• The payment gateway provider. The identifier and result of the transaction, the type of payment instrument, the card brand, the last four digits of the card number, the 3-D Secure result and your e-mail address, if you entered it during the payment process.
• The bank. For bank transfers, the data about the payer and the payment from the account statement.
• The operator of the building or the employer. The registration numbers of vehicles holding a parking permit and details of their holders. This document provides permit holders with the information under Art. 14 GDPR; they are usually informed of their inclusion on the list by whoever requested it.
• The business partner. Contact details of persons acting on behalf of our contractual partner.

Who we pass the data to

We never sell personal data and we do not pass it on for anyone else’s marketing purposes. We pass it only to the following categories of recipient, and always only to the extent necessary for the given purpose:

Recipient / category	Purpose of the transfer
GoPay s.r.o. — payment gateway provider	executing and authorising the payment, settling the transaction, handling payment complaints
Fio banka, a.s. — payment account provider	maintaining the account, receiving and matching bank transfer payments
Cloud infrastructure provider (Microsoft Azure)	running the application, the database and the image storage
E-mail delivery service provider	delivering tax documents and operational messages
Application error tracking tool provider	diagnosing faults and security incidents
IT support and maintenance providers	administering and maintaining the system
Municipal authorities with extended powers	providing data about the vehicle operator from the register of road vehicles
Law firm	legal representation and debt recovery
Debt administration and recovery partner	out-of-court recovery of unpaid claims
Courts, judicial enforcement officers, insolvency administrators	court and enforcement recovery
Public authorities, where they are entitled to it	meeting statutory obligations and providing cooperation
Czech Trade Inspection Authority	out-of-court resolution of a consumer dispute, if the consumer initiates one
Accounting and tax advisers, auditors	bookkeeping and meeting tax obligations

The providers of infrastructure, e-mail delivery, error diagnostics and IT support process the data as processors on our instructions and under a data processing agreement pursuant to Art. 28 GDPR. The payment gateway provider and the bank also process payment data in their own right as controllers where they are meeting their own obligations under the legislation governing payment services.

Diagnostic records of technical faults are configured so that registration numbers, e-mail addresses, payment data and the content of submitted forms and requests do not reach them; they contain technical identifiers and record numbers.

Transfers to third countries

We run the application, the database and the image storage on infrastructure located in data centres in the European Union.

Some of our providers belong to groups established outside the European Economic Area, in particular in the United States. In their case, access to the data from a third country cannot be ruled out, for example in the course of technical support. Such processing is always underpinned by one of the safeguards under Chapter V GDPR — an adequacy decision of the European Commission under Art. 45 GDPR, or standard contractual clauses under Art. 46(2)(c) GDPR, supplemented by technical measures (encryption in transit and at rest, access restrictions, minimisation of the scope transferred).

We will provide you on request with an overview of the providers and of the safeguards applied to a given provider at gdpr@bonzpatrol.cz.

How long we keep the data

Category	Retention period
Images from the camera system (photograph of the vehicle, plate crop)	30 days from capture; irreversibly deleted thereafter
The registration number in a parking record with no breach of the terms	irreversibly replaced by a non-recoverable hash within 90 days at the latest; the record then permits identification of neither the vehicle nor a person
Records and supporting evidence for a breach case	for the duration of the case and for at least 1 year after it is closed
The debt file (payment demand, correspondence, identification of the vehicle operator, evidence)	for the duration of recovery and for the running of the limitation period — as a rule 3 years from the due date plus 1 year; where the claim is awarded by a court, for the period of enforceability of the decision
Tax documents, accounting records and the payment records forming part of them (including an e-mail address entered to receive a document)	10 years, under Act No. 563/1991 Coll. and Act No. 235/2004 Coll.
Operational and security logs of the information system (IP address, browser identification, time and result of the operation)	1 year at most
Correspondence relating to a complaint or an enquiry	for the duration of its handling and for the period during which a claim may be asserted in the same matter
The list of vehicles holding a parking permit and details of the holder	for the validity period of the permit and for the period during which a claim arising from parking in that period may be asserted
Contact details of persons acting on behalf of business partners	for the duration of the cooperation and for the running of the limitation periods under the contracts concluded

Where a breach case has been opened in relation to a record, we keep that record for the duration of the case even if a shorter period under the first two rows of the table would otherwise have expired. Without the evidence we could not substantiate the claim — and you could not effectively dispute it.

Once the stated periods expire, we delete the data or irreversibly anonymise it.

Automated processing

Recognition of the registration plate, calculation of the vehicle’s duration of presence, calculation of the price, matching of the payment and the finding that payment was not made within the time limit are carried out by automated means. The initial record of a breach of the parking terms also arises by automated means.

The system does not itself issue or send a payment demand. Establishing the vehicle operator, issuing the demand and sending it are initiated by an authorised member of staff; the automated record serves as the basis for their decision.

We do not carry out profiling within the meaning of Art. 4(4) GDPR — that is, evaluating personal aspects, behaviour, interests or reliability of persons.

If you believe that the record concerning your vehicle is incorrect (for example because the plate was misread), tell us at gdpr@bonzpatrol.cz or support@bonzpatrol.cz. We will review the record and cancel the case if it turns out that the evidence does not substantiate the claim.

Your rights

• Right of access (Art. 15) — to confirmation as to whether we process data about you, to information about the processing, and to a copy of the data processed.
• Right to rectification (Art. 16) — to have inaccurate data corrected and incomplete data completed.
• Right to erasure (Art. 17) — where the purpose of the processing has ceased, where an objection has been successfully raised, or where the processing is unlawful. It does not apply where we are obliged to keep the data by law (in particular accounting and tax documents) or where we need it for the establishment, exercise or defence of legal claims.
• Right to restriction of processing (Art. 18) — in particular for the period during which we are verifying the accuracy of the data or assessing your objection.
• Right to data portability (Art. 20) — you have the right to receive data processed by automated means on the basis of a contract in a machine-readable format and, where technically feasible, to have it transmitted to another controller.
• Right to object (Art. 21) — see below.
• Right to lodge a complaint with the supervisory authority — see below.

How to exercise a right. Send your request to gdpr@bonzpatrol.cz or in writing to our registered office. Please state the vehicle registration number and the approximate date and place of parking — without those we are usually unable to locate the record, because we do not organise the data by the names of persons.

Identity verification. So that we do not disclose data to the wrong person, we may ask you for additional information enabling us to verify that the request is made by the person the data concerns or by an authorised person (for example the vehicle operator). We will use the information requested solely for verification and will not retain it once the request has been handled.

Time limit. We will handle the request without undue delay and at the latest within one month of its delivery. We may extend that period by up to a further two months having regard to the complexity and number of requests; we will inform you of the extension and of the reasons for it within one month of the delivery of the request.

Fees. Handling is free of charge. Where a request is manifestly unfounded or excessive, in particular because it is repetitive, we may, under Art. 12(5) GDPR, charge a reasonable fee or refuse to act on the request; we will always give you our reasons for doing so.

Complaints about the service provided or a payment made should be raised under the procedure in the rules of operation at reklamace@bonzpatrol.cz; that procedure and its time limits are without prejudice to the exercise of rights under the GDPR.

Right to object

You have the right to object at any time, on grounds relating to your particular situation, to processing that we base on legitimate interest (Art. 6(1)(f) GDPR). This concerns in particular the taking and keeping of camera and photographic documentation, establishing the vehicle operator, and debt recovery.

Send your objection to gdpr@bonzpatrol.cz. Once we receive it, we will not process the data concerned further unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or grounds relating to the establishment, exercise or defence of legal claims. We will inform you of the outcome of our assessment.

We do not process data for direct marketing; should you receive such a communication from us, you have the right to object and we will always comply without further question.

Complaint to the supervisory authority

If you believe that our processing of your personal data infringes the GDPR or Act No. 110/2019 Coll., you have the right to lodge a complaint with the supervisory authority:

Office for Personal Data Protection (Úřad pro ochranu osobních údajů)
Pplk. Sochora 727/27, 170 00 Prague 7 – Holešovice, Czech Republic
uoou.gov.cz ↗

We would welcome you contacting us first at gdpr@bonzpatrol.cz — most matters can be resolved more quickly that way. Your right to approach the authority is not affected.

Is providing the data mandatory

Processing the registration number, the times of entry and exit and the related documentation is a necessary precondition for concluding and performing the parking agreement. You do not provide this data to us by filling in a form — it arises when the vehicle enters the car park. If you do not wish this processing to take place, do not enter the car park; no other way of providing the service is possible, because without a record of entry and exit neither the parking duration nor the price can be determined.

Entering an e-mail address at payment is voluntary and serves only to send the tax document automatically. If you do not enter one, this does not restrict the payment in any way and we will provide the document on request.

We obtain data about the vehicle operator from the register of road vehicles without your involvement; we therefore limit its scope to what is necessary for delivering the payment demand and for any recovery.

Visiting the website

The bonzpatrol.cz website is static. It stores no cookies or other identifiers in your browser and uses no third-party analytics, marketing or functional tools. The hosting or content-delivery provider may set strictly-necessary cookies (protection against attacks, content delivery); these do not track visitors and, under § 89(3) of Act No. 127/2005 Coll., do not require consent.

Our sign-in applications — the payment portal pay.bonzpatrol.cz and the customer portal app.bonzpatrol.cz — do use cookies, but strictly-necessary ones only: a sign-in cookie that keeps your session and a security token against request forgery (CSRF). They do not track you across sites, are not shared with third parties and, under § 89(3) of Act No. 127/2005 Coll., do not require consent — without them you cannot sign in or pay. On the payment gateway’s own pages, cookies are set by the gateway operator under its own policy.

In these applications we process technical connection data (IP address, browser identification, time and result of the operation) in order to secure payments and the system; we keep these logs for 1 year at most.

Verifying that a payment demand is genuine

We never use personal data to approach you with a payment link. We do not send payment links by text message or e-mail, and we never ask for payment card details by telephone, e-mail or text message. We accept payments solely through pay.bonzpatrol.cz and, for debts, in accordance with a payment demand delivered in writing.

You can verify at any time before paying that a payment demand and the payment details stated in it are genuine, at support@bonzpatrol.cz.

Security

Only authorised persons have access to the data, and only to the extent corresponding to their role. The data is stored in an access-controlled environment, transmission and storage are encrypted, and access and changes are logged. Images carry a checksum allowing verification that they have not been tampered with. We have data processing agreements in place with our processors under Art. 28 GDPR.

Effect and changes

This wording takes effect on the day of its publication at bonzpatrol.cz/en/privacy and supersedes the previous wording. The current wording is always available at the same address; we notify substantial changes to the processing by publishing a new wording and, where the changes concern an ongoing case, also directly to the persons affected.

BonzPatrol s.r.o.