Automated License Plate Recognition(“ALPR”) Policy

Automated License Plate Recognition (“ALPR”) Policy

IMT Residential (referred to as “we,” “us,” and “our”) values our residents and property visitors, their information, their privacy, and their trust. California Civil Code Section 1798.90.51 requires ALPR operators to implement and make available a usage and privacy policy regarding the collection, use, maintenance, sharing, and dissemination of ALPR Information. This Automated License Plate Recognition Policy (“ALPR Policy”) has been established to provide you with this information regarding our use of ALPR technology to collect parking usage data, to verify parking times, and other parking and transit management related purposes at our California locations, Citrus Commons and IMT Gallery 421.

Definitions:

“Automated License Plate Recognition” or “ALPR”  means the technology, also known as License Plate Reader, which provides still images and other data, including vehicular attributes such as make, color, license plate, roof rack, and bumper stickers, captured by the ALPR System.

“ALPR Information” means the content obtained by an ALPR, including the Footage metadata, such as time stamp and geolocation of the camera, as well as who has accessed records, search history, and any other auditable data collected by the ALPR System used to store, index, and access the information gathered by an ALPR.

“ALPR System” means the ALPR hardware and software including cameras or device, pole, clamps, solar panel, installation components, and any other physical elements used for the capture, retention, indexing, accessing, and utilizing ALPR Information.

“ALPR Vendor” means SKIDATA GmBH as it relates to the services provided for the Citrus Common property and Frogparking, Inc as it relates to the IMT Gallery 421 property.

“Footage” means still images and other data, including vehicular attributes such as make, color, license plate, roof rack, and bumper stickers, captured by the ALPR System in the course of and provided via the services provided by the ALPR Vendor.

A. Authorized Purposes for Using the ALPR System and Collecting ALPR Information:

The ALPR System will be used solely for enhancing the security and safety measures within the IMT Residential properties. The authorized purposes include:

• 1. Monitoring and controlling access to the properties for residents, guests, and authorized personnel;
• 2. Identifying and deterring criminal activities, such as theft, vandalism, and trespassing within the properties’ common areas;
• 3. Assisting la enforcement in investigating and solving criminal incidents that occur within the properties’ vicinity;
• 4. Implementing traffic management and ensuring compliance with parking rules and regulations for the convenience of residents and visitors.

B. Authorized Personnel and Training Requirements:

Only designated employees and independent contractors with specific job titles, such as General Manager, Off-site Manager, independent Security Expert, or other similar job title or role, with a “need-to-know” to perform their assigned duties will be authorized to access and use the ALPR Systems and collect ALPR Information. Prior to accessing the system, these individuals must undergo training on the lawful and ethical use of the ALPR System, privacy protection, data security, and compliance with applicable laws and regulations.

C. Monitoring and Compliance with Privacy Laws:

The ALPR System will be continuously monitored to ensure the security and integrity of the information collected. To maintain compliance with privacy laws, access to the ALPR Information will be restricted to authorized personnel only. Regular audits and reviews will be conducted to assess adherence to this policy and applicable privacy laws. ALPR vendors and independent contractors will be required through written agreements to maintain the confidentiality and security of ALPR Information according to applicable privacy laws. Any potential violations of this policy, unauthorized access, data breaches, or violations of applicable privacy laws will be promptly investigated and addressed.

D. Sale, Sharing, or Transfer of ALPR Information:

The ALPR Information collected within the park premises will not be sold, shared, or transferred to any third-party entities for commercial or non-essential purposes. Exceptions may only occur when lawfully required by government authorities or law enforcement agencies for the investigation of criminal activities. In such cases, the release of information will be in compliance with relevant laws and regulations.

E. Official Custodian/Owner of the ALPR System:

The General Manager of the applicable property or a designated high-level management official will be the official custodian and owner of the ALPR System. This individual will be responsible for overseeing the implementation, operation, and compliance with the ALPR Policy.

F. Measures for Ensuring Accuracy and Correcting Data Errors:

The ALPR System will employ reasonable measures to ensure the accuracy of the collected data. Regular maintenance, calibration, and testing of the equipment will be carried out to minimize errors. In case of any identified data errors, a well-defined process will be in place to promptly correct the information and rectify any discrepancies. If you have any questions or would like to report a potential error, please contact us using the information in the Contact Us section below.

G. Retention Period and Data Destruction Process:

ALPR Information will be retained for a limited and necessary period depending on the purpose for which it was collected. For ALPR Information collected from visitors or guests of either our residential or retail properties the retention period will be set to the minimum duration required for security and law enforcement purposes, with a maximum retention period of up to 30 days, consistent with general surveillance policy. ALPR Information collected from residents will be retained as long as necessary to serve the purpose of managing resident access to parking facilities. After this period, the ALPR operator will ensure the secure and irreversible destruction of the retained ALPR Information to safeguard the privacy of individuals.

H. Contact Us:

If you have any questions or concerns regarding this policy, please contact us at

IMT Residential
15303 Ventura Blvd. Suite 200
Sherman Oaks, CA 91403
Phone: 800.925.0212
E-mail: connect@imtresidential.com