Privacy Policy

Mitte Technologies Inc. - Privacy Policy

Last Updated: June 3, 2025

THIS POLICY
This Privacy Policy (this "Policy") describes how Mitte Technologies Inc. ("Mitte," "we," "us," or "our") collects, uses, shares, and protects personal information in connection with your use of the Mitte Validation Portal (the “Validation Portal”), our website (www.joinmitte.com), and any other related products and services that refer or link to this Policy (collectively, the “Services”).
This Policy is incorporated into and forms part of the Mitte Validation Portal - Terms of Use (the "Terms of Use"). YOUR USE OF THE SERVICES CONSTITUTES YOUR ACKNOWLEDGEMENT THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY AND THE TERMS OF USE. IF YOU DO NOT AGREE, DO NOT ACCESS OR USE THE SERVICES.
Mitte recognizes the importance of maintaining and protecting the privacy of personal information.

TABLE OF CONTENTS

APPLICABLE PRIVACY LEGISLATION
DEFINITIONS
PRINCIPLES RELATING TO THE PROCESSING OF PERSONAL DATA
INDIVIDUAL PRIVACY RIGHTS
HOW WE COLLECT AND USE PERSONAL INFORMATION
TYPES OF DATA WE PROCESS
LAWFULNESS OF DATA PROCESSING
COOKIES AND TRACKING TECHNOLOGIES
DATA SHARING AND DISCLOSURE
DATA SECURITY
DATA RETENTION
INTERNATIONAL TRANSFERS OF PERSONAL DATA
PRIVACY BY DESIGN
CONTRACTS INVOLVING THE PROCESSING OF PERSONAL DATA
DATA PROTECTION OFFICER (DPO)
YOUR CHOICES AND RIGHTS (ACCOUNT INFORMATION)
CHILDREN'S PRIVACY
AMENDMENTS
CONTACT US

1. APPLICABLE PRIVACY LEGISLATION

Mitte operates internationally and aims to comply with applicable data protection laws in the jurisdictions where we offer our Services or process personal data. Key privacy legislations that may apply include, but are not limited to:

European Union (EU) / European Economic Area (EEA): General Data Protection Regulation (GDPR).
United Kingdom (UK): UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
United States of America (USA):
California: California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).
Other applicable US federal and state privacy laws.

Mitte has a legal obligation to comply with the provisions of this legislation where applicable. This Policy establishes key principles commonly required. Significant fines may be applicable if a breach occurs. It is Mitte’s policy to ensure that our compliance with applicable legislation is clear and demonstrable.

2. DEFINITIONS

The common terms used within this Policy are as follows:

Personal Data (or Personal Information): Any information relating to an identified or identifiable natural person ("Personal Data Principal" or "Data Subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing: Any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. For the purpose of this Policy, Mitte is generally the Data Controller of the Personal Data collected directly from users of its website or for its own account management, and may act as a Data Processor for data processed on behalf of its clients through the Validation Portal.
Data Processor: A natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller.
Data Subject (or Personal Data Principal): The identified or identifiable natural person to whom Personal Data relates.

3. PRINCIPLES RELATING TO THE PROCESSING OF PERSONAL DATA

Mitte is committed to processing Personal Data in accordance with the following data protection principles:

Lawfulness, Fairness, and Transparency: Personal Data shall be processed lawfully, fairly, and in a transparent manner in relation to the Data Subject.
Purpose Limitation: Personal Data shall be collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Data Minimization: Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
Accuracy: Personal Data shall be accurate and, where necessary, kept up to date.
Storage Limitation: Personal Data shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data is processed.
Integrity and Confidentiality: Personal Data shall be processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
Accountability: Mitte shall be responsible for, and be able to demonstrate compliance with, these principles.

Processing of special categories of Personal Data (e.g., revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric data) is generally prohibited unless specific legal grounds apply. Mitte does not intentionally collect such data through the Validation Portal unless explicitly required for a service and legally permissible.

4. INDIVIDUAL PRIVACY RIGHTS

Depending on your jurisdiction and applicable law, you as a Data Subject may have certain rights regarding your Personal Data. These may include:

The right to be informed: About the collection and use of your Personal Data.
The right of access: To access your Personal Data.
The right to rectification: To have inaccurate Personal Data corrected.
The right to erasure (right to be forgotten): To have your Personal Data deleted.
The right to restrict processing: To limit the processing of your Personal Data.
The right to data portability: To receive your Personal Data in a portable format or have it transferred to another controller.
The right to object: To object to certain types of processing (e.g., direct marketing).
Rights in relation to automated decision making and profiling: To not be subject to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.
Right to withdraw consent: Where processing is based on consent, you have the right to withdraw consent at any time.
Right to non-discrimination: For exercising your privacy rights (e.g., under CCPA).

Mitte has procedures to support these rights. Requests will be addressed within the timescales stated in the applicable privacy legislation (typically one month, extendable in certain circumstances). If Mitte does not take action on your request, we will inform you of the reasons. We may request additional information to confirm your identity.

5. HOW WE COLLECT AND USE PERSONAL INFORMATION

Mitte collects Personal Information in the following ways:

Information You Provide Directly:
When you or the entity you represent registers for an account to use the Services (e.g., Validation Portal access for parking operators or their tenants), we collect information such as name, email address, phone number, and company name. Information required for billing purposes, such as billing address, may also be collected. However, Mitte does not directly collect or store full payment card information (e.g., credit card numbers). When payments are made for our Services, these are processed by third-party payment partners and processors, and your payment card information is provided directly to them under their terms and privacy policy.
When you use the Validation Portal to create, manage, or issue validations, you may input Personal Data related to those validations (e.g., vehicle identifiers, validation details, timestamps).
When you contact us with inquiries, for support, or provide feedback (e.g., via email to notices@joinmitte.com).
When you subscribe to newsletters or marketing communications.
Information Collected Automatically:
When you use our Services, we may automatically collect information about your device and usage of our Services, such as IP address, browser type, operating system, pages viewed, links clicked, and usage patterns (see Section 8 on Cookies).
Information from Third Parties:
We may receive information from our business clients (e.g., parking operators) who provide us with data necessary to set up and manage their accounts or integrate their systems with our Validation Portal.
If you integrate third-party services with your Mitte account, we may receive information from those services.

Mitte uses Personal Information for the following purposes:

To provide, operate, maintain, and improve our Services, including the Validation Portal.
To manage billing, invoicing, and set up user accounts.
To manage our client relationships and provide customer support.
To communicate with you, including responding to inquiries, sending service-related announcements, and providing information about our Services.
For marketing and promotional purposes, where permitted by law and with your consent where required.
To personalize your experience on our Services.
For security purposes, to prevent fraud and abuse, and to enforce our Terms of Use.
To comply with legal obligations and protect our legal rights.
For analytics and research to understand how our Services are used and to develop new products and features.

6. TYPES OF DATA WE PROCESS

The types of Personal Data we collect and process depend on your interaction with our Services:

Identity and Contact Data: Name, email address, phone number, postal address, username, company affiliation.
Validation Data (processed via the Validation Portal on behalf of our clients): Information input by users (e.g., tenants, operators) to create and manage parking validations. This may include vehicle license plate numbers, validation codes, timestamps of entry/exit, location data related to parking facilities, and potentially other identifiers related to the validated parking session. Our clients are primarily responsible for the Personal Data they instruct us to process through the Validation Portal.
Transaction and Billing Data: Details about services you (or the entity you represent) have purchased from us, records of such transactions (e.g., service purchased, transaction amount, date), and billing information (such as billing address and invoicing details). Full payment card information is collected and processed directly by our third-party payment processors and is not collected or stored by Mitte.
Technical and Usage Data: IP address, browser type, operating system, login data, page views, website navigation paths, information about how you use our Services.
Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.

We strive to protect your Data from unauthorized access, use, or disclosure using reasonable technical and organizational measures. However, no security measures are perfect or impenetrable.

7. LAWFULNESS OF DATA PROCESSING

Mitte processes Personal Data based on one or more of the following legal bases, depending on the context and applicable law:

Performance of a Contract: Where processing is necessary for the performance of a contract to which you (or the entity you represent) are a party, or to take steps at your request before entering into such a contract (e.g., providing the Validation Portal services as per our Service Agreement with a client).
Legitimate Interests: Where processing is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests (e.g., for improving our Services, security, fraud prevention, direct marketing to business contacts subject to opt-out rights).
Consent: Where you have given consent for us to process your Personal Data for one or more specific purposes (e.g., for certain marketing communications or use of non-essential cookies). You can withdraw your consent at any time.
Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject.
Vital Interests: In rare cases, where processing is necessary to protect your vital interests or those of another natural person.

8. COOKIES AND TRACKING TECHNOLOGIES

Mitte uses cookies and similar tracking technologies (e.g., web beacons, pixels) to collect information about your Browse activities over time and across different websites following your use of our Services. Cookies are small text files stored on your device.
We use cookies to:

Ensure our Services function properly.
Remember your preferences and settings.
Understand how our Services are used (analytics cookies).
Personalize your experience.
For marketing purposes (where applicable).

You can control cookies through your browser settings and other tools. Disabling certain cookies may affect the functionality of our Services. For more information, please refer to our [Link to separate Cookie Policy, if available, or add more detail here].

9. DATA SHARING AND DISCLOSURE

Mitte will not disclose your Personal Information except in the following circumstances:

With Your Consent: We may share information with your consent or at your direction.
Service Providers (Data Processors): We engage third-party service providers to perform functions on our behalf, such as hosting, data analysis, customer service, and marketing assistance. If you make a payment for our Services, your payment information is provided directly to our third-party payment processor, who processes your payment information according to their own privacy policy and security standards. These other service providers will have access to Personal Information needed to perform their functions for Mitte but are contractually obligated to protect it and use it only for the purposes for which it was disclosed by Mitte.
Business Clients: If you are using the Validation Portal as an authorized user of one of our business clients (e.g., a parking operator or their tenant), we share information related to your use of the portal with that client as necessary to provide the service to them.
Business Transfers: If Mitte is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your Personal Information may be transferred as part of that transaction.
Legal Requirements: We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to comply with legal obligations, protect and defend our rights or property, prevent fraud, act in urgent circumstances to protect the personal safety of users of the Services or the public, or protect against legal liability.
Aggregated or De-identified Data: We may share aggregated or de-identified information, which cannot reasonably be used to identify you, for various purposes including analytics and reporting.

10. DATA SECURITY

Mitte implements reasonable technical and organizational security measures designed to protect the Personal Information we process from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include access controls, encryption (where appropriate), and staff training.
However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

11. DATA RETENTION

Mitte will retain Personal Information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you or our client (e.g., for as long as an account is active).
Whether there is a legal obligation to which we are subject (e.g., certain laws require us to keep records for a certain period).
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

When Personal Information is no longer needed, we will securely delete or anonymize it.

12. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Mitte is based in the United States, and the Personal Information we collect is primarily processed in the United States. If you are accessing our Services from other regions (such as the EEA or UK), your Personal Information will be transferred to, stored, and processed in the United States and potentially other countries where our service providers are located.
These countries may have data protection laws that are different from the laws of your country. When we transfer Personal Information internationally, we will take steps to ensure that the information receives an adequate level of protection where it is processed, including by implementing appropriate safeguards such as Standard Contractual Clauses (SCCs) as approved by relevant authorities, or relying on an adequacy decision where applicable, or other legally permitted transfer mechanisms.

13. PRIVACY BY DESIGN

Mitte has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process Personal Data will be subject to due consideration of privacy issues, including the completion of data protection impact assessments (DPIAs) where required by law or best practice.

14. CONTRACTS INVOLVING THE PROCESSING OF PERSONAL DATA

Mitte will ensure that all relationships it enters into that involve the processing of Personal Data on its behalf (i.e., with Data Processors) are subject to a documented contract that includes the specific information and terms required by applicable data protection legislation (e.g., Data Processing Agreements - DPAs).

15. DATA PROTECTION OFFICER (DPO)

Under certain privacy laws (like GDPR), organizations may be required to appoint a Data Protection Officer (DPO) if they are a public authority, conduct large-scale systematic monitoring of individuals, or process special categories of data on a large scale.
Mitte will assess its obligations regarding the appointment of a DPO based on these criteria and applicable laws. If a DPO is required, Mitte will ensure appropriate appointment and will publish their contact details. For privacy-related inquiries, please use the contact details in Section 19.

16. YOUR CHOICES AND RIGHTS (ACCOUNT INFORMATION)

You may generally review, update, or correct your account information by logging into your account on the Services.
You have choices regarding the Personal Information you provide to us:

Marketing Communications: You can opt-out of receiving promotional emails from us by following the unsubscribe instructions in those emails or by contacting us. Even if you opt-out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
Cookies: You can manage your cookie preferences as described in Section 8.
Exercising Your Rights: To exercise any applicable privacy rights (see Section 4), please contact us using the details in Section 19.

17. CHILDREN'S PRIVACY

Our Services are not directed to individuals under the age of 18 (or the relevant age of majority in their jurisdiction). We do not knowingly collect Personal Information from children. If we become aware that we have inadvertently collected Personal Information from a child, we will take steps to delete such information promptly. If you are a parent or guardian and believe your child has provided us with Personal Information, please contact us.

18. AMENDMENTS

Mitte reserves the right to, at any time and from time to time, add to, change, update, or modify this Policy by posting such change, update, or modification on the Services and updating the "Last Updated" date. Your continued use of the Services after such amendments are posted signifies your acceptance of the revised Policy. We encourage you to review this Policy periodically. For material changes, we may provide more prominent notice as appropriate under the circumstances.

19. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Mitte Technologies Inc.
Email: notices@joinmitte.com
Website: www.joinmitte.com