AUTOMATED LICENSE PLATE RECOGNITION (ALPR) USAGE

AND PRIVACY POLICY

Nordic Security Services (“NSS”) collects data through the operation of automated license plate readers at one or more locations serviced by NSS. When in operation, these readers may automatically collect information from license plates, as well as record the location/date/time the information is collected (“ALPR Information”). Encrypted ALPR Information is transmitted to a searchable database of information (“ALPR System”). This Policy is adopted and implemented by NSS in compliance with California Civil Code sections 1798.90.51, et seq.

Purpose and Scope:

The purpose of this Policy is to ensure the collection, access and use of ALPR Information is done in a manner that is consistent with respect for individuals’ privacy and civil liberties, and to comply with the provisions of California Civil Code sections 1798.90.51, et seq. This Policy is available to members of the public through our website at www.nordicsec.com.

NSS controls the ALPR System, and may access and use the ALPR System for lawful purposes, including but not limited to: (i) Enforcing applicable parking rules and regulations; (ii) To cooperate with and/or respond to inquiries from law enforcement agencies, other governing agencies, subpoenas, court orders, or other legal processes.

Custodian/Owner of ALPR Information:

NSS clients are the owners of their respective ALPR Systems.

The following entity is the official custodian and operator of the ALPR Information and ALPR System, and is responsible for implementing this ALPR Usage and Privacy Policy:

Dansk Enterprises, Inc., dba Nordic Security Services

3001 Redhill Avenue

Building 6-105

Costa Mesa, CA 92626

The Director of Security of NSS shall be responsible for monitoring access to and use of the ALPR Information and ALPR System to ensure the security of the information and compliance with this Policy, as well as the correction of any data errors of which he/she becomes aware.

Training and Access:

APLR operators from NSS who collect ALPR Information undergo training regarding the requirements of this Policy.

The only individuals who have access and ability to query data in the ALPR System and retrieve ALPR Information are:

Director of Security

Post Commander

NSS Administration

All log-ins and queries will be stored and monitored including:

1. Username

2. Date

3. Time

4. Purpose of query

5. License plate and other elements used to query the ALPR System

This information will be stored and monitored by the Director of Security of NSS, who will also run periodic audits to ensure access was may only by authorized persons for legitimate business purposes. NSS utilizes safeguards to protect ALPR Information from unauthorized access, use, destruction, modification or disclosure by requiring Username and Password protected access to the APLR System, properly training those employees and/or authorized agents who access the APLR System and APLR Information, providing secure store of computers with access to the APLR databases, and regularly monitoring the access and use of the APLR System and APLR Information.

Data Retention:

License plates will be stored for no longer than 45 days and will be automatically purged from the ALPR System upon expiration of this period, unless it is involved in a citation or enforcement action, open lawsuit, a law enforcement ongoing investigation, to be used as evidence in any action, or as required by a court order.

Privacy:

ALPR Information will not be sold, published, exchanged, or disclosed for commercial purposes; disclosed or published without authorization; disseminated to persons not authorized to access or use the information.

This Policy governs the ALPR System operated by NSS, and it applies to NSS employees and authorized agents. The images stored in the ALPR System are only collected from areas visible to the public where there is no reasonable expectation of privacy. License plate image and affiliated date will be purged after a 45 day period.

This Policy may be revised from time to time. Changes to this Policy will be posted on the NSS website, will take effect upon posting, and will apply to all ALPR Information regardless of when collected, to the extent permitted by applicable law.