Lewis Management Corp. Automated License Plate Reader Usage and Privacy Policy

 

Version Date: May 2026

This Automated License Plate Reader (“ALPR”) Usage and Privacy Policy (“Policy”) describes how Lewis Management Corp., a Delaware corporation (“LMC”) uses ALPR technology to secure the parking facilities at and around the properties we manage in California (“Parking Facilities”). This Policy explains how we process ALPR information in accordance with California Civil Code § 1798.90.5, et seq.

What Is the ALPR System?

The ALPR System is a searchable computerized database that uses one or more fixed cameras combined with computer algorithms to read and convert images of registration plates and the characters they contain into computer-readable data. The information collected by the ALPR System (“ALPR Information”) includes still images of vehicles including the make and model, color, license plates, characters and numbers associated with the license plates, location, and the date and time when the images were collected. In some cases, the ALPR system may also capture your image.

Who Is Authorized To Use or Access the ALPR System?

a. Internal Access

We limit internal access to the ALPR Information to specific individuals who are authorized for such access and who have a legitimate business purpose for such access (“authorized personnel”). These authorized personnel include the following:

  • Select personnel who may use such ALPR Information in connection with detecting, investigating and preventing activities that may violate our policies, be illegal, or otherwise impact our rights and property and the rights and property of our guests and third parties;
  • Property managers and supervisors who oversee the operation of our Parking Facilities;
  • Legal and compliance personnel responsible for defending our rights, compliance with the law, and detecting and preventing fraud against you and/or us.

b. External Access

We will not sell, share, or transfer ALPR Information to a third party, except in limited circumstances, including:

  • To provide service providers with ALPR Information in connection with their performance of services on our behalf; however, these companies are prohibited from using ALPR Information for purposes other than those requested by us or required by law, and for internal research and development. The process for sharing ALPR Information with third-party service providers is governed by our contracts with such providers; and
  • To protect our rights and property and the rights and property of our guests and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.

Why Do We Collect and Use ALPR Information?

ALPR Information is accessed, used, and disclosed solely for the following purposes:

  • To detect and prevent shoplifting and other illegal activities;
  • To provide security for our parking facilities, or protect our rights;
  • To operate and troubleshoot the ALPR System, security cameras, and network video recorders;
  • To identify and track abandoned vehicles;
  • To identify stolen vehicles and report them to law enforcement; and
  • To otherwise cooperate with law enforcement agencies, government requests, subpoenas, court orders, or legal process.

We also may use ALPR Information to enforce our rights or as needed support for external auditing, compliance, and corporate governance functions.

How Are People Trained On How To Use The ALPR System?

We train authorized personnel who have a business reason to interact with ALPR Information on the sensitivity of ALPR Information and the procedures that we have put in place to protect it.

Training addresses legal requirements concerning access, use, and disclosure of ALPR Information, the ALPR System, and ALPR Information security measures.

How Do We Make Sure The ALPR Information Is Accurate?

We will take reasonable measures to ensure the accuracy of ALPR Information generated by the ALPR System but cannot guarantee 100% accuracy. When necessary, we will check to confirm that the plate characters matched by the ALPR System correspond with the digital image of the license plate in question. Further, when necessary, we will aim to correct mistaken translations and other database errors if those errors are identified and confirmed. We and our providers employ reasonable technical measures, including regular testing, to check the accuracy of ALPR Information.

How Will We Monitor And Secure The ALPR Information?

We will use operational, administrative, technical, and physical safeguards and procedural and personnel security measures to monitor and secure ALPR Information, and to protect ALPR Information from unauthorized access, use, modification, disclosure, or destruction. The Internet and our services are not 100% secure, however, so complete security of the ALPR system is not guaranteed.

Who Is The Official Custodian and Owner Of The ALPR Information And ALPR System?

The official custodian and owner of the ALPR Information and ALPR System is LMC.

How Long Do We Keep ALPR Information?

We retain ALPR Information for as long as necessary for the purposes listed above and regularly destroy ALPR Information when we determine its retention is no longer necessary, unless we are informed that we must retain the ALPR Information in accordance with legal process or to satisfy other legal obligations. In most cases, the ALPR Information is destroyed after 30 days.

How Will You Know If This Policy Has Changed?

We may update this Policy from time to time. Any changes to the Policy will take effect upon posting. We will display the “Version Date” when this Policy is updated.

For more information, contact us at ALPRinfo@lewismc.com.