Effective from 4 July 2007. Version 1.0

Introduction

The RingGo parking service ('RingGo' or 'the Service') is operated by Cobalt Telephone Technologies Ltd ('we', 'us' or 'our'). In order to operate the Service we ask you to provide us with personal information about yourself. Specifically, the information that we record when you first contact us will be re-used to minimise the time taken when you contact us, again.

This Privacy Policy describes the information we collect and how we use that information. We take the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy which applies to all services that are hosted on the any of our websites at www.RingGo.co.uk and www.MyRingGo.com ('the Website' or 'the Websites') or offered through our telephone or SMS text interfaces.

By accepting the Privacy Policy, and the Service Terms and Conditions as part of the registration process, you expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

Your privacy is important to us. If you object to your personal information being processed or transferred as described in this Privacy Policy, please do not register for nor use the Service.

What Personal Information Do We Collect?

Required Information

To open a RingGo account, you must provide details of at least one vehicle, specifically the registration number, the colour and make of the vehicle, also your phone number, and valid personal credit card or debit card information.

Transaction Information

When you use the Service to park, we ask you to provide information related to each session, comprising the location in which your vehicle is parked, the length of time you wish to park for and the vehicle that you are parking.

If you use a data network to access the service we also collect the Internet address (IP address) and other identifying information about the computer or device you use to access your RingGo account. Similarly if you use a telephone network we will collect the Calling Line Identity (CLI). In both cases this is in order to help identify your use and to detect possible instances of unauthorised transactions.

Information About You From Third Parties

In order to protect all our customers against potential fraud, we verify the information that you provide with bank processors. In the course of such verification, we receive personally identifiable information about you from such service providers. In particular, if you register a credit card or debit card with us to use the Service, we will use card authorisation and fraud screening services to verify that your card information matches other information that you may supply to us, and that the card has not been reported as lost or stolen.

Website Traffic Information

Because of the way that World Wide Web communication standards work, when you arrive at or leave the Websites, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Websites you visit while you are on the Websites, IP addresses, the type of browser that you use and the times that you access our Websites.

What Do We Use Personal Information For?

We collect, store and process your personal information on servers located in the United Kingdom. Our primary purpose in collecting personal information is to provide you with a smooth, efficient, and effective experience and to enable us to provide a payment facilitation service to the local authorities, public bodies and/or commercial organisations which make parking spaces available for use by motorists on a paid basis and/or levy charges or tolls relating to vehicle or road use ('Authority' or 'Authorities') . You agree that we may use your personal information to:

• allow us to provide the RingGo payment services;
• customise, measure, and improve our Service and the content and layout of our Websites, understand our customers' preferences better and to manage the load on our servers;
• tell you about targeted advertising, marketing, service updates and promotional offers from us and third parties, based on your communication preferences and in accordance with our policy on 'Communicating With RingGo Customers' set out in this Privacy Policy, below;
• allow those Authorities to which we provide payment facilitation services to provide, monitor, measure and improve the parking and vehicle and road use related services that they offer;
• compare information for accuracy and verify it with third parties;
• answer queries and troubleshoot problems;
• enforce our Service Terms and Conditions;
• collect fees;
• reduce the risk of and prevent fraud; and
• resolve disputes.

How Is Your Personal Information Shared?

Service Providers

We will disclose your personal information to service providers including, without limitation, payment processors, customer service outsourcing providers and parking industry service providers to allow us to provide the RingGo payment service.

Authorities

We will disclose your personal information to the Authorities to facilitate the provision and/or future provision of the RingGo payment services and where this is necessary for the purposes for which the personal information was collected.

Disclosure To Unrelated Third Parties

We will not sell or rent any of your personally identifiable information to unrelated third parties.

We may disclose aggregated statistical data for statistical or public relations purposes. For example, we may disclose that a specific percentage of our customers drive a red car. However, this aggregated information is not tied to personal information.

Disclosure Of Payment Details

Other than to those organisations directly involved in the processing of funds to your bank, your credit card number, bank account and other financial information will never be revealed to any third party except with your express permission or if we are required to do so pursuant to a court order or other legal process.

Disclosure Of Information In Response To The Requirements Of Civil Or Criminal Legal Process

We may disclose your personal information including, without limitation, transaction, account information, personal details and the contents of communications if we reasonably believe we are required to do so by (without limitation) the police, security forces, competent governmental, intergovernmental or supranational bodies, competent agencies, departments or regulatory, self-regulatory authorities or organisations or other third parties that we in good faith believe it is appropriate to cooperate with in relation to investigations of fraud or other illegal activity or potential illegal activity, or to conduct investigations of violations of our Service Terms and Conditions.

Our Use Of "Cookies"

"Cookies" are small files of data that reside on your computer and allow us to recognise you as a RingGo customer if you return to the Websites using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your RingGo account by entering your email address and password. These cookies allow us to recognise you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.

We also use longer-lasting cookies to display your phone number on our sign-in form, so that you don't have to retype the phone number each time when you log in to your RingGo account. We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our Websites.

Communicating With RingGo Customers

We communicate with our customers on a regular basis via email or SMS text to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your email address or mobile number to confirm your opening of a RingGo account, to optionally send you notice of payments that you make through RingGo, to send information about important changes to our products and services, and to send notices and other disclosures required by law.

We use your email address or mobile phone number to send you other types of text based communications that you can control, including:

• targeted advertising and marketing of services and promotional offers;
• service updates and security messages.

Authorities and third party service providers approved by us will also use your email address or mobile phone number to send you other types of text based communications that you can control, including:

• details of events occurring in localities in which you have used an Authority's parking or other vehicle or road use related services and security messages;
• targeted advertising and marketing of services, service updates, and promotional offers.

You will be asked specifically if you would like to opt in to each of these communications and can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account on the MyRingGo Website and changing your preferences. You will be given an opportunity to unsubscribe each time we communicate with you.

In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.

From time to time, we may offer optional questionnaires for the purposes of assessing customers' needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our customers in these questionnaires, you will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

Information Security

We are committed to handling your customer information with high standards of information security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfill their job responsibilities.

The security of your RingGo account also relies on your protection of your four digit RingGo PIN code. You may not share your RingGo PIN with anyone. If you do share your RingGo password with a third party for any reason, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your PIN. If you believe someone else has obtained access to your PIN, please change it immediately by logging in to your account on the MyRingGo Website and changing your Profile settings, and also contact us right away as described below.

We do not transfer your personal information to any country or territory outside the European Economic Area. Should we do so in future this Privacy Policy will be updated and your consent obtained as set out in the 'Notification of Changes to this Privacy Policy' section of this Privacy Policy, below.

Accessing And Changing Your Information

You have a right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. (We charge £10 for information requests.). Please contact the data protection team online or by writing to the Data Protection Officer, Cobalt Telephone Technologies Ltd, Intec 2, Wade Road, Basingstoke, Hampshire, RG24 8NE

You can review the personal information you provided us and make any desired changes to such information, or to the settings for your RingGo account, at any time by logging in to your account on the MyRingGo Website and changing your preferences in the Profile page of the "My Account" tab. We will ensure that any changes you make to your account details via our Websites will be updated on all systems on which your data may be held where it has been disclosed by us to third parties including to other Authorities under the provisions of this Privacy Policy.

Retaining Personal Information

We will retain your personal information (including information related to each parking session and for each of your transactions) for only so long as is necessary for the purposes for which the information was collected or as required for legal purposes.

If you close your RingGo account, we will mark your account in our database as "Closed," but will keep your account information in our database for a maximum of 3 years.

Under 18s

Children are not currently eligible to use the Service and we ask that minors (under the age of 18) do not submit any personal information to us or use the Service.

Links To Other Websites

Some pages on the Websites include links to third party websites. These sites are governed by their own privacy statements, and we are not responsible for their operations, including but not limited to their information practices. Customers submitting information to or through these third party websites should review the privacy statement of these sites before providing them with personally identifiable information.

Notification of Changes to this Privacy Policy

This Privacy Policy may be revised over time as new features are added to the Service or as we incorporate suggestions from our service providers or from customers of the Service. We may amend this Privacy Policy at any time by posting a revised version on our Websites. The revised version will be effective at the time we post it. In addition, if we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, we will provide you with at least 30 days' prior notice of such a change by posting notice on the "Policy Updates" pages of our Websites. After this 30 days notice, you will be considered as having expressly consented to all amendments to the Privacy Policy. If you disagree on how we will use your personal information, you may close your account at any time.

As stated above, we will post the amended Privacy Policy prominently on our Websites so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the Websites at any time for the most current version of our Privacy Policy.

Accountability and Contacting Us

For questions about how we use your data please contact us, in writing please, addressed to the Data Protection Officer, Cobalt Telephone Technologies, Intec 2, Wade Road, Basingstoke, Hampshire, RG24 8NE.