Effective date: 1 January 2026

This Privacy Policy describes how PELAGUS IT d.o.o., Slovenia, together with its affiliated companies and authorised partners (“PELAGUS IT”, “we”, “us”, “our”), collects, uses and protects personal information on our websites (the “Site”) and in our mobile parking applications, including mobile parking payment services and related platforms operated under the 123 Park and EasyPark Mobile brands (together, the “Services”).

By accessing or using the Site or installing and using any of our mobile parking applications, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use our Services or provide us with your personal information.

This Privacy Policy applies to all personal information collected through the Site and our mobile parking applications, unless a different privacy notice is expressly provided. In certain cities or regions, local partners may provide first-level services or support under their own privacy notices, which will be made available where applicable.

Personally Identifiable Information Collected on the Site and in Our Mobile Applications

At PELAGUS IT, we respect and are committed to protecting your privacy. You may visit our Site without identifying yourself or providing any personal information, such as your name, address or phone number.

When you choose to interact with us, we may collect personal information that you provide directly, including:

• Contact details, such as your name, email address, postal address, telephone number and company/organization.
• Account and usage data related to our mobile parking applications (including city-branded applications and websites), such as username, mobile number, vehicle identification (e.g. license plate), parking location, duration and other parking session details.
• Payment information related to mobile parking fees payment services, such as transaction amount, time and payment method. We do not store your full credit/debit card details on our systems; payments are processed exclusively through PCI DSS–certified payment service providers or integrations.
• Professional information that you submit when applying for a job or contacting us in a business context, such as your résumé/CV, work experience and qualifications.
• Optional demographic or preference information (for example, your role, interests or language preferences) that you choose to provide in forms, surveys or communications with us.

We may also collect certain information automatically when you use the Site or our mobile parking applications, such as your IP address, device identifiers, browser type, operating system, access times and pages viewed, which we use for security, troubleshooting, analytics and to improve our Services and user experience.

Use of Personal Information

We use the personal information we collect for the following purposes:

• To provide and operate our Services
  Including creating and managing user accounts, enabling and managing parking sessions, processing mobile parking fees, maintaining the functionality and security of our websites and mobile parking applications, and coordination with authorised local partners where required for service delivery or support.
• To process payments
  To handle payments for parking and related services through our PCI DSS–certified payment service providers or integrations, and to maintain records of transactions. We do not store your full credit or debit card details on our systems.
• To communicate with you
  To respond to your inquiries, provide customer support, send service-related notices (such as confirmations, technical notices, updates, security alerts), and manage your relationship with us or our authorised partners acting on our behalf.
• To manage business relationships and recruitment
  To evaluate job applications, manage recruitment processes, and communicate with you in a professional or business context if you contact us as a partner, supplier or client.
• To improve and develop our Services
  To analyse usage patterns and performance, troubleshoot issues, conduct research, and improve the functionality, security and user experience of our websites and mobile parking applications.
• For legal, security and compliance purposes
  To comply with applicable laws and regulations, to protect our rights and property, to enforce our terms and agreements, and to help ensure the safety of our users and the public.

We use your personal information primarily for our internal purposes and in connection with providing and improving our Services. We do not sell or disclose your personal information to third parties for their own marketing or solicitation purposes without your prior consent.

Legal Bases for Processing
Depending on the specific context, we process your personal information on one or more of the following legal bases: (i) performance of a contract with you (for example, to provide our mobile parking services); (ii) compliance with legal obligations; (iii) our legitimate interests in operating, securing and improving our Services and communicating with you; and (iv) your consent where required.

Disclosure and Sharing of Personal Information

We may share your personal information only as described in this Privacy Policy and primarily in connection with providing and improving our Services:

• Service providers and processors
  We may engage third-party companies to perform services on our behalf, such as hosting, payment processing, customer support, analytics, email delivery or IT security. These service providers receive only the personal information necessary to perform their services and are contractually required to keep it confidential and to use it solely for our documented purposes.
• Affiliates and partners
  Where necessary, we may share personal information with our affiliates or business partners involved in delivering or supporting our Services, such as local implementation and support partners for city parking systems, subject to appropriate confidentiality and data protection obligations. Where personal information is transferred to countries outside the European Union/European Economic Area that may not provide the same level of data protection, we take appropriate safeguards, such as implementing standard contractual clauses or other lawful transfer mechanisms, to ensure that your personal information remains protected.
• Legal and safety-related disclosures
  We may access, preserve and disclose your personal information if we believe in good faith that such action is reasonably necessary to: comply with applicable laws, regulations, legal process or enforceable governmental requests; protect and defend the rights, property or safety of PELAGUS IT, our users or the public; or investigate, prevent or take action regarding suspected or actual illegal activities, security incidents or technical issues.
• Business transfers
  In the context of a merger, acquisition, reorganisation, sale of assets or similar corporate transaction, your personal information may be transferred to the relevant third parties, subject to appropriate confidentiality safeguards and, where required, notice or additional consent.

We do not sell your personal information or disclose it to third parties for their own independent marketing or solicitation purposes without your prior consent.

Cookies and Similar Technologies

Our Site may use cookies and similar technologies (such as local storage or SDKs in our mobile applications) to help operate and improve our Services.

Cookies are small text files placed on your device that allow the Site to recognise your browser on return visits and to collect certain non-personal information about how you use our Services. This helps us, for example, to:

• remember your preferences and settings;
• understand which areas of the Site are most interesting or useful;
• improve the functionality, performance and security of our Services.

We do not use cookies to obtain your name or directly identify you, and the information collected through cookies is used primarily for internal purposes. This information may be shared only with our affiliates and service providers who assist us in operating, analysing and improving our Services and who are bound by confidentiality and data protection obligations.

Most web browsers allow you to view, manage and delete cookies and to set your browser to notify you when you receive a cookie or to reject cookies altogether. If you choose to refuse or delete cookies, you will still be able to access most areas of the Site, although some features may function with reduced convenience or performance.

External Links

Our Site and mobile parking applications may contain links to third-party websites, services or content that are not operated or controlled by PELAGUS IT. If you follow such links, you will leave our environment and may provide information directly to third parties.

We are not responsible for the privacy practices, security or content of these third-party websites or services. They may use their own cookies or other tracking technologies and collect personal information in accordance with their own privacy policies.

We encourage you to review the privacy policies of any third-party websites or services you visit before providing them with your personal information.

Children’s Privacy

Our Sites and mobile parking applications are intended for use by individuals 16 years of age or older. We do not knowingly solicit or collect personal information from anyone under the age of 16.

If we become aware that we have collected personal information from an individual who is under 16, we will take reasonable steps to delete such information from our records as soon as practicable.

If you are a parent or legal guardian and believe that your child under 16 has provided personal information to us, please contact us so that we can review and, if appropriate, delete the information.

Security of Your Personal Information

PELAGUS IT maintains appropriate physical, electronic and organisational safeguards to help protect your personal information from loss, misuse, and unauthorised access, disclosure, alteration or destruction.

We take, among others, the following measures:

• restrict access to personal information to those employees, contractors and service providers who need it to perform their duties and who are bound by confidentiality and data protection obligations;
• store personal information on systems with limited access in controlled environments;
• use appropriate technical measures (such as encryption and secure communication protocols) to protect personal information in transit and at rest where reasonable and appropriate;
• process payments only through PCI DSS–certified payment service providers or integrations and do not store your full credit or debit card details on our systems.

We regularly review and enhance our security measures to keep your personal information protected in line with industry standards and the sensitivity of the data we process.

Storage of Your Personal Information

We store your personal information on computer systems with limited access in controlled environments, designed to protect it against unauthorised access, use or disclosure. Where appropriate, we use encrypted storage or logical separation of data according to the nature and sensitivity of the information.

We retain personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy, to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements. After the applicable retention period has expired, we will delete or anonymise your personal information in accordance with our data retention procedures.

Access to and Management of Your Personal Information

You may review, update or correct the personal information you have provided to us through the relevant features of our mobile parking applications or the Site, or by contacting us using the details below. In certain circumstances and subject to applicable data protection laws, you may also have the right to: request access to your personal information; request rectification or update of inaccurate or incomplete information; request deletion of your personal information; withdraw consent where processing is based on your consent.

We will respond to your requests in accordance with applicable laws. In some cases, we may need to retain certain information for legal or contractual reasons, or to complete ongoing transactions. Requests relating to services operated in cooperation with local partners may, where appropriate, be coordinated with the relevant partner to ensure accurate and timely handling.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time, for example to reflect changes in our Services, applicable laws or technical developments. When we make material changes, we will update the effective date at the top of this page and, where appropriate, provide additional notice (such as a notice on the Site or in our mobile parking applications).

Your continued use of our Services after the updated Privacy Policy has been made available signifies your acknowledgement of the changes. We encourage you to review this Privacy Policy periodically.

Contacting Us

If you have any questions, concerns or requests regarding this Privacy Policy or our handling of your personal information, please contact us using the contact details provided on our Contact page on the Site or via the contact information indicated in our corporate communications.

We welcome your questions, feedback and suggestions regarding privacy and data protection.