Friedman’s Home Improvement (“Friedman’s,” “we,” “us” or “our”) may use a camera system provided by a third-party service provider, Flock Safety, at our retail store locations in the City of Sonoma and City of Santa Rosa in California. Friedman’s believes it is not subject to California’s Civil Code § 1798.90.5 et seq. regarding ALPR end-users because Friedman’s is obtaining any potential ALPR data pursuant to one or more permissible uses under the Driver’s Privacy Protection Act 18 U.S.C. § 2721 et seq. (collectively, “DPPA”). However, in an abundance of caution, Friedman’s is issuing this ALPR Usage and Privacy Policy (“Policy”) in the event a court determines that the statute applies. 

This Policy is intended to comply with California’s Civil Code § 1798.90.5 et seq (“California ALPR Statute”) even though Friedman’s believes it is not an ALPR end-user or operator subject to this statute.

For purposes of this Policy, the California ALPR Statute defines the following terms:

• “ALPR System” is defined as “a searchable computerized database resulting from the operation of one or more mobile or fixed cameras combined with computer algorithms to read and convert images of registration plates and the characters they contain into computer-readable data.” 
• “ALPR Information” is defined as “information or data collected through the use of an ALPR System.”

Friedman’s may access and use ALPR Information, if any, solely for the following permissible purposes under the DPPA: 

• In connection with any civil or criminal theft proceedings, including investigations of potential theft, shoplifting, organized retail crime, burglary, vandalism, trespassing, and other criminal activity where civil or criminal litigation is anticipated; 
• In connection with matters of motor vehicle or driver safety and theft (e.g., stolen cars or stolen license plates); or
• As authorized by applicable state law related to public safety (e.g., supporting the recovery of missing or endangered persons, including AMBER Alerts). 

The following job titles are authorized to access and use the ALPR System:

• Safety & Assets Protection Manager;
• Assets Protection Specialist;
• Authorized store management at the store locations in the City of Sonoma and City of Santa Rosa in California; and
• Technology administrators, solely in an administrative capacity for the limited purpose of adding or removing authorized managers, with all such administrative actions requiring prior approval from the Safety & Assets Protection Manager.

Of these job titles, the Safety & Assets Protection Manager is the designated official custodian of the ALPR Information, if any, responsible for implementing this Policy, and is also responsible for monitoring access, use and conducting periodic system audits, which consist of review of use and access quarterly. 

All authorized individuals employed by Friedman’s must complete Flock’s approved training or in-person training with an already trained authorized manager before using or accessing ALPR Information. 

Friedman’s does not sell or transfer ALPR Information to other persons. Friedman’s may share ALPR Information in conjunction with the DPPA permissible purposes set forth above, to comply with laws and regulations, and to satisfy other legal requirements. Friedman’s will consult with outside counsel to determine required compliance with any applicable privacy laws. 

Friedman’s relies on photographic images to confirm the accuracy of any ALPR Information that may be used. To Friedman’s knowledge, no data errors have occurred. 

Friedman’s has been advised by Flock that any ALPR Information is retained for only thirty (30) days from the date that Flock first collects it. Friedman’s may in its discretion retain ALPR Information for DPPA permissible purposes or to comply with legal processes or to satisfy other legal requirements. Flock is responsible for destroying ALPR Information as the ALPR operator.  

Friedman’s may modify or update this Policy by posting the updated Policy on Friedman’s website.