ALPR

THE PROMENADE SHOPS AT ORCHARD VALLEY

Automated License Plate Recognition (ALPR)

Usage and Privacy Policy

Adopted under California Civil Code sections 1798.90.5 through 1798.90.55

Last Reviewed: September 30, 2026

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Introduction and Scope

Orchard Valley Partners, LLC (“Owner”), together with its manager, Grupe Huber Company (“Manager”), owns and operates a private video surveillance system at the shopping center commonly known as The Promenade Shops at Orchard Valley in Manteca, California (the “Property”). A limited number of cameras at the Property have automated license plate recognition (“ALPR”) capability. JLL serves as the Property’s third-party property manager, and Calidad Services, Inc. (“Calidad”) provides on-site security, remote monitoring, and system service at the Property.

This Usage and Privacy Policy (this “Policy”) governs the collection, use, maintenance, sharing, dissemination, retention, and destruction of ALPR information at the Property. It is adopted to satisfy California Civil Code sections 1798.90.51 and 1798.90.53 and to ensure that the Property’s use of ALPR technology is consistent with respect for individual privacy and civil liberties.

This Policy applies to Owner, Manager, JLL, Calidad, and every employee, agent, contractor, vendor, and security provider who operates, accesses, or uses the ALPR system at the Property. It does not apply to non-ALPR video surveillance cameras at the Property.

This Policy is available to the public in writing upon request and is posted conspicuously on the Property website, www.thepromenadeshopsatorchardvalley.com.

Definitions

The following terms have the meanings given in California Civil Code section 1798.90.5:

“ALPR system” means a searchable computerized database resulting from the operation of one or more cameras that capture license plate images and convert them into machine-readable, searchable data.
“ALPR information” means information or data collected through the use of an ALPR system, including plate characters and the associated date, time, and camera location.
“ALPR operator” means a person or entity that operates an ALPR system; “ALPR end-user” means a person or entity that accesses or uses an ALPR system.

For purposes of this Policy, Owner and Manager act as both ALPR operator and ALPR end-user. JLL and Calidad access the ALPR system on Owner’s behalf, only as described in Section 5, and must follow this Policy.

Authorized Purposes for Collection and Use

ALPR information is collected and used at the Property solely for on-site security and property protection. The authorized purposes are limited to the following:

Deterring, detecting, documenting, and investigating criminal activity occurring at or affecting the Property, including vehicle theft, theft from vehicles, burglary, robbery, retail theft, vandalism, arson, and trespass.
Investigating incidents occurring at the Property, including collisions, property damage, personal injury, and other events that are or may become the subject of a claim.
Responding to a lawful, incident-specific request from a law enforcement agency relating to an event occurring at or connected to the Property, in accordance with Section 7 below.
Identifying and addressing abandoned, disabled, or unauthorized vehicles and enforcing posted parking rules at the Property.
Protecting the safety and security of tenants, their employees and customers, and other invitees at the Property.

ALPR information is collected only from vehicles entering, exiting, or parked within the Property. The system does not collect ALPR information from public streets or from any location off the Property.

Prohibited Uses

ALPR information collected at the Property shall not be:

Sold, rented, traded, leased, or licensed to any person or entity.
Uploaded, contributed, or made available to any public, shared, regional, or commercial license plate database, camera-sharing network, or data broker.
Used for marketing, advertising, consumer profiling, audience measurement, foot-traffic analytics, or any other commercial purpose unrelated to security at the Property.
Used to track the movements of any individual outside the Property, or to aggregate an individual’s travel patterns over time.
Used for any purpose that involves discrimination or targeting based on a protected characteristic under California or federal law.
Used for any personal, non-business purpose, including curiosity, harassment, stalking, or monitoring of any person known to the user.

Any use of ALPR information not expressly authorized by Section 3 is prohibited. Violation of this Section by an employee is grounds for discipline up to and including termination; violation by a contractor or vendor is grounds for immediate termination of the engagement and referral to law enforcement where warranted.

Authorized Personnel and Training Requirements

Access to the ALPR system and to ALPR information is restricted to individuals holding the following positions, and only as necessary to carry out an authorized purpose under Section 3:

Chief Operating Officer, Grupe Huber Company (Custodian).
Senior Vice President/Principal, Grupe Huber Company.
Director of Property Management, Grupe Huber Company.
Property Manager assigned to the Property by JLL.
Calidad on-site security officers, solely while on duty at the Property.
Calidad remote monitoring personnel, solely to monitor the Property during hours when on-site security officers are not present.
Calidad service technicians, solely for installation, configuration, maintenance, and repair, and only under the supervision or written authorization of the Custodian.

No tenant, tenant employee, member of the public, or other third party is permitted to access the ALPR system or ALPR information.

Training requirements

Before being granted access, each authorized individual must complete training covering: (a) the requirements of California Civil Code sections 1798.90.5 through 1798.90.55; (b) the terms of this Policy, including authorized purposes and prohibited uses; (c) proper handling and non-disclosure of ALPR information; and (d) the consequences of misuse. Training is refreshed when this Policy is materially amended. Each individual must sign a written acknowledgment of this Policy, which the Custodian retains for the duration of the individual’s access and for two (2) years thereafter.

Monitoring, Auditing, and Compliance

The ALPR system is monitored for security and compliance with this Policy as follows:

ALPR information is stored on a locally hosted system at the Property. Remote access is available only to the authorized individuals listed in Section 5, using their own login credentials. The system is not integrated with, and does not send ALPR information to, any external, shared, regional, or public database or camera network.
Each authorized individual is assigned unique login credentials. Shared or generic accounts are prohibited. Permissions are assigned on a least-privilege, role-based basis.
Each access to and query of ALPR information is logged (see Section 12).
The Custodian periodically reviews access logs to confirm that access was for an authorized purpose by an authorized individual, and documents each review.
The Custodian conducts a periodic system audit, covering user accounts and permissions, retention and deletion settings, disclosure records, training records, physical and technical security, and vendor compliance. Audit findings and remediation are documented in writing.
Credentials are revoked promptly upon separation, reassignment, or termination of a vendor engagement.
Any suspected unauthorized access, use, or disclosure of ALPR information must be reported to the Custodian immediately and is investigated, documented, and remediated.

Sale, Sharing, and Transfer of ALPR Information

ALPR information collected at the Property is never sold, rented, traded, leased, or licensed. It is not shared with data brokers, marketers, camera-sharing networks, or any commercial aggregator, and it is not uploaded to any external searchable database. The system is not connected to any multi-property or multi-jurisdiction network.

ALPR information may be disclosed only in the following limited circumstances, and only to the extent necessary:

Legal process. In response to a valid search warrant, subpoena, court order, or other lawful compulsory process, subject to review by counsel.
Incident-specific law enforcement requests. To a law enforcement agency upon a written request that identifies the requesting agency and officer, the specific incident or case number, the reason the information is sought, and a defined date, time, and location range. Each request must be approved in advance by the Custodian (or a designee authorized by the Custodian). Blanket, standing, bulk, or open-ended requests are denied. No law enforcement agency is granted direct, remote, or self-service access to the system.
Claims and litigation. To Owner’s or Manager’s legal counsel, insurance carrier, claims administrator, or retained expert in connection with an actual or reasonably anticipated claim, in each case subject to an obligation of confidentiality.
Service providers. To Calidad, solely as necessary to monitor the Property and maintain the system as described in Section 5, under a written agreement prohibiting any secondary use, retention, or disclosure.
As otherwise required by law.

The Custodian maintains a written record of every disclosure, including the date, the recipient, the incident or matter, the scope of information disclosed, the legal basis, and the approver. Disclosure records are retained for two (2) years.

Official Custodian

The official custodian and owner of the ALPR system and ALPR information for purposes of California Civil Code sections 1798.90.51(b)(2)(E) and 1798.90.53(b)(2)(E) is the Chief Operating Officer of Grupe Huber Company (the “Custodian”). The Custodian is responsible for implementing this Policy, approving and revoking access, approving disclosures, conducting reviews and audits, and responding to inquiries and complaints.

Questions and requests may be directed to the Property Manager, who will forward them to the Custodian:

Brian Bettencourt, Property Manager (JLL)

The Promenade Shops at Orchard Valley

209-601-8445 | brian.bettencourt@am.jll.com

Written requests may also be mailed to:

Chief Operating Officer (ALPR Custodian)

Grupe Huber Company

1203 N. Grant Street, Stockton, California 95202

Accuracy of ALPR Information and Correction of Errors

ALPR reads are generated automatically and may contain errors. Owner and Manager use the following reasonable measures to ensure accuracy and correct errors:

Every ALPR read is stored together with the corresponding camera image, and no ALPR read is treated as accurate or relied upon without visual verification of the underlying image by an authorized individual.
No action adverse to any person or vehicle is taken on the basis of an ALPR read alone.
Cameras are inspected and serviced by Calidad at least annually, including verification of image quality, focus, positioning, lighting, and read accuracy.
When an error is identified, the record is corrected, annotated, or deleted, and any downstream use is corrected.

Any individual may submit a written request to the Custodian to review, correct, or delete an ALPR record they believe is inaccurate or pertains to them. Requests should include the license plate number and the date, time, and location. The Custodian will respond within a reasonable time.

Retention and Destruction

ALPR information is retained for no more than thirty (30) days from the date of capture. The system is configured to delete or overwrite ALPR information automatically at the end of that period.

A specific record may be preserved beyond the standard retention period where the Custodian determines in writing that the record is:

relevant to a specific, documented security or criminal incident at the Property that is under active investigation;
responsive to a lawful preservation request, subpoena, warrant, or court order;
subject to a litigation hold or relevant to a pending or reasonably anticipated claim; or
necessary to a pending insurance claim or coverage determination.

Preserved records are segregated, access restricted, and logged. The Custodian reviews preserved records periodically and destroys them once the underlying matter concludes and no legal obligation requires further retention. ALPR information is not retained indefinitely.

Security Procedures and Practices

Owner and Manager maintain reasonable operational, administrative, technical, and physical safeguards to protect ALPR information from unauthorized access, destruction, use, modification, or disclosure, including:

Storage on a private, locally hosted system at the Property that is not publicly accessible, with remote access limited as described in Section 6.
Access limited to the positions listed in Section 5, unique credentials, least-privilege permissions, and prompt revocation upon separation or reassignment.
Technical controls appropriate to the system (password requirements, network segmentation, and current firmware and software updates).
Physical security of recording equipment in a locked area with limited access.
Written agreements with any vendor that has access, requiring confidentiality, prohibition on secondary use, security measures, breach notification, and secure destruction or return of ALPR information upon termination.

Records of Access

In accordance with California Civil Code section 1798.90.52, each access to or query of ALPR information is recorded. Each access record includes:

the date and time the information was accessed;
the license plate number or other data elements used to query the system;
the username of the person accessing the information and, as applicable, that person’s organization or affiliation; and
the purpose for accessing the information.

Access records are retained for two (2) years and are reviewed by the Custodian as described in Section 6. ALPR information may be used only for the authorized purposes described in Section 3.

Public Notice and Availability of This Policy

Owner and Manager provide notice of the Property’s use of ALPR technology as follows:

Signage is posted at each vehicular entrance to the Property, advising that the Property uses video surveillance and recording.
This Policy is posted conspicuously on the Property website, www.thepromenadeshopsatorchardvalley.com, and is reachable from a link in the footer of every page.
A printed copy of this Policy is available at no charge upon written request to the Custodian and is maintained at Manager’s office at 1203 N. Grant Street, Stockton, California 95202.

Questions, Requests, and Complaints

Questions, requests relating to ALPR information, and complaints may be directed to the Custodian using the contact information in Section 8. The Custodian will respond within a reasonable time. Complaints and any corrective action are documented and retained for two (2) years.

Review and Amendment

The Custodian reviews this Policy at least annually and whenever there is a material change to the ALPR system, the vendor, applicable law, or the Property’s use of the technology. Amendments take effect upon posting, and the “Last Reviewed” date is updated. Prior versions are retained by the Custodian.

Adopted by Orchard Valley Partners, LLC and Grupe Huber Company.