It describes what information we hold, why we hold it and how we use it. This policy applies to anyone who uses our websites, www.whereismytransport.com (“Sites”), the “Collector” app (“Collector App”), and/or any application, website, plugin, feature or service provided by us in connection with the Sites and Collector App. We'll refer to the Sites, the Collector App, and any application, website, plugin, feature or service provided by us in connection with the Sites and Collector App together as the “App”.
We are WhereIsMyTransport Ltd, a company registered in the UK (together with its group companies from time to time “WIMT”, “we”, “our” or “us”). We're the data controller as defined by the General Data Protection Regulation and are registered with the Information Commissioner's Office (the UK data protection authority) under number ZA550766. If you have any questions about this policy or would like to contact our Data Protection Officer please contact us through the App or send an email to firstname.lastname@example.org
1. INFORMATION WE HOLD AND WHY?
We process three kinds of information: (1) information you provide, (2) information created when you use any features provided by WIMT’s apps or websites; and (3) information from other sources, as explained in more detail below.
2. Information you provide
When you use our App, or any features provided by WIMT’s apps or websites, you might provide us with: (1) personal information; (2) information as to places and preferences; and (3) information shared via direct communication.
2.1 Personal Information
When you install and use the Collector App we do not collect personal information such as your name or email address. To log onto the Collector App and use its functionality, you’re required to enter a four digit pin linked, which you will receive separately on signing a work agreement with WhereIsMyTransport. Furthermore, a device ID number is randomly generated each time you install the Collector App (see section 3 below).
2.2 Direct Communications
When you communicate with us (for example when you respond to in-App survey questions, report problems, raise queries etc.) we may receive information about the type of phone you're using, your service provider and, if you've enabled the location permissions in your device, the latitude and longitude of your location when you contact us. We use this information to fix problems in the App and to reply to your communications. We may also anonymise and analyse this data in aggregate to improve the App.
3. Information created when you use our App
Each time you install the Collector App, a device ID number is randomly generated. When you use our App, the following kinds of information are created, and this information is associated with your device ID. This device ID is used to pseudonymise the data we collect from you. We do not access any permanent device ID numbers.
3.1 Your Location
When using the Collector App, you’ll receive a notification and permission request for background location tracking. We use location tracking only when you start a route and stop tracking once you complete the route. We use this information to generate accurate public transport routes
3.2 Your Device
We do not collect any permanent device ID numbers, but we do collect information about the devices you use to access our App. This may include the type of computer or device you use, the device ID of the App on your device, the hardware model, operating system and versions, software, file names and versions, the preferred language, time zone settings, and device motion information. This information helps us to diagnose bugs and improve the App.
3.3 Your Usage
Each time you open the App, we collect information about how and when you use it (such as the time and date, searches in the App features and routes tracked, pages visited, app crashes, your IP address and other system activity). This information helps us to improve our App. For example, it helps us to fix bugs and learn which features our users find most helpful.
3.4 User Contributions
You, along with other users of the Collector App, upload information about public transport routes that you collect. This information will be linked to your profile and used to improve our understanding of the city’s public transport network as well as evaluate your performance. We are the sole owner of the resulting IP.
Cookies may be used to:
- 3.5.1 remember that you have used our website before, which allows us to identify the number of unique visitors we receive and to ensure that we have enough capacity for the number of users of the website. They may also be used to customise elements of the promotional layout and/or content of the relevant web pages; and
- 3.5.2. collect information about how you use the App so that we can improve the App and get feedback as to the utility of its features. Some of the cookies which may be used by our App are set by us and some are set by third-party analytics and crash/error-reporting companies as described in this policy. Most browsers automatically accept cookies but you can change your browser’s settings to prevent acceptance of cookies or to notify you each time a cookie is sent. By blocking or deleting cookies you may not be able to take full advantage of the App's features.
4. SUMMARY OF HOW WE USE YOUR INFORMATION
- 4.1 In summary, we use the information we collect to:
- 4.1.1 deliver and improve the services provided through our App;
- 4.1.2. improve our understanding of public transport networks
- 4.1.3. evaluate your performance
- 4.1.4. respond to your communications in relation to the App;
- 4.1.6. identify issues with the App’s operation, and provide crash reports with a view to resolving such issues;
- 4.1.7. improve the design, functionality and/or content of the App and make them more relevant to the user;
- 4.1.8. disclose to relevant authorities when required to do so by law or when, in our opinion, it is otherwise appropriate to do so in response to a request from a relevant authority.
5. WHO WE MAY SHARE INFORMATION WITH
- 5.1. To improve the App and enhance user experience, we may sometimes share information with third parties. To the extent possible, we pseudonymise (remove information that identifies you) and minimize the data we send to them.
- 5.1.1. Analytics Vendors: We may use third-party vendors to understand what you have tapped or clicked on the App. They receive information showing only that someone has tapped or used certain features in the App. They organise that information and give it back to us so that we can make improvements to the App.
- 5.1.2. Crash/Error Reporting Vendors: We may use third-party vendors to report on crashes you experience with the App and errors with our backend, so we can fix those.
- 5.1.3. Messaging Apps: If you decide to use certain sharing features in our App, then you may be sharing your information with those companies, depending on encryption policies used by the messaging company. If the messaging app company you choose uses end-to-end encryption, your location link cannot be used or intercepted by that messaging app company.
6. LEGAL BASIS FOR INFORMATION PROCESSING
- 6.1. We'll only process your personal information where we have a legal basis for doing so. Our legal basis to process your personal data includes processing that is:
- 6.1.1. necessary for our legitimate interests, which are:
(a) to research, develop, fix and provide new and tailored features for the App users;
(b) to provide on-trip support to users and to ensure that the App are secure for users;
(c) to verify users' identity to prevent fraudulent or unauthorised use of our services; and
(d) to prevent breaches of our terms and policies or to prevent harmful or illegal activity;
- 6.1.2 necessary for the performance of our contract with you;
- 6.1.3. necessary to comply with relevant legal and regulatory requirements; and
- 6.1.4 based on your consent (for example, where you provide us with marketing consents), which may be withdrawn at any time by contacting us at the email address specified below.
- 6.1.1. necessary for our legitimate interests, which are:
7. WHAT ARE YOUR RIGHTS IN RELATION TO PERSONAL DATA WE HOLD ABOUT YOU? (Subject to the specific Jurisdiction)
You have a legal right to request access to a copy of the personal information we hold about you. To do this, please contact us at email@example.com using the subject line “DSAR” and include details about what personal information you are looking for.
We store your personal information for as long as is necessary to provide our services and products. You have the right to request we delete your personal information if you believe that we no longer need it for the purposes for which it was provided, you wish to withdraw your consent (and we have no other lawful basis to use the data), or we are not using your information in a lawful matter. For legal reasons, we may not always be able to delete your information. If you ask us to delete your personal information by emailing us at firstname.lastname@example.org, please use the subject line “Data Deletion”. Note that residual copies may take longer to be removed from our backup systems which cannot be immediately overwritten. Where residual copies are still kept on our back-up systems, they are merely held on the system and are not used for any other purpose. We will keep a record of your request in order to ensure compliance with legal obligations.
7.3 Marketing opt-out
You have the right at any time to prevent the use of your personal information for direct marketing purposes. If you no longer want to receive marketing messages from us, please let us know by writing to us at email@example.com or clicking on the unsubscribe button at the bottom of marketing emails and you will be unsubscribed accordingly. Please note that sometimes it can take a short amount of time to refresh our records for these purposes. Also, we may still send you non-promotional, transactional messages, or information about your account.
We may send you information we think you may find useful or which you have requested from us by push notification and/or by email (if provided). You can opt-out of receiving certain notifications if you wish by having no route preferences selected.
8. HOW WE KEEP YOUR INFORMATION SECURE
The privacy of our users is of paramount importance to us and we use methods such as encryption, pseudonymisation, information access controls, and firewalls to protect information associated with our users. Please be aware that submission of information over the internet and mobile networks is never entirely secure, so we cannot guarantee the security of information you submit via the App whilst it is in transit over the internet or mobile networks and any such submission is at your own risk.
9. INFORMATION RECORDS
We create records that contain your information and manage these records to help us to serve our users well and to comply with legal and regulatory requirements. How long we keep records depends on the type of record, the nature of the activity, product or service and the applicable legal or regulatory requirements. How long we retain your information may change based on business or legal and regulatory requirements.
10. INFORMATION STORAGE
Certain Information that you submit via the App is sent to and stored on secure servers located in Europe. Information submitted by you may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above, which may be situated outside the European Economic Area (for instance in the United States).
11. YOUNG CHILDREN
If you're unhappy about the way we handle your data, please contact us by email at firstname.lastname@example.org.