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Privacy Policy (Platform)

Who are we, and what is our approach to privacy?

We work with transport operators and other partners ("Online Partners") to provide passenger demand analytics and to personalise their communications with passengers, either through their own web/mobile sites and Apps, email, interactive kiosks or on third party messaging services ("Partner Services"). We do this through a platform that we make available to our Online Partners that analyses current and predicted passenger demand on transport networks, and delivers personalised journey information through our clients’ online or offline channels (the"Zipabout Service").

When we collect and use personal information through Partner Services, we do so both on the instructions of the relevant Online Partners, in order to provide them with the Zipabout Service, and for our own purposes. For instance, we aggregate information from a number of Partner Services to improve the accuracy of the Zipabout Service. This Privacy Policy sets out how we use your personal information in this way.

You should also, however, ensure that you read the privacy notice or policy applicable to any Partner Service you access to understand how your personal information may be used by the relevant Online Partner when they use the Zipabout Service.

If you have any questions about this Privacy Policy or how we use your personal information, please contact us using the details at the end of this Privacy Policy.

Who is responsible for the use of your personal information?

Zipabout Local Limited determines and is responsible for the uses of your personal information described in this Privacy Policy, meaning that we will be the controller of your personal information when we use it in these instances.

The Online Partner whose Partner Service you access determines and is responsible for how we use your personal information when we do so on their instructions when providing them with the Zipabout Service, meaning that they will be the controller of your personal information in those instances.

How we collect personal information

Depending on the type of device you use to access the relevant Partner Service, we will use browser cookies, pixels, web beacons, and SDKs to collect information about how you interact with the Partner Services. These technologies automatically collect the transport information you view when you use the Partner Services.

The information collected through the relevant Partner Service will be associated with a unique identifier linked to the device you use to access the Partner Service. This identifier consists of a string of technical and random characters identifying your device.

If you do not opt in to receiving personalised journey information, this identifier will only be used when aggregating usage data in relation to a Partner Service to help improve the accuracy of that aggregated data (for instance, to avoid counting the same person twice when predicting passenger numbers).

If you do opt in to receiving personalised journey information, we will also associate this identifier with an ID linked to the messaging system through which you decide to receive personalised messages (such as an ID associated with your account on the applicable messaging platform such as Messenger or WhatsApp, or your phone number for SMS messaging). We may also use this ID to link information you send to us and the relevant Online Partner through these messaging services with information collected through the Partner Service itself.

Personal information we collect and how we use it

When you use a Partner Service, we collect the following information about the features you use, the pages you view on the Partner Service and how you interact with the Partner Service:

  • Intended journey. We will collect information relating to the journeys that you plan or the transport services that you monitor through the Partner Service, including intended start and end points for your journey or journeys, and the time and date of travel.
  • Journey bookings. Where applicable, we will collect information about journeys you have booked through a Partner Service, including the details of your journey or journeys, and the booked time and date of travel.
  • Specific journey intent. Where you have opted in to receiving personalised journey information through a Partner Service, we will also collect the content of responses you give to the Online Partner regarding the specific journey you are looking to make and whether you make that journey on a regular basis.
  • Crowding information. Where you have agreed to provide further information to the Online Partner about your journey, we will collect the responses you give, such as whether your journey was busy or crowded, or your reason for travel.
  • Offers and discounts. Where you have agreed to receive and/or redeem an offer or discount (“Offer”), for example a travel or retail discount from one of our Online Partners related to your journey, we will collect information about your interactions with this Offer, such as the date/time and location of the redemption, and details of any additional purchases made related to the Offer.

We aggregate the above information and combine it across the various Partner Services integrated with the Zipabout Service, so that it can no longer be used to identify you. We will use this information to provide more accurate estimates of predicted passenger numbers and crowding across the transport network, and we may share such anonymised and aggregated information with our Online Partners and public sector agencies. We may also share this aggregated and anonymised information with analytics partners (such as Google Analytics and Facebook) for the purpose of understanding and improving the user experience of the Zipabout Service.

When using certain features of the Zipabout Service, we license various third-party services to provide functionality (e.g. location lookup and maps). Your usage of these services may be subject to the following additional terms:

  • Location auto-complete and maps (where identified as ‘powered by Google’) is powered by the Google Maps API, and is subject to Google’s Terms of Service and Privacy Policy.

These processing operations are necessary for our legitimate interests, namely the improvement of the accuracy and quality of the Zipabout Service and the calculation and provision of aggregated transport demand information to our Online Partners and public sector agencies.

How long we store your personal information

The processing operations we undertake for our own purposes in respect of your personal information are limited to anonymising and aggregating that personal information. Once this is done, the resulting information cannot be used to identify you.

Our Online Partners may, however, ask us to store your personal information on their behalf for longer. Please refer to the privacy notice for the Partner Service you access to find out how long the relevant Online Partner may store your personal information.

Recipients of your personal information

We may share personal information with companies owned by or under common ownership with Zipabout, including our subsidiaries (i.e., any organisation we own or control) and our ultimate holding company (i.e., any organisation that owns or controls us) and any subsidiaries it owns. These companies may use your personal information in the same way as described under this Privacy Policy.

Your rights in respect of your personal information

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:   

Right of access.

You have the right to obtain

  • (i) confirmation of whether, and where, we are processing your personal information;
  • (ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
  • (iii) information about the categories of recipients with whom we may share your personal information; and
  • (iv) a copy of the personal information we hold about you.
Right of portability

You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

Right to rectification.

You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

Right to erasure.

You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

Right to restriction.

You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

Please note that, in order to exercise your rights with respect to any personal information that we hold about you on behalf of an Online Partner, we will need to ask for instructions from the relevant Online Partner whose Partner Service you have used before we take any action. We therefore recommend that you contact that Online Partner directly if you would like to exercise your rights in respect of this personal information.

Opting out

You can also opt out of the processing activities described in this Privacy Policy in respect of the device you are using by switching the slider at the end of this Privacy Policy to the red position. If you do so, we will set a cookie on your device to tell us not to collect any information from your device.

Please note, however, that opting out in this way will only opt you out from us collecting data through a specific browser or device. You will need to opt out separately for each device that you use to access a Partner Service.

This opt out may also not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or devices, or use another operating system, you will need to opt-out again.

Changes to this policy

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

Contacting us

Please contact us if you have any questions,comments and requests regarding this Privacy Policy.

If we are unable to deal with any issues you raise with us, you also have the right to lodge a complaint with your national data protection authority. Further information about how to contact your local data protection authority is available at:

https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

This privacy policy was last modified on 23rd June 2023.

If you do not want to receive personalised information generated by Zipabout, you can disable the collection of data by Zipabout by switching the slider below to the RED position