Privacy Policy

Effective date: September 10, 2018

This Privacy Policy describes how Change Transit Ltd. (“Change Transit” or “us” or “we”) collects, uses and disclose your personal information (your “Data”) and how you can communicate with us regarding that collection, use and disclosure. The “App” means our mobile application that you have downloaded and will be using.

What data we collect
For the Data that you provide or that we collect, we are the data controller.

Data that we collect from you:
• Account Profile: Name, email, age, gender, and any other personal information you provided during the account signup process.
• Purchase Information: Information about any purchases you make using the App such as transit ticket purchases, where that function is enabled in your region.
• Location: Information about your current and prior locations, based on GPS, where location services are enabled by your mobile phone for use with the App, IP address and WiFi data. If location services have not been enabled, then this will affect the functionality of the App. Since we rely upon user location data to provide accurate journey information to you and our other users, depending on your mobile device location settings, we collect information about your location also while you are not using the App.
• App Usage: Information about how and when you use the App (including information about your journeys).
• Mobile Device Information: Information about the type of mobile device, unique device ID and operating system type and version number of the mobile device you use to access the App.

Data that you choose to share with us:
• Social Media Login: Your login information for any social media feeds you link to your Change Transit account.
• My Rewards: Where you have chosen to enrol in the My Rewards program, we collect the demographic data from any of the responses you provide to the survey. All responses to the survey all optional.
• User Content: From time to time, you may send us comments or information that may contain Data.

What we do with the Data

App Functions:
We use your Data to provide you with access to the App and its functionality and features as well as to improve your overall user experience:

In particular, we use your Data to:
• Create your account and My Rewards enrolment (where selected).
• Provide trip planning, transit and other transportation information (such as delayed transit) based on your trip selection.
• Provide you with news, weather, and sports information.
• Provide you with access to location based Live TV broadcasts (where available).
• Provide you with links to your third party social media accounts.
• Facilitate your purchases of products and services (such as transit tickets) using the App where enabled in your region.
• Comply with applicable legal or regulatory requirements

Personalized Experience:
Your Data will also be used to provide you with a personalized experience such as providing you with offers, products and services that are tailored to your interests and profile. In addition to general advertising from our third party advertising partners, we will use your Data to create advertising experiences and promotional offers that are more relevant to you. For example, if during the My Rewards survey you indicated that you regularly drink coffee and you use the App to plan journeys to local coffee shops, we might work with a local coffee shop to provide you with a coffee promotional offer.
We may also receive de-identified information and analysis from third party sources to help us further personalize your experience.
By downloading the App, setting up an account and, if applicable, enrolling in the My Rewards program, you consent to us using your Data to create this personalized experience.

Sharing Data:
We will share your Data with:
• transportation operators (such transit and ride-share operators), but they will only receive anonymous location and route information in order to show available transit and ride-share options;
• payment processors where required to enable your journey transportation purchases and to facilitate any other purchases you make using the App (where available). When you make purchases using the App, you authorize us to disclose your Data to those payment processors;
• third party advertisers in order for them to provide you with promotional offers and advertising that is of interest to you. We identify what ads/offers may be relevant to you solely based on the information you provide to us in your Account Profile and My Rewards enrolment survey as well as your App usage, but not based on any activities outside of the App.

Anytime we share your Data with our third party advertising partners, the Data will always be de-identified or aggregated so that the third party will never be able to identify any particular information to you. So for example, if your Account Profile indicates that your name is Stephanie Jones and you are a 30 year old female, we will only share with the third party information about Change Transit Internal UserNo. 834432, a 30 year old female. We recognize that the Data you provide in response to the survey during the My Rewards enrolment may contain sensitive information such as information about your race/ethnicity and religion (“Sensitive Data”). Again, we only share de-identified information with our third party advertising partners. So our third party advertising partners would only know that Change Transit Internal UserNo. 834432 is a 30 year old Asian female that drinks 3 cups of coffee a day and has no way of connecting that information to you personally. And the only Sensitive Data we collect is the completely optional survey responses you choose to provide us during the My Rewards enrolment – you can choose to not answer some or all of those survey questions.

Email Marketing
We may use your email address to provide you with information about our products and services or those of our third party advertising partners. In the Account Profile setup, you can opt-in to receive these messages and can Unsubscribe at any time by clicking the Unsubscribe option at the bottom of any of our emails to you. But we don’t share your email address with third party advertisers.

How we collect data
Your Data is collected and stored on our servers or those of our third party subprocessors. Our third party service subprocessor is Microsoft Inc. as a cloud service provider. Your Data may be transferred to, and stored at, a destination outside the EU as designated by Microsoft Inc. We will take all steps reasonably necessary to ensure that your Data is treated securely and in accordance with this Privacy Policy.
We will store your Data for until you delete your account. However, we may store some of your Data in an encrypted form for a longer period where required for regulatory or other legal requirements or for fraud detection purposes.

How can I choose not to participate in collection and/or use of Data
Your Data is required to provide you with the features and functionality of the App and to provide advertising to make the those features and functionality freely available to you and other users. That being said, if you don’t want us to use your Data, here are some things you can do:

Sensitive Data:
The collection of Sensitive Data for the My Rewards program is completely optional. You can choose to not enrol in the My Rewards program or even if you do enrol, you can choose to not answer some or all of the questions in the enrolment survey.
Delete your account:
You can delete your account by choosing the Delete Account option in the Account Profile settings. Subject to our requirements to continue to store certain of your Data, the deletion of your account means that we will no longer collect any of your Data and any Data we use will no longer be identifiable to you.

Who to contact if I have a concern
If you have any questions about this Privacy Policy or are seeking to exercise your rights, please contact us at:
support@change-transit.com. If you live in the EU, please contact us at that email address and we will provide you with contact information located in the EU.

Minors
Our App is not for use by any person under 16. If you are under 16, you may not use this App. If you are the parent of a person under 16 and are aware of that minor using the App, please contact us so that we can disable the account.

Cookies
Our App does not use cookies to track or monitor your usage of the App. However, since the App links to third party sites that we do not control, cookies may be used by those third parties. We are not responsible for any cookies used by those third parties.

EU Users
To the extent that our processing of your Data is subject to the General Data Protection Regulation (the “GDPR”), we rely upon:
1. our legitimate interests in (i) optimizing our products and services delivered to you through the App; (ii) marketing third party products and services to you; (iii) providing advertising to make the App available to users at no charge; and (iv) developing new services and features.
2. the contractual necessity of using your Data (such as location information) to provide you with the features and functionality of the App.
Furthermore, if the processing of your Data is subject to the GDPR, you have the right to request access to, update, remove, delete, and restrict the processing of your Data as well as the right to object to the processing of your Data. If you restrict or object to the processing of your Data, you should delete your account as this will affect the availability of the App’s features and functionality or the availability of the App itself. You may request a copy of your Data by contacting us (first copy will be at no charge while further requested copies may be subject to a reasonable administrative fee).
Users in the EU have a right to file a complaint regarding our processing of Data by contacting their local Data Protection Authority.

Changes to policy:
We may change this Privacy Policy from time to time as required for our business purposes and/or to ensure compliance with applicable laws. We will post the changes to our Privacy Policy and offer you an opportunity to review the changes. If you disagree with the changes to this Privacy Policy, you should stop using the App and delete your account. If you continue to use the App after we notify you of the change, that will mean that you agree to them.