Stagecoach Connect Privacy Policy

Stagecoach Connect Privacy Policy 

Welcome to our Privacy Policy.  Stagecoach respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website or use our Stagecoach Connect app and tell you about your privacy rights and how the law protects you.  You can also view our full Privacy Policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1. This Privacy Policy aims to give you information on how Stagecoach Connect collects and processes your personal data through your use of the Stagecoach Connect app, including any data you may provide through the Stagecoach Connect app.
1.2. It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data and your rights in relation to your personal data. 
1.3. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
1.4. Controller [Stagecoach Services Limited], is the data controller and is responsible for your personal data (collectively referred to as "Stagecoach Connect", "we", "us" or "our" in this Privacy Policy).
1.5. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
1.6. Contact details If you have any questions about this Privacy Policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: Stagecoach Services Limited
Email: [email protected]
Phone: 0161 880 5000
Postal address: One Stockport Exchange, 20 Railway Road, Stockport, SK1 3SW
1.7. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.8. Changes to the Privacy Policy and your duty to inform us of changes  We keep our Privacy Policy under regular review.
1.9. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.10. Third-party links The Stagecoach Connect app may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third parties and are not responsible for their privacy statements. When you leave our website or app, we encourage you to read the Privacy Policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

2.1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes home address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments from you and other details of products and services you have purchased or used
• Technical Data includes your login data, location, and other technology on the devices you use to access the Stagecoach Connect app.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our mobile app, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
2.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.5 Where and how we collect your personal information You may give us information about you by filling in forms on our site, within the Stagecoach Connect mobile application or by corresponding with us by phone, e-mail or otherwise. We collect personal information about you in several ways: 

• When you fill in a form on our website, app or Wi-Fi portal. 
• When you contact us via phone, email, social media or another route
• When you register with us and fill in a form on our website or mobile app, either directly or via a social media account
• When you subscribe to our services
• When you purchase tickets 
• When you opt-in to receive special offers and promotions, travel tips and latest news by email, post and other electronic means 
• When you enter a competition, prize draw or promotion 
• When you complete a survey distributed by us or on our behalf
• When you browse our website, use the Stagecoach Bus App or use our on bus Wi-Fi 
• When you open or click on any marketing emails we send you

2.6 We also collect your personal information from other organisations and sources, for example when you contact us through a social media company such as Facebook, Twitter, LinkedIn or Instagram. Before providing information to us via these channels you should check these companies’ privacy policies and settings to understand how they use your personal information.
2.7 When you fill in a form or purchase tickets, within the Stagecoach Connect app, we only require you to supply the information that we need to provide the service you have requested.  We will normally ask you to provide us with: 

• Your name
• Your contact details
• Details of your bank, credit card or alternative payment provider
• Your location, ticket and travel information 
• Information when reporting a problem, submitting queries or comments

2.8 When you visit our website, app or register to use our on-bus WI-FI services, we may collect the following information automatically:

• Technical information, including the IP address used to connect your computer to the Internet, unique identifiers assigned to your device, your login information, the browser you’re using, time zone setting, browser plug in types and versions, the operating system, device type and platform you are using
• Location data and WI-FI usage
• Information about your website or app visit that will help us to improve our service.  This can include date and time, which products you looked at or searched for, how long you spent on certain pages, resources you accessed and how you moved around the page, how you clicked to, through and from our website or app and any phone number used to contact us.

2.9 In our communications with you by email or other electronic means, we automatically collect data relating to:

• How you interact with our communications, such as which emails you opened or clicked a link within, and how long the email was opened for
• Where you are when you interact with our messages
• What type of device, model and operating system you’re using.

This helps us build a better picture of whether our marketing is effective.

2.10 We also collect information about your visits to our website using cookies. More information about how we use cookies and how you can control this, if you wish to, can be found in our Cookie Policy.
2.11 When you complete a survey, we may collect additional personal information for customer profiling and monitoring purposes, including (but not limited to): age bands, gender, employment status, postcode and email address.
2.12 Whilst we mainly use the personal information that you provide to us, we may sometimes use other public sources of information about our customers and enquirers where you have given your permission for your data to be shared.  We do this to help us understand more about our customers, to ensure that our public messages are relevant and to make sure that the marketing information we send you, with your consent, is also relevant.  We take great care in sourcing this information but if you prefer us not to use your data in this way then please let us know by contacting [email protected].
2.13 CCTV - We employ CCTV on our buses in order to:

• Prevent, deter and detect crime
• Apprehend and prosecute offenders, and provide evidence to take action in the courts
• Help provide a safer environment for our staff
• Protect public safety
• Monitor operational and safety-related incidents
• Assist with the verification of claims.

2.14 You have the right to make a Subject Access Request for CCTV images of yourself and to ask for a copy of them. Please direct any such request to [email protected]. To protect the rights of other individuals whose images may also be captured by the same images, we reserve the right to redact images.
2.15 We reserve the right to withhold information where permissible by the applicable data protection legislation, and we will only retain CCTV images for a reasonable period or as long as is required by law. In certain circumstances, we may need to disclose CCTV images for legal reasons. When this is done, there is a requirement for an organisation that has received the images to adhere to the relevant data protection legislation.
2.16 If you fail to provide personal data - Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

• apply for our products or services;
• create an account via our Stagecoach Connect mobile app;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

4. HOW WE USE YOUR PERSONAL DATA

4.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
4.2 Please see section 10 to find out more about the types of lawful basis that we will rely on to process your personal data.
4.3 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
5.1 We have set out below, in a list format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.  
5.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the list of activities below.
1. To register you as a new user
Type of data: (a) Identity; and (b) contact
Lawful basis for processing including basis of legitimate interest: Performance of contract with you
2. To process and deliver your transactions including: (a) manage payments, fees and charges; and (b) collect and recover money owed to us
Type of data: (a) Identity; (b) contact; (c) financial; (d) transaction; and (e) marketing and communication
Lawful basis for processing including basis of legitimate interest: (a) Performance of contract with you; and (b) Necessary for our legitimate interests (to recover money due to us)
3. To manage our relationship with you which will include: (a) notifying you about changes to our terms or Privacy Policy; and (b) asking you to leave a review or take a survey
Type of data: (a) Identity; (b) contact; (c) profile; and (d) marketing and communication
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you; (b) necessary to comply with a legal obligation; and (c) necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
4. To enable you to partake in a competition or complete a survey
Type of data: (a) Identity; (b) contact; (c) profile; (d) usage; and (e) marketing and communication
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you; and (b) necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
5. To administer and protect our business and the Stagecoach Connect app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity; (b) contact; and (c) technical 
Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and (b) necessary to comply with a legal obligation
6. To deliver relevant app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data: (a) Identity; (b) contact; (c) profile; (d) usage; (e) marketing and communication; and (f) technical 
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop our products/services, to grow our business and to inform our marketing strategy)
7. To use data analytics to improve our mobile app, products/services, marketing, customer relationships and experiences
Type of data: (a) Technical; and (b) usage 
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
8. To make suggestions and recommendations to you about products/services that may be of interest to you
Type of data: (a) Identity; (b) contact; (c) profile; (d) usage; (e) marketing and communication; and (f) technical 
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)
5.3 Marketing
5.3.1 We only use your personal information for marketing where you have given us permission to do so or you have provided permission to other organisations to allow us to market to you. 
5.3.2 Where you’ve given us permission to do so, we use some of your personal information for marketing. For example, we may use information like name, address, location and past journeys to ensure we make our marketing relevant, accurate, and measure its effectiveness.
5.3.3 By using the information you provide we are able to contact you with specific marketing messages about special offers and promotions, travel tips and latest news and, depending on the permission you have given us or another organisation this may be by post, email, telephone, SMS, social media or other electronic means.  
5.3.4 If you have given us your consent to use your personal information for marketing, you have the right to withdraw your consent at any time by contacting our Data Controller by email [email protected], clicking the “unsubscribe” link in our marketing emails or replying STOP to a text message.  You can also log into your account on our website or app at anytime to update your marketing opt-in permissions.
5.3.5 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the personal data control mechanisms detailed below:
5.4 Promotional offers from us
5.4.1 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
5.4.2 You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
5.5 Sharing your personal information
5.5.1 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
5.5.2 Stagecoach Bus may share your information within Stagecoach Group PLC. We do not share or sell your personal information to any other company for marketing purposes. 
5.5.3 Third-party companies will be required to use your personal information in accordance with the Data Protection legislation currently in force. We may also use information in aggregate, where personally identifiable information is removed, for marketing and strategic development to improve and support our business.
5.5.4 We may disclose your personal data to the following recipients for the purposes described in this Privacy Policy:

• Ioki GmbH our technology provider to enable you to use the Stagecoach Connect app in the most seamless way possible
• Stripe Payments Europe, Ltd, payment services for the processing of fares for credit and debit purposes
• Ioki GmbH analytics through Tableau to understand ride data and build anonymised reporting for statistical purposes.

5.5.5 All personal information sent to our trusted suppliers is transferred securely. In all cases we require these companies to comply strictly with our instructions and they are not allowed to use your information for their own business purposes. We also require these companies to have sufficient organisational and technical measures in place to ensure the security of your personal information. 
5.5.6 We may use suppliers who operate outside of the country of which you are a resident, for example in the United States.  These countries may not offer the same legal protection of your personal information as the UK.  If we use one of these organisations, we take appropriate steps to ensure that they provide an adequate level of protection in accordance with UK data protection law.  By submitting your personal information to us you agree to this transfer, storing or processing of your personal information at our approved locations outside the EEA.  If you would like to know more about the ways in which we safeguard your personal information, please get in touch using the contact details in this policy.
5.5.7 Under some circumstances we may be required to disclose or share your information without your consent, for example if we are required by the police, the courts or for other legal reasons.
5.6 Automated Decision Making
5.6.1 An automated fraud assessment may take place to decide whether to accept or decline your purchase. You have the right to contest the decision, to express your point of view, and to require a human review of the decision. You can exercise this right by contacting us using the contact details provided.
5.7 How we keep your personal information up to date 
5.7.1 We have a legal obligation to keep the personal information we collect accurate and up to date. You have the right to ask us to correct any inaccuracies in the personal information we hold about you and to restrict the use of your information until it has been corrected.   
5.7.2 The simplest way to keep your data accurate is to log in into your Stagecoach Bus account to update your information or change marketing preferences.
5.7.3 We also keep your information accurate by: 

• Giving you the opportunity at any time to contact us to correct or change your information 
• Asking you to confirm certain details when you contact us 

5.7.4 We have specific rectification, restriction, objection and erasure policies in place to make sure we respond effectively to your request to correct data and to respond to erasure requests.
5.8 How we keep your personal information safe
5.8.1 We use administrative, electronic and physical security measures to ensure the information we collect about you is protected from access by unauthorised persons and protected against unlawful processing, accidental loss, destruction and damage.
5.8.2 By using our website and/or services, you acknowledge and agree that, except to the extent required by the Data Protection laws, we shall not be responsible for any unauthorised use, distribution, damage or destruction of personal data. We will only retain your information for a reasonable period or as long as is required by law.
5.9 How long we keep your personal information
5.9.1 Of the data we process outside of any contract we retain the data for no longer than is necessary. Where there is a legal requirement to retain data for longer than Stagecoach Bus requires, we will do so. Where reasonably practicable data is minimised so not to be identifiable to the data subject unless required by law or is subject to a Subject Access Request.
5.9.2 We keep your personal information where we have:

• A legal or regulatory requirement that requires us to hold data for a specific time
• A legal basis to retain data including data opt-ins, revised opt-ins and renewed consents

5.10 What to do if you have a complaint about our use of your personal information
5.10.1 If you have a complaint about the information we hold or how we use that information, please contact our Data Controller [email protected] who will deal with your request promptly. If you are not satisfied with the way your complaint was handled, you can refer your complaint to UK Information Commissioner’s Office.
5.11 Links to other websites 
5.11.1 We link our website directly to other sites. This privacy notice does not cover the links within our site linking to other websites and organisations. We encourage you to read the privacy statements on the other websites you visit. 

6. CHANGES TO THIS PRIVACY NOTICE

6.1.1. This privacy notice does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation using the contact details at the beginning of this privacy policy.

7. OPTING OUT

7.1. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
7.2. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us because of a product/service purchase, product/service experience or other transactions.

8. COOKIES

8.1. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Stagecoach Connect app  may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

9. CHANGE OF PURPOSE

9.1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
9.2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
9.3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

10. DISCLOSURES OF YOUR PERSONAL DATA

10.1. How we use your personal information - We use the personal information you provide to: 

• Provide you with the service or information you’ve requested. 
• Handle the administration of your account, payment, issue your tickets or confirm orders
• Alert you about updates to your bus journey, timetable or tickets
• Provide post-sales support and deal with any complaints, refunds or other ticketing or travel issues or queries
• Contact you to invite you to participate in research
• Personalise your experience of our website and app by using your purchases and browsing activity to make recommendations that we think may be of interest to you
• Improve our website, app and the range of services and products we provide 
• Analyse and optimise our marketing activities
• Evaluate and improve our existing products and services, or develop new ones  
• Contact you with your consent to tell you about our special offers and promotions, travel tips and latest news
  
  
  11. OUR LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION
  
  11.1. Under UK data protection law, we must have a valid basis for using your personal information and we may not collect store or use information other than as described in this policy. There are four ways we may have a valid basis for using your personal information:
  11.1.1. Contract—Most of the information we collect from you is necessary to allow us to fulfil our contract with you or to enter into a contract with you e.g. you provide a billing address when you purchase tickets via our website; we may need to contact you to notify you about changes to our services.
  11.1.2. Consent—When you register and open an online account with us you will be invited to give us your consent to use your personal information as described in ‘How we use your personal information for marketing’. By opting in you are giving us your permission to process your data using consent as our legal basis. If you have given consent to our use of your personal information, you are entitled to withdraw this consent at any time.
  11.1.3. Legitimate Interests—We have a legitimate interest in using your personal information e.g. to ensure that the content on our website and app is presented to you and your device as effectively as possible. If this is our reason for using your personal information, we must make sure that our interests do not override yours and you can object to this use of your personal information. We also have a legitimate interest in exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  11.1.4. Legal Obligation—Lastly, we have a legal obligation to use your personal information where lawfully requested or required to do so by public authorities.
  11.1.5. A full description of the different types of personal information we process, the purpose of the processing and the legal basis for the processing is shown below:

11.1.6 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.  We may share your personal data with the parties set out below for the purposes set out in the list in section 4 above.

• External Third Parties as set out in the Glossary at section 17 below. 
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

11.1.7 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

12. INTERNATIONAL TRANSFERS

12.1. We may transfer your data outside the European Economic Area (EEA) where an external third parties are based outside the EEA and their processing of your personal data involves a transfer of data outside the EEA.
12.2. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  
  

13. DATA SECURITY

13.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
13.2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

14. DATA RETENTION

14.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
14.2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
14.3. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
14.4. In some circumstances you can ask us to provide a copy of, amend, correct or delete your data (see section 9 below for further information regarding your legal rights).
14.5. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

15. YOUR LEGAL RIGHTS

15.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data.
15.2. You have the right to:
1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
15.3. If you wish to exercise any of the rights set out above, please contact us.

16. Accessing your Data by Subject Access Request (SAR)

16.1. You have the right to request a copy of the information that we hold about you, this is known as a Subject Access Request (SAR). We will provide this to you free of charge once we have confirmed your identity within 30 days of receipt of your request.
16.2. If you would like a copy of some or all of your personal information, please complete a Data Subject Access Form and send it to the Data Controller via email or post to the addresses below: 
Email: [email protected]
Phone: 0161 880 5000
Postal Address: One Stockport Exchange, 20 Railway Road, Stockport, SK1 3SW
16.3 Unless you specify otherwise we will provide your information electronically.
16.4 If we do hold information about you we will: 

• Give you a description of it 
• Tell you why we are holding it 
• Tell you who it could be shared with 
• Tell you how long we will keep the information
• If the information was not provided by you, we will give you any available information such as the source of the data 
• Tell you if the information has been used for automated decision making and explain the logic involved in the decision making process
• Tell you if the information is stored outside of the European Economic Area, and if so what safeguards are in place to protect your personal information
• Let you have a concise and clear copy of the information

16.5 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
16.6 What we may need from you - We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
16.7 Time limit to respond - We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a few requests. In this case, we will notify you and keep you updated.

17 GLOSSARY

LAWFUL BASIS
Legitimate Interest means the interests of our company in conducting and managing our business [to enable us to give you the best service/products and the best and most secure experience].
For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests. It can also apply to processing that is in your interests as well.
When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing. If you wish to do so, please let us know by contacting [email protected].  Please bear in mind that if you object, this may affect our ability to carry out the tasks for your benefit.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation to which we are subject.

THIRD PARTIES
External Third Parties

• Stagecoach Connect uses best in third party service providers to perform certain functions.
• Ioki GmbH our technology provider to enable you to use the Stagecoach Connect app in the most seamless way possible and to understand ride data and build anonymised reporting for statistical purposes.
• Stripe Payments Europe, Ltd, payment services for the processing of fares for credit and debit purposes
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
  
  

Stagecoach Connect Privacy Policy version 3. This version was last updated on 15 February 2023.