Our contact details:
Name: Wiltshire Connect (Wiltshire Council)
Address: Wiltshire Council’s Passenger Transport Unit, County Hall, Trowbridge. BA14 8JN
Phone Number: 01225 718080
E-mail: WiltshireConnect@wiltshire.gov.uk
The type of personal information we collect:
We collect and process the following information provided by you:
- Your name
- E-mail address
- Phone number
- Credit/debit card information
How we get the personal information and why we have it:
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- Booking journeys/rides with the Wiltshire Connect on-demand bus service.
- Paying your fare through the Wiltshire Connect app.
We may receive information about you if you use any other services Wiltshire Council provides. We are also working closely with third parties (including, for example, business partners, bus operators, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.
We use the information that you have given us to:
- Provide an on-demand bus service to passengers.
- Process payments for applicable fares for using the service.
- For marketing purposes where consent has been provided.
- To provide operational information and updates.
This forms the lawful basis for processing the information which is necessary for providing the service. Users of the Wiltshire Connect service also have the option to give consent to the processing of their personal data for one or more specific purposes in relation to marketing communication.
Third party sub-processors:
To provide the service, it is usually necessary to use the services of sub-processors. These include:
- Ioki GmbH our technology provider to enable you to use the Wiltshire 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.
- Google Maps – This is used to graphically show the route to the passenger. Google Maps is also used to display the route even if the location services are not activated.
- The bus operator under contract to Wiltshire Council.
External sub-processors who process data on our behalf are carefully selected by us and strictly contractually bound. The sub-processors work according to our instructions, which is ensured by strict contractual regulations, technical and organisational measures and supplementary controls.
We may also disclose your personal data to any competent law enforcement body, regulator, government agency or other third party where we believe disclosure is necessary:
(i) as a matter of applicable law or regulation
(ii) to exercise, establish or defend or legal rights; or
(iii) to protect your vital interests or those of any other person
Wiltshire Connect App:
When you download the Wiltshire Connect app, the necessary information is transferred to the App Store, i.e. in particular the username, e-mail address and customer number of your account, time of download and individual device ID. We have no influence on this data collection and are not responsible for it. By using the app on your smartphone, your device connects to our servers. The operating system as well as the version of our app used will be transmitted to us and processed. The transmission and processing is used to improve the app and to correct errors.
To perform at its best, the app requires the authorisation to use location services of the terminal device. You have the possibility to grant permission to use the location services when using the app for the first time. If you do not grant the authorisation, you will have to enter your address manually when requesting a trip. If you do not grant the authorisation to use the location services, the app can be used except for the aforementioned restriction. You can revoke the granted authorisation at any time in the settings of your app.
The App uses the Google Maps API application operated by Google Ireland Limited Gordon House, Barrow Street Dublin 4 Ireland (“Google”). The terms of use for Google Maps can be found at: https://www.google.com/help/terms_maps.html. The Google Privacy Policy can be found at: https://policies.google.com/privacy?hl=en. Google Maps is used to display a map in the App. This map interactively shows you the distance to the vehicle that is driving your journey. If you have consented in the use of your GPS location data, this data will be processed based on Article 6 para. 1 lit. a GDPR.
When booking and conducting a trip, we collect the following data at the time of booking:
- At the time of booking start location (address) – If you have enabled the GPS on your device and consented in using the location services, this data will be used to find a pick-up location.
- If the GPS data is not stored. Pickup location (address or stop)
- Drop-off location (Destination address or stop)
- Information about your end device (operating system).
- Payment method
- Number of seats required.
- Discounts/offers granted.
- If applicable and if necessary, mobility information about whether you are a wheelchair user or use a walking aid.
- During or after the end of the journey we collect the following data: Journey time in minutes and driven mileage.
Firebase, a service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) is used in our app. In the event of an app crash, information is transferred to us in anonymised format. The data is used in order to trace the cause of the respective crash and resolve it more quickly. Existing errors are analysed and identified, and the quality of the app is assured. Furthermore Firebase is used to measure the success of individual functions of the app. Firebase analyses the acceptance of the functions by the user. The transferred data is purely technical and has no personal context. If you want to receive push notifications, you must explicitly agree to receive the push notifications. You can revoke your consent at any time. You will be asked for your consent to receive push notifications during installation or the first use.
Billing:
The app has the option to pay the costs of your trips by debit/credit card. The card payment is conducted by the payment service provider: Stripe Payments Europe, Ltd., The One Building, 1 Grand Canal Street, Lower, Dublin 2, Ireland
The privacy policy of Stripe Payments Europe, Ltd. can be accessed here: https://stripe.com/de/privacy
For payment by debit/credit card, the first and last name of the card holder, the issuer of the card, the first six and last four digits of the card number and the card expiration date must be provided in order to process the payment. Stripe Payments Europe, Ltd. is PCI DSS certified (Payment Card Industry Data Security Standard).
When you enter your card details, the data is transmitted directly to the payment service provider we use via an encrypted connection. Our payment service provider then conducts a so-called authentication of your payment method. This ensures that your payment method is an active payment method. For security reasons, only the first six and last four digits of your credit card are transmitted to us, and we store them for identification and verification purposes.
How we store your personal information
Your information is securely stored and the transmission of personal data from the end device (e.g. smartphone) of the data subject is always encrypted.
We will not retain your personal data for any longer than is necessary to fulfil the purposes for which we collected that personal information, unless the law permits or requires that we retain it for longer.
Your rights:
Your rights are set out in the current Data Protection legislation and includes:
- The right to access your personal information, to request rectification or erasure of certain personal information and to object to processing in certain circumstances.
- The right to withdraw any consent you may have given to process your personal information.
- The right to complain to the Information Commissioner if you feel we are processing your personal information unlawfully
- The right to restrict processing activity in certain circumstances.
- The right to object to certain types of processing activity.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at: InformationGovernance@wiltshire.gov.uk or
Wiltshire Council’s Passenger Transport Unit, County Hall, Trowbridge. BA14 8JN
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
