Privacy Policy

Passenger respects the privacy of its users and therefore treats personal information with the appropriate level of discretion and security. This policy outlines frequently asked questions relating to the information we gather and how we use it.

This is the website of Passenger Technology Group. Our postal address is: Passenger Technology Group Ltd, 18 Albert Road, Bournemouth, Dorset, UK, BH1 1BZ. We can be reached via email at [email protected]. Or you can reach us by telephone: +44(0)330 460 9998

What this policy does not apply to

This Privacy Policy does not apply to any data collected, processed or otherwise dealt with in accordance with our Passenger applications or Passenger Platform. The EULA provided on each platform applies when you use our applications.

Website data policy

What information do you store?

We use cookies to record past activity at a site in order to provide better service when visitors return to our site. Cookies are small data files that are stored by your browser on your computer’s hard drive. Cookies are held on your web browser for varying amounts of time depending on their use.

You can easily change your browser settings to refuse or delete cookies or to let you know when you get a new cookie if you do not want to accept cookies on any website. The method of choosing to refuse or delete cookies differs depending on your browser so you will need to consult your browser’s menu for further guidance.

For each visitor to our Web pages, our Web server automatically records the page requests when users visit our Website. These ‘Server Logs’ typically include your web request, internet protocol (IP) address, browser type, browser language, date and time of your request and one or more cookies.

Cookies being set

All cookies are stored on the user’s web browser only.

What do you do with the information you collect?

The information we collect is used to improve the content of our Web pages, used to customise the content and/or layout of our page for each individual visitor, used to notify consumers about updates to our website, used by us to contact our site visitors for marketing purposes and to notify of any future events or information we feel may be of interest to the consumer.

The Cookies we store are necessary to use third-party applications on our site such as Google Analytics. The information we gather from these applications does not identify specific individuals and is used by us for statistical purposes only. Disabling cookies will disable this functionality on the site.

What other information do you keep track of, about me?

We collect the domain name and email address (via a subscription service) of visitors to our web pages, the email addresses of those who post messages to our forums, the email addresses of those who communicate with us via email, aggregate information on what pages consumers access or visit, user-specific information on what pages consumers access or visit, information volunteered by the visitor, such as survey information and/or site registrations, name and address, telephone number, fax number.

Do you sell my information to anyone?

We do NOT sell your personal information to any third party under any circumstances.

Do you share my information with other parts of your company?

We only share your information with other parts of Passenger Technology Group.

Do you share my information with other companies?

We do not share your information with other individuals/companies ‘outside’ of Passenger Technology Group without prior consent.

Why do you want to know my name and email address?

If you supply us with your email address online you may receive periodic emails from us with information on our activities and upcoming events. If you do not wish to receive such mailings, please let us know by calling us at the number provided above, emailing us at the above address or visiting our Contact us page.

Changes to our policy

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will post the policy changes to our Website to notify you of these changes and we will use for these new purposes only data collected from the time of the policy change forward. If you are concerned about how your information is used, you should check back at our Website periodically. Customers may prevent their information from being used for purposes other than those for which it was originally collected by emailing us at the above address, calling us at the above telephone number or visiting our Contact us page.

Who can I talk to if I have a question about my privacy?

If you feel that this site is not following its stated information policy, you may contact us at the number provided above, email us at the above address or visit our Contact us page.

Links to third party websites

This website contains links to other websites. Please note that this Privacy Policy applies solely to us and we are not responsible for the privacy practices of any other website. We encourage you to read the privacy policies of every website that collects personal information.

Sales and accounts data policy

What this policy applies to

Where we refer to Data Protection Law below this means;

• unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK, and then
• any successor legislation to the GDPR or the Data Protection Act 2018.

Your privacy is important to us and we will process your data in accordance with Data Protection Law. This says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
• 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.

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data that has been truly anonymised. We will collect, store, and use the following categories of personal information about you:

• Identity Data such as first name, last name and title.
• Contact Data such as addresses, telephone numbers, and personal email addresses.

If you fail to provide personal information

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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal information collected?

You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Sign up to newsletters.
• Sign up to email updates.
• Request demos and other interactive features.
• Inbound email or phone calls

How we will use information about you

We will only use your personal information when the law allows us to.

To administer and protect our business (including, sales & marketing activity, essential and nonessential communication, troubleshooting, data analysis, support, reporting) we will use your personal information where it is necessary to comply with a legal obligation or for our legitimate interests (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), or those of a third party, but only where your interests and fundamental rights do not override our interests.

We may also use your personal information in the following situations, which are likely to be rare:

• where we need to protect your interests (or someone else’s interests); or
• where it is needed in the public interest.

Situations in which we will use your personal information
We need all the categories of information we keep about you primarily to allow us to use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:

• To provide the relevant service or feature that you have requested.
• To manage your preferences.
• To gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our newsletters and email subscriptions.
• To conduct data analytics studies to review and better understand how and when people interact with us and our products.
• Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

You will have the ability to unsubscribe from any repeat communications at any time.

Change of purpose

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data sharing

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU, as set out in “Transferring information outside the EU” below. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors, designated agents, and software provisions). The following categories of third-party service providers process personal information about you for the following purposes:

• Service providers acting as processors based in the UK and US who provide IT, development system administration services or software.
• 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 United Kingdom who require reporting of processing activities in certain circumstances.

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Transferring information outside the EU

As our customer relationship software provider is based in the United States we have to transfer your personal data out of the EEA. As our provider is part of the Privacy Shield it is required to provide your personal data with similar protection as it would receive inside the EEA. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en

Passenger’s User Research Programme Privacy Policy

At Passenger, we are committed to enhancing your interaction with our products. We offer selected users the opportunity to engage in UX research. This research is designed to improve our understanding of how our products are used and to identify potential improvements. Participation in this research is entirely voluntary and is based on your explicit consent.

Consent

By agreeing to participate in our User Research Programme, you consent to the collection and analysis of data related to your usage of our app. This includes app usage patterns, responses to surveys or interviews, and interactions within the app.

Opt-Out Process

You may withdraw from our User Research Programme at any time. To opt-out, please contact us at the email address above. Withdrawing your consent will not affect your use of the app.

Data Utilisation and Sharing

The data collected will be used exclusively to enhance the app’s functionality and user interface. We respect your privacy; your data will be treated confidentially and will not be shared with any third parties without your explicit consent.

Subprocessors

We use third-party services from AWS, Google, Apple, and Campaign Monitor to process some of the data collected through our User Research Programme. These sub processors are carefully chosen to ensure they meet high standards of data protection and are compliant with GDPR. Data is stored and processed in the UK and US via the Data Privacy Framework.

Data Storage and Retention

Data collected through our User Research Programme is stored securely on servers managed by Passenger and our subprocessors. We retain this data for no longer than six years from the date of collection, after which it will be securely deleted.

Your Rights

As a participant, you have the right to access the data collected about you. You can also request the correction or deletion of your data at any time. Additionally, you have the right to obtain a copy of your data in a standard electronic format.

Contacting Us

If you have any questions about this privacy notice or our handling of your data, you can contact us via the email address above. If you believe that we are not adhering to this privacy notice, you may contact us, or you have the right to complain to a data protection authority.