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.

Who we are

Our Role

When acting as a processor

When we provide our services to our customers, we are acting on their behalf as their service provider and processor. If you are a user that is using our service on behalf of one of our customers, your personal data is processed in accordance with:

• Data protection legislation;
• Instructions given to us by the Customer;
• The section in our privacy policy that talks about our Customers, Customers’ End-users and;
• The privacy policy of the Customer, which is made available by them on their website or app.

When functioning as a processor, we undertake information processing based on explicit directives provided by our customers, who serve as the Data Controllers in this context. For additional insights regarding our data usage as a processor, you can refer to our customer’s privacy policy.

In the capacity of a processor, there might be instances where we handle Special Category Data pertaining to our Customer’s Users. While it is infrequent for us to regularly process such specialized data, it’s important to note that any such processing would strictly adhere to the permissions and exemptions established by the respective Customer acting as the Data Controller.

Information we collect about you

These are the categories of data we may process:

• Contact Details: examples include real name, email address, address, telephone number, social media username, title, and physical address;
• Financial Data: examples include employee’s bank account number, billing address, transaction code (TAN), income information;
• Household and Relationships: examples include emergency contact, marital status, parent/guardian status, family status, information about an individual’s children, next of kin, emergency contact details;
• Identifiers and Legal Documents: examples include public health number, passport, proof of residence, right to work status, visa status, national insurance number, driving license data, national identification document, signature;
• Activity and Behavioural: examples include browsing history, search history, likes, clicks, shopping cart information, products purchased;
• Personal Characteristics: examples include sex, nationality, date of birth, gender, academic qualifications, height, age;
• Location Data: examples include tracking data, approximate location;
• Communications Data: examples include instant messaging data, social media posts, postal content;
• Images and Recordings: examples include CCTV footage, photos, videos, voice recordings, profile picture, photo ID;
• Views and Opinions: examples include survey responses, testimonials/references, opinions (non-political/religious/philosophical);
• Work-related Data: examples include name of employer, occupation, completed tasks, details of grievance, disciplinary proceedings, curriculum vitae / resume;
• Technical Identifiers: examples include IP address, mac address, usernames, passwords, browser data, other device identifiers, unique identifiers;
• Criminal Records;
• Special Category Data, examples include:
  • personal data revealing racial or ethnic origin;
  • data concerning health;
• Aggregated Data: examples include 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 website 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.

This is just an overview, see the next section to see in more detail exactly what we use.

We use a third party payment service provider to process payments. Your payment details are securely collected and processed by the payment service provider as our subprocessor. We do not store or have access to your payment details.

Legal justifications we rely on to use your data

We process your information for the purposes described in this policy based on the following legal bases:

• Consent: the individual has given explicit consent for us to process their personal data for a specific purpose;
• Legitimate interests: a legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your rights and interests;
• Contractual Obligations: the processing is necessary for a contract we have with the individual or because they have asked us to take specific steps before entering into a contract;
• Legal Obligations: the processing is necessary for us to comply with the law.
• Vital Interests: the processing is necessary to protect someone’s life.

How we use your data if you are one of our Contractors

How we use your data if you are one of our Customers

How we use your data if you are one of our Customers’ End-users

How we use your data if you are one of our Job Applicants

How we use your data if you are one of our Leads

Personal data

How we use your data if you are one of our Staff

Personal data

Sensitive data

How we use your data if you are one of our Visitors to our premises

Personal data

How we use your data if you are one of our Website Visitors

Personal data

How we collect your personal data

We use different methods to collect data from and about you, including through:

Direct interactions

You may give us information on your Contact Details, Identifiers, and Financial Data… (all the categories that come through direct interactions) by filling in forms or by corresponding with us by post, phone, email, via our website or otherwise. This includes personal data you provide when you:

• Apply for our products or services;
• Create an account with us;
• Subscribe to publications;
• Request marketing to be sent to you; or
• Give us feedback or contact us.

Automated technologies or interactions

As you interact with our website and services, we will automatically collect Technical, Profile and Usage Data about your equipment, browsing actions, and patterns.

Third parties or publicly available sources

We might receive personal data about you from various third parties or publicly available sources like the ones set below.

• Work-related data from online recruitment platforms or professional networks;
• Identity and Contact Data from publicly available sources.

Third Parties & Sub-Processors

We might store or send personal data about you to various third parties set out below.

International Transfers

Some of our external third parties are based outside the UK and EEA, so their processing of your personal data will involve transferring data outside the UK and EEA. Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• The country to which personal data is being transferred has been deemed to provide an adequate level of protection for personal data by the European Commission; or
• We use specific contracts approved by the European Commission which give personal data the same protection it has in the UK and Europe.

Data Security

We have implemented 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.

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.

Where you have chosen a password that enables you to access certain parts of our applications, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

Data Retention

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 with respect to our relationship with you.

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.

List of processes

In specific scenarios where our role is designated as a data processor, the duration for which data is retained is not determined by us. Instead, this time period is set and mandated by the data controller, in accordance with their policies and regulatory requirements. This ensures a clear understanding and compliance with the data controller’s guidelines and legal obligations.

Automated decision-making and profiling

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

Your Legal Rights

You have the right to:

Request access

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.

Request correction

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.

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 to continue 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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.

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 which override your rights and freedoms.

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.

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.

Withdraw consent

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.

Make a complaint

You have the right to make a complaint at any time to the relevant regulator

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.

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 concerning your request to speed up our response.

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 several requests. In this case, we will notify you and keep you updated.

Third-Party Links

Our websites 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-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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