FTS Driver Companion Application
Privacy Policy
Non-Employees
FTS Driver Companion Application
Privacy Policy
We ask that you read this
privacy policy carefully as it contains important information on the personal
information we collect about you, how we use it, your legal rights, and the
situations in which we may share your information with other organisations when
using this App.
Please note that the collection and use of your personal information is
required for the App to operate properly. Any refusal, disruption or tampering
with the App which affects how the App collects and uses your personal
information could result in the App not functioning properly, which in turn may
result in you being unable to provide and be paid for services to First Travel
Solutions.
1. WHO WE ARE
2. THIS POLICY
3. THE DATA WE COLLECT ABOUT YOU
4. HOW WE USE YOUR PERSONAL DATA
5. PURPOSES FOR WHICH WE USE YOUR
PERSONAL DATA
6. YOUR LEGAL RIGHTS
7. SHARING YOUR PERSONAL DATA
8. INTERNATIONAL TRANSFERS
9. DATA SECURITY
10. DATA RETENTION
11. COOKIES AND SIMILAR TECHNOLOGIES
12. WHO WE ARE
This mobile application software, FTS Driver Companion Application (the
"App") is operated by First Travel Solutions Limited ("FTS",
"we", "us"), who is a
subsidiary of FirstGroup plc. We are the proprietor of all rights in and
to the Service, and you. The Service is provided by www.firsttravelsolutions.com is operated by First Travel Solutions Limited
("we", "us", or "our"). We are registered
in England & Wales under company number 1966624, and have our registered
office at Unit 5 Petre Court, Petre Road, Clayton Business Park, Clayton Le
Moors, Accrington, BB5 5HY. Our VAT number is 464644528.
We are a "controller" for the purposes of the EU General Data
Protection Regulation 2016/679 and the Data Protection Act 2018 (the
"Act" and "GDPR" respectively, and together the "Data
Protection Legislation"). This means that we are responsible for, and
control the processing of, your personal information. We are registered as a data controller with the Information
Commissioner's Office and our registration number is Z283227X.
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.
If you have any questions about how we use your personal information, please
contact travel.solutions@firstbus.co.uk or you can write to us at First Travel
Solutions, Unit 5 Petre Court, Petre Road, Clayton
Business Park, Clayton Le Moors, Accrington, BB5 5HY.
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 or
other competent supervisory authority of an EU member state if the App is
downloaded outside the UK, about how we use your personal information for the
operation of the App.
2.THIS POLICY
This policy (together with the App's terms of use applies to your use of the
App once you have downloaded a copy of the App onto your mobile telephone or
handheld device.
Changes to the privacy policy
We keep this privacy policy under regular review. It may change and if it does,
these changes will be posted on this page and, where appropriate, notified to
you when you next open the App. The new policy may be displayed on-screen and
you may be required to confirm that you have read the changes to continue your
use of the App.
3.THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about
you through your use of the App, as follows:
·
Device Data – the type of mobile
device that you use, a unique device identifier (for example, your Device’s
IMEI number, the MAC address of the Device’s wireless network interface, or the
mobile phone number used by the Device), and your mobile operating system;
·
Personal Data – your first name,
last name and contact number;
·
Usage Data – details of your use
of the App, including analytics data where you consent to analytics; and
·
Location Data – your location
data while the App is running on your mobile device
·
Vehicle Data – your vehicle
registration and mileage
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 for the purposes of the App.
4.HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. Most
commonly we will use your personal data in the following circumstances:
·
Where you have consented before
the processing.
·
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 process your
personal data in pursuit of our legitimate interests, we take steps to ensure
that we are only collecting information that we need to ensure that your
fundamental rights are not overridden.
·
Where we need to comply with a
legal or regulatory obligation.
5.PURPOSES FOR WHICH WE USE YOUR
PERSONAL DATA
Installing the App and redeeming a service as a driver for tracking.
It is necessary for our legitimate interests (to require use of the App as this
is more efficient that the use of other technologies that perform the same or
similar functions).
Type of Data
·
Device Data
·
Personal Data
To administer and protect our
business and this App including troubleshooting, data analysis and system testing.
It is necessary for our legitimate interests (for running our business,
provision of administration and IT services, network security). Consent (in
particular your consent for the use of analytics technologies on your device).
Type of Data
·
Device Data
·
Usage Data
To monitor the services that you are providing to us
Consent (on our using shared data and your consent for the use of analytics technologies
on your device)
Type of Data
·
Device Data
·
Usage Data
·
Personal Data
·
Location Data
· Vehicle Data
To monitor trends so we can
improve the App for users
Consent (in particular your consent for the use of analytics technologies on
your device). Necessary for our legitimate interests (to keep records updated
and to analyse how App users use the App).
Type of Data
·
Device Data
·
Usage Data
·
Personal Data
·
Location Data
6.YOUR LEGAL RIGHTS
In addition to the right to be informed about how we use your personal
information (as set out in this privacy notice), you have various other rights
in respect of the personal information we hold about you – these are set out in
more detail below. If you wish to exercise any of these rights, please contact
us at the details in Section 1 above.
·
Access to your personal
information: You can contact us to request the information we hold about you,
as well as supplementary information such as why we have that information, who
has access to the information and where we got the information.
·
Withdrawing consent: If you have
given us your consent to use your personal information, you can withdraw your
consent at any time. This will not affect the lawfulness of our use of your
information before you withdrew your consent. We only require your consent for
the use of analytics technologies on the App, and you can withdraw your consent
to this by deleting the App from your device.
·
Correction of your personal
information: If the information we hold about you is out of date, incomplete or
incorrect, you can ask us to update it. You can also update your information at
any time on the App.
·
Erasure of your personal
information: You can request that we erase the information we hold. When we
receive your request, we will confirm whether the information has been deleted
or tell you the reason why it cannot be deleted. For example, we may need to
continue to hold your information if we need it for legal reasons or in
connection with legal claims.
·
Objection to processing your
personal information: You have the right to request that we stop processing
your information 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. Upon receiving the request, we
will contact you to tell you if we are able to comply or if we have legitimate
grounds to continue – for example, we may need to continue to hold your
information for regulatory or legal reasons. Please note that if you object to
the collection and use of personal data by the App, this may result in you
being unable to provide and be paid for services to FTS.
·
Restriction: You can ask us to
temporarily limit the use of your personal information, for example where you
have questioned the accuracy of your information or how it is being used, but
you do not want us to delete it. Please note that if you ask us to restrict the
processing of your personal data in a way that inhibits the full functionality
of the App, this may result in you being unable to provide and be paid for
services to FTS.
·
Portable data: You can ask us to
provide you or a third party with some of the personal information that we hold
about you in a structured, commonly used, electronic form, so it can be easily
transferred. Once we have received your request, we will comply where it is
feasible to do so.
Please note, some of these rights only apply in certain circumstances and we
may not be able to fulfil every request. If we receive a request from you
to exercise any of the above rights, we may ask you to verify your identity
before acting on the request; this is to ensure that your data is protected and
kept secure.
You can make a complaint to us by contacting us at the details in Section 1
above or to the data protection supervisory authority – in the UK, this is the
ICO, at https://ico.org.uk/.
7.SHARING YOUR PERSONAL DATA
We may pass your information to the following third parties for limited
purposes:
·
Other members of our group for
administration or reporting purposes;
·
Technology service providers who
provide IT support for the running of the App;
·
Our IT contractors who help with
the operation and support of the App.
Occasionally, we may need to disclose your personal
information to third parties where necessary for the legitimate interests of
our business or in order to comply with legal obligations, for example:
·
If we have to disclose or share
your personal information in order to comply with any legal obligation or
request from a regulator or governmental agency, or to detect or prevent fraud
or crime;
·
with our professional advisers,
including lawyers, bankers, auditors and insurers who provide various services
to us; and
·
To enforce or apply our App terms
or other agreements, to protect the rights, property or safety of our group,
our customers or others, and in connection with legal claims.
8.INTERNATIONAL TRANSFERS
We may need to transfer your personal information to countries which are
located outside the EEA and UK for the purpose of improving our service.
Information
Commissioner's Office (ICO)
We will take all steps reasonably necessary to
ensure that your personal information is handled securely and in accordance
with this privacy notice and the relevant Data Protection Legislation. These
include ensuring, where the country does not provide an adequate level of
protection, that our overseas suppliers enter into a European Commission
approved contract.
If you would like further information, please contact us at the details in
Section 1 above.
9.DATA SECURITY
Your use of the App
When you are using the App, you will have access to the personal data
(including names and addresses) of our customers. You should handle this
information with utmost care and in compliance with your data processing
obligations under your service agreement with FTS.
In the event that you lose your device or otherwise disclose any of the
personal data without authorisation, you must contact our 24/7 control centre
immediately.
Your personal data held on the App
All information you provide to us is stored on our secure servers. Where we
have given you (or where you have chosen) a service identifier to redeem a
service that enables you to access the App, you are responsible for keeping
this confidential. We ask you not to share a service identifier or password
with anyone, for any purposes.
Once we have received your information, we will use strict procedures and
security features to try to prevent your personal data from being accidentally
lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach
involving the App and where this affects your data, we will notify you and any
applicable regulator when we are legally required to do so.
If you would like any further information about our policies and procedures
relating to the security of your personal data, please contact us using the
details in Section 1 above.
10.DATA RETENTION
We will not retain your personal information for any longer than is necessary
for our purposes, including for the purposes of satisfying any legal,
accounting or reporting requirements. If you would like further information,
please contact us using the details in Section 1 above.
In some circumstances you can ask us to delete your data: see Section 6 above
for further information.
11.COOKIES AND SIMILAR TECHNOLOGIES
We use certain technologies to store and access information on your device in
connection with your use of the App. For detailed information on our use of
these technologies, the purposes for which we use them and how you can exercise
your choices regarding our use of these technologies, see our Cookie Policy