CITYMAPPER'S PRIVACY POLICY

This privacy policy takes effect on 23 May 2018. In this version of our privacy policy, we have increased the level of detail used to describe what information we collect from you, on what basis we collect it, how we use it, and rights you have to control how we use it.

This policy applies to anyone who uses our website, www.citymapper.com ("Site"), our app ("Citymapper App"), our transportation services ("CM Smart Ride"), and our driver app ("Driver App"). We'll refer to the Site, Citymapper App, and Driver App together as "the App".

"We", Citymapper Limited, a company registered in the UK, are the data controller as defined by the General Data Protection Regulation.

WHAT INFORMATION DO WE COLLECT AND WHY?

There are three categories of information we collect: (1) information you provide, (2) information created when you use our App or CM Smart Ride; and (3) information from other sources.

  1. Information you provide

    When you use our App or CM Smart Ride, you might provide us with (a) personal information; (b) places and preferences; and (c) direct communications.

    1. Personal Information

      If you're a user of the Citymapper App and Site and you choose to create a Citymapper account, you provide us with your name and email address, which we use to ensure your saved places and other personalisation features are synced across your multiple devices. When you log in using Facebook or Google, we do not send them any data about you, and we do not collect any information from them.

      If you're a CM Smart Ride Passenger, you provide us with your name and email address because private hire regulations require us to record your name, and we require your email address to provide customer service and help ensure the safety of our transport services. You are also required to provide payment details in order to ride on our services.

      If you're a CM Smart Ride Driver ("Driver"), you provide us with your name, email address, phone number, address, date of birth, driver licence information, vehicle information, insurance information, bank details, national insurance number, private hire licence information, vehicle inspection reports, history of tickets/fines/violations, your driving shifts and your driver log-in details. This information is required for us to comply with relevant legal requirements, including regulatory requirements and tax laws, as well as to perform our contract with you.

    2. Places and Preferences

      Regardless of whether you have a Citymapper account, you may choose to provide us with information on your places and preferences, such as Home, Work, Saved Places, and other travel preferences. We process this information in order to provide you with personalised journey-planning services. We also store and analyse this data in aggregate to improve the Citymapper App (for example, by ranking certain journey results more highly than others), and to create and evaluate routes for CM Smart Ride.

    3. Direct Communications

      Communications you might send to us include responses to in-App survey questions, reporting a problem, or submitting queries, concerns or comments regarding the App or CM Smart Ride. These messages to us will also contain details such as the type of phone you're using, your service provider, and if you've enabled the location permissions in your device, the latitude and longitude of your location when you contact us. We process this information in order to fix problems in the App or with CM Smart Ride, to reply to your communications, and to keep CM Smart Ride safe.

  2. Information created when you use our App or CM Smart Ride

    The following are the types of information created when you use our App or CM Smart Ride. We associate this information with an installation ID number that is randomly generated each time you install the Citymapper App. We use this installation ID to pseudonymise the data we collect from you, and do not access any permanent device ID numbers.

    1. Location Information

      Users of the Citymapper App: We aggregate and analyse journey start and end points. Assuming you've enabled your device to provide location information and you haven't entered your start point manually, we collect and use your start location information as determined through data such as GPS, mobile phone towers, and WiFi. If you haven't enabled your device to provide location information, you will have to manually enter your start and end points, which is then the location information we collect and use.

      When you hit GO in the Citymapper App, we collect your location information throughout your journey. We use this data to provide on-trip support, such as alerting you when to get off a bus. We also store and analyse this data in aggregate, as we do with the other types of location data described in this "Location Information" section, to improve the journey results we show to all users and to create and evaluate routes for our transportation services.

      Passengers of CM Smart Ride: If you are a passenger of CM Smart Ride, we collect your location information when the Citymapper App is running both in the foreground and background of your device during your journey. Knowing your location at all times during your Smart Ride journey enables us to provide on-trip support and maintain passenger and driver safety.

      When you ride CM Smart Ride, in addition to your location data, we collect and store your booking details, your Driver and vehicle information, the date and time of your journey, the amount charged, your pick up and drop off location, cancellations and no-shows. We store and use this information to comply with legal record-keeping requirements, for operational reasons, such as providing customer support, and to improve our service.

      Drivers of CM Smart Ride: If you are a Driver of CM Smart Ride, we collect your location information throughout your shift, starting from when you log in to the Driver App and stopping when you log out of the Driver App.

    2. Device Information

      We collect information about the devices you use to access our App and to use CM Smart Ride, including the type of computer or device you use, the installation ID of the App on your device, the hardware models, operating systems and versions, software, file names and versions, the preferred languages, time zone settings, and device motion information. This information is necessary for us to diagnose bugs and improve the App.

    3. Log and Usage Information

      Each time you interact with our App, we collect information about how and when you use it, such as the time and date when you opened the App, the searches you make, the features and journey results you click on, pages visited, app crashes and other system activity. We use this information to improve our App in multiple ways. For example, using App crash data, we can fix bugs and prevent future crashes, and by knowing what gets tapped or scrolled most often, we can replace unpopular features with other, more helpful features.

    4. Cookies

      The App uses cookies to store certain information. Cookies are pieces of information that a website or app transfers to your hard drive or mobile device to store and sometimes track information about you. Although they identify a user's device, cookies do not reveal the name, email address or other obvious identifiers of users.

      When you interact with the App, we try to make that experience simple and meaningful. When you visit our App, our server sends a cookie to your computer or mobile device, depending on how you access the site or App. Cookies are small pieces of information which are issued to your computer when you visit a website and which store and sometimes track information about your use of the site. A number of cookies we use last only for the duration of your web session and expire when you close your App. These are known as "session cookies". Other cookies are used to remember you when you return to the App and will last for longer. These are known as "persistent cookies".

      We use cookies to:

      • remember that you have visited us before, which allows us to identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get; customise elements of the promotional layout and/or content of the pages of the App; and

      • collect information about how you use the App so that we can improve the App and learn which parts of the App are most popular to visitors.

      Some of the cookies used by our App are set by us, and some are set by the third-party analytics and crash/error-reporting companies we've described in this policy who are acting on our instructions. For example, Mixpanel tracks what users do in the Citymapper App so we can improve the design and functionality.

      Most browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers. By blocking or deleting cookies you may not be able to take full advantage of the App's features.

  3. Information from Other Sources

    Citymapper collects the following types of information from other sources.

    1. User feedback on Drivers of CM Smart Ride

      We receive feedback on Drivers from users of CM Smart Ride in the form of ratings, compliments or incidents. We use this feedback to improve the CM Smart Ride experience for passengers and to help ensure that CM Smart Ride is safe and reliable.

    2. Payment information

      In order to pay for your ride on CM Smart Ride, you will need to provide payment information to our third-party service provider, Stripe, such as your credit card details. Apple Pay and Google Pay are also enabled in the Citymapper App. These three companies provide us only with the last four digits of your card number and expiration date, which we require in order to handle operational issues such as passenger queries about charges.

    3. Log-in Information

      If you log into your Citymapper account using Facebook or Google, those companies provide us with your name and email address, which are necessary for us to log you in to the Citymapper App. We do not collect or use any other information received from those two companies.

    4. Insurance providers

      If you are a Driver, we receive information relating to your insurance policies and licensing information. This information is necessary for us to comply with relevant legal requirements and to ensure the safety of CM Smart Ride.

HOW WE USE YOUR INFORMATION, SUMMARISED

In summary, we use the information we collect to:

We work hard to improve the App and add functionality, which we think will make it safer, more fun and more useful for our users. New functionality may involve similar or incidental uses of your data to those set out above. We regularly review the way we use data, and will update our privacy policy to reflect these improvements to the App.

WHAT OTHER COMPANIES RECEIVE YOUR INFORMATION?

To the extent we share information with other companies, we do so to enhance your experience with the App, and we pseudonymise and minimize the data we send to them.

WHAT'S OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION?

We'll only process your personal information where we have a legal basis for doing so. Our legal basis to process your personal data includes processing that is:

WHAT ARE YOUR RIGHTS IN RELATION TO PERSONAL DATA WE HOLD ABOUT YOU?

Access

You have a legal right under the GDPR to request access to a copy of the personal information about you held by us. In order to do this, contact us at support@citymapper.com. Please use the subject line "DSAR" and include details about what personal information you're looking for. You will need to have created an account in order for us to provide you with your information because without an account, we are not able to connect your Installation ID to a verifiable email address.

Deletion

Subject to any legal obligations to keep your information longer, we store your personal information for as long as is necessary to provide our services and products, or until you ask us to delete it, whichever comes first.

If you ask us to delete your personal information by emailing us at support@citymapper.com, please use the subject line "Account Deletion."

Note that residual copies may take longer to be removed from our backup systems. We will keep a record of your request in order to ensure compliance with legal obligations.

Marketing opt-out

You have the right at any time to prevent the use of your personal information for direct marketing purposes. If you no longer want to receive marketing messages from us, please let us know by writing to us at support@citymapper.com, and you will be unsubscribed accordingly. Please note that sometimes it can take a short amount of time to refresh our records for these purposes. Also, we may still send you non-promotional messages, such as receipts for your rides or information about your account.

Notifications

We may send you information we think you may find useful (e.g., tube line and subway disruptions and alerts about CM Smart Ride relevant to you) or which you have requested from us by push notification and/or by email (if provided), and we or your device's operating system will give you the option to opt-out of receiving further notifications or emails.

HOW WE KEEP YOUR INFORMATION SECURE

We place great importance on the security of all information associated with our users. We use measures such as encryption, pseudonymisation, information access controls, and firewalls.

Keep in mind that submission of information over the internet and mobile networks is never entirely secure. We cannot guarantee the security of information you submit via the App whilst it is in transit over the internet or mobile networks and any such submission is at your own risk.

WHAT COUNTRIES WILL YOUR PERSONAL INFORMATION BE SENT TO?

Information that you submit via the App is sent to and stored on secure servers located in the United Kingdom, other European Economic Area countries and in the United States. Information submitted by you may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above, which may be situated outside the European Economic Area (for instance in the United States).

DO YOU COLLECT CHILDREN'S INFORMATION?

We do not knowingly collect personal information from children under the age of 13. If you're under the age of 13, please do not submit any personal information through the App or email. We encourage parents and legal guardians to monitor their children's internet use and to help enforce our privacy policy by instructing their children never to provide personal information on our website without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us as specified below, and we will work to delete that information from our databases.

HOW WILL YOU KNOW ABOUT CHANGES TO OUR PRIVACY POLICY?

We may revise this privacy policy from time to time. Any changes and additions to this privacy policy will be posted in the App and are effective from the date on which they are posted. Please review this privacy notice from time to time to check whether we have made any changes to the way in which we use your personal data. This privacy policy was last updated on 23 May 2018.

WHAT IF YOU HAVE A COMPLAINT?

We work hard to handle your information responsibly. If you're unhappy about the way we do this, please contact our Data Protection Officer by email to support@citymapper.com.

However, you also have the right to lodge a complaint about the data processing activities carried out by Citymapper with our lead supervisory authority, the UK Information Commissioner's Office.

HOW TO GET IN TOUCH WITH US

Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to our Data Protection Officer at support@citymapper.com. You can also reach us at Data Protection Officer, Citymapper Limited, Cargo Works, 1-2 Hatfields, London, SE1 9PG, United Kingdom.