Effective date: November 10, 2019
Our Services allow you to buy (or receive) and use transit passes with participating transit agencies (“Agency” or “Agencies”) through our mobile applications (also referred to as the “TT App”) or through third party applications (including mobile applications and/or websites) that integrate with our Services if you have agreed to use the Services through such third party applications (each a “Third Party App with TT Integration”).
We endeavor to protect the security of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. You must prevent unauthorized access to your account and Personal Information by limiting access to your computer or device and browser, for example, by never sharing your log-in information.
We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Information such as your name, email address, and phone number. If you make a purchase through the TT App or through a Third Party App with TT Integration, we may collect information or be provided with information by provider of the Third Party App with Integration (“Third Party App Provider”) needed to process your transaction, and use and disclose it for that purpose. This information may include your email address, full name, and your payment information such as cardholder information, credit card or debit card and bank information. Certain information may be required to register with us or to take advantage of some of our features.
We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, where permitted by law, we may send you promotional email offers regarding our Services, on behalf of other businesses, or email you about your use of the Services. If you provide us with your wireless phone number for the purpose of obtaining access to the TT App or use our Services through a Third Party App with TT Integration, you understand and agree that you will receive an access code to enable you to access and use the TT App or use our Services through a Third Party App with TT Integration via text message. This may be sent using automated dialing technology. If you make a purchase, you understand and agree that you may receive a receipt and other transaction documents at the email address you provide. Separately, if you confirm that you want to receive other text or email messages, Token Transit may send you information that may facilitate your use of the Services, which may include Token Transit using automated dialing technology to text you at the wireless number you provided. If you do not want to receive commercial communications from us, please indicate your preference by emailing email@example.com. If you opt-out, you may still receive transaction notices or receipts from us by email if you make a further purchase. We may also collect and use your Personal Information for other purposes which are permitted or required by applicable law, or which we disclose to you and you consent.
Whenever you interact with our Services (including through the TT App or through a Third Party App with TT Integration), we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data (see below, “Location Information”), device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features (for example, you may need to allow for cookies if you want to remain logged into our website over repeat visits).
We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
Whenever you interact with our Services through a Third Party App with TT Integration, the third party responsible for the Third Party App with TT Integration (the “Third Party App Provider”) may provide us with the following information so that we can provide the Services requested (e.g., make or validate a ticket purchase from within the Third Party App with TT Integration):
How do we collect location information? Our Services make use of precise (and non-precise) location-based data, which may be derived from your mobile device’s WiFi signal, Bluetooth signal, GPS data, your device’s cellular data, and other settings on your device. This data may be collected when your TT App or a Third Party App with TT Integration is in “background” mode, which means it may be collected even if your TT App or a Third Party App with TT Integration is not open, depending on your device settings for the TT App or Third Party App with TT Integration. Some Agencies use “beacons” on their vehicles in conjunction with our Services. These beacons emit a signal and if you have Bluetooth enabled on your device for the TT App or Third Party App with TT Integration, we are able to calculate the range between your device and the Agency beacon. The use of beacons with our Service improves our ability to connect the user to a specific vehicle. If you are using our Service through the TT App, we will provide you with notification of this location tracking, its purpose, and information regarding your options within the TT App. If you are using the Service through a Third Party App, the Third Party App Provider, not TT, is responsible for providing you with notification of this location tracking, its purpose, and information regarding your options within the Third Party App with TT Integration.
How do we use location information? We use, and may share with Agencies, precise and non-precise location information for different purposes, including, (i) to present nearby options and promotions that may be relevant to you (for example, to select Agencies that are closest to you so you can purchase passes from them through the Service without having to locate and select the Agency manually in the TT App), (ii) with some Agencies to enable the use of the TT App to ride on vehicles without the need for you to open the TT App or provide visual verification that you purchased a pass, and (iii) for analytics purposes to improve our Service and the service of the Agencies; for example, in connection with Agencies we work with, we may use location data to determine when users of our Service board and depart vehicles, and at which stops, which helps determine how popular individual origin and destination stops are at different times of day and how many miles users of our Service have traveled. We may also share this location analytics data with Agencies for their own ridership reporting requirements and/or planning purposes (e.g., to help them improve their services). The Third Party App Provider may also collect location data when you use the Third Party App with TT Integration; TT is not responsible for any Third Party App Provider.
What choices do you have regarding collection of location information? You may be able to adjust the settings of your device so that information about your physical location is not sent to us by (a) disabling location services and/or Bluetooth within the mobile device and/or mobile app settings, depending on the platform you use to access our Services or (b) denying certain websites or services permission to access location information by changing the relevant preferences and permissions in your browser settings. Please be advised, for some features of our Service to function, you may be required to enable location services and/or Bluetooth for the TT App or the Third Party App (if you are using the Services through a Third Party App); in some cases opting out may disable your ability to use the Services or features within the TT App or Third Party App to buy and use transit passes (including when this is required by an Agency’s policy).
Transit Agencies. We may share your Personal Information with an Agency (a) to enable that Agency to provide you with customer support regarding your use of our Services with that Agency and (b) to allow the Agency to verify that you have an appropriate transit pass in the TT App or Third Party App with TT Integration when you ride the Agency’s vehicles, including Transit Program passes (described above). We may also share analytical data to assist the Agency in analyzing its services by sharing information such as when and where users of our Service board and depart Agency vehicles and the frequency that riders use different types Agency passes). We have no control over the policies and practices of Agencies as to privacy or anything else, so if you choose to take part in any transaction or service relating to any Agencies, including purchasing transit passes for use with a Agency, please review their policies.
Affiliated Businesses. In certain situations, businesses or third party websites and services we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we may share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites services as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or service, please review all such services’ or websites’ policies.
Agents and Service Providers. We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to receive and process your credit card transactions for us and a telecommunications company to send our text messages to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
Business Transfers. We may choose to buy assets or sell our business assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
Information that’s been de-identified. We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners without restriction. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal experience.
Analytics. Token Transit uses third party analytics services, including Google Analytics to collect and analyze this data, as described here: www.google.com/policies/privacy/partners/.
We may also disclose your Personal Information for other purposes which are permitted or required by applicable law, or which we disclose to you and you consent.
Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:
The information you can view, update, and delete through your account settings may change as the Services change. You may have a right under applicable law to request access to your Personal Information and to request a correction to it if you believe it is inaccurate. If you have submitted Personal Information to Token Transit and would like to have access to it, or if you would like to have it removed or corrected, please contact us at firstname.lastname@example.org. We will try to comply with your request; however, in some cases we may not be able to allow you to access certain Personal Information in certain circumstances, for example if it contains Personal Information of other persons, or for legal reasons. We may require you to verify your identity before we are able to provide you with your Personal Information. If you have any questions about viewing or updating information we have on file about you, please contact us at email@example.com.
Although we have taken measures to help protect Personal Information that we have collected from unauthorized use, access, disclosure, misuse, alteration or destruction, no security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.
Some or all of the Personal Information we collect may be stored or processed on servers located outside your jurisdiction of residence, including in the United States, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.
You can always opt not to disclose certain information to us, and you may be able to opt out of or disable certain location tracking features as described above, but keep in mind some information may be needed to register with us and use the Services or to take advantage of some of our features.
You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by contacting firstname.lastname@example.org. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.