Privacy Policy

UWL TRAVEL APP CUSTOMERS AND PASSENGERS

1. Who does this privacy notice apply to, and what is it about?

This privacy notice applies to you if you are or were a passenger on the University of West London shuttle bus service, which we operate on behalf of the University of West London (the “UWL Services”).

This privacy notice also applies to you if you are visitor to, or registered user of, the associated website at https://uwl.bushub.co.uk/ (the “Website”) and/or the associated UWL Travel mobile application (the “Travel App”).

This privacy notice explains:

what personal data we collect about you;
what we do with your personal data;
your rights in respect of your personal data; and
what to do if you have any questions or complaints about our use of your personal data.

We take your privacy very seriously and are committed to abiding by the Data Protection Law which protect your privacy.

This privacy notice may change from time to time and the most up-to-date version will always be available on the Website and the Travel App. It is your responsibility to read this privacy notice and check the Website or the Travel App for the current version.

2. Who is controller of your personal data?

For the purposes of this privacy notice, we shall mean The Kings Ferry Limited, trading as National Express Transport Solutions.

The controller’s representative for the purposes of this privacy notice is the National Express UK Data Protection Officer, who can be contacted using the contact details provided at the end of this notice.

3. What personal data do we collect about you, and how?

We collect the following types of personal data about you:

your name;
your contact information, including student email address;
if you register to use the Website and/or the Travel App, your email address, username and password;
if you claim a free travel ticket or annual pass on the Website and/or the Travel App;
your image, where it is captured by CCTV or other visual recording equipment on the passenger carrying vehicles used to provide the UWL Services;
your voice, where this is captured by CCTV or any other audio recording equipment at on the passenger carrying vehicles used to provide the UWL Services and/or where captured in recorded telephone conversations with you in respect of the UWL Services, the Website and/or the Travel App; and
any other personal data that you provide to us when you communicate with us in respect of the UWL Services, the Website and/or the Travel App.

Technical data, including:

Browser type and version;
Time zone setting and location;
Operating system and platform;
Account use, history and analytics; and
IP/ID Device identifiers to allow push notifications to be sent to the passengers on changes for services and/or allowing the passenger to track the vehicle at any time.

Transaction data, including:

The full Uniform Resource Locators (URLs) clickstream to, through and from the Website or the Travel App (including date and time);
Time on Website or Travel App page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page; and
Travel preferences, browsing behaviour so we can see what is being accessed and viewed the most.

We collect your personal data in a variety of ways, including:

by you:
- When you visit the Website or Travel App;
- creating an account on the Website or Travel App;
- accessing products and/or services from the Website or Travel App;
- submitting your personal data on the Website or Travel; App, for example, via the ‘Contact Us’ page
- providing your personal data to us when communicating with us in any manner in respect of the UWL Services the Website and/or the Travel App, for example, when you:
  - speak to one of our representatives in person on-board one of our passengers’ carrying vehicles; and
  - contact us by letter, email, telephone call or on social media;
- submitting information when registering or using our on-board Wi-Fi or entertainment services;
by us:
- making visual and/or audio recordings on the passenger carrying vehicles used to provide the UWL Services; and
- recording telephone conversations with our customer contact centre representatives in respect of the UWL Services , the Website and/or the Travel App.

4. What do we do with your personal data and on what basis?

We use your personal data for the following purposes and describe below the legal basis on which we process your personal data:

Purpose
- To provide our products and services to you
- To provide you with information, advice and guidance about our products and services
- To manage our relationship with you, including to respond to any questions you ask and deal with any complaints you make
- To develop our strategy and operational processes
- To study how our customers and/or passengers use products and services provided by us and third parties
- To manage how we work with other companies that provide services to us and our customers
- To comply with the laws and regulations that apply to us
- To seek to enforce and defend our legal rights
- To seek to detect, investigate, prevent and report crime and anti-social behaviour
- To seek to protect and promote your health & safety and that of our other customers, staff and third parties
Legal Basis
- Fulfilling our legal duty
- Performance of a contract to which you are a party
- Legitimate interest
Explanation
- Being efficient about how we fulfil our legal and contractual duties and manage our relationship with you
- Keeping our business records up to date
- Developing and improving our business
- Developing our products and services, and what we charge for them
- Developing relationships with business partners, to enhance our product and service offering
- Preserving our legal position, seeking to detect and prevent crime and anti-social behaviour and seeking to promote health and safety
- Enabling us to provide safe passenger transport services

5. What if we have obtained your consent to use your personal data?

If we obtain your consent for any use of your personal data (which is likely to be for a purpose that is not described in this privacy notice), you may withdraw that consent at any time and we will give you further information in any consent form by which we obtain your consent on how to withdraw your consent.

6. What are our obligations to collect, and your obligations to provide, personal data?

We have no legal obligation to collect personal data about you, but we need to collect some personal data in order to provide you with our products and services, and deal with any questions or complaints you have about them. You have no legal obligation to provide your personal data to us, but we may not be able to provide you with our products and services or deal with your questions or complaints if you do not provide us with your personal data.

7. Who will we share your personal data with?

We may share your personal data with:

other National Express Group companies;
our suppliers and subcontractors who help us to provide our products and services to you;
our legal and professional advisors;
government bodies and regulatory authorities, including the Driver and Vehicle Standards Agency, the Police and other crime prevention and detection agencies and the UK Information Commissioner’s Office;
the Traffic Commissioners, the courts and other dispute resolution arbitrators and mediators, other parties to legal proceedings and passenger transport watchdogs; and
other companies that take on any part of our business as a result of a restructure, merger or transfer of that part of our business.

In addition, if you follow a link to any of the websites of advertisers and affiliates on the Website or the Travel App, these third-party websites may have their own privacy notices or policies. We do not accept any responsibility or liability for these notices or policies or the third parties’ handling of your personal data. Please check the relevant third party’s privacy notice before you submit any personal data to them.

8. Do we make international transfers of personal data?

There may be occasions where it is necessary for us to transfer your personal data to a country outside of the European Economic Area (“EEA”). It is possible that the country concerned may not be deemed to provide a similar level of protection for individuals’ rights in relation to their personal data as in the EEA.

Where we transfer your personal data to other National Express Group companies and/or third parties who process your personal data on our behalf in countries outside the UK that are not deemed to provide a similar level of protection for individuals’ rights in relation to their personal data as in the UK, we have entered into appropriate contracts with those National Express Group companies and/or third parties approved for use in the UK which give personal date the same protection as it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

9. For how long will we process your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting or reporting requirements in respect of our relationship with you.

Where we process your personal data to fulfil:

a legal obligation, we will process such personal data for so long as necessary to fulfil that obligation; or
a contract to which you are a party, we will process such personal data until that contract is fulfilled and for so long thereafter as may be necessary to keep a record of such fulfilment, which will typically be for 6 years, and to deal with any complaints or claims relating to that contract, which will be until the final resolution of such complaints or claims (having regard to the nature of any potential claims and the limitation of liability periods that apply to them).

Where we process your personal data based on our legitimate interest, we will process such personal data for so long as necessary to achieve that legitimate interest, which will typically be for 6 years after we collect your personal data or the last time, we use your personal data (or longer in relation to any legal claims that might arise having regard to the nature of any potential claims and the limitation of liability periods that apply to them

We may also retain your personal data for longer if we cannot delete it for legal, regulatory or technical reasons.

10. What rights do you have in relation to your personal data?

You have a number of rights under the Data Protection Law in relation to your personal data. These include the right, subject to exceptions, to:

request access your personal data;
request rectification or erasure of your personal data;
request restrictions on the processing of your personal data; and
object to our processing of your personal data.

You also have the right in some circumstances to receive a copy of your personal data in a portable format. This right is limited to personal data you have provided to us and is processed on the basis of a contract to which you are a party and/or your consent. It does not cover personal data that we process on other grounds.

If you wish to exercise any of these rights and/or request a portable copy of the data that you have provided and is processed on these bases, please contact the National Express UK Data Protection Officer.

11. What should you do if you have any questions or complaints?

If you have any questions or complaints about how we process your personal data, or otherwise about the matters set out in this privacy notice, please contact the National Express UK Data Protection Officer at:

Address: Data Protection Officer, National Express, National Express House, Birmingham Coach Station, Mill Lane, Digbeth, Birmingham B5 6DD

Email address: data.protection@nationalexpress.com

You also have the right to complain at any time to the UK Information Commissioner's Office about how we use your personal data and can contact them on their helpline: 0303 123 1113 or website at https://ico.org.uk/