Version 1.0 - 28 February 2017
The App is operated by TravelHero Limited ("TravelHero", “we”, “us”, “our”). We are a company registered in England & Wales (Company Number: 1940333, VAT No. GB 435 7578 19), and have our registered office at One Stockport Exchange, 20 Railway Road, Stockport SK1 3SW. TravelHero is the data controller of your personal data and is subject to the Data Protection Act 1998 (“DPA”) (and, once in force, to EU Regulation 2016/679 (the “GDPR”)).
You can find all our contact details at www.travelheroapp.com.
Information we may collect from you
We offer you the ability to register a personal account, so that your preferences and travel data can be accessed from different devices that you use.
This means we need to collect certain information from you, which will be linked across our systems, such as:
● your log in details, to record your experience on the App
● your preferences, such as your favourite journeys or locations
● contact information, such as your name, email address or telephone number
● messages you send us when reporting a problem, submitting queries or comments
● information from surveys that we run on the App
You don't have to provide any of the above information, but if you choose not to share something, we may not be able to provide you with some of our services.
Your credit/debit card and related personal details are collected on our behalf by trusted third party payment service providers in order to process your orders.
More details about the payment service providers we use are available from us on request.
If you are not the credit/debit card holder, you must ensure that you have the card holder’s consent before entering any details and that those details are true.
We will also collect the following information automatically when you use the App:
● your location, movement and method of transport used
● details of your visits to the App
● searches you make
● pick-up and destination addresses and booking details for on-demand transport
● resources you access
● data you download
● the unique identifiers that we assign to your mobile device
● the type of mobile device you use
● the operating system you use
Using your information
We will use the information we collect to:
● provide our services to you
● personalise the App and provide you with information relevant to you
● recommend transport options which match your stated preferences and previous use of the App
● administer your account with us
● respond to your emails to discuss your use of the App and answer any questions you may have about the App
Our main legal basis for processing your personal information for the purposes set out above is that we have your consent to do so.
You can withdraw this consent at any time by contacting us using the link below.
Please note that, if you do so, we may no longer be able to provide some or all aspects of the TravelHero services to you.
Another legal basis is that it is necessary for us to process this personal information in order to enter into and perform a contract with you.
We will also use the information to:
● identify issues with the operation of the App and provide crash reports to resolve performance issues
● to help develop and improve our services
● improve the design, functionality and content of the pages of the App and customise them for users
● carry out research on our users' transport choices
● analyse the performance of our business and services generally
● disclose to lawful authorities when required to do so by law or where appropriate in our opinion as a responsible company
● develop or inform measures to enhance users’ experience
● to prepare anonymised and aggregated data sets (see further below)
Our legal basis for processing your personal information for the purposes set out above is that such processing is necessary for our legitimate interests in improving our services and operating our business and services efficiently.
We may disclose aggregate statistics about users of the App and anonymised data on your location, movement and transport choices, to selected third parties for research analysis, product development and for other lawful purposes. These statistics will not include any personally identifiable information.
We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the App or enforce the terms under which you transact with us or enforce the rights, property or personal safety of any person.
We may also disclose your personal information to organisations that provide services to us that require the processing of your information (for example, contractors involved in the update and/or maintenance of the App, including App designers, technical consultants and other third parties who track or analyse the information collected through the App).
This information will be used by such organisations only to perform their functions and/or to provide the service you have requested and for no other purpose.
We will transfer your personal information to third party transport operators (“Operators”), in order for them to fulfil the journeys booked through the App.
Please note that TravelHero is the Operators’ agent, and, on booking a journey, you will enter into a separate agreement with each Operator.
This means that each Operator will be responsible for their use of your personal information (acting as a data controller), and TravelHero takes no responsibility for such use.
In addition, we may share your personal information with our employees, agents and professional advisers, with other companies in the Stagecoach Group plc group of companies, and with purchasers, or potential purchasers, of all or part of our business, and their professional advisors. Any such information will be shared on a confidential basis.
Storage of your information
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) and may be processed by staff operating outside the European Economic Area.
While we will always take appropriate steps to protect and secure your personal information, please be aware that some countries outside the European Economic Area have laws or standards concerning the protection of personal data which are significantly poorer than those of countries within the European Economic Area.
By submitting information via the App, you agree to this storing, processing and/or transfer of that information.
The App may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
We may send you information we think you might find useful or which you have requested from us by push notification, SMS (Short Message Service) and/or email (if provided), and we or the operating system will always give you the option to opt-out of receiving further notifications, SMS and/or emails.
We take the privacy of your personal information very seriously and we are committed to ensuring we comply with the DPA (and, once in force, the GDPR), which includes taking steps to prevent unauthorised access, alteration, disclosure or destruction of information we hold.
Some of the important measures we take are to:
● continually review our information, storage and processing practices, including physical security measures, to guard against unauthorised access to systems
● restrict access to personal information to Stagecoach Group employees, contractors and agents who process it for us
We use many administrative, electronic and physical security measures to ensure your personal information remains secure, but we can't guarantee that loss, misuse or alteration of information will never happen, because there is always some risk involved when transferring information via the internet.
We may retain your personal information for as long as permitted for legal, regulatory, fraud and other financial crime prevention and legitimate business purposes.
After this period, while we will take reasonable steps to delete your personal information, there may be residual personal data that remains within our databases.
You have a legal right under the Data Protection Act 1998 to a copy of all your personal information held by us.
On request, we will provide you with a copy of this information subject to an administrative fee.
You also have a right to correct any errors in that information. As mentioned in the Notifications section above, you have a right to prevent the use of your personal information for marketing purposes.
In addition to the above, once the GDPR comes into force in May 2018, you will also have:
- the right to require us to erase your personal data, and
- the right to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller (known as the right to “data portability”)
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
You can exercise the above rights by contacting us at any time by clicking on the link below.
If you are not satisfied with how we are using your personal information, you should contact in the first instance by using the link below. Alternatively, you have the right to lodge a complaint with the Information Commissioner (www.ico.org.uk).
When you interact with the App, we try to make that experience simple and meaningful. When you visit our App, our server sends a token to your mobile device.
These tokens are small pieces of information which are issued to your device when you visit an App and which store and sometimes track information about your use of the App.
A number of tokens we use last only for the duration of your App session and expire when you close your App.
These are known as "session tokens". Other tokens are used to remember you when you return to the App and will last for longer than the duration of your app session.
These are known as "persistent tokens".
We use tokens to:
- remember that you have visited us before; this means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users of the App
- customise elements of the promotional layout and content of the pages of the site
- collect statistical information about how you use the site so that we can improve the App and learn which parts are most popular
Some of the tokens used by our App are set by us and some are set by third parties delivering services on our behalf.
For example, we use Google Analytics to track what users do on the App so we can improve its design and functionality.