Having read this policy, if you want to change the way in which we use your data or if you have a question about how your personal information is used please contact us for customer information using the methods below:
Phone: +39 0712901106
Postal address: WiFiBus by FASTMEDIA srl, Via Albertini 36 – 60131 ANCONA (ITALY)
- Where and how we collect your personal information
- What personal information do we collect and hold about you
- Our legal basis for using your personal information
- Our legitimate interests and your right to object
- How we use your personal information
- How we use your personal information for marketing
- Sharing your personal information
- Your rights regarding our use of your personal information
- Automated Decision Making
- How we keep your personal information up to date
- How we keep your personal information safe
- How long we keep your personal information
- What to do if you have a complaint or query about how we use your information
- Changes to this privacy notice
Where and how we collect your personal information
We collect personal information about you in several ways:
- When you fill in a form on our website, app or wifi portal.
- When you contact us via phone, email, social media or another route
- When you register with us and fill in a form on our website or mobile app, either directly or via a social media account
- When you subscribe to our services
- When you opt-in to receive news by email
- When you complete a survey distributed by us or on our behalf
- When you browse our website, use the WiFibus App or use our on bus Wi-Fi
- When you open or click on any marketing emails we send you
We also collect your personal information from other organizations and sources, for example when you contact us through a social media company such as Facebook, Twitter, LinkedIn or Instagram. Before providing information to us via these channels you should check these companies’ privacy policies and settings to understand how they use your personal information.
What personal information do we collect and hold about you?
When you fill in a form we only require you to supply the information that we need to provide the service you have requested. We will normally ask you to provide us with:
- Your name
- Your contact details
- Information when reporting a problem, submitting queries or comments
- How you would like us to contact you
We don’t collect date of birth information unless such information is necessary for the performance of a contract. We recognize that young people use our services and are legally able to provide consent after the age of 13 years.
When you visit our website, app or register to use our on-bus WI-FI services, we may collect the following information automatically:
- Technical information, including the IP address, used to connect your computer to the Internet, unique identifiers assigned to your device, your login information, the browser you’re using, time zone setting, browser plug in types and versions, the operating system, device type and platform you are using
- Location data and WI-FI usage
- Information about your website or app visit that will help us to improve our service. This can include date and time, which products you looked at or searched for, how long you spent on certain pages, resources you accessed and how you moved around the page, how you clicked to, through and from our website or app and any phone number used to contact us.
In our communications with you by email or other electronic means, we automatically collect data relating to:
- How you interact with our communications, such as which emails you opened or clicked a link within, and how long the email was opened for
- Where you are when you interact with our messages
- What type of device, model and operating system you’re using.
This helps us build a better picture of whether our marketing is effective
When you complete a survey, we may collect additional personal information for customer profiling and monitoring purposes, including (but not limited to): age bands, gender, employment status, postcode and email address.
Whilst we mainly use the personal information that you provide to us, we may sometimes use other public sources of information about our customers and enquirers where you have given your permission for your data to be shared. We do this to help us understand more about our customers, to ensure that our public messages are relevant and to make sure that the marketing information we send you, with your consent, is also relevant. We take great care in sourcing this information but if you prefer us not to use your data in this way then please let us know by contacting firstname.lastname@example.org.
Our legal basis for using your personal information
Under EU data protection law, we must have a valid basis for using your personal information and we may not collect store or use information other than as described in this policy. There are three ways we may have a valid basis for using your personal information:
- Contract—Most of the information we collect from you is necessary to allow us to fulfill our contract with you or to enter into a contract with you e.g. you provide a billing address when you purchase our service via our website; we may need to contact you to notify you about changes to our services.
- Legitimate Interests—We have a legitimate interest in using your personal information e.g. to ensure that the content on our website and app is presented to you and your device as effectively as possible. If this is our reason for using your personal information, we must make sure that our interests do not override yours and you can object to this use of your personal information. We also have a legitimate interest in exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- Legal Obligation—Lastly, we have a legal obligation to use your personal information where lawfully requested or required to do so by public authorities.
A full description of the different types of personal information we process, the purpose of the processing and the legal basis for the processing is shown below:
|Our use of your data||Legal basis for processing|
|To carry out our contract with you to provide you with products and services||Necessary for the performance of our contract with you or to take steps to enter into that contract|
|To notify you of any changes to our service||Necessary for the performance of our contract with you or to take steps to enter into that contract|
|To provide you with marketing information via email, post or other electronic means about goods and services we believe may be of interest to you||You have given us your consent or we rely on legitimate interest|
|To understand the effectiveness of the online advertising we show you and to deliver relevant advertising to you via our website||Our use of your data is necessary for our legitimate interests in ensuring that the service we provide to you is relevant|
|To make recommendations via our website or app regarding goods and services we believe may be of interest to you||Our use of your data is necessary for our legitimate interests in ensuring that the service we provide to you is administered effectively|
|To ensure that the content on our website and app is presented to you and your computer as effectively as possible so that you can use our services||Our use of your data is necessary for our legitimate interests in ensuring that the service we provide to you is administered effectively|
|To create statistical information, market research, analysis and customer group profiles to better manage and run our business||Our use of your data is necessary for our legitimate interests in ensuring that the service we provide to you is administered effectively|
|To monitor our website and app to ensure that they are functioning correctly and that you receive the correct advice|
|To allow you to use the interactive features of our website and app|
|To verify and protect your personal information when using our website or app|
|To provide data to public authorities where legally required.||We have a legal obligation to use your personal information where lawfully requested or required to do so by public authorities|
Our legitimate interests and your right to object
Legitimate Interests means the interests of our company in conducting and managing our business [to enable us to give you the best service/products and the best and most secure experience].
How we use your personal information
- Provide you with the service or information you’ve requested
- Handle the administration of your account, payment, confirm orders
- Alert you about software or hardware updates
- Provide post-sales support and deal with any complaints, refunds or other issues or queries
- Contact you to invite you to participate in research
- Personalise your experience of our website and app by using your browsing activity to make recommendations that we think may be of interest to you
- Improve our website, app and the range of services and products we provide
- Analyse and optimize our marketing activities
- Evaluate and improve our existing products and services, or develop new ones
- Contact you with your consent to tell you about our special offers, promotions, and latest news
How we use your personal information for marketing
We only use your personal information for marketing where you have given us permission to do so or you have provided permission to other organizations to allow us to market to you.
Where you’ve given us permission to do so, we use some of your personal information for marketing. For example, we may use information like name, address, location and past journeys to ensure we make our marketing relevant, accurate, and measure its effectiveness.
By using the information you provide we are able to contact you with specific marketing messages about special offers and promotions,latest news and, depending on the permission you have given us or another organization this may be by post, email, telephone, SMS, social media or other electronic means.
If you have given us your consent to use your personal information for marketing, you have the right to withdraw your consent at any time by contacting us by email info(at)wifibus.it, clicking the “unsubscribe” link in our marketing emails or replying STOP to a text message.
Sharing your personal information
WiFiBus do not share or sell your personal information to any other company for marketing purposes.
Third-party companies will be required to use your personal information in accordance with the Data Protection legislation currently in force. We may also use information in aggregate, where personally identifiable information is removed, for marketing and strategic development to improve and support our business.
Where we use trusted suppliers to help us deliver our service to you, we allow the supplier concerned limited access to the personal data they need to provide their service. A list of just some of the service suppliers are listed below:
- Mailing houses to send you bus tickets, smartcards or other information
- A cloud hosting company, which we use to run our website, app, retail, timetable and database services
- Website hosting companies which we use to administer our website content, including personalized timetables
- Third party payment providers including but not limited to Paypal
- An email service provider to send you emails about information you have requested
- Third parties which we use to analyze traffic and other pseudonymized data on our website and app and use of our services
- Market research and analysis organizations working on our behalf
- Organisations that support our ticketing activities
- Fraud checking and prevention organizations
We also use trusted suppliers to help us with marketing:
- Online media owners who help us target, deliver and track our marketing campaigns using cookies.
All personal information sent to our trusted suppliers is transferred securely. In all cases, we require these companies to comply strictly with our instructions and they are not allowed to use your information for their own business purposes. We also require these companies to have sufficient organizational and technical measures in place to ensure the security of your personal information.
We may use suppliers who operate outside of the country of which you are a resident, for example in the United States. These countries may not offer the same legal protection of your personal information as the EU. If we use one of these organizations, we take appropriate steps to ensure that they provide an adequate level of protection in accordance with EU data protection law. By submitting your personal information to us you agree to this transfer, storing or processing of your personal information at our approved locations outside the EEA. If you would like to know more about the ways in which we safeguard your personal information, please get in touch using the contact details in this policy.
Under some circumstances, we may be required to disclose or share your information without your consent, for example, if we are required by the police, the courts or for other legal reasons.
Your rights regarding our use of your personal information
You provide us with details of what we ‘can do’ with your data and have the right to manage your choices as detailed in How we use your personal information for marketing.
You have the following rights:
- To know that your data is being processed
- To access your personal data
- To have your information corrected if inaccurate
- To data portability, if applicable
- To request that your data be erased, to restrict processing, to object to processing
- To be made aware of your rights relating to automated decision making and profiling
Automated Decision Making
An automated fraud assessment may take place to make a decision whether to accept or decline your purchase. You have the right to contest the decision, to express your point of view, and to require a human review of the decision. You can exercise this right by contacting us using the contact details provided.
How we keep your personal information up to date
We have a legal obligation to keep the personal information we collect accurate and up to date. You have the right to ask us to correct any inaccuracies in the personal information we hold about you and to restrict the use of your information until it has been corrected.
The simplest way to keep your data accurate is to log in into your account to update your information or change marketing preferences.
We also keep your information accurate by:
- Giving you the opportunity at any time to contact us to correct or change your information
- Asking you to confirm certain details when you contact us
We have specific rectification, restriction, objection and erasure policies in place to make sure we respond effectively to your request to correct data and to respond to erasure requests.
How we keep your personal information safe
We use administrative, electronic and physical security measures to ensure the information we collect about you is protected from access by unauthorized persons and protected against unlawful processing, accidental loss, destruction and damage.
By using our website and/or services, you acknowledge and agree that, except to the extent required by the Data Protection laws, we shall not be responsible for any unauthorized use, distribution, damage or destruction of personal data. We will only retain your information for a reasonable period or as long as is required by law.
How long we keep your personal information
Of the data we process outside of any contract we retain the data for no longer than is necessary. Where there is a legal requirement to retain data for longer than WiFiBus requires, we will do so. Where reasonably practicable data is minimized so not to be identifiable to the data subject unless required by law or is subject to a Subject Access Request.
We keep your personal information where we have:
- A legal or regulatory requirement that requires us to hold data for a specific time
- A legal basis to retain data including data opt-ins, revised opt-ins and renewed consents
What to do if you have a complaint about our use of your personal information
If you have a complaint about the information we hold or how we use that information, please contact us at info(at)wifibus.it who will deal with your request promptly.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 15.05.18