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©2019 Modal Limited

Company number 09957136

*figures are as at 5 November 2019

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Privacy Policy

This privacy policy takes effect on 4 July 2019. It describes in detail 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, modal.org.uk ("Site"), or our app ("Modal Rail") (together, “App”). "We", Modal Limited, a company registered in the UK, are the data controller as defined by the General Data Protection Regulations.

Information we collect and why

 

There are two categories of information we collect:

  1. Information that you provide to us

  2. Information generated when you use our App

Information you provide to us

When you use our App you may provide us with:

  • Personal information

  • Direct communications

Personal information

If you're a user of the App, you provide us with your name and email address to sign up. This allows us to communicate with you and ensure your all Account details, and other personalisation features, can be synced across multiple devices. Other Account details that can be provided to us include:

  • Home and work train stations

  • Home and work addresses

  • Mobile number

  • Season ticket details

  • Bank details

 

We use these details to help us identify your regular train journeys and potential train delay refunds, and to assist you with the processing of delay claims. We also store and analyse this data in aggregate to improve the App.

Direct communications

 

Communications you might send to us include:

  • Responses to our emails or in-App surveys

  • Reporting missing journeys or claims, or other issues

  • Submitting feedback

We process this information in order to improve our service, fix problems with the App or to reply to your messages.

Information generated when you use our App

Types of information generated when you use our App include:

 

  • Location

  • Device

  • Usage and logs

 

We associate this information with a random ID that is generated when you first sign up to the App. We use this ID to pseudonymise the data created by you, and we do not access any permanent device ID numbers.

Location information

 

We collect and analyse location information to help identify your train journeys and potential train delay refunds. Location is determined through data such as GPS, mobile phone towers and WiFi. We also analyse this data in aggregate to improve the performance of the App.

Device information

 

We collect information about the devices you use to access our App, 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. This information is necessary for us to diagnose bugs and improve the App.

Usage and logs

 

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 features and journeys that you tap, 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.

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

  • 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 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.

 

How we use your information

 

In summary, we use the information we collect to:

 

  • Provide and improve our App

  • Build a profile of your commute so we can personalise the App

  • Verify your identity and administer your account with us

  • Process delay claim refunds and fees

  • Send you transactional emails associated with your delay claims

  • Respond to your emails to discuss your use of the App, and answer any support queries you may have

  • Send you marketing communications by email or in-App notifications, and let you know about our policies and terms or when we launch on your train line

  • Identify issues with the operation of the App, and provide crash reports in order to find resolution for performance issues

  • Disclose to lawful authorities when required to do so by law, or when appropriate, in our opinion, to respond to their request.

 

We are continuously improving the App and this may affect your data. We regularly review the data that we collect and use, and we will update our privacy policy to reflect any changes.

What are our legal reasons for processing the data?

 

We'll only process your personal information where we have legitimate reason to do so. Our legal basis to process your personal data includes processing that is:

  • Necessary for our legitimate interests (e.g. provide and develop the App)

  • Necessary for the performance of our contract with you

  • Necessary to comply with applicable legal requirements (e.g. legal and regulatory obligations or mandatory disclosures)

  • Based on your consent

What are your personal data rights?

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 team@modal.org.uk.

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.

You can ask us to delete your personal information by emailing us at team@modal.org.uk. Please note that 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 contact us at team@modal.org.uk. Please note we may still send you non-promotional, transactional messages, such as information about your delay claims or Account.

Notifications

 

We may send you information we think you may find useful, or which you have requested from us, by push notification and/or by email. Your device's operating system or we will give you the option to opt-out of receiving further notifications.

How do we keep your information secure?

 

We place great importance on the security of all information associated with our users. We use measures such as information access controls (e.g. two factor authentication), encryption, pseudonymisation, and firewalls.

Please note 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.

Where does the information go?

 

Information that you provide or create 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.

What about changes to this 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 Site 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 1 March 2019.

 

What if you have a complaint?

 

We work hard to manage your information responsibly. If you're unhappy our approach, please contact us at team@modal.org.uk.

How do you get in touch?

 

Please send any questions or feedback about this privacy policy, or any requests regarding your personal data, by email to team@modal.org.uk.