Transreport is committed to protecting the privacy of its Users. This notice describes how Transreport collects, processes, and protects its Users’ personal data.
This notice applies to Users who access and/or use the Technology Platforms and will outline all data which may be collected and held by Transreport across all the Technology Platforms. Therefore, the actual data collected from each User may vary depending on which Technology Platform and features are used.
By accessing and/or using of any of the Technology Platforms, you indicate your consent to Transreport:
- processing your Location Data (including details of my current location disclosed by location services so that location-enabled services are activated to facilitate the provision of the Client Services).
You may change your mind and withdraw consent at any time by contacting Transreport via the contact details listed below. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting Transreport.
Third Party Resources means (a) providers acting as processors of IT and system administration services; (b) professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers, (c) HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who may require reporting of processing activities in certain circumstances.
PA Marketing Website: the Passenger Assistance marketing website made available at https://passengerassistance.com/ by Transreport to Users to inform them about the Services, how it works and to answer any queries.
PA Mobile: the Passenger Assistance mobile application made available by Transreport to Users to facilitate the provision of the Services.
Services: the Passenger Assistance services made available to Users by Service Providers, the provision of which is facilitated by the Technology Platforms.
Service Providers: the persons, firms or companies who license any of the Technology Platforms from Transreport from time to time and who provide of the Services.
Technology Platforms: PA Mobile and PA Marketing Website collectively and any other technology platforms made available by Transreport from time to time to facilitate the provision of the Services (as such platforms may be amended or updated from time to time).
Transreport: Transreport Ltd a company incorporated and registered in England and Wales with company No. 09911874 whose registered office is at 15 Emerald Square, London, SW15 5FP.
Users: anyone entering personal data into the Technology Platforms or whose personal data has been entered (with their Consent) on their behalf by someone else for the purpose of accessing the Services. Users may also be referred to as, “you” or “your”, in these Terms.
Important information and who Transreport are
Transreport is the data controller and is responsible for your personal data.
Transreport’s details are as follows:
Full name of legal entity: Transreport Ltd
Name or title of DPO: Paralegal
Email address: [email protected]
Postal address: Transreport Ltd, 3rd Floor, 3 Shortlands, Hammersmith. London. W6 8DA.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, although we would appreciate the opportunity to address any concerns which you may have first.
Third party links
The Technology Platforms may, from time to time, contain links to and from the websites of Transreport’s partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through these links have their own privacy policies and that Transreport does not accept any responsibility or liability for these policies or any personal data that may be collected as a result, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
The data Transreport collects about you
Transreport may collect, use, store and transfer different kinds of personal data about you as follows (which are further described in the paragraph below): (i) Identity Data, (ii) Contact Data, (iii) Device Data, (iv) Profile Data, (v) Usage Data, (vi) Marketing and Communications Data, and (vii) Location Data.
Description of categories of personal data
- Identity Data: first name, last name, username or similar identifier, title, date of birth, gender and disability type.
- Contact Data: contact address, contact email address and contact telephone numbers.
- Device Data: includes the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, operating systems, software version.
- Profile Data: includes your username and password, preferences, feedback and survey responses.
- Usage Data: includes details of your use of any of our Technology Platforms or your visits to any of the Technology Platforms including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Marketing and Communications Data: includes your preferences in receiving marketing from Transreport and our third parties and your communication preferences.
- Location Data: includes your current location disclosed by location services.
The only special category of personal data which Transreport collects from you, are details relating to your disability and only to the extent reasonably required for Service Providers to carry out the Services.
Transreport will not collect any other special category of personal data from you, including details about your race or ethnicity, religious/philosophical beliefs, sexual orientation, political opinions, trade union membership, genetic/biometric data and health information which is unrelated to your condition or impairment. Transreport does not collect any information about criminal convictions or offences.
How is your personal data collected?
Transreport will collect and process the following data about you:
- Information you give Transreport. This is information about you (including Identity, Contact, and Marketing and Communications Data) which you consent to giving to Transreport, either by filling in forms on the Technology Platforms, or by corresponding with Transreport (for example, by email). It includes information you provide when you download or register to use any of Technology Platforms, access the Services, share data via the Technology Platforms, subscribe or request to receive marketing, enter a competition, promotion or survey, and when you report a problem with any of Technology Platforms. If you contact Transreport, a record of that correspondence will be kept.
We do not knowingly collect data from or market to children under 16 years of age. By using our Technology Platforms or accessing our Services, you represent that you are at least 16 years of age. Please note that if you are entering personal data on behalf of another User, you confirm that you have either obtained their consent to give it, or consent from their parent or guardian (if the User is under 16).
If we learn that information from Users less than 16 years of age has been collected (without appropriate consents being given, where applicable), we will deactivate the relevant account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under 16 years of age, without the consent of their parent or guardian, please contact us immediately using the contact details listed above.
- Information Transreport collects about you and your device. Each time you visit or use one of the Technology Platforms Transreport will automatically collect personal data including Device, Content and Usage Data.
- Location Data. Transreport also use location services to determine your current location. Some of our location-enabled features require your personal data for the feature to work. If you wish to use a particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
- Information Transreport receive from other sources including third parties and publicly available sources. Transreport will receive personal data about you from various third parties and public sources as set out below:
Device Data from:
- analytics providers based either inside or outside of the UK;
- advertising networks based either inside or outside of the UK; and
- search information providers based either inside or outside of the UK.
Contact, Financial and Transaction Data from providers of technical services, based either inside or outside of the UK;
Identity and Contact Data from data brokers or aggregators based either inside or outside of the UK; and
Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK.
How Transreport use your personal data
Transreport will only use your personal data when the law allows Transreport to do so. Most commonly Transreport will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where Transreport need to comply with a legal or regulatory obligation.
Purposes for which Transreport will use your personal data
|Purpose/activity||Type of data||Lawful basis for processing|
|To install the Technology Platforms and register you as a new Technology Platforms user||Identity|
|To manage our relationship with you including answering your questions and notifying you of changes to the Technology Platforms or any Services||Identity|
Marketing and Communications
Necessary for our legitimate interests (to keep records updated and to analyse how Users use our products/ Services)
Necessary for the performance of our contract with you and to comply with legal obligations (to inform you of any changes to our terms and conditions)
|To send you marketing communications and materials regarding our product and services (including any promotional deals), to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Identity|
Marketing and Communications
Necessary for our legitimate interests (to communicate with our customers and improve our products/services and ensure that our marketing/promotions only go to those who are interested).
|To administer and protect our business and the Technology Platforms including troubleshooting, data analysis (including to improve the Technology Platforms, products/services, marketing, customer relationships and experiences) and system testing||Identity|
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to develop our business and inform our marketing strategy)|
Necessary for the performance of our contract with you
|Sharing with Service Providers||Identity|
|Necessary for our legitimate interests and/or for the performance of our contract with you (for the performance of the Services)|
|Sharing with Third-Party Resources||Identity|
|Necessary for our legitimate interests and/or for the performance of our contract with you|
(for running our business, provision of administration and IT services, and the performance of the Services)
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for which Transreport will use your personal data) above.
Third-Party Resources such as cloud service providers.
Service Providers providing the types of services included in the table, above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some Third-Party Resources are based outside of the UK, so processing your personal data may involve a transfer of data outside the UK.
Whenever Transreport transfers your personal data outside of the UK, Transreport ensures a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Transreport will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government.
- Where Transreport use certain service providers, Transreport may use specific contracts approved for use in the UK which gives personal data the same protection it has in the UK.
Please contact Transreport if you want further information on the specific mechanism used when transferring your personal data out of the UK.
All information you provide to Transreport is stored on our secure servers.
Where you are required to create a password, you are responsible for keeping this password confidential. Transreport ask you not to share your password with anyone.
Once Transreport have received your information, Transreport will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
Transreport will collect and store personal data on your device using application data caches and browser web storage (including HTML5) and other technology.
Transreport have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when Transreport are legally required to do so.
When we have no ongoing business purpose to justify the processing of your information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.
From time to time, Transreport would like to tell you more about our products, services, promotions, special offers and upcoming features. If you have given your Consent, we will do this by sending you marketing materials. If you have given Consent, we may share your personal data with carefully selected third party organisations and business partners and they may contact you directly. If you would prefer to no longer receive direct marketing communications from third parties and partners after previously giving your Consent, please contact those third parties and partners directly to withdraw the Consent.
You have the right to opt out of receiving such marketing information at any time, by clicking the unsubscribe link in every subsequent newsletter or contacting Transreport’s DPO at [email protected] Opting out of receiving any marketing messages will have no impact on your use of the PA Mobile services. We will still send you any necessary transactional or service messages as needed, and your opt out will not apply to personal data provided to us in connection with your use of the PA Mobile services.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
You also have the right to ask Transreport not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting Transreport at [email protected]
Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data Transreport hold about you and to check that Transreport are lawfully processing it.
- Request correction of the personal data that Transreport hold about you. This enables you to have any incomplete or inaccurate data Transreport hold about you corrected, though Transreport may need to verify the accuracy of the new data you provide to Transreport.
- Request erasure of your personal data. This enables you to ask Transreport to delete or remove personal data where there is no good reason for Transreport continuing to process it. You also have the right to ask Transreport to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where Transreport may have processed your information unlawfully or where Transreport are required to erase your personal data to comply with local law. Note, however, that Transreport may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where Transreport are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where Transreport are processing your personal data for direct marketing purposes. In some cases, Transreport may demonstrate that Transreport have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask Transreport to suspend the processing of your personal data in the following scenarios:
o if you want Transreport to establish the data’s accuracy;
o where our use of data is unlawful, but you do not want Transreport to erase it;
o where you need Transreport to hold the data even if Transreport no longer require it as you need it to establish, exercise or defend legal claims; or
o you have objected to our use of your data but Transreport need to verify whether Transreport have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. Transreport will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for Transreport to use or where Transreport used the information to perform a contract with you.
- Withdraw consent at any time where Transreport are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, Transreport may not be able to provide certain products or services to you. Transreport will advise you if this is the case at the time you withdraw your consent.
Last updated: 01/06/2021
What are cookies
Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the PA Marketing Website or a third-party to recognize you and make your next visit more useful and easier for you.
Cookies can be “persistent” or “session” cookies.
When you use and access this website, we may place a number of cookies files in your web browser.
We use two types of cookies, including both persistent and session cookies:
- Performance – cookies which measure how often you visit our site and how you use it. We use this information to get a better sense of how our users engage with our website so that we can improve it and provide a better experience. For example, we collect information about which of our pages are most frequently visited, and by which types of users. We also use third-party cookies to help with performance. For example, the Google Analytics cookie gives us information such as your journey between pages.
- Advertising – cookies that are used to collect information about your visit to our site, including the content you have viewed, the links you have followed and information about your browser, device and your IP address. We have set out more details on this below.
|Cookie names||Cookie description||Cookie classification|
|_gat_UA-196309537-1, _ga, _gid, AMP_TOKEN||Google Analytics Used to manage request rates and distinguish site users, including understanding site usage and user behaviour||Persistent|
|_gcl_au||Google Tag Manager This helps us to monitor the effectiveness of advertising and marketing elements.||Session|
|Guest_id, twid||Cookies set by Twitter to identify and track website visitors, and to monitor social sharing of site links||Persistent|
|Facebook / Instagram Pixels||Measure actions on site for social media advert targeting||Persistent|
The advertising techniques we use do not collect personal data such as your name, email address, postal address or phone number. We sometimes use information such as your IP address and browser type and also sometimes share some limited aspects of this with others for advertising purposes.
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In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the website.
What are your choices regarding cookies
You can switch some cookies off through the Your Online Choices site. You may need to do this again each time you use a different IP address, device, or virtual private network. You can also adjust the global privacy setting or plug-in which should be communicated to use via your browser.
It is also possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.
- Cookie settings in Internet Explorer
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Where can your find more information about cookies
You can learn more about cookies and the following third-party websites:
- AllAboutCookies: http://www.allaboutcookies.org/
- Network Advertising Initiative: http://www.networkadvertising.org/
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