TRAVELAI LTD “WECYCLE” PRIVACY POLICY
1.1 We are TRAVELAI LTD, a limited company registered in England with registered address at Studio F7, 80 Silverthorne Road, London, SW8 3HE and registered number 07960903 (referred to as "we", “us” and “TRAVELAI”).
1.2 We provide and operate WeCycle, it is mobile application that collects how and where you travel to help make our cities and towns friendlier for cyclists and safer for everyone. It’s always on in the background, effortlessly figuring out how you're moving so you don't need to start it, stop it, or tell it what you're doing. For the purposes of these terms of service, the WeCycle mobile application software, any data supplied with the software, and any updates or supplements to it shall be referred to herein as the “App”.
1.3 We are committed to protecting and respecting your privacy.
2. SCOPE OF POLICY
2.1 This policy (together with our Terms of Use viewable through the App which can also viewed at travelai.info and any additional terms of use incorporated by reference into such terms, the “Terms”) applies to your use of:
(a) the App, once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device(s) (a “Device” or “Devices”);
(b) any of the services accessible through the App (the “Services”) that are available on the App or other sites of ours (the “Websites”), unless the Terms states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.
2.2 This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. In this policy, ‘personal information’ means any information by which you can be identified with or identifiable by such as; your name, the identification number of the device(s) you many be using the App on, your geo-location data, or any other online identifier relating to your physical, physiological, genetic, mental, economic, cultural or social identity.
2.3 For the purposes of the Data Protection Act 1998 and all subsequent and additional legislation governing the collection and processing of personal information, the data controller is TRAVELAI LTD of Studio F7, 80 Silverthorne Road, London, SW8 3HE.
3. INFORMATION WE COLLECT FROM YOU
3.1 We will collect and process the following data about or relating to you:
(a) Information you give us (“Submitted information”)
This is information you give us about you by filling in forms on the App or the Websites, or by corresponding with us (for example, by e-mail or SMS). It includes information you provide when you register to use the App, download the App on one or more Devices, subscribe to any of the Services, make an in-App purchase, share data via an App's social media functions, enter a competition, promotion or survey hosted by the App, and/or when you report a problem with an App, the Services, or any of the Websites. If you contact us, we will keep a record of that correspondence. The information you give us via the app may include your name, age, weight, e-mail address the Device's ID, model and make.
(b) Information we collect about you and your Devices.
Each time you visit one of the Websites or use the App we will automatically collect the following information:
(i) technical information, including: the type of mobile Device(s) 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, and any other information gleaned from your use of the App (the “Device Information”);
(ii) details of your use of any of the App or any of our other software applications or your visits to any of the Websites including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access (the “Log Information”).
(c) Location information.
To provide the App, TravelAi, our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your Devices. We will use GPS, Bluetooth, your IP Address and other geolocation technology to determine your current location, your mode of transport(s), frequented places and other travel behaviour patterns. By using the App, you consent to your data being used for this purpose. If you turn off the location services settings for the App, the App will not be able to perform its journey functions.
(d) Information we receive from other sources (“Third Party Information”).
We work closely with third parties (including, for example, business partners, sub-contractors in technical, delivery services, analytics providers) and may (as detailed herein) share and receive information from them. We will notify you when we receive personal information about you from them and the purposes for which we intend to use that information.
(e) Installation Information.
When you install or uninstall the App, or accept automatic updates, information about your installation, for example, the type of operating system, device model and make may be sent to us.
4. COOKIES
4.1 We use cookies to distinguish you from other users of the App, the Services, or the Websites. This helps us to provide you with a good experience when you use the App or browse any of the Websites and also allows us to improve the App and the Websites.
4.2 A cookie is a small file of letters and numbers that we store on your Device.
4.3 We use the following cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of the App, the Services, or the Websites. They include, for example, cookies that enable you to log into secure areas of the App, the Services, or the Websites, or make use of e-billing services. If you block these cookies, the App, the Services, or the Websites may not operate properly.
(b) Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how users navigate around the App, the Services, or the Websites when they are using it. This helps us to improve the way the App, the Services, or the Websites work, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These cookies are used to recognise you when you return to the App, the Services, or the Websites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(d) Targeting cookies. These cookies record your visit to the App, the Services, or the Websites, the pages you have visited and the links you have followed. We will use this information to make the App, the Services, or the Websites and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
4.4 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
4.5 You may block cookies by activating the setting on your browser that allows you to refuse the operation of all or some cookies. However, if you use your browser settings to block all cookies (including without limitations strictly necessary cookies) you may not be able to access or use all or parts of the App, the Services, or the Websites.
5. HOW WE USE YOUR PERSONAL INFORMATION
5.1 We use information held about you in the following ways:
(a) Submitted Information:
(i) to identify you when you use the App, the Services or the Websites and when you communicate with us;
(ii) to provide the Services to you;
(iii) to facilitate you sharing your activities through your social media accounts;
(iv) to allow you to take part in competitions, promotions or surveys;
(v) to assist you with problems using the App, the Services or the Websites; and
(vi) for the purposes of crime and fraud prevention and detection;
(b) Device information:
(i) to enable the App to function on your Device(s);
(ii) to facilitate performance of the Services;
(iii) to enable us to collect Location information and process that information;
(iv) to provide the Services to you;
(v) to assist you with problems using the App, the Services or the Websites; and
(vi) for the purposes of crime and fraud prevention and detection;
(c) Content Information:
(i) to facilitate you sharing your activities through your social media accounts; and
(ii) to allow you to take part in competitions, promotions or surveys;
(d) Log information:
(i) to assist you with problems using the App, the Services or the Websites;
(ii) to develop and improve your profile with the App;
(iii) the improve the Services; and
(iv) for the purposes of crime and fraud prevention and detection;
(e) Location information:
(i) to enable the App to function on your Device(s);
(ii) to facilitate performance of the Services;
(iii) to process that information;
(iv) to provide the Services to you;
(v) to improve the Services;
(vi) when aggregated with information from other users, to develop models and information about general travel usage and patterns;
(vii) to develop new Services;
(viii) to assist you with problems using the App, the Services or the Websites; and
(ix) for the purposes of crime and fraud prevention and detection;
(f) Third Party Information:
(i) to enforce our rights under the Terms;
(ii) for the purposes of crime and fraud prevention and detection;
(iii) to provide the Services to you; and
(iv) to improve the Services,
(g) Installation Information:
(i) to assist you with problems using the App, the Services or the Websites; and
(ii) to monitor account creation and usage.
5.2 We may associate any category of information with any other category of information and will treat the combined information as personal information in accordance with this policy for as long as it is combined with personal information.
6. DISCLOSURE OF YOUR INFORMATION
6.1 We will disclose the information we collect from you to the following third parties:
Category of information |
Recipient |
Purpose |
Submitted |
Law enforcement agencies; competition promoters and sponsors; service providers; social media platforms with whom you wish to share content; professional advisors |
Prevention and detection of crime and fraud; provision of services to us |
Device, Content, Log |
Service providers |
Provision of services to us |
Location |
Travel/Transport Partners of TRAVELAI; purchasers of travel behaviour data sets; government and educational bodies |
Analysing travel demands and the performance of the transport system; research; educational purposes; development of new products; to serve you with relevant advertisements |
Third Party |
Service providers; law enforcement agencies |
Prevention and detection of crime and fraud; processing or payments and fulfilment of orders for Services; provision of services to us |
Installation |
Service providers |
Provision of services to us |
6.2 You agree that we have the right to disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
6.3 We may share your information with selected third parties including:
(a) business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
(b) analytics and search engine providers that assist us in the improvement and optimisation of the App, the Services and the Websites.
6.4 We do not disclose your personal information to third parties (unless required to do so by law) and other than as required to enable us to provide you with access to the App, the Services and the Websites. However, we may provide third parties with anonymous information about our users.
6.5 We may also use such anonymous aggregate information to help advertisers reach the kind of audience they want to target (for example, people in a certain age range who travel by train).
6.6 We may also disclose your personal information to third parties:
(a) If TRAVELAI or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers may be one of the transferred assets.
(b) If we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request.
(c) If we are requested to by a law enforcement agency or governmental organisation (whether or not we are in receipt of a court order, warrant or formal demand for such information).
(d) To enforce or apply our Terms of Use and other agreements made between you and TRAVELAI or to investigate potential breaches.
(e) To protect the rights, property or safety of TRAVELAI our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and crime detection.
7. WHERE WE STORE YOUR PERSONAL INFORMATION
7.1 The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or our contractors. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this privacy policy.
7.2 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to the App, through the Services or the Websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7.4 We will collect and store personal information on your Device using application data caches and browser web storage (including HTML 5) and other technology.
8. YOUR RIGHTS
8.1 You have the right to ask us to delete some or all of the personal information that we hold about you from time to time – unless we have to keep that personal information for legitimate business or legal purposes. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). You can request for deletion of your personal information by contacting us at [email protected].
8.2 You also have the right to ask us to stop processing your personal information. If you do so, we will, without undue delay, erase all of your personal information that we hold. However, please note that the App will not be able to perform its journey functions if we cannot process certain personal information, such as your unique device identification numbers and your locational data.
8.3 These rights in clauses 8.1 and 8.2 only relate to your personal information and do not relate to non-personal information that we may have collected or received about you or your use of the App, the Services and/or the Websites. We have the right to retain any personal information despite your request to delete it for a reasonable period of time to enable us to take payment for any Services you have ordered, to defend or prosecute any dispute with you or as required or requested by any law enforcement agency or governmental body.
8.4 We will ask you before adding you to marketing lists (opt-in). You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your personal information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information. You can also exercise the right at any time by contacting us at [email protected].
8.5 The Websites or the App may, from time to time, contain or direct you to links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal information that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal information to these websites or use these services.
9. ACCESS TO INFORMATION
9.1 The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
9.2 For other information we hold, we will provide you with access for any purpose including to request that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes.
10. CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next start the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.
11. CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected]
6.3 We may share your information with selected third parties including:
(a) business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
(b) analytics and search engine providers that assist us in the improvement and optimisation of the App, the Services and the Websites.
6.4 We do not disclose your personal information to third parties (unless required to do so by law) and other than as required to enable us to provide you with access to the App, the Services and the Websites. However, we may provide third parties with anonymous information about our users.
6.5 We may also use such anonymous aggregate information to help advertisers reach the kind of audience they want to target (for example, people in a certain age range who travel by train).
6.6 We may also disclose your personal information to third parties:
(a) If TRAVELAI or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers may be one of the transferred assets.
(b) If we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request.
(c) If we are requested to by a law enforcement agency or governmental organisation (whether or not we are in receipt of a court order, warrant or formal demand for such information).
(d) To enforce or apply our Terms of Use and other agreements made between you and TRAVELAI or to investigate potential breaches.
(e) To protect the rights, property or safety of TRAVELAI our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and crime detection.
7. WHERE WE STORE YOUR PERSONAL INFORMATION
7.1 The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or our contractors. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this privacy policy.
7.2 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to the App, through the Services or the Websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7.4 We will collect and store personal information on your Device using application data caches and browser web storage (including HTML 5) and other technology.
8. YOUR RIGHTS
8.1 You have the right to ask us to delete some or all of the personal information that we hold about you from time to time – unless we have to keep that personal information for legitimate business or legal purposes. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). You can request for deletion of your personal information by contacting us at [email protected].
8.2 You also have the right to ask us to stop processing your personal information. If you do so, we will, without undue delay, erase all of your personal information that we hold. However, please note that the App will not be able to perform its journey functions if we cannot process certain personal information, such as your unique device identification numbers and your locational data.
8.3 These rights in clauses 8.1 and 8.2 only relate to your personal information and do not relate to non-personal information that we may have collected or received about you or your use of the App, the Services and/or the Websites. We have the right to retain any personal information despite your request to delete it for a reasonable period of time to enable us to take payment for any Services you have ordered, to defend or prosecute any dispute with you or as required or requested by any law enforcement agency or governmental body.
8.4 We will ask you before adding you to marketing lists (opt-in). You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your personal information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information. You can also exercise the right at any time by contacting us at [email protected].
8.5 The Websites or the App may, from time to time, contain or direct you to links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal information that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal information to these websites or use these services.
9. ACCESS TO INFORMATION
9.1 The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
9.2 For other information we hold, we will provide you with access for any purpose including to request that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes.
10. CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next start the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.
11. CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected]