For the purposes of the laws governing data protection in the UK, including the EU's General Data Protection Regulation, the Data Protection Act 1998 and the replacement Data Protection Act when it comes into effect, the controller of any personal data we process is Greater Manchester Travelcards Limited trading as System One Travel, a company registered in England and Wales under company number 01848309 and with our registered office at Greater Manchester Travelcards Ltd, c/o Stagecoach Manchester Head Office, Hyde Road, Manchester M12 6JS.
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
The website at www.systemonetravelcards.co.uk (our Site) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.
We may collect and process the following data about you:
It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data which you have provided to us changes during your relationship with us.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We use different methods to collect data from and about you, including through:
We may collect information about your computer, including where available your IP address, operating system and browser type for system administration and internal marketing purposes. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our Site and to deliver a better and more personalised service. They enable us:
The data 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 for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the safeguards approved under the data protection regime is implemented.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted by our third party payment provider using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site and 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.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer for any of our products or services, to deliver any products which you order from us to you, and to make available any interactive content you choose to access on our Site to you||Identity and contact details||Performance of a contract with you|
|To manage our relationship with you which will include: (a) notifying you about changes to our terms or privacy notice (b) asking you to leave a review or take a survey||Identity and contact details, and information about your marketing and communications preferences||(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how visitors use our Site)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity and contact details, information about your marketing and communications preferences, and Technical Data||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Identity and contact details, information about your marketing and communications preferences, and Technical Data||Necessary for our legitimate interests (to study how users use our Sites, to develop our Site, and to inform our strategy)|
|To use data analytics to improve our Site and user experience for visitors to our Site||Technical Data||Necessary for our legitimate interests (to define types of users for our Site and products, to keep the Site updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you||Identity and contact details, information about your marketing and communications preferences, and Technical Data||Necessary for our legitimate interests (to develop our products and services and grow our business)|
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at:
firstname.lastname@example.org If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you, and we or they may contact you about these by telephone.
If you are an existing customer, we will only contact you by electronic means with information about goods and services similar to those which were the subject of a previous sale to you, and we will always give you the opportunity to opt out of receiving further information of this type when we contact you.
If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
Before we collect personal information from you which we might subsequently use to allow us or any third party to contact you for marketing purposes, we will give you the opportunity to indicate your marketing and communication preferences. If you do not want us to use your data in the ways described in this section on marketing, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data.
We may 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 UK Companies Act 2006.
We may disclose your personal information to third parties:
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We keep basic information about customers who buy products or services through our Site for six years after their latest purchase, unless you have asked us to provide you with marketing communications, in which case we will retain your contact details for these purposes until you ask us to stop (which you may do at any time). If you opt out of receiving marketing communications, we may still need to retain information about you if it is required for any of the purposes described above How we use your information
In some circumstances you can ask us to delete your data: see below for further information. Request Erasure
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your 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 data. You can also exercise the right at any time by contacting us at email@example.com
In addition you have the right to:
If you wish to exercise any of the rights set out above, please contact us at
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.