The website at www.systemonetravel.co.uk (our Site) may include links to third-party websites 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:

• • Information that you provide by filling in forms or uploading photographs on our Site. This includes information provided at the time of registering to use our Site, applying for a membership card, subscribing to our service, ordering any travel travelcards listed on our Site ('Travelcards') or requesting further services. We may also ask you for information when you report a problem with our Site. The information we collect and process may include information about your identity and your contact details.
• If you contact us, we may keep a record of that correspondence.
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Details of any transactions you carry out through our Site and of the fulfilment of your orders. The information we collect and process about you if you carry out a transaction through our Site may include bank account and payment card details, together data about the payments you make to us and the products you buy.
• Details of your visits to our Site including, but not limited to, the IP address you use to access our Site, usage and traffic data, location data, weblogs and other communication data, ("Technical Data") whether this is required for our own billing purposes or otherwise and the resources that you access.
• Information about your marketing and communications preferences.

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 also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data with that of other visitors to our Site to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy policy.

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:

• direct interactions, when you provide us with information by post, phone, email, through social media or otherwise.
• automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. We may also receive Technical Data about you if you visit other websites using our cookies. Please see below for more information on cookies IP addresses and cookies.
• third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Google, advertising networks; and search information providers;
  • contact, and financial data from providers of technical, payment and delivery services where required for investigative purposes (e.g. pursuant to a query);
  • identity and contact data from publicly availably sources such as Companies House and the Electoral Register.

We may collect information about your computer, including where available your IP address, operating system and browser type for system administration. 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:

• To estimate our audience size and usage pattern.
• To store information about your preferences, and so allow us to customise our Site according to your individual interests.
• To speed up your searches.
• To recognise you when you return to our Site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Site.

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 policy (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	(a) Necessary for our legitimate interests (to study how users use our Sites, to develop our Site, and to inform our strategy); and (b) on the basis of consent obtained from you.
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:

customerservice@systemonetravelcards.co.uk 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. Where you have consented to this, you have the right to withdraw your consent.

Before we collect personal data 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.

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:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• if Greater Manchester Travelcards Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Greater Manchester Travelcards Limited, the operators of the transport services listed on our Site, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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 contact details 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 under the section "How we use your personal data"

In some circumstances you can ask us to delete your data. For further information, see "Request erasure of your personal data" below under the section "Your rights".

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 personal data 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.

In addition 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 we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we 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 we are relying on our 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 we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We 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 us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we 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, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at

customerservice@systemonetravelcards.co.uk

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 within one month of receiving your request together with the reasons for the delay and keep you updated.

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.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to customerservice@systemonetravelcards.co.uk

Alternatively, please write to our registered office at Greater Manchester Travelcards Ltd, c/o Stagecoach Manchester Head Office, Hyde Road, Manchester M12 6JS.