1. Our Privacy Policy

When does our Privacy Policy apply?

This Policy applies to “Personal Information” (also known as “Personal Data”), which generally means information identifying, relating to or about an identified or identifiable individual, as described in Section II of this Policy.

This Policy applies to information we may collect from you when you use our customer-facing websites (such as Columbus.in.gov) and any customer services provided by Columbus Transit such as Columbus Fixed Loop services, paratransit services (Call a Bus), parking services, receiving SMS alerts or other service alerts, enrolling in fare and pass programs, and interacting with our customer service departments (collectively, “Services”). This includes when you purchase or re-load fare media; use our transit services or visit our stations and facilities; complete applications, registrations or other forms that we provide in connection with our Services (such as registering for an account with us, registering for a free or reduced fare program, completing surveys, providing feedback, signing up for SMS alerts, or other fare media) (collectively, “Forms”); when we communicate with you electronically, such as through our Services, email, text message and other electronic messages between  Columbus Transit and you; and when you interact with advertising and applications on third party websites and services, if those services, advertising, websites, or applications include links to this Policy.

1. Personal Information

What is Personal Information?

Personal Information is information that you provide to us or that we collect from or about you when you engage with our Services, by which you may be personally identified such as:

• Contact Information, such as your name, addresses (including home, mailing, and billing), email address, or telephone numbers (including home, work, and mobile);
• Transaction Information, such as your credit card or other payment information, fare purchase history or transit system transactions;
• Other Identifying Information, such as your driver’s license number, license plate number, date of birth, or employment or institutional information.

The term Personal Information as used in this Policy does not include depersonalized, de-identified or aggregated data that cannot directly be linked back to an individual.

If you provide us with Personal Information about any other individual (such as a family member), you represent that you have any necessary consents to give us their information for use in accordance with this Policy.

What types of Personal Information do we collect and how do we collect it?

We collect and use Personal Information in order to provide and operate our Services. In some instances, you may choose whether and how much information to share with us. In other instances, we may collect information from you automatically.

Information you provide to us. You may provide Personal Information to us through our Services. You can choose how much Personal Information you share with us. For example, you may choose to share more Personal Information with us by signing up for SMS Alerts or by applying to one of our free or reduced fare programs or for our paratransit service, or you may choose to share no Personal Information with us

You provide Personal Information:

• When you fill in Forms, such as when registering for an account with us, applying to a free or reduced fare or pass program, applying for our paratransit, requesting correspondence from us, updating or changing your information, completing informational forms (such as contact information), signing up for our mailing lists or SMS Alerts, or requesting further services. We may also ask you for information when you report a problem with our Services;
• When you send us correspondence or respond to surveys, questionnaires, and feedback forms that we might ask you to complete;
• When you interact with our vendors and other partners, such as when you use our paratransit services; and
• When you provide other information that we request from you when using our Services.

Information we collect as you use our Services. We collect Personal Information, travel data and information about your internet activity and the computers, devices and browsers you use as you use and interact with our Services.

We automatically collect and keep a record of:

• Travel location tap data, which may include boarding and exit stations and origin/destination addresses for the Transpo, date and time of your use, error information, video recordings, and details of your purchases and transactions when you visit our Services. We collect travel history data to help us monitor system usage and evaluate travel patterns over time.
• Information about your online activity, including your use of our Services, and any internet services and Wi-Fi we offer. The information we collect when you use these services includes browsing and search history on our Services and information regarding your interaction with our Services including unique identifier, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number. We also collect information about the interaction of your apps, browsers, and devices with our Services, including IP address, device type, crash reports, system activity, wireless carrier name (when you use a wireless or mobile device), and the date, time, and referrer URL of your request.

The technologies we use for this automatic data collection may include: automatic passenger counters, on-board payment validators, cookies, and pixels or pixel tags. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. A pixel or pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking certain activity, such as views of a website or when an email is opened. Pixel tags are often used in combination with cookies.

Electronic Notifications: Details of our electronic notification programs including SMS Alerts, are outlined below:

• When you affirmatively opt-in to one or more of our electronic notification programs and consent to receive text messages, emails and/or push notifications from us through a sign-up page, checkbox or shortcut, we will enroll you in the selected message program(s). Message frequency can vary. You may continue to receive transactional updates from us unless you update your notification preferences to turn off notifications. You can also stop receiving text messages from us at any time by texting “STOP” to any message we send you, and text notifications for that program will be turned off. You may opt out of receiving certain email messages from us as detailed above. If you opt out of a notification program, we will send you an acknowledgement message to confirm that you have been unsubscribed. If you want to join again, just sign up again for the program by texting “SUBSCRIBE”.
• By opting into a notification program, you consent to being sent periodic emails or autodialed and/or non-autodialed messages at the email address or phone number that you provided at the time of joining and confirm that the contact information provided is your contact information and you have the authority to grant us the right to send messages to that number or address. Joining a notification program is not a condition of making any purchase. If you change or deactivate your participating address or number, you must promptly notify us of this change to continue receiving notifications.
• As always, message and data rates apply for any text messages sent to you from us and to us from you. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.
• Participating wireless carriers are not liable for delayed or undelivered text messages. We are not liable for perceived legal violations (such as under the Telephone Consumer Privacy Act) caused by a carrier network failure or malfunction, or your failure to opt-out of a text notification program as directed here.

How do I access and correct my Personal Information?

Access, corrections, and deletion. As a Customer, you may review, change or update certain account information you have given us by logging into your account or by contacting Customer Support to be put in touch with the correct business unit. Please inform us of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. Please contact us if you have any questions about your Personal Information.

You may request to delete certain Personal Information through your account or by contacting Customer Support. We will make reasonable efforts to honor such requests by deleting or de-identifying it, except for data that we must retain for legal or other necessary purposes. For example, we may be unable to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect. In some instances, you may be able to sever the connection between your trip history and your personal identity by de-linking a fare credential from your account. Doing this will remove all personal identifiers and anonymize your trip history. In the event that we cannot honor a request to delete certain data due to business process requirements or our records retention rules, we will endeavor to provide you with an explanation for the denial.