This policy was last updated on 9th June 2020.
Southdown PSV Limited (Southdown) values the personal information you provide to us and wouldn’t want to use your personal data in a way that you wouldn’t expect. This Privacy Notice explains how we protect your privacy and how you control the use your personal information. Having read this information, if you want to change the way in which we use your data or if you have a question about how your personal information is used please contact the Data Controller for customer information using the methods below: -
send an email to: email@example.com
use the chat icon on the right and to the bottom of this page
phone 01342 719 619
Write to us at Southdown Buses, Silverwood, Snow Hill, Copthorne, West Sussex. RH10 3EN
Our ICO Registration Number for us is: Z3598306.
You can find out more information on the ICO website https://ico.org.uk/
- Where and how we collect your personal information
- What personal information do we collect and hold about you
- Our legal basis for using your personal information
- How we use your personal information
- Sharing your personal information
- Your rights regarding our use of your personal information
- Accessing your Data by Subject Access Request (SAR)
- How we keep your personal information up to date
- How we keep your personal information safe
- How long we keep your personal information
- What to do if you have a complaint or query about how we use your information
- Links to other websites
- Changes to this privacy notice
Where and how we collect your personal information
We collect personal information about you in several ways:
- When you fill in a form on our website.
- When you contact us via phone, email, social media or another route.
- When you register with us and fill in a form on our website, either directly or via a social media account.
- When you subscribe to our services.
- When you purchase tickets.
- When you opt-in to receive special offers and promotions, travel tips and latest news by email, post and other electronic means.
- When you complete a survey distributed by us or on our behalf.
- When you browse our website.
We also collect your personal information from other organisations and sources, for example when you contact us through a social media company such as Facebook, Twitter or Instagram. Before providing information to us via these channels you should check these companies’ privacy policies and settings to understand how they use your personal information.
What personal information do we collect about you?
When you fill in a form or purchase tickets we only require you to supply the information that we need to provide the service you have requested. We will normally ask you to provide us with:
- Your name
- Your contact details
- Details of your bank, credit card or alternative payment provider
- Identification details including but not limited to Student ID
- Account log in details
- Your location, ticket and travel information
- Information when reporting a problem, submitting queries or comments
- How you would like us to contact you
When you visit our website we may collect the following information automatically:
- Technical information, including the IP address used to connect your computer to the Internet, your login information, the browser you’re using, time zone setting, browser plug in types and versions, the operating system and platform you are using;
- Information about your website or app visit that will help us to improve our service. This can include date and time, which products you looked at or searched for, how long you spent on certain pages and how you moved around the page, how you clicked to, through and from our website and any phone number used to contact us.
We employ CCTV on our buses in order to:
- Prevent, deter and detect crime
- Apprehend and prosecute offenders, and provide evidence to take action in the courts
- Help provide a safer environment for our staff
- Protect public safety
- Monitor operational and safety-related incidents
- Assist with the verification of claims.
You have the right to make a Subject Access Request for CCTV images of yourself and to ask for a copy of them. Please direct any such request to firstname.lastname@example.org. To protect the rights of other individuals whose images may also be captured by the same images, we reserve the right to redact images. We reserve the right to withhold information where permissible by the applicable data protection legislation, and we will only retain CCTV images for a reasonable period or as long as is required by law. In certain circumstances, we may need to disclose CCTV images for legal reasons. When this is done, there is a requirement for an organisation that has received the images to adhere to the relevant data protection legislation.
Our legal basis for using your personal information
Under UK data protection law, we must have a valid basis for using your personal information and we may not collect store or use information other than as described in this policy. There are four ways we may have a valid basis for using your personal information:
Most of the information we collect from you is necessary to allow us to fulfil our contract with you or to enter into a contract with you e.g. you provide a billing address when you purchase tickets via our website; we may need to contact you to notify you about changes to our services.
When you register and open an online account with us you will be invited to give us your consent to use your personal information as described in ‘How we use your personal information for marketing’. By opting in you are giving us your permission to process your data using consent as our legal basis. If you have given consent to our use of your personal information, you are entitled to withdraw this consent at any time.
3. Legitimate Interests
We have a legitimate interest in using your personal information e.g. to ensure that the content on our website and app is presented to you and your device as effectively as possible. If this is our reason for using your personal information, we must make sure that our interests do not override yours and you can object to this use of your personal information. We also have a legitimate interest in exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
4. Legal Obligation
Lastly, we have a legal obligation to use your personal information where lawfully requested or required to do so by public authorities.
Our legitimate interests and your right to object
Legitimate Interests means the interests of our company in conducting and managing our business [to enable us to give you the best service/products and the best and most secure experience].
For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests. It can also apply to processing that is in your interests as well.
When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing. If you wish to do so, please let us know by contacting email@example.com . Please bear in mind that if you object, this may affect our ability to carry out the tasks for your benefit.
How we use your personal information
We use the personal information you provide to:
- Provide you with the service or information you’ve requested
- Handle the administration of your account, payment, issue your tickets or confirm orders
- Alert you about updates to your bus journey, timetable or tickets
- Provide post-sales support and deal with any complaints, refunds or other ticketing or travel issues or queries - Contact you to invite you to participate in research
- Improve our website, app and the range of services and products we provide
- Analyse and optimise our marketing activities
- Evaluate and improve our existing products and services, or develop new ones
- Contact you with your consent to tell you about our special offers and promotions, travel tips and latest news
How we use your personal information for marketing
We only use your personal information for marketing where you have given us permission to do so or you have provided permission to other organisations to allow us to market to you.
Where you’ve given us permission to do so, we use some of your personal information for marketing. For example, we may use information like name, address, location and past journeys to ensure we make our marketing relevant, accurate, and measure its effectiveness.
By using the information you provide we are able to contact you with specific marketing messages about special offers and promotions, travel tips and latest news and, depending on the permission you have given us or another organisation this may be by post, email, telephone, SMS, social media or other electronic means.
If you have given us your consent to use your personal information for marketing, you have the right to withdraw your consent at any time by contacting our data controller on firstname.lastname@example.org.
Sharing your personal information
We do not share or sell your personal information to any other company for marketing purposes.
Third-party companies will be required to use your personal information in accordance with the Data Protection legislation currently in force. We may also use information in aggregate, where personally identifiable information is removed, for marketing and strategic development to improve and support our business.
Where we use trusted suppliers to help us deliver our service to you, we allow the supplier concerned limited access to the personal data they need to provide their service.
A list of just some of the service suppliers are listed below:
– Mailing houses to send you bus tickets, smartcards or other information
- website hosting companies which we use to administer our website content, including personalised messaging
- Third party payment providers including but not limited to Secure Trading
- An email service provider to send you emails about the tickets you buy and travel information you have requested.
- Third parties which we use to analyse traffic and other pseudonymised data on our website and app and use of our services
- Market research and analysis organisations working on our behalf
Your rights regarding our use of your personal information
Southdown will not share any of your information with any third party.
Automated Decision Making
An automated fraud assessment may take place to make a decision whether to accept or decline your purchase. You have the right to contest the decision, to express your point of view, and to require a human review of the decision. You can exercise this right by contacting us using the contact details provided. Accessing your Data by Subject Access Request (SAR) You have the right to request a copy of the information that we hold about you, this is known as a Subject Access Request (SAR). We will provide this to you free of charge once we have confirmed your identity within 30 days of receipt of your request.
If you would like a copy of some or all of your personal information, please email or write to us using the contact details in this policy. Unless you specify otherwise we will provide your information electronically.
If we do hold information about you we will:
- Give you a description of it
- Tell you why we are holding it
- Tell you who it could be shared with
- Tell you how long we will keep the information
- If the information was not provided by you, we will give you any available information such as the source of the data
- Tell you if the information has been used for automated decision making and explain the logic involved in the decision making process
How we keep your personal information safe
We use administrative, electronic and physical security measures to ensure the information we collect about you is protected from access by unauthorised persons and protected against unlawful processing, accidental loss, destruction and damage.
By using our website and/or services, you acknowledge and agree that, except to the extent required by the Data Protection laws, we shall not be responsible for any unauthorised use, distribution, damage or destruction of personal data. We will only retain your information for a reasonable period or as long as is required by law.
How long we keep your personal information
Of the data we process outside of any contract we retain the data for no longer than is necessary. Where there is a legal requirement to retain data for longer than Southdown requires, we will do so. Where reasonably practicable data is minimised so not to be identifiable to the data subject unless required by law or is subject to a Subject Access Request.
We keep your personal information where we have:
- A legal or regulatory requirement that requires us to hold data for a specific time
- A legal basis to retain data including data opt-ins, revised opt-ins and renewed consent
What to do if you have a complaint about our use of your personal information