Link Microtransit Application Privacy Policy
Effective August 1st, 2020
This Privacy Policy applies to any information collected by Cityway USA Inc. (" Cityway ") pertaining to your use of Link Microtransit / Transit On-demand Application which may be accessed through mobile applications or our website (collectively, the “Services”). The Services are owned by Cityway. By accessing, using or otherwise interacting with any part of the Services, or by otherwise providing information to Cityway related to the Services, you agree to the collection, disclosure, and use of your information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, do not download, access or use the Services or provide personal information to Cityway.
Please also review our Terms of Use.
TABLE OF CONTENTS
INFORMATION CITYWAY MAY COLLECT THROUGH THE SERVICES
Information You Provide to Cityway Directly
Information Cityway Collects Automatically As You Access the Services
Cookies and Local Storage.
Pixel Tags.
Embedded Scripts.
Click Through URLs.
User Content
Social Media Interactions
Send to a Friend Features and Information You Provide about Others
HOW CITYWAY MAY USE THE INFORMATION COLLECTED
WHEN CITYWAY DISCLOSES YOUR INFORMATION TO THIRD PARTIES
Related Entities and Departments.
Third Parties Providing Services on Our Behalf.
Administrative and Legal Reasons.
Sweepstakes, Contests, Promotions.
Business Transfers.
THIRD PARTY LINKS AND CONTENT
THIRD PARTY ANALYTICS COMPANIES AND SIMILAR THIRD PARTIES
HOW CITYWAY RESPONDS TO “DO NOT TRACK” SIGNALS
DATA SECURITY
CONSENT TO TRANSFER AND STORAGE IN THE UNITED STATES
ACCESSING AND UPDATING YOUR INFORMATION AND YOUR CHOICES
CHANGES TO PRIVACY POLICY
CONTACT US
INFORMATION CITYWAY MAY COLLECT THROUGH THE SERVICES
Cityway collects information from you directly, automatically when you visit the Services, and sometimes from third parties. Some of this information may be considered “personal information” under various applicable laws. We consider information that identifies you as a specific, identified individual to be personal information (such as contact information), and we treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. And, if Cityway combines information we consider to be non-personal with personal information, we will treat that combined information as personal information under this Privacy Policy and as required by law. Note that Cityway may de-identify personal information so that it is non-personal, such as aggregating or converting it to a code, sometimes using a function commonly known as a “hash”. We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.
Information You Provide to Cityway Directly
Cityway may ask you to provide information directly when you interact with us, such as contact information (including your name, phone number, mailing address, and email address), current location (such as address or intersection), other information about you, such as demographic information (ZIP code, and date of birth, for example) and information about your preferences and interests. You may provide personal information, demographic data and other information through various forms and features on the Services or when you otherwise interact with us. Cityway will also collect personal information and payment information when you make a purchase through us.
Our Services are intended for a general audience and Cityway does not knowingly collect personal information from people younger than the age of 18.
Information Cityway Collects Automatically As You Access the Services
We, and our third-party business partners (including any third-party service, content, or analytics providers), may use a variety of technologies that automatically or passively collect certain information about your use of the Services whenever you visit or interact with the Services (“Usage Information”). This Usage Information may include the website browser or operating system you are using, the URL that referred you to our Services, the search terms you entered into a search engine that led you to our Services, Location Data (defined below), all of the areas within our Services that you visit, and the time of day, the next website you visit after leaving our Services, among other information. Cityway may use this Usage Information for a variety of purposes, including analyzing trends, administering the Services, tracking users' movements around the Services, gathering demographic information about our user base as a whole, and enhancing or otherwise improving the Services.
In addition, Cityway automatically collects your IP address or other unique identifier (“Device Identifier”) for your mobile phone, computer, or other device used to access the Services. A Device Identifier is a number that is automatically assigned to your device used to access the Services, and our servers identify your device by its Device Identifier.
Cityway may capture and record or infer certain location data regarding your use of the Services and your travels ("Location Data"). This may include precise Location Data from the device you use to access the Services if you have permitted such collection through our mobile application or your browser. You may be able to turn off the collection of precise Location Data through your device settings. However, please note that Cityway may still be able to infer your approximate location through other information Cityway collects, such as IP address. We may link Location Data to other information used on the services, but we only use this information to provide and improve the services.
Cityway uses the following types of tracking technologies to automatically collect information when you interact with us online:
Cookies and Local Storage. “Cookies” and local storage are pieces of information (data files) transferred to an individual’s browser on their device when the device is used to visit a site. These technologies are able to store a unique identifier for a device to allow a certain Internet site to recognize the device whenever the device is used to visit the Services. These technologies may be used for many purposes by Cityway and our third-party service providers, such as automatically collecting Usage Information, enabling features, and remembering your preferences. Cityway may use cookies and other technologies to study traffic patterns on our Services, to make them even more rewarding as well as to study the effectiveness of our customer communications. And Cityway may use cookies to customize your experience and provide greater convenience each time you interact with us. The information we store includes internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. You can find more information about cookies and how they work at www.allaboutcookies.org.
If you choose to disable cookies or restrict local storage, some features of the Services may not function properly.
Pixel Tags. Pixel tags are tiny graphic images or other web programming code that tell us what parts of our website customers have visited or to measure the effectiveness of searches customers perform on our Services. Pixel tags and similar technologies may be used for a number of purposes, including, without limitation, to count visitors to a site, to monitor how users navigate the Services, to count how many emails that were sent were actually opened, to count how many particular links were actually viewed. Pixel tags also enable Cityway to send e-mail messages in a format customers can read.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected to a site and is deactivated or deleted thereafter.
Click Through URLs. In some of our e-mail messages we use a "click-through URL" linked to content on the Services. When a customer clicks one of these URLs, they pass through our web server before arriving at the destination web page. Cityway tracks this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications.
In addition, Cityway may use a variety of other technologies that collect similar information for security and fraud detection purposes.
User Content
The Services may provide you the opportunity to register and create an account which may allow you to submit questions, comments, survey responses or other content (collectively “User Content”), and may have separate terms that govern your submission of User Content. Please see our Terms of Use, for more information about User Content and our Usage Rules.
If you submit User Content the User Content may be used by Cityway for our business purposes.
Social Media Interactions
The Services may permit or facilitate interactions with an interactive third-party website or service (“Social Media”), such as enabling you to “like” or “share” content. If you choose to share content or otherwise post information from or via the Services to Social Media, that information may be public and the third party may have access to information about you and your use of our Services. You may also choose to participate on Social Media in a way that connects that third-party service with our Services, such as posting to one of our pages on a Social Media platform. Doing so may allow Cityway to collect (or the third party to share) information about you, including personal information, and the third party may allow us to re-post content related to us on our Services.
Also, both Cityway and the third party may have access to certain information about you and your use of the Services and the third-party service. These Social Media sites may collect information about your visit to our Services through the features we have integrated into the Services and may be able to collect certain information about your visits to the Services regardless of whether or not you affirmatively interact with the feature and whether or not you are logged into (or have) an account with the social networking company.
Cityway may also receive information about you if other users of Social Media give us access to their profiles and you are one of their connections or “friends”. The information Cityway collects is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third-party website or service. The third party may allow you to remove the application or feature, in which case Cityway will no longer collect information about you through the application or feature, but may retain the information previously collected.
Send to a Friend Features and Information You Provide about Others
If you send a friend a communication from the Services such as sharing your estimated time of arrival (ETA), the information you provide (names, email addresses, etc.) is used on a one-time basis to facilitate the communication and is not used for any other purpose, unless Cityway obtains consent from that person. If you otherwise disclose any personal information relating to other people to Cityway, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.
HOW CITYWAY MAY USE THE INFORMATION COLLECTED
Cityway may use information collected through the Services (including your personal information and Usage Information) in order to: (1) allow you to participate in the Services and providing you with services, announcements, information, and any features or activities Cityway offers through the Services, including marketing and offers from us and on behalf of third-parties; (2) personalize your experience including to provide relevant information based on user’s position (next scheduled trip, etc.), and tailor content we display to you, such as recommendations we display to you; (3) process information you provide via your account registration with the Services, including, verifying that your email address is active and valid; (4) fulfill transactions and process payments and orders; (5) provide customer service, including in connection with any delivery, billing, or payment processing inquiries; (6) communicate with you regarding your use of the Services (such as part of the registration process, alerts about monthly consumption targets, disturbances in the transportation services and time slots (such as caused by inclement weather)), a transaction, to notify you if you have won a contest or promotion, or to respond to you when you contact us) or other administrative communications, including, in our discretion, changes to the Services’ Privacy Policy, or any of our other terms or policies; (7) protect our Services and our customers from errors, misuse of the Services, fraud, or any criminal activity and detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Services; (8) further internal business purposes, such as to improve our Services or our products and services, and to comply with regulatory and legal obligations; or (9) as otherwise disclosed in this Privacy Policy, as disclosed at the time you provide your information or otherwise with your consent.
WHEN CITYWAY DISCLOSES YOUR INFORMATION TO THIRD PARTIES
Cityway may share non-personal information, such as Usage Information, de-identified or aggregated user statistics with third parties in our discretion. Cityway does not share your personal information with third parties for those third parties' marketing purposes. In addition, Cityway may share information we have collected about you, including, without limitation, personal information and Usage Information, as disclosed at the time you provide your information or otherwise with your consent, as described in this Privacy Policy and in the following circumstances:
Related Entities. Cityway may share information among its affiliated entities (Transdev North America, Transdev Services Inc.).
Third Parties Providing Services on Our Behalf. Cityway may share information with third parties who perform services on our behalf, such as website hosting, processing information, sending email or other communications, fulfilling customer orders and processing payments (including clearing and processing credit card payments), running promotions, providing marketing assistance and data analysis (including assessing your interest in our products and services or conducting customer research/satisfaction surveys), and performing other services. Cityway may provide access to your personal information to such third parties in order for them to perform these services. Without such information being made available to these third parties, it might be difficult for you to purchase services, receive customer service, provide Cityway feedback to improve our services, or access certain services, and content on the Services.
Administrative and Legal Reasons. Cityway may transfer and disclose information, including your personal information, Usage Information, and Device Identifier (e.g. IP address) with third parties to comply with a legal obligation, when we believe in good faith that the law requires it; at the request of government or investigatory authorities conducting an investigation; to verify or enforce our applicable Services terms and policies; or otherwise to protect our rights, property, safety, or security or that of other Services visitors or the public, such as when we are investigating potential fraud. For example, Cityway may share information to respond to a court order or subpoena. Cityway may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers, or law enforcement agencies, in our discretion.
Sweepstakes, Contests, Promotions. Cityway may offer sweepstakes, contests, or other promotions (any, a “Promotion”), that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the Promotion, which may require specific requirements of you (including, without limitation, and except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, as required by law or permitted by the Promotion’s terms or official rules (such as on a winners list).
Business Transfers. In the event Cityway goes through a transition such as being sold, has all or a portion of its assets acquired or transferred, whether voluntary or involuntary (such as through bankruptcy), or merges or becomes affiliated with any other division, individual or entity (including, without limitation, during the course of any due diligence process), any customer information owned or under the control of Cityway (including, without limitation, your personal information) will likely be one of the transferred assets. Cityway reserve the right, as part of this type of transaction, to assign or otherwise transfer your information (including, without limitation, your personal information) and other information Cityway has collected from users of the Services. By providing your personal information, you agree that Cityway may transfer such information to the acquiring entity without your further consent. For example, if part of our business was sold Cityway may give our customer list as part of that transaction.
THIRD PARTY LINKS AND CONTENT
The Services may link to or incorporate websites or content hosted and served by third parties over which we have no control and which are governed by the privacy policies and business practices of those third parties. Cityway is not responsible for the privacy practices or business practices of any third party.
THIRD PARTY ANALYTICS COMPANIES AND SIMILAR THIRD PARTIES
Cityway works with analytics partners, service providers, and other vendors to provide us with information regarding traffic on and use of the Services (including pages viewed and the actions taken when visiting the Services).
These third parties may set and access their own tracking technologies on your device (including cookies and web beacons) and may otherwise collect or have access to information about you, including Usage Information. Some of these parties may collect personal information over time when you visit the Services. One analytics provider with whom Cityway may work is Google Analytics. Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This Google service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google's practices by going to google.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout.
HOW CITYWAY RESPONDS TO “DO NOT TRACK” SIGNALS
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, our Services do not alter their practices when they receive a “Do Not Track” signal from a visitor’s browser except as specifically required by law. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
DATA SECURITY
Cityway uses commercially reasonable security methods -- including administrative, technical, and physical measures -- to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction.
However, no system can be guaranteed 100% secure. We therefore cannot ensure or warrant the security of any information that you transmit to us, or that Cityway transmits to you, or guarantee that it will be free from unauthorized access by third parties. You use the Services and provide us with information at your own initiative and risk.
CONSENT TO TRANSFER AND STORAGE IN THE UNITED STATES
Cityway is a United States company. Please be aware that information Cityway collects will be transferred to and processed in the United States and possibly other countries. By using the Services, or providing Cityway with any information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States and other jurisdictions, the privacy laws of which may not be as comprehensive as those in the country where you reside and/or are a citizen. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to laws in those jurisdictions.
ACCESSING AND UPDATING YOUR INFORMATION AND YOUR CHOICES
You can unsubscribe from marketing emails through the opt-out mechanism included in each marketing email Cityway sends to you. Note that we reserve the right to send you certain email or postal communications relating to your use of our Services, service announcements, notices of changes to this Privacy Policy, our Terms of Use or our other terms, or similar administrative or transactional messages, and these transactional account messages may be unaffected if you choose to opt-out from marketing communications.
You may have the opportunity to utilize features on the Services that permit you to register for a user account. If you have an online account, you are responsible for maintaining and updating, as applicable, your account registration data with current, accurate, and complete information. You may have the ability to view, update, and/or edit the registration data you have provided to Cityway , or to delete your account, by logging in to your account and following the appropriate instructions or by contacting us with your request at the following email [link.support@cityway.io]. If Cityway offers and you utilize such a feature, we will make requested changes in our active databases as soon as reasonably practicable. Note, however, that we may retain information associated with the account, including the information that you have updated or changed for internal or administrative purposes.
CHANGES TO PRIVACY POLICY
To the extent allowed by applicable law, Cityway reserves the right to change or modify this Privacy Policy in our discretion at any time and will notify you of material changes by posting the changed or modified Privacy Policy on our Services. Cityway may also provide notice to you in other ways in other discretion, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified, and your continued use of the Services after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy) will constitute your consent to those changes to the fullest extent allowed by applicable law. Cityway will not use your personal information in a manner materially different than promised at the time the information was collected without giving you the chance to consent (which may be opt-out consent or which may occur through your continued use of the Services) to the new policy, as required.
CONTACT US
If you have questions or concerns about Cityway's Customer Privacy Policy or data collection or use, please send an e-mail to link.support@cityway.io.
Address: Cityway USA Inc., 720 E. Butterfield Road, Lombard, Illinois 60148
Phone: (630) 382-1107