Privacy Notice of Bahrain Public Transport Company

Overview

In this privacy statement, Bahrain Public Transport Company describes how it collects, uses, and discloses passenger data, as well as information about visitors to its website. The Privacy policy outlines the way in which we use cookies and similar methods on all our websites owned by Bahrain Public Transportation Company W.L.L. (hereafter referred to as "BPTC"), along with our other marketing and customer service activities.

The purpose of this privacy statement is to provide you with information about

Collection and Use of Information
What information do we collect?
How will this information be used?
Who will we share your information with?
Where do we store your information?
For how long will we process your personal data?
What rights do you have in relation to your personal data?
General Information

We take the protection of your privacy very seriously and are committed to observing the Personal Data Protection Law of Bahrain Law No. (30) of 2018. The information contained in this privacy notice may change from time to time, and the most recent version will always be available on our website. It is your responsibility to read this privacy notice and to visit our website regularly.

1. Collection and Use of Information

What data collection methods do we use?

Our website uses a variety of data collection methods and technologies (including cookies). Using these tools, we collect data for the purpose of performing transactions with you, gathering statistics and analytics on traffic to our website and user behaviour, evaluating the effectiveness of our marketing campaigns, requesting user feedback, and improving the quality of our website and customer service.

Through our website, we also enable third-party cookies and other technologies, including those used by advertisers.

You may be able to disable cookies in most modern web browsers through your browser security settings; however, certain parts of our website may not function properly if your security settings are too high. These technologies may place cookies in your browser cache or use other methods to show third-party content.

We collect personal information when you purchase a personalized "Go Card". All information entered and/or feedback submitted through our website forms. Any interaction with us on social media platforms such as Facebook, Instagram, WhatsApp, linked in, etc. In the course of traveling on the bus services provided by Bahrain Public Transport Company, and within the premises of the bus station.

In addition to using the websites or using the technology, we also collect data directly from you. We collect through our direct representatives while in station by our retail agent or through our customer service centre or while applying for job roles or during the recruitment process. The listed are not the only way of collecting the information’s. They are subject to vary based on improvement and law abide.

2. What information do we collect?

- • your name and title;
- • your address and country of residence;
- • your contact information, including telephone number and email address;
- • your CPR/Driving License/Passport Number/ Personal Number;
- • our Age, Gender, Date of Birth, Nationality;
- • your transaction or payment information - however please note that full debit card and credit card information is not processed by us as it is passed through to a PCI-DSS compliant third party payment provider in accordance with good industry practice;
- • if you are disabled or have special needs, information about your disability, special needs or mobility requirements, or where you are arranging transport for someone else information about their disability, special needs or mobility requirements;
- • your image, where it is captured by CCTV or other visual recording equipment on our owned or occupied sites, such as stations and/or on the passenger carrying vehicles used to provide our passenger travel services;
- • your voice, where this is captured by CCTV or any other audio recording equipment at our owned or managed premises, such as, stations and/or on the passenger carrying vehicles used to provide our passenger travel services and/or where captured in recorded telephone conversations with you; and
- • any other personal data that you provide to us when you visit our website, use our apps, or when you communicate with us.

In addition, each time you visit our website or use our apps we may automatically collect the following information:

- • technical data, including:
  - ⋄ IP address;
  - ⋄ browser type and version;
  - ⋄ time zone setting and location; and
  - ⋄ operating system and platform;
- - • Transaction data, including:
    - ⋄ the full Uniform Resource Locators (URLs) clickstream to, through and from our website or apps (including date and time);
    - ⋄ Go Card number used to purchase the products listed on our supplier websites.
    - ⋄ Transaction medium of purchase of the Go card affiliated products.
  - • time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
  - • In our passenger travel services provided by BPTC, we will collect data on the dates and times of travel, routes used, as well as start and stop points, transfers between services, along with methods of payment;

We collect your personal data in a variety of ways, including:

by you:

- • submitting your personal data on our website or apps
- • providing your personal data to us when communicating with us in any manner, for example, when you:
  - ⋄ speak to one of our representatives in person at our stations or on-board one of our passenger carrying vehicles; and
  - ⋄ contact us by letter, email, text message, telephone call or on social media;
- • consenting to receive certain information from us, such as marketing emails and other promotional material about sales, offers, exclusive deals and travel ideas;
- • submitting information when registering or using our on-board Wi-Fi.

by us:

• making visual and/or audio recordings at our owned or occupied sites, including at our stations and on the passenger carrying vehicles used to provide our travel services;
• recording telephone conversations with our customer contact center representatives; and
• gathering statistical information around email opening and clicks.

We may also receive your personal data if you use any of the other websites from third parties, such as companies that market and sell our products and/or services on our behalf.

3. How will this information be used?

The main purpose of the data collection activities are to help us maintain and improve the services that we offer to our customers.

We may use your information:-

Purpose

Legal basis

Explanation

To provide you with information, advice and guidance about our products and services

To manage our relationship with you, including to respond to any questions you ask and deal with any complaints and/or feedback you make and, on occasion, to ascertain whether you wish to be a brand ambassador for us

To develop our service and new and/or better ways of meeting our customers’ needs, including by considering your feedback, carrying out market research and consulting with you

To develop our strategy, operational processes, and marketing activities

To study how our customers use products and services provided by us and third parties

To manage how we work with other companies that provide services to us and our customers

To comply with the laws and regulations that apply to us

To seek to enforce and defend our legal rights.

To seek to detect, investigate, prevent and report crime and anti-social behaviour.

To seek to protect and promote your health & safety and that of our other customers, staff and third parties

Fulfilling our legal duty

Performance of our contract with you Legitimate interest

Consent

Being efficient about how we fulfil our legal and contractual duties and manage our relationship with you

Keeping our Service records up to date

Developing and improving our business

Developing our products and services, and what we charge for them

Developing relationships with business partners, to enhance our product and service offering

Preserving our legal position, seeking to detect and prevent crime and anti-social behaviour and seeking to promote health and safety.

Enabling us to provide safe passenger transport services

To market and promote products and services to you offered by us.

To inform you about incomplete purchases of our products and services

Consent

Legitimate interest

To inform you about similar products and services to those you have previously bought from us

help us monitor and improve our communications to you

To assist you in completing your purchase

To administer and manage our website and apps, including troubleshooting and testing

To ensure that our website content is presented to customers in the most effective and tailored manner

For data analysis, research, statistical and survey purposes

Legitimate interest

Consent (to our use of cookies)

Providing an efficient and tailored means for customers to get information about our products and services

4. Who will we share your information with?

We may disclose relevant information to:

- • Our regulators, lawyers and auditors;
- • The Ministry of Transport & Telecommunications;
- • The Ministry of Justice, the Ministry of the Interior, the Police or courts;
- • Other companies within our group, which means our subsidiaries, partners, our ultimate holding company and any subsidiaries;
- • Persons where required by law under a court order or subpoena;
- • Third party service providers or agents acting on our behalf; and providers of any of the services and technologies identified in the paragraph 'What data collection methods do we use?' and advertising networks.

5. Where do we store your information?

The data that we collect from you may be transferred to, and stored at, a destination in Bahrain or GCC. By submitting your personal data, you agree to this transfer and/or storing of your personal data. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with the privacy policy.

Kindly contact DPO, Bahrain Public Transport Company if you would like to have further information on how your personal data is transferred outside Bahrain.

6. For how long will we process your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting or reporting requirements in respect of our relationship with you.

Personal information will be retained only for as long as the purpose for which it was collected continues, in accordance with Personal Data Protection Law of Bahrain Law No. (30) of 2018 . It will then be destroyed; although copies may be retained if required to satisfy our legal, regulatory or accounting requirements.

7. What rights do you have in relation to your personal data?

You have a number of rights under Data Protection Laws in relation to your personal data. These include the right, subject to exceptions, to:

- • request access to your personal data by filling the data subject access rights form
- • request rectification or erasure of your personal data;
- • request restrictions on the processing of your personal data; and
- • object to our processing of your personal data.

You also have the right in some circumstances to receive a copy of your personal data in a portable format. This right is limited to personal data you have provided to us and is processed on the basis of your contract with us and/or your consent. It does not cover personal data that we process on other grounds.

If you wish to exercise any of these rights that you have been provided and is processed on these bases, please contact BPTC data guardian by submitting the filed form (Click Here).

8. General Information

Changes to the Privacy Policy

If we change the policy, we will post the new policy on the relevant page of our website and highlight this on the home page. If the change means that we will use your information differently, we will notify you. You may accept the change of use, or if you do not, we will continue to use your information in accordance with the policy under which it was originally collected.

Keeping your data secure

We will use technical and organizational measures to safeguard your personal information; for example:

• All information you provide to us is stored on secure servers;
• Any electronic payment transaction information will be encrypted and transmitted using appropriate methods;
• Access to your personal information is managed and controlled to prevent inappropriate disclosure;
• A designated Data Controller will monitor activities to ensure compliance;
• Statistical data is anonymized before analysis;

Whilst we will use reasonable efforts to safeguard your personal information, you acknowledge that the use of the internet is never entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which are transferred from you or to you via the internet.

Our responsibility to you

We confirm our intention is to meet our obligations under the privacy policy statement, and to comply with the requirements of the Personal Data Protection Law of Bahrain Law No. (30) of 2018

Other Websites

Our website may contain links to the websites of other companies that are outside of our control. These websites are not covered by the privacy policy. If you access other sites through our website then the operators of these sites may collect information from you which will be used by them in accordance with their own privacy policies, which may differ from ours.

Legal Entity

Bahrain Public Transport Company W.L,L, with company number 911400-1, of the registered office Central Bus Depot, Isa Town 840, Post Box Number 33277, Southern Governate, Kingdom of Bahrain.

Bahrain Public Transport Company W.L.L is the 'data controller' for the purposes of the Personal Data Protection Law of Bahrain Law No. (30) of 2018.

Copyright

All copyright, database rights, design rights, and all intellectual property rights in and to all text and graphics, and all other materials on this website belong solely to Bahrain Public Transport Company W.L.L.

No part of our website can be reproduced in any form whatsoever whether electronically or otherwise without our prior written consent other than temporarily in the course of using our website or to keep a record of a transaction entered into using this website.

Liability Disclaimer

We disclaim and exclude any responsibility for errors in respect of the information on the website. Your reliance on this website and your use of this website is entirely at your own risk. We exclude all warranties, terms and conditions implied by law in relation to this website.

You may not rely on any statement or representation in the website, and when you buy tickets for travel from Bahrain Public Transport Company you agree that you have not relied on any statement or representation in this website.

We do not exclude our liability for fraudulent misrepresentation.

We shall have no liability for any loss or damage you suffer as a result of relying on any fact or statement that proves to be incorrect.

Cookies

In this section you will find information on internet cookies; the cookies that may be set when you visit the Bahrain Public Transport Company website; and how to manage and delete these through your browser.

What is a cookie?

A cookie is a small amount of data in the form of a text file, which often includes a unique identifier that is sent to your computer or mobile phone device’s browser from a website's computer and is stored on your device.

Each website can send its own cookie to your browser if your browser's preferences allow it; but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows.

Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these means that certain personalised features cannot then be provided to that user and accordingly they may not be able to take full advantage of all of the website's features. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

How do we use cookies?

During the course of any visit to the Bahrain Public Transport Company website, the pages you see, along with any cookies, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things like find out whether the device (and probably its user) has visited the website before. This is often done on a repeat visit by checking to find the cookie left there on the last visit.

Information supplied by cookies allows us to analyse the profile of our visitors and can help us to provide you with a better user experience.

How to manage and delete cookies

Bahrain Public Transport Company will not use cookies to collect personally identifiable information about you. However, if you wish to restrict or block the cookies that are set by the Bahrain Public Transport Company website, or indeed any other website, you can do this through your browser settings. The Help function within your browser should tell you how to do this.

Alternatively, you may wish to visit the website “https://aboutcookies.org” which contains comprehensive information on how to do this on a wide variety of web browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.

Google Analytics

Bahrain Public Transport Company uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of the website and compile reports for us and our agents, about the user activity on our website.

Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using the Bahrain Public Transport Company website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.