1. Who is responsible
The organisation responsible for your information is [Legal company name], at [Registered address]. Questions and privacy requests can be sent to [Privacy email].
2. What this pilot collects
The pilot may collect the information you enter, including your name, household size, saving choice, notification choice and app settings.
If you connect a digital identity, the pilot may receive confirmation that your identity and eligibility were checked. It should not collect more identity information than it needs.
If you connect a travel pass or contactless bank card, the pilot may store a protected card reference, the card type, its status and the transport network. It should not store the full payment card number.
Journey records may include the transport operator, journey status, distance, time, qualifying amount and pollution avoided. The pilot is designed to prove that a journey happened without building a detailed history of where you went.
3. Why the information is used
- To check whether you can take part in the pilot.
- To connect a travel card to your verified identity.
- To confirm eligible public transport journeys and prevent the same journey being claimed twice.
- To show example balances, goals and journey records.
- To protect the pilot from fraud and keep it reliable.
- To send notifications only when you allow them.
4. Device storage and pilot data
This demonstration stores much of its example data on your device. Clearing browser storage or choosing “Start empty” in the app may remove it. A live pilot may also use secure cloud services to keep accounts and journeys in sync.
5. Legal basis
Before a live launch, [Legal company name] must confirm the lawful reason for each use of personal information. This may include performing a service you request, meeting a legal duty, your consent, or a legitimate interest that does not override your rights.
6. Who information may be shared with
Information may be shared with transport operators, identity providers, payment providers, hosting and security providers, and public bodies that run an approved programme. Each party should receive only what it needs for its role.
The pilot does not sell personal information.
7. How long information is kept
Information should be kept only as long as needed for the pilot, fraud prevention, payment records and legal duties. The final retention periods must be added here before launch: [Retention schedule].
8. Your rights
Depending on where you live, you may ask to see, correct, delete, restrict or move your information. You may also object to some uses or withdraw consent where consent is used. Contact [Privacy email] to make a request.
You may also complain to your local data protection authority.
9. Security and international transfers
Reasonable technical and organisational steps should protect your information. No online service can promise perfect security. Before launch, this policy must identify any countries outside the European Economic Area where information may be handled and the safeguards used: [Transfer details].
10. Children
The pilot is not intended for children under the minimum age that applies in their country unless a parent or guardian has provided any permission required by law.
11. Changes to this policy
If this policy changes, the date at the top will change. Important changes should also be explained in the app before they take effect.
12. Contact
Privacy questions: [Privacy email]
Postal address: [Registered address]
Data protection contact: [Name or role]