Privacy Policy for Rejsekort as an app

Valid from 25th February, Version 3.5.

Data Controller

Rejsekort & Rejseplan A/S is the data controller for the processing of personal data in connection with the registration of information in the Rejsekort system and related systems, including personal data registered via the Rejsekort app and the website, www.rejsekort.dk. Our contact details are as follows:

Rejsekort & Rejseplan A/S
Automatikvej 1
2860 Søborg
CVR No.: 27 33 20 72

Rejsekort & Rejseplan A/S’ Data Protection Officer (DPO) can be contacted at: DPO@rejsekort.dk or by phone at +45 70 20 40 08 on weekdays between 10:00 AM and 15:00 PM.

For further contact information, see section 1 below.

Privacy policy for Rejsekort as an app

At Rejsekort & Rejseplan A/S, it is important to us that you feel comfortable being our customer.

Therefore, we process your personal data responsibly, with respect for your privacy and in accordance with all relevant legislation, including the General Data Protection Regulation.

You can read more about our processing of your data and a description of your rights in this privacy policy.

You can always see at the top of our privacy policy when the policy was last updated and/or changed.

Rejsekort as an app is a mobile application (hereinafter referred to as "app" or "the app") developed by Rejsekort & Rejseplan A/S, in which you can purchase a valid ticket (travel document) for public transport from transport companies affiliated with Rejsekort & Rejseplan A/S. For information about the affiliated transport companies, see section 3 in Terms and conditions for Rejsekort as an app.

1. Contact details of the data controller and data protection officer

Rejsekort & Rejseplan A/S is the data controller for the processing of personal data in Rejsekort as an app. Our contact details are:

Rejsekort & Rejseplan A/S
Automatikvej 1
2860 Søborg, Denmark
CVR no.: 27 33 20 72

Rejsekort Customer Service Phone: 70 11 33 33 33

Via contact form at https://www.rejsekort.dk/rejsekort_app/Kontaktformular

By letter to:

 Rejsekort Customer Service PO Box 736
 2500 Valby, Denmark

Contact details for our Data Protection Officer (DPO) are

DPO@rejsekort.dk
Phone: 70 20 40 08

Phone hours are weekdays between 10AM-15PM.

2. What data do we collect and what is the purpose of the processing

2.1. Information about your journey, location and activity in connection with your use of Rejsekort as an app

We process the information you provide when you register as a user of Rejsekort as an app. We also process a number of data that is created through your use of the app.

The information that you need to provide when creating a profile is: 

• Your mobile phone number
• Your email address
• Your first and last name
• Your date of birth
• Information about the associated payment method

A system-generated unique user ID is also created and linked to your profile

Once you have created your profile and choose to check in multiple travelers while using the app, we register this on your journey to calculate the correct fare. We only record the customer types you check in and the number of travelers per customer type on the trip.

Once you have created your profile and use the app to purchase public transport tickets, we register the necessary location (GPS) and activity information from your mobile phone to provide the Rejsekort as an app service.

We register your location as soon as you open the app, but this is done locally on your phone for 5 minutes at a time, after which the registration is overwritten with new data. This is done to find the nearest station or stop, which becomes the start location for your check in. If you open and close the app without checking in, the registered location information prior to check-in will not be saved on your phone and we do not collect this data. If you open the app and check in, we only collect location data for the last 2 minutes prior to check-in to verify that the stop identified by the system is the correct one.

When you check in, the time and place of check-in is recorded, and the app then tracks your location and activity until you are checked out again. When you check out, we register the location that represents the end of the journey. This is done to provide you with a valid ticket for the entire journey by generating the correct ticket corresponding to your travel route and means of transport used and to calculate the correct price for it. Once you have checked out and the system has calculated your journey, we no longer register your location or activity. Rejsekort as an app only collects data when the app searches for a station or stop when you are actively travelling and until you check out yourself or use Smart check out, and are thereby automatically checked out of the app.

In other words, we do not register and collect data on your phone or in the Rejsekort system when your app is closed, and we only register information locally on your phone that will not be saved if the app is closed without check-in. Read more about location information and activity information in section 2.2.

The app only has access to data that is necessary to provide you with a valid public transport ticket from the affiliated transport companies and only when you open the app and between check-in and check-out - even if you must select 'Always allow' for location sharing on iPhone.

For the app to function properly and to ensure that we can serve you if you experience problems with the app, we also process certain technical data. This concerns:

• Your IP address and device ID
• Your ticket settings, including customer type and any discount level
• Information about the mobile device used:
  • Make and model
  • Operating system
  • Wi-fi and Bluetooth signals
  • Battery status

As you have the right to access your purchase history for 36 months, we store your journey history and purchase history in the app for this period. This allows you to continuously verify that the app has correctly calculated your journeys. If you have checked in multiple travelers using Rejsekort as an app, this will also be visible in your journey and purchase history. Additionally, this data enables the Rejsekort Customer Service to assist you if, for example, you detect an error in your journey. Your journey history includes information about your completed journeys, including location data up to 5 minutes after your final destination, while your purchase history contains details of your completed payments

We also process your location and activity data for the purpose of detecting and preventing misuse. Read more about our processing to detect and prevent abuse in section 3 below.

We also use the information in pseudonymous form to train the system's algorithms to calculate your journey more accurately, to identify and make system fixes in case of errors and to develop new features to improve the usability of the app.

If you contact Rejsekort Customer Service, we will also store the personal data you provide in this connection that is relevant to your customer relationship.

When contacting the Rejsekort Customer Service by phone, your calls may be recorded if you give your specific consent. The recordings are used for documentation and training purposes and are continuously deleted after 30 days.

We also collect data about how you interact with the app, such as date and time of access, app features or pages accessed, app crashes and other system activity, and browser type. However, we only process this data in anonymised form.

Rejsekort as an app works by recording your journey activity (journey data) when you use the app. Specifically, we record location and activity data from your mobile device.

We only register your location information from the time you open Rejsekort as an app, during your journey while you are checked in and until you are checked out and your journey is calculated.

However, we do not record information about you when you are not using the app and have it running in the background on your phone and are not checked in, as described in section 2.1.

After you have checked out, we will stop recording your location information again as soon as possible when the system is able to determine exactly where the check-out was made. In areas with poor mobile connectivity this may take longer than in areas with good mobile connectivity.

If you do not check out immediately after the end of your journey, we will continue to register your location and activity information until you check out.

We do this because you have a valid travel document as long as you are checked in. At some point when you check out, your journey will be calculated and the most likely place your journey actually ended will be the final destination on your ticket.

We process the location data relating to the time after you actually completed the journey by public transport until check-out is made, to ensure:

Proper functioning of the system, including fixing system errors and system improvement

1. that you have not misused our solution, and
2. that we serve you in the best way possible at the Rejsekort Customer Service

For no. 1, we store and process the personal data in pseudonymous form, i.e. where the personal data is masked and cannot be directly attributed to you without additional information.

For no. 2 and 3, we need to process and store the personal data in directly personally identifiable form, as we need to know the identity of the individual customer in order to process it, e.g. to correct your journey information where a final destination has been (stated) incorrectly calculated.

We store the location data and activity data from motion sensors that are collected from 5 minutes after you exit the last public transport vehicle until check-out is performed. This data is stored in a pseudonymized form for a period of two months to be used for system improvements and corrections of system errors, after which it is deleted. Additionally, this data is also stored in a directly identifiable form for a period of two months. This is done to 1) prevent fraud with the application and 2) to support the work of the Rejsekort Customer Service, including the ability to correct any errors in journey records.

If there is a gap of more than 30 minutes between two modes of transport (e.g., bus and train), location data and activity data from motion sensors are deleted according to the following rules:

• The transit period, starting five minutes after the first mode of transport and lasting until five minutes before the next mode of transport, is deleted after two months.
• The first five minutes after the first mode of transport, as well as the five minutes immediately before the next mode of transport, are retained as part of your travel data and are deleted after 36 months.

Thus, only the location data and activity data related to your public transport journey—including five minutes before and five minutes after your trip—are stored for 36 months.

3. Profiling for the purpose of detecting and preventing misuse of the app

In the app, we use profiling to detect and prevent misuse of Rejsekort as an app.

Profiling is conducted by the app identifying misuse-like behavior during completed journeys. This occurs within the system, where each journey is automatically checked for signs of misuse-like behavior. The system assigns a score to all completed journeys based on whether the travel pattern indicates potential misuse. Previous behavior and scores are not considered in this calculation. Based on this, an overall point tally (a "fraud score") is generated for all customers, depending on their travel behavior. If a customer's overall fraud score becomes sufficiently high, it will be flagged in the system, after which a specific manual case review will take place. During the review of the overall point tally, previous behavior and scores will be taken into consideration.

Misuse-like behavior may result in sanctions, such as being blocked from using the app, based on a manual case review. Generally, sanctions will require that you have received one or more warnings related to the observed behavior beforehand. In Rejsekort as an app, profiling thus serves as decision support for caseworkers, and no automated decisions are made.

3.1. Information about any profile blocking                   

Under certain circumstances, we may block your profile in the event of abusive behavior. Read more about the rules for blocking in the Terms and Conditions for Rejsekort as an app, which you can find directly in the app and at www.rejsekort.dk under "Terms and Conditions".

4. Who has access to personal data?

Only employees with a work-related need at Rejsekort & Rejseplan A/S and at our data processors have access to the personal data collected.

This includes employees in:

• Public Transport Operator

  Relevant employees in the affiliated Public Transport Operators have access to the information necessary to serve and manage your customer relationship. This includes your travel and payment history, as well as personal information about you, such as your name, date of birth, and contact details.

  • The Public Transport Operators are:
    • GoCollective
    • DSB
    • Metroselskabet
    • Fynbus
    • Nordjyllands Trafikselskab
    • Midttrafik
    • Sydtrafik
• IT supplier
  Our IT supplier, Fairtiq, acts as a data processor and has signed a data processing agreement and a confidentiality declaration, which legally binds them to comply with data protection regulations. This means they are only allowed to process your personal information in accordance with our instructions. Fairtiq is responsible for delivering and operating Rejsekort as an app and its associated systems.
  Additionally, we use the following IT suppliers to support various functions within the system: MailJet, Amazon Simple Email Service, and LINK Mobility are used for sending emails and SMS notifications to Rejsekort users. VIPPS MobilePay, Billwerk+, and Lector handle payment processing and other administrative case management.

4.1 Disclosure of personal data

If applicable, we will disclose your personal data, including journey history, journey price and number (not GPS points), in pseudonymous form to the affiliated Public Transport Operators in connection with revenue sharing and settlement with them and for their independent processing of financial matters, cf. the Act on Transport Companies.

If relevant, we will disclose your personal data in directly personally identifiable form to the affiliated transport operators in connection with their independent processing of control fee cases, collection cases, customer complaints, journey duration guarantee cases and financial cases. It is assessed that we can lawfully disclose the necessary personal data to the affiliated Public Transport Operators on the basis of Article 6(1)(f) of the General Data Protection Regulation, as RKRP and Public Transport Operators in question thereby pursue a legitimate interest in protecting and collecting their claims under the agreements with the customers, and as the customers' interests do not override this.

Similarly, and only if relevant, we will disclose your personal data to public authorities, e.g. to the Danish Transport Authority, which, among other things, performs revenue sharing for certain revenues in public transport.

We disclose relevant information about you, such as your name, address, phone number, email address, and case number, to the research institutes Wilke, Epinion, and Axcessnordic for the purpose of conducting customer satisfaction surveys on our behalf. Participation in a satisfaction survey is voluntary. The research institutes are required to delete the received personal data once the task has been completed. We assess that we are legally permitted to share the necessary personal data with these research institutes, as the customer satisfaction surveys are conducted for a compatible purpose that ensures the continuous optimization of customer relations, including our solutions and processes.

Additionally, we disclose personal data in certain situations for use in research projects. We only disclose personal data if we specifically determine that it is lawful to do so, that the disclosure serves a legitimate and justifiable purpose, and that it is ethically responsible. Furthermore, we ensure that the disclosed information is secured to the greatest extent possible, including through pseudonymization, if full anonymization of the data is not feasible.

5. How and for how long do we store information about you?

We store your personal data in IT systems with controlled and restricted access and on servers located at AWS Amazon in Ireland. We also secure your personal data with appropriate technical and organisational security measures from the time of registration until deletion. We delete your personal data as soon as we no longer need it to fulfil the purpose for which it was collected.

We store information about you as a customer for as long as it is necessary for the purposes mentioned in section 2, cf. the table below:

These deletion deadlines may, after a specific assessment, be deviated from so that the personal data is deleted at an earlier or later date if there are specific, objective reasons for this. This may be the case, for example, if you request deletion without ever having used the app to buy a ticket/ticket dokument. In such a case, deletion of your data may take place earlier than the time specified in the form. If, on the other hand, a case is pending before the courts, the specified retention periods may be extended after a specific assessment.

Transfer of data to 3rd countries

We only store data on servers located within the EU. However, we have suppliers based outside the EU, in Switzerland and the United States, respectively. The supplier in the US is affiliated with the EU-U.S. Data Privacy Framework, and is thus subject to the EU Commission's adequacy decision from July 2023. Switzerland is also on the EU Commission's list of secure third countries.

6. Legal basis for processing operations

We process your personal data based on the following processing bases:

• When necessary to fulfil an agreement with you (Article 6(1)(b) of the GDPR). This processing basis applies in the ongoing customer relationship where you are registered as a customer in the app.
• When it is necessary for us to fulfil a legal obligation (Article 6(1)(c) of the General Data Protection Regulation). This basis for processing applies as we are obliged to retain information about, among other things, financial transactions pursuant to section 12 of the Bookkeeping Act.

  When you have given your consent to the processing (Article 6(1)(a) of the General Data Protection Regulation). This processing basis applies to telephone recordings in connection with customer enquiries to Rejsekort Customer Service.

• When it is necessary for us to fulfil a legitimate interest (Article 6(1)(f) of the General Data Protection Regulation). This basis for processing applies to our processing of data for the purposes of:
  •  Identification and prevention of misuse, cf. section 3. The legitimate interest in this processing is the identification, prevention, and handling of misuse in the app. We assess that the purpose is legitimate and that the processing is proportionate in relation to achieving this purpose.
  • Processing of location data collected by the app that is not related to your journey using public transport. This includes location data collected if you fail to check out after completing your journey. This processing is carried out to ensure that customer service has the ability to correct data, to analyze whether the route calculation in the system functions correctly, and to prevent and manage fraud. We assess that these purposes are legitimate and that the processing is proportionate in relation to achieving these purposes.
  • Disclosure of information, cf. section 4.1. The legitimate interest in disclosure is to support the legitimate and lawful purposes for which the recipients of the information process the data.

7. Your rights

You have a number of rights under the General Data Protection Regulation in relation to our processing of your personal data. If you want to exercise your rights, please contact us. See our contact details above under point 1.

Your rights are:

Right to see information (right of access)
You have the right to access the personal data we process about you.

Right to rectification (correction)
You have the right to have inaccurate information about yourself corrected. You also have the right to have your data supplemented with additional information if it will make your personal data more complete and/or up-to-date. You have the option to correct your profile information yourself directly in the app.

Right to erasure
In special cases, you have the right to have data about you erased before the time of our regular general erasure occurs.

Right to restriction of processing
In certain cases, you have the right to have the processing of your personal data restricted. If you have the right to have the processing restricted, we may in future only process the data - except for storage - with your consent, or for the establishment, exercise or defence of legal claims, or to protect a person or important public interests.

Right to object
In certain cases, you have the right to object to our otherwise lawful processing of your personal data. This only applies if our processing is based on Article 6(1)(f) (legitimate interest) of the General Data Protection Regulation.  As stated in this Privacy Policy, this relates to the data we process for the purposes of identification and prevention of misuse. We may then no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing also is necessary for the establishment, exercise or defence of legal claims. You can also object to the processing of your information for direct marketing purposes.

Withdrawal of consent
You have the right to withdraw your consent at any time if you have given it. You can do this by contacting the Rejsekort Customer Service at the contact details stated above in section 1. If you choose to withdraw your consent, this will not affect the legality of the processing carried out before you withdrew your consent.

If you withdraw your consent, this means that we generally restrict the future processing of your personal data by deleting or anonymising the personal data processed in accordance with the consent. As stated above in section 2.1, this concerns recordings of telephone conversations when contacting the Rejsekort Customer Service by telephone.

Right to transmit data (data portability)
In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have this personal data transferred to another data controller without hindrance.


Right to complain to the Danish Data Protection Agency
You can complain about our processing of your personal data to the Danish Data Protection Agency.

The Danish Data Protection Agency has the following contact details:

Danish Data Protection Agency
Carl Jacobsens Vej 35.
2500 Valby, Denmark
Phone: +45 33 19 32 32 00
Mail: dt@datatilsynet.dk
www.datatilsynet.dk

8. changes to this privacy policy

We regularly review this privacy policy to keep it updated and in line with the way Rejsekort as an app works as well as applicable principles and legislation. The privacy policy is subject to change without notice.

You can always see at the top of this Privacy Policy when the policy was last updated or changed. Significant changes to the Privacy Policy will be published on our website www.rejsekort.dk together with an updated version of the Privacy Policy.