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Privacy statement regarding the personal data of travel card holders and single-ticket passegers

Oy Matkahuolto Ab

Business identity code 0111393-9

(Hereinafter “Matkahuolto” or “We”).

The Travel Card is a card offered by Matkahuolto that can be used to store Matkahuolto’s ticket products, such as season and multiple tickets. A single ticket is a ticket available at Matkahuolto outlets, agents, travel agencies or Matkahuolto’s online sites.

Matkahuolto is the controller of the personal data that our customers like yourself disclose to us in order to buy and use the ticket products and single tickets available for downloading to the Travel Card. As the controller, Matkahuolto is responsible for all personal data provided by you and the processing of this data. As data protection is about trust, the protection of your privacy and personal data is of great importance to Matkahuolto. This is why Matkahuolto only collects personal data to the extent necessary to be able to offer you first-rate service. A more detailed description of the ways in which your personal data is processed and the purposes of such processing is provided in this privacy statement. When we process your personal data for the purposes described below, you are the data subject referred to in the privacy statement and have, for example, the rights laid out in section 8.

If you want more information about how your personal data is processed in order to implement our electronic and non-electronic services, customer service and communications, please read Matkahuolto’s Customer Data Privacy Statement.

Contact details related to the processing of personal data

Oy Matkahuolto Ab

Customer Service Centre

P.O. Box 100

00101 Helsinki

Tel. 020 710 5000

tietosuoja@matkahuolto.fi

Personal data collected form Travel Card users

Personal data collected from Travel Card users is processed to enable the provision of Matkahuolto services to data subjects, including the development of its services.

Matkahuolto processes the following personal data about Travel Card users:

  • Identification and contact details of the data subject: full name, telephone number, e-mail address, postal address and other address details.

  • Basic Travel Card information: Travel Card number, Travel Card status information (such as card in use, blocked, lost or found). The data subject’s Travel Card number is also stored on his/her Travel Card.

  • Other information about the Travel Card: payment and billing information, date and place of top-up transactions, ticket product, validity of the right to travel and information on any refunds.

  • Information on the use of the Travel Card: date and time when the Travel Card is used (read), the means of transport on which the card is used, ID no. of the reader device, the bus operator and service, and information on the boarding stop or location.

  • Other information received from the data subject, such as complaints, messages and replies to Matkahuolto’s inquiries and surveys.

  • Any direct marketing ban or permission for sending (electronic) direct marketing filed by the data subject.

In addition, other personal data, as described in more detail below, is collected on the users of Subsidised School Trip Tickets for upper secondary students, personal Travel Cards subsidised by municipalities or cities, Employee Ticket products and ticket products subsidised by the Finnish Defence Forces or the Centre for Non-Military Service, in order to provide relevant services.

Matkahuolto also processes any changes to the personal data collected from the data subjects as well as any additional information provided.

Subsidised School Trip Ticket for upper secondary students

The Subsidised School Trip Ticket for upper secondary students is a ticket product offered by Matkahuolto and subsidised by the Social Insurance Institution of Finland (Kela) for those full-time students whose studies meet the criteria specified in the Subsidised School Trips Act (48/1997).

Matkahuolto processes the following personal data of upper secondary students who use the Subsidised School Trip Ticket:

  • Detailed identification data of the data subject: personal identity number and customer group.

  • Information concerning the data subject’s right to buy the ticket and its verification (purchase certificate and transaction data on receipt of the purchase certificate).

  • Travel Card purchase counter based on the Social Insurance Institution’s top-up restriction.

  • Other information concerning the Travel Card, such as information on the issue of the Travel Card to the data subject. Information on Subsidised School Trip Tickets and the period of validity of the right to travel is also stored on the data subject’s Travel Card.

Personal Travel Cards subsidised by municipalities or cities

Personal Travel Cards subsidised by municipalities or cities mean city or regional ticket products downloaded onto personal Travel Cards (season or multiple cards), ticket products intended for comprehensive school students and ticket products intended for war veterans. The issuance of these ticket products is based on the data subject’s residence within the limits of a given municipality or city or region. A further criterion for the issuance of the tickets for comprehensive school students and war veterans is their personal status (student or war veteran).

Matkahuolto processes the following personal data of holders of personal Travel Cards subsidised by municipalities or cities:

  • Detailed identification data of the data subject: customer group. In the case of comprehensive school students, Matkahuolto also processes personal identity numbers.

  • Information concerning the data subject’s right to buy the ticket and its verification (purchase certificate and transaction data on receipt of the purchase certificate).

  • Travel Card purchase counter based on the Social Insurance Institution’s top-up restriction.

  • Other information concerning the Travel Card, such as information on the issue of the Travel Card to the data subject. Information on the subsidised ticket product and the period of validity of the right to travel are also stored on the data subject’s Travel Card.

Ticket products subsidised by the Finnish Defence Forces or the Centre for Non-Military Service

Ticket products subsidised by the Finnish Defence Forces or the Centre for Non-Military Service mean ticket products downloaded to the Travel Cards of conscripts and those completing non-military service (season or multiple card), the issuance of which is based on the data subject’s personal status (conscript or person completing non-military service).

Matkahuolto processes the following personal data of holders of Travel Cards issued to conscripts and those completing non-military service:

  • Detailed identification data of the data subject: customer group. With regard to conscripts, the data processed by Matkahuolto also includes the name of the troop unit. With regard to those completing non-military service, the data includes the personal identity number.

  • Information concerning the data subject’s right to buy the ticket and its verification (purchase certificate and transaction data on receipt of the purchase certificate).

  • Travel Card purchase counter based on the Social Insurance Institution’s top-up restriction.

  • Other information concerning the Travel Card, such as information on the issue of the Travel Card to the data subject. Information on the ticket product subsidised by the Finnish Defence Forces or the Centre for Non-Military Service and the period of validity of the right to travel are also stored on the data subject’s Travel Card.

Employee Ticket products

An Employee Ticket means a subsidised ticket product (season or multiple card) offered by an employer based on the data subject’s employment with the company involved.

Matkahuolto processes the following personal data of holders of Employee Ticket products:

  • Detailed identification data of the data subject: personal identity number and customer group. Additionally, Matkahuolto stores information on the workplace of the person entitled to such a work-related benefit.

  • Information concerning the data subject’s right to buy the ticket and its verification (purchase certificate and transaction data on receipt of the purchase certificate).

  • Travel Card purchase counter based on the Social Insurance Institution’s top-up restriction.

  • Other information concerning the Travel Card, such as information on the issue of the Travel Card to the data subject. Information on the Employee Ticket product and the period of validity of the right to travel is also stored on the data subject’s Travel Card.

Data collected from online ticket holders

For customers who have purchased a single ticket through Matkahuolto’s digital channels, we process the personal data given by the data subject to Matkahuolto for the purpose of verifying their right to travel and allowing Matkahuolto to deliver the receipt by e-mail, such as the person’s basic information, travel details, e-mail address and payment data.

Basis for and purposes of the processing of personal data

Matkahuolto processes the personal data of Travel Card holders and single-ticket passenger mainly:

  • to implement and develop services and products and travel related services, including the verification of the right to travel, blocking lost cards and transferring unused travel validity to a new Travel Card, identifying the owners of found Travel Cards, verifying usage transactions and investigating errors, as well as

  • to manage, analyse and develop the customer relationship, for example to provide customer service and implement customer communications, such as bulletins and informative messages.

Additionally, Matkahuolto may process personal data for the purpose of conducting customer analyses, such as customer satisfaction surveys, and for direct marketing purposes to the extent permitted by law provided that the data subject has not forbidden the use of his/her personal data for direct marketing purposes.

The processing of data subjects’ identifying data is necessary to verify the data subject’s transactions, their right to buy a personal Travel Card as well as their personal communications and visits. The identification data required depends on the ticket product.

As far as single tickets are concerned, processing of identification data is necessary in order to verify the right to travel and deliver the receipt by e-mail.

The legal basis for processing personal data is either compliance with the agreement between Matkahuolto and the data subject, Matkahuolto’s legitimate interest based on the customer relationship, or the data subject’s consent given to Matkahuolto. In order for Matkahuolto to be able to implement the agreement it has entered into with you, it is necessary to process your personal data, for example to verify your right to travel or be able to invoice the subsidising party when you wish to purchase subsidised ticket products. Processing based on Matkahuolto’s legitimate interest refers, among other things, to situations in which Matkahuolto processes your data for administrative purposes or in order to prevent or investigate misuse, as well as to develop and target direct marketing. The purpose of processing based on consent is always clearly stated when consent is sought.

Furthermore, in some cases the processing of personal data is based on Matkahuolto’s statutory obligation (cf. School Trips Subsidy Act 48/1997 under which the data subject is required to disclose his or her personal identity number to the seller of the ticket eligible for such subsidy, or Accounting Act 1336/1997 under which companies are obligated to retain receipts).

The data subject’s obligation to disclose personal data as provided in this privacy statement is partly a statutory obligation and partly a precondition for the conclusion of an agreement between the data subject and Matkahuolto. For example, under section 12.2 of Subsidised School Trip Act 48/1997, the data subject is required to disclose his/her personal identity number to the seller when buying a ticket eligible for school trip subsidies. If the data subject refuses to disclose his or her personal data to Matkahuolto as explained in this privacy statement, Matkahuolto is unable to verify the data subject’s right to buy the ticket and cannot therefore issue the Travel Card to the data subject.

The above obligation to disclose personal data does not apply to consent for sending (electronic) direct marketing.

Regular sources of data

Matkahuolto collects information from the data subject him- or herself when issuing Travel Cards and at other times when the data subjects have any transactions with Matkahuolto either at its service outlets or its agents’ outlets or any online service.

Data on the use of the card is collected whenever the card is used. Matkahuolto uses a technical interface to collect data on the use of the Travel Card from bus operators on whose means of transport the card is used.

Additionally, Matkahuolto collects information on topping up transactions from parties at whose sites the Travel Card can be topped up.

Matkahuolto collects information on single tickets from the data subjects themselves.

The employer of the person entitled to the Employee Ticket notifies Matkahuolto of validity data.

Recipients and personal data

Matkahuolto transfers the personal data of data subjects to the following recipients and groups of recipients as needed:

  • Information system vendors and other service providers: Matkahuolto may transfer personal data to information system vendors and other service providers processors for the purpose of providing services or completing tasks they have been assigned to carry out, such as IT system maintenance or other data processing tasks.

  • Bus operators: Matkahuolto transfers personal data to a limited extent to bus operators for the purpose of providing travel services. For example, the card readers used by bus operators make it possible to elicit the following information from the cards: Travel Card number, ticket product and the period of validity of the right to travel.

In addition, Matkahuolto will disclose the personal data of the holders of its subsidised ticket products to the recipients specified below. The purpose of the disclosures is to enable the invoicing of subsidised ticket products and to verify Matkahuolto’s invoicing basis and the appropriateness of invoicing. In the case of Employee Tickets, Matkahuolto does not disclose personal data unless it has been specifically agreed with the employer of the person involved that Employee Tickets will be topped up by Matkahuolto’s agent.

  • Subsidised School Trip Ticket for upper secondary students Matkahuolto discloses information to the Social Insurance Institution of Finland (Kela) as needed for it to grant school trip subsidies and credit the amount to Matkahuolto on a monthly basis. Provisions on the disclosure of information are set out in section 1 of the Decree on School Trip Subsidies for General Upper Secondary and Vocational School Students (425/2004).

  • Personal Travel Cards subsidised by municipalities or cities: Matkahuolto discloses information to the municipality or city as needed for it to grant the subsidy and credit the amounts to Matkahuolto on a monthly basis.

  • Ticket products subsidised by the Finnish Defence Forces or the Centre for Non-Military Service: Matkahuolto discloses information to the Finnish Defence Forces or the Centre for Non-Military Service as needed for it to pay the cost of the trip under section 103 of the Conscription Act (1438/2007) or section 52 of the Non-Military Service Act (1446/2007) and credit the price of the tickets used to Matkahuolto on a monthly basis.

No personal data will be transferred to outside the European Union or the European Economic Area.

Retention period and erasure of the data

The retention period of the data is determined by the type of data involved and its intended purpose. Matkahuolto or the processors who carry out the processing of such data on behalf of Matkahuolto in connection with the use of Travel Cards retains the personal data of data subjects in accordance with applicable legislation for only as long as the retention of data is necessary to achieve the purpose of the processing of personal data.

In some cases, the retention period of personal data is also determined by the terms and conditions of the agreement made with the subsidising party or by legislation binding on Matkahuolto. For instance, Matkahuolto is obligated to retain information contained in accounting material for the period of time specified in accounting laws (up to 10 years).

As far as single tickets are concerned, the data subject’s name is retained and receipts stored in the system for the period of time required under the Accounting Act. The data subject’s e-mail address is always retained in the system for the duration of the preceding financial year.

When Matkahuolto no longer needs the personal data for the original purposes, the data is erased from Matkahuolto’s and processors’ IT systems and other files or irrevocably anonymised. When Matkahuolto no longer needs the personal data for the original purposes, the data is erased from Matkahuolto’s and processors’ IT systems and other files or irrevocably anonymised.

Rights of data subjects

The EU General Data Protection Regulation guarantees data subjects a number of rights that they can exercise to determine how their personal data is processed.

Right of access: The data subject has the right to receive a confirmation from Matkahuolto as to whether Matkahuolto processes his or her personal data and the right to check such data. Matkahuolto may request the data subject to formulate his or her request in more detail regarding the procedure for the delivery of the data, etc.

  • Right to correct personal data: The data subject has the right to correct any errors in the personal data processed by Matkahuolto or complete any incomplete data. When requesting a correction, the data subject needs to be aware that all information cannot be changed retroactively by such request. For example, the contents of the decisions concerning the data subject’s benefits cannot be amended. Specific appeal procedures exist for such decisions as explained in each individual decision.

  • Right to be forgotten: If there is no longer any legal basis for the processing of personal data or a statutory or contractual provision obligating Matkahuolto to retain personal data ceases to apply, the data subject has the right to demand that Matkahuolto erase his or her personal data and Matkahuolto is required to comply with the request.

  • Limitation of processing: In certain cases stipulated by law, the data subject may have the right to demand that Matkahuolto limit the processing of his or her personal data.

  • Right to transfer personal data: Subject to certain statutory provisions, the data subject may have the right to receive from Matkahuolto the personal data concerning him or her in Matkahuolto’s possession in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from Matkahuolto.

  • Direct marketing and the right to forbid the processing of personal data for direct marketing purposes: The data subject has the right to forbid the processing of his or her personal data for direct marketing purposes. If the data subject has given his or her consent to receiving direct marketing material from Matkahuolto, he or she may cancel such consent at any time.

The data subject may check and correct his or her personal data using the electronic services provided by Matkahuolto, such as the mobile application, or by contacting Matkahuolto’s Customer Service Centre mentioned in section 1 of this privacy statement. Any requests for the erasure, transfer or limitation of the use of the personal data or objection to direct marketing must be submitted to Matkahuolto’s Customer Service Centre.

Matkahuolto will take prompt action in response to the data subject’s request and will provide the data subject with information on the exercise of rights normally within one month of receipt of the request.

Additionally, the data subject has the right to lodge a complaint concerning the processing of personal data by Matkahuolto with the data protection authority. Any complaint must be filed with the competent authority, in Finland with the Data Protection Ombudsman in accordance with the instructions they provide. Address of the Data Protection Ombudsman’s website: http://www.tietosuoja.fi.

In conclusion

Matkahuolto reserves the right to update and revise this privacy statement. Matkahuolto will notify any changes in the processing of personal data in an appropriate manner.

Matkahuolto is not generally obliged to individually notify data subjects of any changes, for example when the provision of such information proves impossible or would require unreasonable effort (for instance, when there are no up-to-date contact details on the data subject). Therefore, the data subjects are occasionally encouraged to check this statement for any changes.

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