The pilot service is offered in collaboration with Holo, which is Ruter's research and development partner and operator for the vehicles. Bookings are managed through an app and fleet management system from Moovit, the autonomous driving technology is from Mobileye, and the video communication solution is provided by MobileThinking.

Why are personal data processed and who is responsible?

Personal data is processed for the following reasons (purposes):

1. Offer and develop the pilot service: Ruter as the data controller and Holo as the data processor, process personal data to offer, plan, implement, and develop the pilot service, as well as to handle any damage cases. In the event of damage cases, Holo is the data controller and follows up the case with its insurance company.
2. Passenger safety: Ruter will process personal data in connection with customer support and unwanted incidents in the form of video communication inside the vehicle for the safety of passengers.
3. Traffic Safety: Our partner in the project, Mobileye, also occasionally processes personal data in connection with necessary video monitoring on the outside of the vehicle to ensure that the vehicle can be driven in a traffic-safe manner. You can read more about this on Mobileye's website.
4. Use of personal data for research purposes and to create anonymous statistics: The information will also serve as a basis for research on the service, and to create anonymous statistics.

What is the legal basis for Ruter to process personal data?

Offer and develop the pilot service

Processing of customer information, travel details, booking information, favorite places, and feedback is based on consent from you as a user of the service.

Safety for passengers

Act on the trial of autonomous vehicles §§ 12, cf. GDPR art 6, paragraph 1 letter e.

Traffic safety

Act on the trial of autonomous vehicles §§ 11-12, cf. GDPR art 6, paragraph 1, letter e.

Use of personal data to create anonymous statistics and research purposes

Ruter relies on legitimate interest as the basis for processing to create anonymous statistics and to research the use of the pilot service.

What personal data is processed and what is it used for?

We process the following personal data about you:

• Customer Information: When you create a user profile in the Autonomous-app, customer information about you is stored to provide you with the service and to be able to offer customer support during your journey, should you need it. As this is a Research and Development project, we also need to be able to contact you regarding the service. The following information is stored:
• Name (first name and last name)
• Email address
• Phone number
• Year of birth
• Travel Information: When you perform a travel search, information about the planned trip is stored. This is to make it easier for you to find your previous travel searches, as well as to plan and provide the service. The following travel information is stored for the trip you are planning:
• The position or address you wish to travel from and to.
• Your GPS position if you choose to use your current location as the desired departure or arrival place.
• The location where you are offered to be picked up and driven to.
• The date and time you wish to travel, as well as the planned pickup and arrival time
• Booking details: When you book a trip, we store the travel details mentioned above, as well as information about your booking. The information is stored to carry out the trip you book. The following booking details are stored:
  • Number of passengers you are booking travel for
  • Payment information:
• Information about the price you paid for the trip
• Accounting data such as VAT etc.
• Ruter does not have access to payment information about the card being used; this is handled by the payment intermediary.
  • Updated information on estimated departure and arrival times
• Favorite places: To quickly book a trip from or to your favorite places, you can choose to save them. We only store your favorite places if you have actively saved a favorite. In that case, the position/address of your favorite places is saved so that you can use them when planning your journey.
• Video communication: If you as a customer wish to speak with a customer service representative, you will be able to initiate a video call (including video and audio) between the vehicle and Ruter's customer service representatives. For security reasons, the customer service representative may also, in certain cases, initiate a video call with the vehicle if an unwanted incident occurs.
• Customer Service: If you contact customer service, we store and process the following to provide you with the assistance you need:
  • All inquiries, and the dialogue associated with your case.
  • Contact Information
  • If you are calling about a specific trip, we can link your inquiry to information about your travel.
  • If you contact us by phone, we will also record the phone conversation to ensure that your inquiry is reproduced as accurately as possible. Read more about Customer Service and privacy at Ruter.
• Feedback: In order for Ruter to further develop the service, you may be asked to provide optional feedback about the service. In such cases, we will process the following information about you.
  • Contact Information
  • Your feedback
  • This information can be linked to details about your trip, such as how often you use the service or where you have traveled with the service.
• Statistics and research: We also use information about your purchases, travel searches, and similar activities to compile statistics on the use of the service, and as a basis for researching the service, without linking this to contact information such as name and email address.

What access does Ruter have to your information, and is it shared with others?

Access to information about you is restricted. Permissions are granted only based on what is necessary from an official need to achieve the purpose of the processing.

Customer support and technical support

Our partner Holo, as a data processor, will have access to personal information about you in order to assist with good customer service. Our partner Moovit, as a data processor, will have access to personal information about you in order to assist with technical support for the app and customer support systems.

Research

We will share information about travel searches and the use of the service with research institutions, where the results of the research will be anonymized.

Other collaborators

We will share anonymized data with our partners in public transport/mobility services.

Video communication inside the vehicle

Ruter and Holo have access to personal data from video communication inside the vehicle. Additionally, the provider of the communication solution will have limited access in connection with necessary technical support of the solution.

Video monitoring on the outside of the vehicle

Mobileye and Holo individually have access to personal data from video monitoring on the outside of the vehicle when needed to analyze events to improve the vehicle's maneuvering for traffic safety reasons.

Cloud services

The service uses AWS cloud services for storage and accessing personal data related to the services you use. Although the service uses an American provider, only services that are approved according to the CISPE Code of Conduct are used, and in such a way that the provider commits to not transferring personal data out of the EEA. Moovit and Mobileye could access personal data from Israel, which the European Commission has determined is a country with an adequate level of protection under GDPR Article 45.

The USA and the EU have also entered into an agreement, which according to the EU Commission's adequacy decision, ensures an adequate level of data protection as specified in the GDPR. You can read more about the agreement on Datatilsynets nettsider.

As part of our ongoing work with information security, Ruter is always working on improving services.

Other third parties

Your personal information will not be disclosed to other third parties unless legally required to do so by public authorities.

How are personal data stored and deleted?

Your personal information will be processed as described below.

You can withdraw your consent to the processing of personal data that you have agreed to at any time by deleting your profile.

• Customer Information: Your customer information is stored as long as you choose to have a profile. Once you have deleted your profile, there is no way for Ruter to retrieve information about you.
  • If you only delete the app without deleting the profile first, your information will still be stored with us.
• Travel and booking information: Once you have booked a trip, sales and travel information are stored for up to 400 days to manage the customer's right to complain to the Transport Complaints Board. See the regulations on the transport complaints board § 5-2. After this, the information will be anonymized and no longer associated with you as a customer.
  • Information related to a travel search for a trip that is not booked will be anonymized after 90 days. After this, the travel search will not be associated with you as a customer.
• Favorite places: Information about a favorite place can be deleted at any time in the app.
• Video Communication: Video and audio from the video communication between the vehicle and our customer service representatives will not be stored, and is only available to the customer service representative during the call.
• Customer Service: For the time being, you must notify Ruter's customer service if you want to delete information you have provided to us in any inquiries to customer service. We are working on a simpler solution for this.
• Feedback: Any voluntary feedback you provide about the service is anonymized after 45 days.

However, Ruter cannot delete personal data if other legislation, such as accounting laws, requires Ruter to continue processing the information. In such cases, we will further restrict access and log any access to such information.

What are your rights?

You have the right to access, rectify, data portability, and erasure of your personal data.

You have the right to object to the processing of personal data that is collected in connection with internal vehicle video communication. In such cases, the data controller will no longer process the personal data unless it can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or for the establishment, exercise or defense of legal claims. An example is if there has been an undesirable incident onboard the vehicle.

You have the right to complain about what you believe is incorrect processing of personal data to the Data Protection Authority, but please feel free to contact us first through our data protection officer.

Contact Ruter's Data Protection Officer if you have any questions, or read more about privacy in Ruter's services.

How can I request access to or deletion of information?

Some of your personal information can be accessed, modified, or deleted in the Self-driving app:

• If you delete your profile, the information will be stored with us for 2 days and then deleted.
• If you delete the app without deleting your profile first, your information will still be stored with us.

If you want access to all the personal information about you, you must send this in writing, either by mail or through a contact form.

Request access through the contact form

Contact us

Can I still use Ruter's services without being logged in?

You cannot use the pilot service Autonomous without logging in, but you can travel anonymously with Ruter's other public transport services in the area such as bus, subway, tram, and train.