To access electric scooters, electric bikes, and city bikes, also known as micro-mobility, in the Ruter app, you must create a Ruter profile. Anonymous users cannot access micro-mobility, but can access basic functions such as travel search and ticket purchase in the Ruter app. It is not sufficient to register payment information. The reason is that it is an external payment intermediary, not Ruter, that stores your bank card and/or account details. If you have a confidential address and/or confidential phone number, we recommend that you use Ruter's anonymous service options for safety reasons, see more about the review of Ruter's cloud services below.

• Privacy Policy for the use of the Ruter app
• How we handle your data when you register
• The Personal Data Act on lovdata.no

Terms for bicycle, electric bicycle, and electric scooter in the Ruter app:

• Terms of Service for Voi
• Terms of Service for Ryde
• Terms and Conditions for Bolt
• Terms of Service for Oslo City Bike

Purpose

Ruter processes personal data in order to provide the desired micromobility services and to follow up on the agreement and offer you good customer service. To offer better services, we also conduct a limited analysis of driving patterns. We have a number of activities related to these purposes, see the description below.

This includes, among other things, checking if you already have a profile when you log in to use e-scooters, e-bikes, or bikes that are integrated into the Ruter app. The latter includes processing information necessary to unlock, use, and end a ride, enable you to pay for the ride, collect outstanding claims, claim compensation for vandalism/loss of the vehicle, provide you with assistance and clarifications if you have questions about the rides you take with the service provider in the Ruter app as customer relations and the like, or provide you with help if you have overpaid (refund). You can choose to give feedback on the user interface, functionality, and the services as a whole in the app. The feedback is sent from your mobile to customer service with profile information and rental reference.

Ruter will run pilot projects on these types of mobility services to develop new socially beneficial transport services. This can be linked to other ticket products such as Reis. You will be able to choose if you want to participate in these and Ruter will then be able to contact you to get feedback on how the pilot is experienced by you.

Personal data that we process

We process the following information about you in the following situations:

Generally

When you register or log in to the app, we need to check if your user profile already exists. We use your phone number for this. To give you access to micromobility in the Ruter app, we must use your phone number to look up in the profile database to find your user ID. In customer service, we use profile information (first name/last name, phone number, email) to link the rental agreement to you and provide you with the necessary follow-up and in case of breach of contract. As a rule, we do not share profile information with the service provider, see exceptions below.

Information related to the sale of a trip or periodic access to a vehicle, such as the time of purchase, from area/rack to area/rack (not exact position), amount, and type of ticket.

Specific to Bolt's service

When you rent an electric bike or electric scooter from Bolt in the Ruter app, we must provide your phone number to the supplier. A phone number is mandatory to create and complete a rental in their systems.

GPS position from your mobile is collected at the end of the ride and sent to Bolt for processing. The position from your phone and the scooter's position are used together to enhance accuracy and assess whether the vehicle is parked in a permissible area.

Your position when using city bikes

• Distance to the city bike station is used to provide you with information on how far away you are from a specific station.
• Ruter processes your GPS location to respond to requests you make from the app for travel searches. For city bikes, this will mean temporary processing of GPS location to show the way you need to go to get to the station. Your exact GPS coordinates are only processed locally on your phone. When drawing a walking route, an isolated position is sent to Ruter, without any connection to a registered user. The sender of the position (you) is listed as 'Ruter', and it is only a matter of a single search without connection to other positions.
• A check is also made on the distance to the city bike rack to determine whether you are more than 100 meters away. 100 meters is the maximum distance to the rack for you to be able to start renting. These calculations are only done on your mobile device and are not stored in Ruter's backend systems.
• During the trip, the GPS position from your mobile device is used so you can see where you are on the map. This way, you can check if there is a station nearby where you can park. This view is temporary and only for you on your smartphone and is not processed or stored in Ruter's backend systems.
• To analyze the travel patterns of customers, Ruter stores the locations from and to where the city bike trips are made. This is done without any connection to you. The stations where the city bikes are placed are located in densely populated areas in Oslo, and analyses of trips from and to the stations will not be able to identify you.

Your position on the use of electric scooters and electric bicycles

• The distance to the vehicle is used to provide you with information on how far away you are from a specific electric scooter or electric bike.
• Ruter processes personal data such as GPS location to respond to requests you make from the app for travel searches. For electric scooters or electric bikes, this will mean temporary processing of GPS location to show the path you need to take to reach the vehicle. Your exact GPS coordinates are processed only on your phone. When drawing a walking route, an isolated position is sent, without any connection to the user, without knowing what type of position it is. The sender of the position (you) is listed as 'Ruter' and it is only a matter of a single search without connection to other positions.
• A check is also made on the distance to an electric scooter or electric bike to determine whether you are more than 400 meters away. 400 meters is the maximum distance to the vehicle if you are to start the rental. These calculations are only made on your mobile device and are not stored in Ruter's backend systems.
• During the trip, the GPS position from your mobile device is used so you can see where you are on the map. This way, you can check if you are in a "slow zone", "no parking zone", or similar. This display is temporary and only for you on your smartphone and is not processed or stored in Ruter's backend systems.
• When you press pause (not all providers have this functionality) during an electric scooter or e-bike ride in the Ruter app, we will store both the vehicle's position and the position of the mobile phone, because the latter is more accurate than the bike's position, so that you can easily find your way back to the bike. Your phone will then fetch the vehicle's position and store it temporarily. The position of the scooter or e-bike is only stored once, so if it is moved, the position may differ from what you see on the map. When an electric scooter or e-bike needs to be parked within a small marked zone, it requires a lot from the technology to do this accurately. The phone's GPS is more accurate than the vehicle's GPS. Ruter performs a temporary processing of data related to your position. The data is available to Ruter for one hour after the rental ends before it is deleted. The data is not available in logs thereafter. The data is available during this time period to prevent data loss during system downtime. The service provider will not be able to link this data to the customer.

Analysis to further develop the service

To analyze customers' travel patterns, Ruter does not store your exact location permanently, but conducts a temporary processing of data based on Ruter's legitimate interest in providing a robust and socially beneficial transport service, for two different purposes:

• Analyze which routes customers take using electric bicycles or electric scooters. Ruter establishes a geographical grid based on basic statistical units. A basic statistical unit is a smaller geographical entity used to produce anonymous statistics. Oslo is divided into 589 basic statistical units. These units are used to divide the service provider's business areas into such geographical entities. Ruter gets an overview of where trips start and end between basic statistical units and can produce statistics on this. In Asker and Bærum, one cannot park freely, but must use designated parking zones for parking. Each individual parking zone covers a larger geographical area so that it is not possible to identify where you use the electric scooter or electric bicycle. In areas with parking zones, these will be included in the grid solution. Ruter gets an overview of where trips start and end and can produce statistics on this, without it being traceable to you.
• Analyze the exact position for the start and stop of all electric scooter and electric bike trips. By storing the start and stop positions at Ruter, the link between the exact position and the user/rental is broken. This allows Ruter to see with great accuracy where the trips are started from or finished, but cannot see who is renting or which route the trips take.

Pilot projects

In connection with the Travel and Discount program for rides with electric scooters or electric bikes, information about the timing and duration of your trips will form the basis for the discount. The information will otherwise be processed as described in the privacy statement.

Other processing of personal data

• Profile information is only disclosed upon a specific request from the service provider where a breach of terms has occurred or in situations where Ruter deems it necessary (such as in the case of accidents, complaints, and compensation matters) to transfer the case to the service provider. Ruter and the service provider will contact you on the mobile phone number or email address saved on your user account.
• When you take a parking photo of the electric scooter or electric bike at the end of the rental, both you and Ruter can demonstrate that the vehicle has been parked as specified in the agreement. You are responsible for ensuring that the scooter or bike is centered in the middle of the photo using the frame in the photo service and that the photo is of the vehicle and not of yourself or other people. In cases where the photo is used as evidence in a dispute, Ruter reserves the right to share the photos with the supplier and/or municipality and will only store the data for as long as necessary to fulfill the purpose. After that, they will be deleted. In cases where the photo is used in a specific case and linked to your profile, individuals who appear in the photo will be made unrecognizable by blurring.
• If you want to contact customer service at the service provider (during an active rental) due to an issue with an electric scooter or electric bike, Ruter will assist you in filling out the email with your name, email, and references so that the service provider can locate your trip in their systems and contact you. You will be able to see which personal information is filled in before you send the email.
• If you want to contact customer service at Oslo City Bike (during an active rental) due to an error at the station or with the city bike, Ruter will assist you by offering a chat solution directly with the supplier. For the supplier to be able to locate your trip in their systems, an identifier associated with the specific rental and a userID is automatically shared.

Legal basis

We process your information where it is necessary to fulfill the agreement on micromobility services with you. For analysis and further development of digital products, Ruter uses legitimate interest as the basis for processing.

In addition, we process personal data that is necessary according to the accounting regulations, and we will disclose information to the police/prosecutorial authorities if we are required to do so in accordance with Norwegian law.

Access, use and your rights

You have the right to access and correct your personal data, as well as the right to data portability and the deletion of information stored about you (unless there is a specific legal basis for storage, such as the accounting regulations).

Learn more about your rights under Privacy in Ruter's services

Subcontractors

Ruter receives assistance from data processors to deliver services. Currently, this includes Bolt, Voi, Oslo City Bike & Ryde, which ensure that Ruter can offer micromobility to its customers. In addition, Ruter uses data processors that assist in the analysis, design, and development of digital products, to collect and process data about you and your travel habits. All data processors will handle personal information to fulfill the purpose stated above. Personal information or personal data will not be used for purposes other than those mentioned above.

Learn more about your rights under Privacy in Ruter's services

We do not disclose your personal information to other third parties unless we are required to do so by public authorities.

Ruter uses AWS cloud services for storage and accessing personal information related to the aforementioned services you use. Although Ruter employs an American provider, wherever possible, Ruter has chosen to use services that are approved according to the EU's Code of Conduct CISPE. By using CISPE approved solutions in the EEA, the provider commits to not transferring personal data out of the EEA.

For services that are not CISPE-certified and where processing in the USA cannot be excluded in certain cases, Ruter has implemented a number of contractual, organizational, and technical measures, such as isolation of information and encryption, to prevent the provider from accessing the information. For such services, Ruter requires the recipient to commit to complying with data protection regulations, and we use the European Commission's revised standard contractual clauses, which are available here:

See the European Commission's revised standard on europa.eu

In addition, the EU has also approved the United States as a country that provides adequate data protection for many businesses in the US, effective for Norway as of July 17, 2023. AWS is on a list of companies considered to have adequate data protection, and Ruter will continue to monitor the status of such approvals for its subcontractors going forward and take necessary measures.

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

Right to appeal

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.

Send an email to personvernombud@ruter.no

Request access to or deletion of information

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

Request access through the contact form

Contact us

Storage and deletion

Your information will be stored and deleted according to the following:

• Sales information (related to your use of the service) is stored for up to 410 days after the ticket has expired, or alternatively 410 days after you as a complainant have submitted a written complaint to Ruter about an issue with your journey. This is to be able to handle your right to complain to the Transport Complaints Board.
• Customer information about you is stored as long as you are a customer with us.
• An agreement ID specific to the service with Oslo City Bike is stored as soon as the terms of service for using the bikes are signed, and is retained as long as you are a customer with us. This ID is not shared with third parties.
• Routes generate a userID as a replacement for your contractID which is shared with Oslo City Bike. This allows Oslo City Bike to assist you if you need help when renting a city bike. This generated ID is replaced every 12 months.
• For accounting purposes, sales information is stored for up to 5 years.
• To ensure good quality when parking your electric bike and electric scooter, Ruter will have a temporary processing of data related to your smartphone's location. The data is available to Ruter for 1 hour after the rental ends before it is deleted.
• GPS data (converted to grid) associated with your electric bike and electric scooter rides will be stored for one hour. After this, they will be anonymized and used in general analyses.
  See the regulation on the transport appeal board § 5-2

Access on the phone

For the Ruter app to function optimally, it needs access to certain features on your phone. You can choose to turn off these permissions, but some features may then be unavailable or not work optimally. You can turn off the permissions in your phone's settings.

To use micromobility services in the Ruter app, location services for the smartphone must be turned on. This is necessary to be able to find, start, and end the rental.