The pilot service is provided in collaboration with Holo, Ruter's research and development partner and operator. Orders are managed through an app and fleet management system is provided by Moovit, the self-driving technology is provided by Mobileye, and the video communication software is provided by MobileThinking.
Why are personal data processed, and who is responsible?
Personal data are processed for the following purposes:
- Providing and developing the pilot service: Ruter, as the data controller, and Holo, as the data processor, process personal data to offer, plan, execute, and develop the pilot service as well as to handle potential incidents. In case of incidents, Holo is the data controller and coordinates with its insurance company.
- Passenger safety: Ruter processes personal data related to customer support and unwanted events through video communication inside the vehicle to ensure passenger safety.
- Traffic safety: Mobileye, our project partner, occasionally processes personal data through external video monitoring to ensure the vehicle operates safely. More information can be found on Mobileye's privacy page: https://www.mobileye.com/privacy-roadclips/.
- Use of personal data for research and creating anonymous statistics: The data will also serve as a basis for research on the service and for generating anonymous statistics.
What is the legal basis for Ruter processing personal data?
Providing and developing the pilot service
Processing customer information, travel information, booking information, favorite locations, and feedback is based on consent from the user.
Passenger safety
Lov om utprøving av selvkjørende kjøretøy (law on piloting of self-driving vehicles) §§ 12, cf GDPR Article 6, first paragraph, letter e.
Traffic safety
Lov om utprøving av selvkjørende kjøretøy (law on piloting of self-driving vehicles) §§ 11-12, cf. GDPR Article 6, first paragraph, letter e.
Use of personal data for research and creating anonymous statistics
Ruter relies on legitimate interest to create anonymous statistics and conduct research on use of the pilot service.
What personal data is processed, and how is it used?
The following personal data is processed:
- Customer information: When creating a user profile in the Selvkjørende app, customer information is stored to offer you the service and to provide customer support if you need that, also during your trip. Since this is a research and development project, we may also need to contact you regarding the service. The following customer information is stored:
- Name (first and last name)
- Email address
- Phone number
- Year of birth
- Travel information: When conducting a travel search, information about the planned trip is stored to help you find past searches and to plan and offer the service. The following travel information is stored:
- The location or address where you want to travel to and from.
- Your GPS location if you choose your current location as your desired departure or arrival location.
- The location you are offered to be picked up and dropped off.
- The date and time you want to travel, and estimated pickup and arrival times.
- Booking information: When you book a trip, we store the travel information described above, as well as information about your booking. These include:
- Number of passengers you book the trip for
- Payment information:
- Information about the price you payed for the trip.
- Accounting data such as VAT etc.
- Ruter does not have access to payment information about the payment card that is being used, this is managed by the payment processor.
- Updated departure and arrival times
- Favorite locations: You can choose to save your favorite locations so that you can quickly book trips to and from these locations. We only store this information if you actively have saved a favorite. In that case the position/address of your favorite locations are stored so that you can access these when planning your trip.
- Video communication: You can initiate a video call with one of Ruter's customer service agent if needed. For safety reasons, a customer agent may also in certain situations start a video call in case of an unwanted event.
- Customer service: If you contact customer service, we store the following information to provide you with the help you need:
- All inquiries and the dialogue related to your case.
- Contact information
- If you contact us regarding a specific trip, we can link the inquiry to information about your journey.
- If you contact us by phone, we will also record the phone conversation to ensure that your inquiry is represented as accurately as possible. You can read more about this here: Kundeservice og personvern (only in Norwegian).
- Feedback: For Ruter to continue developing the service, you may be asked to provide optional feedback on 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 data to generate statistics about the use of the service and as a basis for research on the service without linking this to contact information such as your name and email address.
What access does Ruter have to your data, and is it shared with others?
Access to your information is restricted. Access is granted only based on what is operationally necessary to achieve the purpose of the processing.
Customer support and technical support
Our partner Holo, as a data processor, will have access to personal data about you to assist with good support of you as a customer. Our partner Moovit, as a data processor, will have access to personal information about you to assist with technical support for the app and customer support systems.
Research
We will share data about travel searches and service usage with research institutions, where the results from the research will be anonymized.
Other partners
We will share anonymized data with our partners within public transportation/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 for the solution.
Video monitoring outside the vehicle
Mobileye and Holo have occasional access to personal data from video monitoring outside the vehicle when needed to analyze incidents to improve the vehicle's maneuvering for traffic safety reasons.
Cloud services
The service uses AWS cloud services for storing and accessing personal data related to the services you use. Although the service uses an American provider, only services approved under the CISPE code of conduct are used, ensuring that the provider is obligated not to transfer personal data outside the EEA. However, Moovit and Mobileye may access personal data from Israel, which the European Commission has determined has an adequate level of protection under GDPR Article 45.
The USA and the EU have also entered into an agreement, which according to EU Commission's ens adequacy decision ensures a sufficient level of privacy protection as stated in GDPR. You can read more about the agreement on the Norwegian Data Protection Authority's website (only in Norwegian).
Other third parties
Your personal data will not be disclosed to other third parties unless there is a legal obligation to do so towards public authorities.
As part of our ongoing efforts in information security, Ruter is continuously working on improving its services.
How are personal data stored and deleted?
Your personal data is processed as described below.
For the processing of personal data that you have consented to, you can withdraw this consent 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 delete your profile, there is no way for Ruter to retrieve information about you.
- If you only delete the app without deleting your profile first, the information will still be stored with us.
- Travel and booking information: When you have booked a trip, sales and travel information is stored for up to 400 days to handle the customer's right to file complaints with the Passenger Complaint Handling Body (Transportklagenemnda). See Forskrift om klagenemnd for oassasjertransport § 5-2 (only in Norwegian). After this, the information will be anonymized and no longer linked to 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 linked to you as a customer.
- Favorite locations: Information about a favorite location can be deleted in the app at any time.
- Video communication: Video and audio from video communication between the vehicle and our customer service agents will not be stored and is only available to the customer service agent during the conversation.
- Customer service: Until further notice, you must notify Ruter's customer service team yourself if you want to delete information you have shared when contacting us. We are working with a simplified process for this.
- Feedback: Voluntary feedback you provide about the service will be anonymized after 45 days.
However, Ruter cannot delete personal data if other legislation, such as accounting laws, requires Ruter to continue processing the data. In such cases, we will further restrict access and log any access to this data.
What are your rights?
You have the right to access, correct, request data portability, and to delete your personal data.
You also have the right to object to the processing of personal data collected through video communication inside the vehicle. In such a case, the data controller will stop processing your personal data unless they demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims. An example would be if there has been an unwanted incident onboard the vehicle.
You have the right to file a complaint with the Data Protection Authority if you believe your personal data is being processed incorrectly. However, we encourage you to contact us first through our Data Protection Officer.
Contact Ruter's Data Protection Officer if you have any questions, or learn more about privacy in Ruter's services.
How can I request access to or deletion of my personal data?
Certain personal data can be accessed, modified, or deleted directly through the Selvkjørende app:
- If you delete your profile, the information will be stored with us for 2 days before being permanently deleted.
- If you delete the app without first deleting your profile, the information will remain stored with us.
If you want access to all personal data related to you, you must send a written request, either by mail or via our contact form.
Request access via contact form
Can I still use Ruter's services without being logged in?
You cannot use the pilot service Selvkjørende without logging in, but you can travel anonymously using Ruter's other public transport services in the area, such as buses, metro, trams, and trains.
Last updated: 10.09.2024, 13:00