Privacy policy for the use of micromobility

This data protection declaration applies to the use of Ruter's supplementary services of your choice. Please note that separate terms and conditions also apply to the use of the individual service.

To access e-scooters, e-bikes and city bikes (also known as micromobility vehicles) in the Ruter app, you must create a Ruter profile. Anonymous users cannot access micromobility vehicles, but they are granted access to basic functions such as travel searches and ticket purchases in the Ruter app. It is not sufficient to register your payment information.

The reason for this, is that the external payment services and not Ruter stores your bank card and/or account details. If you have a secret address and/or secret phone number, we recommend for security reasons that you only use Ruter's anonymous service options; read more about this topic below, under the heading Ruter's Cloud Services.

Terms and conditions for bicycles, e-bikes and e-scooters in the Ruter app:

Purpose

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

This includes e.g. checking whether you already have a profile when you log in to use e-scooters, e-bikes or bicycles that are integrated in the Ruter app. The latter includes processing information necessary to unlock, use and end a trip, giving you the opportunity to pay for the trip, collecting outstanding claims, to claim compensation in case of vandalism/loss of vehicle, to provide you with help and clarifications if you have questions about the trips you make with the service provider in the Ruter app such as the customer relationship and the like, or providing you with assistance if you have paid too much (refund). You may choose to provide feedback on the user interface, functionality and services entirely within the app. The feedback is sent from your cell phone to our customer service database with profile information and a rental reference.

Ruter runs pilot projects on these kinds of mobility services to develop new transport services that benefit society. This can be linked to other ticket products such as Reis. You will be able to choose whether you want to participate in these, and Ruter will then be able to contact you to get feedback on your experience of the pilot project.

Personal data that we process

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

Generalities

  • 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 need to use a phone number to query the profile database to find a user ID. Customer service uses profile info (surname, first name, phone number, e-mail) to link the rental agreement to you and provide you with necessary follow-up and for any violations of contract. Basically, we do not share profile info with the service provider, except for the exceptions described below.
  • Information relating to the sale of a trip or periodic access to vehicles, such as time of purchase, from area/rack to area/rack (not exact location), payment amount and ticket type.

Your location when using city bikes

  • Distance to city bike station is used to give you information about how far away you are from a specific station.
  • Ruter processes your GPS position to be able to respond to the requests you make via our app about travel searches. For city bikes, this will mean short-term processing of GPS position to show the way you have to walk to get to the station. Your exact GPS coordinates are only processed locally in your phone. When drawing up a walking route, an isolated position is sent to Ruter, without being linked to the registered user. The sender of the location (you) is listed as "Ruter" and it is only a single search without linking to other positions.
  • A distance check is also made to the city bike rack to determine if you are more than 100 meters away. 100 meters is the maximum distance to the rack for you to start renting. These calculations are only made on your cellular device and are not stored in Ruter's back-end systems.
  • The GPS location is used during the trip from your cellular device so you can see where you are on the map. This allows you to see if there is a station where you can park nearby. This display is temporary and only for you on your smartphone and is not processed or stored in Ruter's back-end systems.
  • In order to analyse our customers' travel patterns, Ruter stores where the journeys by city bike go from and to. This happens without any connection to you. The stations where the city bikes are stationed are located in densely populated areas of Oslo, so trip analyses from and to the stations will not be able to identify you.

Your position when using e-scooters and e-bikes

  • Distance to the vehicle is used to give you information about how far away you are from a specific e-scooter or e-bike.
  • Ruter processes personal data such as GPS position to be able to respond to the requests you make via our app about travel searches. For electric scooters or electric bicycles, this will mean short-term processing of GPS position to show the way you have to walk to get to the vehicle. Your exact GPS coordinates are only processed in your phone. When drawing up a walking route, an isolated position is sent, without linking to the user, without knowing what type of position it is. The sender of the location (you) is listed as "Ruter" and it is only a single search without linking to other positions.
  • A distance check is also made to the e-scooter or e-bike to determine if you are more than 400 meters away. 400 meters is the maximum distance to the vehicle for you to start renting. These calculations are only made on your cellular device and are not stored in Ruter's back-end systems.
  • The GPS location is used during the trip from your cellular device so you can see where you are on the map. This way you can see 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 back-end systems.
  • When you press pause (not all providers have this functionality) during an e-scooter or e-bike ride in the Ruter app, we will store both the position of the vehicle, but also the position of the cell phone, because this is more accurate than the position of the bike, so you can easily find your way back to the bike. Then your phone will retrieve 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 e-scooter or e-bike is to be parked within a small marked zone, it requires a lot of technology for this to be done accurately. Your phone's GPS is more accurate than the vehicle's GPS. Ruter temporarily processes data related to your location. The data is available to Ruter for one hour after the end of the rental before being deleted. The data is not available later in any logs. The data is available during this time period to avoid data loss due to system downtime. The service provider will not be able to link this data to the customer.

Analyses to further develop our service

In order to analyse our customers' travel patterns, Ruter does not permanently store your precise location, but conducts (based on Ruter's legitimate interest in providing a robust and societal transport service) a temporary processing of data for two different purposes:

  • Analyse the routes on which customers ride e-bikes or e-scooters. Ruter creates a geographic grid based on basic statistical units. The basic statistical unit is a small geographical unit used to produce anonymous statistics. Oslo is divided into 589 basic statistical units. These statistical units are used to divide the service provider's business areas into such geographic units. Ruter then has an overview of where trips go to and from between these units, and can create statistics on this. You are not allowed to park wherever you like in Asker and Bærum, but must use specific parking zones. Each parking zone covers a larger geographical area, so it is not possible to identify where you are using your e-scooter or e-bike. In areas with parking zones, these will be included in the grid solution. Ruter gets an overview of where trips go to and from, and can then create statistics on this, without it being linked to you.
  • Analysing the exact position of starting and stopping all e-scooter and e-bike rides. When Ruter stores data on start and stop positions, the link between the exact position and the user/rental agreement is broken. In this way, Ruter can see with great accuracy where the trips start from or end, but cannot see who is renting or what route the trips are taking.

Pilot projects

For the purpose of creating travel and discounts on trips by e-scooter or e-bike, information about the time and length of your trips will form the basis for the discount. The information will otherwise be treated as described in the data protection declaration.

Other processing of personal data

  • Profile information is only disclosed at the specific request of the service provider where breaches of the terms and conditions have occurred or in situations where Ruter considers it necessary (such as in the case of accidents, complaints and compensation cases) to transfer the case to the service provider. Ruter and the service provider will contact you by the cell phone number or e-mail stored in your user account.
  • When you take a parking photo of the e-scooter or e-bike at the end of the rental, both you and Ruter will be able to show that the parking of the vehicle has been done as stated in the agreement. You are responsible for ensuring that the scooter or e-bike is centred in the middle of the image using the visual frame in the image service and that the image is of the vehicle and not of yourself or other people. In cases where the image is used for evidence in the event of a disagreement, Ruter reserves the right to share the images with the supplier and/or municipality and will only store the data for as long as is necessary to fulfil the purpose. Then they are deleted. In cases where the image is used in a specific case and linked to your profile, people who have been included in the picture will be made unrecognisable by blurring.
  • If you want to contact customer service at the service provider (during active rental) due to a malfunctioning e-scooter or e-bike, Ruter will help you fill in the e-mail with your name, e-mail address and references so the service provider can find your trip in their systems and contact you. You will be able to see for yourself what personal information is filled in before you send the e-mail.
  • If you want to contact customer service at Oslo City Bike (during active rental) due to a fault at the station or malfunction of a city bike, Ruter will help you enter a chat solution directly with the supplier. In order for the supplier to be able to find your trip in their systems, an identifier associated with the specific rental and a user ID are automatically shared.

Legal basis

We process your data where necessary to fulfil the micromobility services agreement with you. For analysis and further development of digital products, Ruter uses legitimate interest as a basis for processing.

We also process personal data that is necessary for bookkeeping pursuant to the bookkeeping regulations and we will disclose information to the police/prosecuting authorities if we are required to do so in accordance with Norwegian law.

Access, use and your rights

You have the right to access your personal data and have any errors corrected, as well as the right to data portability and deletion of the data stored about you (unless there is a special legal basis for storage, such as the bookkeeping regulations).

Your rights regarding personal data protection in Ruter's services

Subcontractors

Ruter receives assistance from data processors to deliver our services. Currently, this applies to TIER, Voi, Oslo City Bike & Ryde, which ensure that Ruter can offer micromobility to customers. Ruter also uses data processors who assist in the analysis, design and development of digital products, to collect and process data about you and how you travel. All data processors will process personal data to fulfil the purpose as stated above. Personal data or personal information will not be used for purposes other than those stated above.

Your rights regarding personal data protection in Ruter's services 

We do not disclose information about you to third parties as long as we are not required to do so by public authorities.

Ruter uses AWS cloud services for storage and access of personal data related to the services described above which you use. Although Ruter uses an American supplier, Ruter has, where possible, chosen to use services that are approved according to the EU's CISPE code of conduct. By using CISPE approved solutions in the EEA, the supplier agrees not to transfer personal data outside the EEA.

For services that are not CISPE-approved and where processing in the United States cannot be excluded in some cases, Ruter has taken a number of contractual, organizational and technical measures (such as information isolation and encryption) to prevent the provider from having access to the information. For such services, Ruter requires the recipient to commit to complying with data protection regulations and we use the EU Commission's revised Standard Contractual Clauses.

See the EU Commission's revised Standard Contractual Clauses at eur-lex.europa.eu

In addition, on 17 July 2023, the European Union (also with effect for Norway) approved the United States as a country that has adequate privacy protections for many businesses in the United States. AWS is on a list of companies that are considered to have adequate data protection and Ruter will follow up the status of such approvals for its subcontractors in the future and take necessary measures.

As part of our continuous work with information and data security, Ruter is always working on improvements to its services.

Right of appeal

You have the right to submit a complaint to the Data Protection Authority if you think we are processing your personal data incorrectly, but feel free to contact us first via our data protection officer.

Send an e-mail to our data protection officer

Request access or deletion of information

If you want to access or delete the data stored about you, we ask you to request this in writing, either by conventional mail or via our contact form.

Request access via contact form

Contact us

Storage and deletion

Your data will be stored and deleted as follows:

  • Sales information and travel information are stored for a limited period (410 days) after the ticket has expired, or alternatively 410 days after a complainant was submitted in writing to Ruter about the conditions of a journey. This is to be able to handle your right of appeal with the Transport Appeals Board
  • Customer information about you is stored as long as you are a customer with us.
  • An Agreement ID that is specific to the service for Oslo City Bike is stored as soon as the Oslo City Bike Terms and Conditions are signed, and is retained as long as you are a customer with us. This ID is not shared with third parties.
  • Ruter generates a user ID as a replacement for your Agreement ID that is shared with Oslo City Bike. This is how Oslo City Bike can assist if you need help when renting a city bike. This generated ID is replaced every 12 months.
  • For accounting purposes, sales data is stored for up to 5 years.
  • In order to ensure good quality when you park your e-bike and e-scooter, Ruter will temporarily process data related to your smartphone's location. The data is available to Ruter for 1 hour after the end of the rental before being deleted.
  • GPS data (converted to the grid) associated with your trips with e-bikes and e-scooters will be stored for one hour. After this, it is anonymised and used for general analyses.

See section 5-2 of the Transport Appeals Board Regulation (in Norwegian)

Access via cell phone

For the Ruter app to work properly, the app must have access to certain features on your phone. You can choose to turn off these accesses and still use the app, but some functions will then either not be available or will not work optimally. You can turn off the accesses in your phone settings.

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

Access for iPhone

Place

Used to find your location, so you can find nearby vehicles or stations, see where you are on the map and where you drive, have search results sorted by where you are and find routes to or from where you are.

Notifications

Used to send notifications of detours, deviations, notify you before a ticket expires and payment cards. If notifications are rejected, you can still buy a ticket and see deviations in the app.

Camera

Used to enter card details when buying a ticket if you do not want to enter the card details manually, to take a photo when parking, and to read QR codes to start e-scooter rides.

Mobile data

Used to communicate with Ruter and the Service Provider when renting and paying for an e-scooter, e-bike or city bike. If mobile data is turned off, you must have access to a wireless network (wifi) to rent and pay.

E-mail

When you use the help function in the Ruter app to contact your service provider, the app helps you autofill information that customer service needs to identify your trip. This applies to simple information such as name, e-mail address and rental references. The information is not sent to Ruter.

Access for Android

Access accurate locations (GPS and network based)

Used to find your location, so you can find nearby vehicles or stations, see where you are on the map and where you drive, have search results sorted by where you are and find routes to or from where you are.

Receive data from internet

Used to communicate with Ruter and the Service Provider when renting and paying for micromobility. If mobile data is turned off, you must have access to a wireless network (wifi) to rent and pay.

Camera

Used to enter card details when buying a ticket if you do not want to enter the card details manually, to take a photo when parking, and to read QR codes to start e-scooter rides.

E-mail

When you use the help function in the Ruter app to contact your service provider, the app helps you autofill information that customer service needs to identify your trip. This applies to simple information such as name, e-mail address and rental references. The information is not sent to Ruter.

If you want to turn off access, do this under Ruter from the settings on your phone.

Statistics

We want to make the Ruter app better. We use the Amplitude analysis tool to collect anonymous information about the use of the service. The usage information is sent to us anonymised and cannot be linked to you as a user – regardless of whether you have registered a profile or not. IP addresses and other identifying information are neither stored nor logged.

Last updated: 12.09.2023 at 08:05