Customer and Passenger Privacy Policy

1. Who does this privacy notice apply to, and what is it about?

This privacy notice applies to you if you are or were a customer or passenger of National Express Transport Solutions.

In addition, we may process and store your personal data if you have made a booking through a third party agent.

This privacy notice explains:

• what personal data we collect about you;
• what we do with your personal data;
• your rights in respect of your personal data; and
• what to do if you have any questions or complaints about our use of your personal data.

We take your privacy very seriously and are committed to abiding by the Data Protection Laws which protect your privacy.

This privacy notice may change from time to time and the most up-to-date version will always be available on our website. It is your responsibility to read this privacy notice and check our website for the current version.

2. Who is the controller of your personal data?

The National Express group company established in the United Kingdom that sells or provides you with passenger transport services is the controller of your personal data that is
or was processed for the purposes explained in this privacy notice.

This will be that one of the following named National Express UK group companies:

Our representative for the purposes of this privacy notice is the National Express UK Data Protection Officer, who can be contacted using the contact details provided at the end of this notice.

If you are in the EEA, our subsidiary National Express Bus & Coach Services Limited is our representative in the EEA and can be contacted using the contact details provided at the end of this notice.

3. What personal data do we collect about you, and how?

We may collect the following types of personal data about you:

• your name and title;
• your home address, including postcode and country of residence;
• your contact information, including telephone number and email address;
• if you register to use our website or apps, your email address and password;
• your transaction or payment information - however, please note that full debit card and credit card information is not processed by us as it is passed through to a PCI-DSS compliant third party payment provider in accordance with good industry practice;
• if you are disabled or have special needs, information about your disability, special needs or mobility requirements, or where you are arranging transport for someone else information about their disability, special needs or mobility requirements;
• your marketing preferences;
• your image, where it is captured by CCTV or other visual recording equipment on our owned or occupied sites, such as coach stations and/or on the passenger carrying vehicles used to provide our passenger travel services;
• your voice, where this is captured by CCTV or any other audio recording equipment at our owned or managed premises, such as coach stations and/or on the passenger carrying vehicles used to provide our passenger travel services and/or where captured in recorded telephone conversations with you; and
• any other personal data that you provide to us when you visit our website, use our apps, or when you communicate with us.

In addition, each time you visit our website we may automatically collect the following information:

technical data, including:

• IP address;
• browser type and version;
• time zone setting and location; and
• operating system and platform;

transaction data, including:

• the full Uniform Resource Locators (URLs) clickstream to, through and from our website (including date and time);
• products/journeys you viewed or searched for; and
• time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.

We collect your personal data in a variety of ways, including:

by you:

• searching for products and/or services and/or purchasing products and/or services from our website;
• purchasing products and/or services through any of our other sales channels, including our third party ticket agents;
• submitting your personal data on our website, for example, via the ‘Contact Us’ page;
• providing your personal data to us when communicating with us in any manner, for example, when you:

1. speak to one of our representatives in person on-board one of our passenger carrying vehicles; and
2. contact us by letter, email, text message, telephone call or on social media;

• consenting to receive certain information from us, such as marketing emails and other promotional material about sales, offers, exclusive deals and travel ideas;
• entering one of our competitions or participating in post journey, market research and other surveys that we organise or conduct; and
• submitting information when registering or using our on-board Wi-Fi

by us:

• making visual and/or audio recordings at our owned or occupied sites, including on the passenger carrying vehicles used to provide our travel services;
• recording telephone conversations with our customer contact centre or sales representatives; and
• gathering statistical information around email opening and clicks.

We may also receive your personal data if you use any of the other websites operated by other National Express Group companies or from third parties, such as companies that market and sell our products and/or services on our behalf or from any person who has bought our products and services for you or contacted us on your behalf.

4. What do we do with your personal data and on what basis?

We use your personal data for the following purposes and describe below the legal basis on which we process your personal data:

5. What if we have obtained your consent to use your personal data?

Where we process your personal data on the basis of your consent, you may withdraw that consent at any time.

Where you have provided consent for us to send you marketing communications, you may withdraw that consent at any time, by updating your marketing preferences by clicking on the “unsubscribe” link in any marketing communications we send you.

Where you have consented to the use of cookies, you may withdraw that consent at any time by changing your cookie settings as explained in our cookie policy.

6. What are our obligations to collect, and your obligations to provide, personal data?

We have no legal obligation to collect personal data about you, but we need to collect some personal data in order to provide you with our products and services, collect payment for such products and services and deal with any questions or complaints you have about them.

You have no legal obligation to provide your personal data to us, but we may not be able to provide you with our products and services or deal with your questions or complaints if you do not provide us with your personal data.

7. Who will we share your personal data with?

We may share your personal data with:

• other National Express Group companies;
• our suppliers, sub-contractors, business partners and our brand ambassadors who help us to provide our products and services to you;
• other business partners in connection with the provision of their products and services to you;
• our legal and professional advisors;
• government bodies and regulatory authorities, including the Driver and Vehicle Standards Agency, the Police and other crime prevention and detection agencies and the UK Information Commissioner’s Office;
• the Traffic Commissioners, the courts and other dispute resolution arbitrators and mediators, other parties to legal proceedings and passenger transport watchdogs;
• analytics and search engine providers that assist us in the improvement and optimisation of our websites; and
• other companies that take on any part of our business as a result of a restructure, merger or transfer of that part of our business.

Where we share your personal data with business partners for the purpose of providing products and services to you, it may be essential to do this to fulfil a contract with you. Where this applies, the relevant business partner is the controller of your personal data that we provide to them and their privacy notices or policies apply to how they handle your personal data. We do not accept any responsibility or liability for such third parties or their handling of your personal data. Please check the relevant third party’s privacy notice before you submit any personal data to them.

In addition, if you follow a link to any of the websites of advertisers and affiliates on our websites, these third party websites may have their own privacy notices or policies. We do not accept any responsibility or liability for these notices or policies or the third parties’ handling of your personal data. Please check the relevant third party’s privacy notice before you submit any personal data to them.

8. Do we transfer your personal data outside of the UK?

There may be occasions where it is necessary to transfer your personal data to a country outside of the United Kingdom (“UK”). It is possible that the country concerned may not be deemed to provide a similar level of protection for individuals’ rights in relation to their personal data as in the UK.

Where we transfer your personal data to other National Express Group companies and/or third parties who process your personal data on our behalf in countries outside the UK, we ensure a similar degree of protection is afforded to it by implementing one of the following safeguards:

• we transfer to a country that has been deemed to provide an adequate level of protection for personal data; or

• where the country has not been deemed to provide an adequate level of protection for personal data, we will have entered into contracts approved for use in the UK which give personal data the same protection as it has in the UK.

Please contact the National Express UK Data Protection Officer if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

9. For how long will we process your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting or reporting requirements in respect of our relationship with you.

Where we process your personal data to fulfil:

• a legal obligation, we will process such personal data for so long as necessary to fulfil that obligation; or
• a contract with you, we will process such personal data until we fulfil that contract and for so long thereafter as may be necessary to keep a record of that contract, which will typically be for 6 years, and to deal with any complaints or claims relating to that contract, which will be until the final resolution of such complaints or claims (having regard to the nature of any potential claims and the limitation of liability periods that apply to them).

Where we process your personal data based on:

• our legitimate interest, we will process such personal data for so long as necessary to achieve that legitimate interest, which will typically be for 6 years after we collect your personal data or the last time we use your personal data (or longer in relation to any legal claims that might arise having regard to the nature of any potential claims and the limitation of liability periods that apply to them); or
• your consent, for example, to send you marketing information, we will process such personal data until you withdraw that consent. Please bear in mind that it may take a short time to process any withdrawal of your consent. We aim to do this within 72 hours of receipt of your request, although you may still receive emails that are already in process around the time of your withdrawal.
• We may also retain your personal data for longer if we cannot delete it for legal, regulatory or technical reasons.

10. What rights do you have in relation to your personal data?

You have a number of rights under Data Protection Laws in relation to your personal data. These include the right, subject to exceptions, to:

• request access your personal data;
• request rectification or erasure of your personal data;
• request restrictions on the processing of your personal data; and
• object to our processing of your personal data.

You also have the right in some circumstances to receive a copy of your personal data in a portable format. This right is limited to personal data you have provided to us and is processed on the basis of your contract with us and/or your consent. It does not cover personal data that we process on other grounds.

If you wish to exercise any of these rights and/or request a portable copy of the data that you have provided and is processed on these bases, please contact the National Express UK Data Protection Officer.

11. What should you do if you have any questions or complaints?

If you have any questions or complaints about how we process your personal data, or otherwise about the matters set out in this privacy notice, please contact the National Express UK Data Protection Officer at:

• Address: Data Protection Officer, National Express, National Express House, Birmingham Coach Station, Mill Lane, Digbeth, Birmingham B5 6DD

or

• Email address: data.protection@nationalexpress.com

If you are in the EEA, our subsidiary National Express Bus & Coach Services Limited is our representative in the EEA and can be contacted at eurep.nx@nationalexpress.com

You also have the right to complain at any time to the UK Information Commissioner's Office about how we use your personal data and can contact them on their helpline: 0303 123 1113 or website at https://ico.org.uk/