This RTD Privacy Policy (Policy) is intended to provide an understanding of how information collected in association with accessing the mobile software application known as the FlexRide app (FlexRide App) is handled. RTD uses Kyyti (Kyyti), a company that offers customer access for planning trips using both RTD’s fixed-route network and FlexRide and for seamless booking. RTD will also be integrating payment and mobile ticket (mTicket) sales through the app with our mobile ticketing provider, Masabi. We ask that you read this Policy carefully as it contains important information about how your personal data will be used. This Policy also explains the types of personal information that RTD collects from customers using the FlexRide App and the circumstances in which this personal information may be disclosed to a third party.

Collection and Use of Personal Information

Information that you provide

This Policy covers only the provision of data related to the purchase of the mobile ticket and the collection of that data by RTD, Masabi, and Kyyti. Information you provide to Kyyti through your use of the FlexRide App to purchase mTickets is governed by Kyyti’s terms and conditions, including Kyyti’s separate privacy policy.

We may retain a record of any contact you make with us. We will obtain personal information about you whenever you purchase mTickets through the RTD Mobile Tickets App, FlexRide App, and other integrated third-party applications. Such personal information includes:

  • Information about mTickets purchased and activated, such as the mTicket ID, type of mTicket, date and time of purchase and activation of the mTicket, the validity period of the mTicket, and expiration of the mTicket.
  • Payment details, information about the financial transactions related to the credit or debit cards used for purchases, the email address to which the purchase receipt was sent, and information about credit or debit cards saved in your account.
  • Device information: We may also collect information about your device each time you use the App. For example, we may collect information on the type of mobile device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface), the type of mobile browser that you are using, the mobile operating system that you are using, mobile network information, and the time zone setting.

Consent

Your consent to the collection and use of your personal information by RTD, Masabi, and Kyyti is implied by your purchase of an mTicket through the RTD Mobile Tickets App and other integrated third-party applications and by using the mTicket for travel. Although we may request your consent for some disclosures described in this Policy, please be aware that by purchasing an mTicket or using the mTicket for travel, you are deemed to have accepted and agreed to the collection and use of your information by RTD, Masabi, and Kyyti in the manner described in this Policy, and we will not be required to obtain your consent for any disclosure described in this Policy.

Use of Your Personal Information

RTD and Masabi use your personal information for the following purposes:

  • Research, statistical analysis and behavioral analysis;
  • Fraud prevention and detection (for instance, if your phone is lost, stolen, or damaged, we will use the personal information you provided to verify that you are the individual who made any purchases of mTickets through the App);
  • Billing and order fulfillment (including in-App purchase fulfilment);
  • Improving our services; and
  • To comply with legal and regulatory requirements.
  • Our third-party analytics providers do not receive any personally identifiable information to track the browsing of individual users. We view aggregated analyses prepared by our third-party analytics providers, but these analyses do not include any personally identifiable information.

Disclosure of Your Personal Information

We may disclose your personal data to:

  • Kyyti;
  • Other companies within the Masabi group;
  • RTD’s agents and service providers; and
  • Law enforcement and regulatory agencies in connection with any investigation or to help prevent unlawful activity or as otherwise required by applicable law.

Access

RTD complies with the Colorado Open Records Act (CORA). For mTicket information, mTicket users will be required to file a request through CORA. You may be charged a fee for RTD to fulfill your request.

Submit a CORA Request

SAFEGUARDS

We will use technical and organizational measures to safeguard your personal data; for example:

  • Access to your account is controlled by a password and username that are unique to you;
  • We store your personal data on secure servers; and
  • We may require our vendors to agree to maintain the confidentiality of your personal data.
  • While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and, for this reason, we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.

Changes to Privacy Policy

We reserve the right to modify and change this Policy at any time without notice. For any significant changes affecting your rights, we will post a more prominent notice of the change to our website. We encourage our customers to review this Policy periodically. You should check this policy frequently to ensure you are aware of the most recent version that will apply each time you use the App.

Questions and Comments

RTD is committed to adhering to this Policy and to protecting the privacy of its customers. RTD welcomes your questions and comments. If you wish to contact us, please call RTD Customer Care at 303-299-6000 or contact us online.