Privacy policy

(Last modified on July 18, 2020)

Introduction and Definitions

Welcome to the Chrono Application and Services. We are confident that you will find our Services useful. For easier understanding of this Privacy Policy (the “Policy”), please refer to the following definitions for clarification:

Application” refers, as applicable, to (i) the free app for iOS or Android called “Chrono”, created and owned by the ARTM, or (ii)  the functionality for purchasing virtual rights to transportation  accessible through a mobility app published by another company. The Application provides access to the Services that allow you to plan your trip on public transit, and use related functionalities, such as the purchase of virtual rights to transportation, where applicable. Application also includes any Application updates and upgrades that the ARTM may provide to you or make available, or that you obtain after the date you obtain the initial copy of the Application, to the extent that such items are not accompanied by a separate privacy policy. The Application may be specified as either “iOS Application” or “Android Application”, for use with respect to the Application’s operating system environment.

ARTM” refers to l’Autorité régionale de transport métropolitain, a legal person established in the public interest under the laws of the Province of Quebec, Canada, with registered office at the address listed in the “Contacting Us” section below. Where the present Policy refers to the “ARTM”, it may refer to the ARTM and / or its affiliates, shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns (collectively “Representatives”), depending on the context. Any reference to “we”, “our”, or “us” in this Policy refers to the ARTM. In this Policy, a Services user may be referred to as “you”. When you have an account and are logged in, you may be referred to as a “Logged-in User”.

Device” refers to the handheld or tablet device onto which you have downloaded the Application and with which you are accessing and using the Services.

Services” are the proprietary software services that the ARTM has developed that are available through the Application that allow you to find information about and plan trips on public transit in the Greater Montreal area, and use various related functionalities. The Services may include the functionality or feature for purchasing virtual rights to transportation.

Additional definitions shall be made throughout this Policy, but they will be recognizable as they will be capitalized, bolded, and in quotation marks.

Acceptance and Modifications

By downloading, using, or accessing the Application on your Device you hereby accept to be bound by the terms of the Policy. You may also have explicitly accepted the Policy following your installation of the Application and launch of the Application for the first time. By submitting Personal Information to us through the Application or via other means, you consent to the ARTM’s collection, use and disclosure of such Personal Information (as that term is defined hereinbelow) in accordance with this Policy (as amended from time to time) and as permitted or required by law. If you do not agree to all the provisions contained in the Policy, you are not authorized to use the Services. If you have downloaded the Application and do not agree to all the provisions of the Policy, you must delete the Application from your Device.

The ARTM reserves the right, at any time and without prior notice, to modify or replace any of the Policy. Any changes to the Policy can be found at this URL. It is your responsibility to check the Policy periodically for changes. Your use of the Application and Services following the posting of any changes to the Policy constitutes acceptance of those changes. If there are any significant changes to the Policy that materially affect the way we treat your information, we will post those changes at his URL.

The Policy should be read in conjunction with the Terms of Use, as both these documents govern your use of the Application and Services.

Contacting Us

If you have any questions about the Policy or if you wish to inquire about and / or access any Personal Information the ARTM holds about you, please contact:

ARTM
Privacy Officer
vieprivee@artm.quebec

or at :

ARTM
Privacy Officer
700, rue De La Gauchetière Ouest, 4th floor
Montréal (Québec) H3B 5M2

Our Respect for Your Privacy and Protection of Personal Information

The ARTM takes your privacy and security of Personal Information very seriously. We have provided a secure environment and this strict Policy that describes the limited ways the information is used and the limited access to such information.

What Does This Privacy Policy Cover?

This Policy covers the treatment of personally-identifiable information, i.e. any information that identifies an individual, or can be used in conjunction with other information to identify an individual (“Personal Information”) and other information gathered by the ARTM when you are using the Application and Services. This Policy also covers the ARTM’s treatment of any Personal Information or other (non-personal) information that the ARTM may share with its partners or other third parties under very limited circumstances.

This Policy does not apply to the general practices and treatment of information (whether personal or not) by third parties that the ARTM does not own or control, including but not limited to any third-party websites or services that you elect to access through the Application or Services or via a link from the Application or Services (“Third-Party Website”), or to individuals that the ARTM does not manage or employ. While we attempt to facilitate access or link only to those Third-Party Websites that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Websites. We encourage you to carefully review the privacy policies of any Third-Party Website you access. We have named and provided links to the most important of these Third-Party Websites elsewhere in this Policy where it is feasible and appropriate.

Finally, this Policy does not cover any Personal Information you send to the ARTM via any non-secured mode of communications such as email, instant messenger or Twitter, as communications via these methods may be subject to interception, loss, or alteration. While we welcome your comments and suggestions sent to us in this manner, and we will treat such information as Personal Information once we receive it, we encourage you to carefully examine what Personal Information you send to the ARTM via these methods.

(Applicable solely to the Chrono Application)

We Do Not Collect Your Personal Information Without Asking You

The ARTM does not, as a matter of course, gather any of your Personal Information while you are using the Services, unless you are asked to provide such information, for example by signing up for an account. Personal Information is only gathered with your informed consent. Where you have provided Personal Information, it will only be used for the stated purpose, as detailed more specifically in the next section.

The Personal Information We Collect and What We Use It For

The following is an exhaustive list of Personal Information collected from you when you use the Services and what we use it for. You acknowledge that you are submitting this Personal Information with your informed consent.

  • Account Information”. As specified in the Terms of Use, users may create an account and enter the following Personal Information in order to use certain functions the Services: an email address. This Account Information is used to manage your account, to verify your credentials for logging-in to those portions of the Services requiring an account, and to communicate with you information about your account. The submission of this Account Information is strictly voluntary; however certain functions of the Services may not be available to you without it.
  • Location Information”. To the extent your location can be considered Personal Information, your Location Information is used in order find information about public transit close to you, and to help plan your trip on public transit. The submission of this Location Information is strictly voluntary; however, the Services may not provide the best results without this information.
  • “Transaction Information”. When users acquire one or more rights to transportation via the Application, they are redirected to a banking transaction acquirer and required to provide the necessary information to conduct the associated banking transaction (email address, name on credit card, credit card number, expiration date, CSV number and any additional information required to complete a transaction of this nature).

How We Protect Your Personal Information

The ARTM uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including Personal Information) secure. In addition, the ARTM uses third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the Services and storing data, and these third parties have been selected for their high standards of security, both electronic and physical.

We Only Disclose Your Personal Information to Third Parties in Very Limited Circumstances

Except as provided in the next paragraph and the next section of this Policy on Email Communications, the ARTM does not divulge any Personal Information gathered via the Services or any other means to third parties. Moreover, the ARTM does not sell, rent, trade or license any Personal Information regarding its users to third parties. Only the employees, Representatives, subcontractors, officers, agents, or assigns of the ARTM are responsible for the management and development of the Application and Services, and only these individuals who require this information to provide the Application and Services have access to the information (including Personal Information) collected. These employees, Representatives, subcontractors, officers, agents or assigns are all under obligations of confidentiality.

Notwithstanding anything in the Policy to the contrary, we may share any information we have collected about you or that you have submitted (whether Personal Information or not): (1) in response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims or demands; (2) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of the Terms of Use; (3) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Services infrastructure or the Services generally); (4) to a parent organization, subsidiaries, or other organizations under common control with the ARTM (in which case we will require such entities to honour this Policy); (5) if the ARTM merges with another entity or is subject to a reorganization (in which case we will require the new entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy); or (6) to banking transaction acquirers so that you can access their services for the purpose of conducting transactions to purchase rights to transportation.

(Applicable solely to the Chrono Application)

Email Communications

The ARTM currently uses SendGrid to send out emails from the Services. Personal Information (your email address) is transferred to SendGrid for our email communications to function properly. Your Personal Information is only used for the proper sending out of email; SendGrid does not use this Personal Information for any other purpose and will not transfer or sell your Personal Information to any other third party.

The ARTM collects certain data automatically through the third-party analytics software Azure Application Insights and Google Analytics for Firebase in order to gain a better understanding of how its users make use of the Services; however, none of this information identifies you personally. We use this information exclusively in aggregate form in order to understand your needs and those of other users of the Services.

(Applicable solely to the Chrono Application)

Our Use of Tracking Technology

The ARTM uses certain tracking technologies called “tokens” in the Application and by using the Services you agree to their use. These tokens are used for the following purposes:

  • to implement the functions of the analytics programs listed in the previous section of this Policy; and
  • to save your searches and preferences so that your user experience will be improved during future use of the Services.

Your Device can be set to refuse delete such technology after they have been stored. Please refer to your Device’s help section for instructions.

Aggregated and Anonymous Information

In addition to the information collected by the analytics and monitoring programs as described elsewhere in this Policy, we may also generate and use aggregated and / or anonymized information and statistics about the Services and Services users. We use this information for our internal purposes, specifically better understanding our users and improving our Services, and transit services generally. However, no user of the Services will be individually identifiable from these aggregated and / or anonymized information and statistics.

This aggregated and anonymous information may also be shared with ARTM’s partners. These partners will only use the aggregated and anonymous information in order to understand their users in the aggregate and improve their public transit services.

(Applicable solely to the Chrono Application)

General Information Transfer from the Services

Any information (Personal or not) the Services collect while you use them may be stored locally on your Device and then transferred to servers controlled by the ARTM, and the ARTM may obtain this information as a result of the data being sent to our servers from the Services. The information, however, is only used (or not used) by the ARTM as described elsewhere in this Policy.

(Applicable solely to the Chrono Application)

How the Application Accesses Your Device (“Permissions”)

The following is a complete listing and description of what functions on the Device that were developed by third parties are accessed and / or modified by the iOS and Android Applications. Where noted, they operate with user permission only. You acknowledge that denying explicit permission may affect or reduce your user experience with the Services.

iOS Application:

  • Location services. Allows the Application to determine your location through network and GPS services (user permission only).
  • The Application may send you notifications (user permission only).
  • Background refresh. Allows the Application to refresh information from the internet while running in the background.

Android Application:

  • Location services Allows the Application to determine your location through network and GPS services (user permission only).
  • Network services access. Application will access your Wi-Fi or cellular services to display your network connection, and exchange data (including Personal Information) with servers controlled by the ARTM. Allows retrieval and sending of information from and to the internet in general.

Storage. Allows the Application to read and write to your Device’s memory.

(Applicable solely to the Chrono Application)

Using Your Device’s Settings and Uninstall for the Application

You can access and change certain user settings for the Application from the settings menu on your Device. You may also uninstall; uninstall methods may vary depending on your Device or iOS or Android version. The ARTM has no control over these functions and denies any responsibility of your use thereof, and any data or Personal Information sent to third parties as a result of said activities.

Your Rights to Verify, Correct and Delete the Personal Information We Hold

You have the right to: (i) verify what Personal Information the ARTM holds about you; (ii) ask for your Personal Information to be corrected or updated; and (iii) to withdraw your consent to the use by the ARTM of your Personal Information and have it deleted from our records, subject to certain legal requirements as described further in this section. If you wish to inquire about and verify and / or correct Personal Information the ARTM holds about you, or if you wish to have all your Personal Information permanently deleted from our records, please contact us using the contact information further up in this Policy.

Please note that deletion of your Personal Information may make it impossible for you to use the Services, or certain portions thereof, and the ARTM accepts no responsibility for any damages, pecuniary or otherwise, resulting therefrom. If you request deletion of your Personal Information, the ARTM reserves the right to retain some of your Personal Information for a reasonable time in order to satisfy our legal obligations (as described more fully in the “We are Compliant with Privacy Laws” section below) or under a legal procedure of any sort.

There are Risks When Using the Internet and Wireless Data Transmission

Despite the ARTM’s best efforts to ensure that third parties will not access or obtain your Personal Information through your use of the Services, complete confidentiality and security cannot currently be guaranteed on the Internet and / or where data is transferred via wireless digital technology of any type. Communication via the Internet or wireless transmission is subject to interception, loss, or alteration. You acknowledge and agree that the ARTM cannot be held responsible for damages resulting from the transmission of confidential information or Personal Information in this manner and that such communications are at your own risk.

We are Compliant with Privacy Laws

As a public body, this Policy and the ARTM’s practices in general are designed to be in compliance with Quebec’s Act Respecting Access to Documents Held by Public Bodies and the Protection of Personal Information (RLRQ, C. A-2.1). If you have any questions regarding this compliance, please contact us using the contact information further up in this Policy.

© l’Autorité régionale de transport métropolitain 2020