Privacy Notice - Customers and Passengers

  1. PRIVACY NOTICE – CUSTOMERS AND PASSENGERS 

    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 of The Kings Ferry Limited;  and/or a passenger on any of the passenger transport services arranged or provided by The  Kings Ferry Limited. 

    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 Law  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 this website. It is your responsibility to read this privacy notice and check this  website for the current version. 

    1. Who is controller of your personal data? 

    For the purposes of this privacy notice, we shall mean The Kings Ferry Limited, trading as National Express Transport Solutions.  

    The controller’s 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. 

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

    We collect the following types of personal data about you: 

    • your name and title; 
    • your contact information, including telephone number and email address; 
    • if you register to use our websites and/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 good industry practice; 
    • if you are disabled or have special needs, information about your disability, special  needs or mobility requirements; 
    • if you set up an account with us, your marketing preferences; 
    • if you purchase a travel card from us, your image; 
    • your image, where it is captured by CCTV or other visual recording equipment 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 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 communicate with us. We collect your personal data in a variety of ways, including: 
    • by you: 

    🖉 creating an account with us; 

    🖉 purchasing products and/or services from our websites and/or apps; 

    🖉 submitting your personal data on our websites and/or apps, for example, via  the ‘Contact Us’ page; 

    🖉 providing your personal data to us when communicating with us in any  manner, for example, when you:

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

    🖉 submitting information when registering or using our on-board Wi-Fi or  entertainment services; 

    • by us: 

    🖉 making visual and/or audio recordings on the passenger carrying vehicles  used to provide our travel services; and 

    🖉 recording telephone conversations with our customer contact centre representatives. 

    1. 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: 

  2.  

    Purpose 

    Legal basis 

    Explanation

    • To provide our products and  services to you 

    • To provide you with  

    information, advice and  

    guidance about our products  and services 

    • To manage our relationship  with you, including to respond  to any questions you ask and  deal with any complaints you  make and, on occasion, to 

    ascertain whether you wish to  be a brand ambassador for us • To develop our strategy and operational processes  

    • To study how our customers  use products and services  

    provided by us and third  

    parties 

    • To manage how we work with  other companies that provide  services to us and our  

    customers  

    • To comply with the laws and  regulations that apply to us 

    • To seek to enforce and  

    defend our legal rights 

    • To seek to detect, investigate, prevent and report crime and  anti-social behaviour 

    • To seek to protect and  

    promote your health & safety  and that of our other  

    customers, staff and third  

    parties

    • Fulfilling our legal  duty 

    • Performance of our contract with  you 

    • Legitimate interest • Consent

    • Being efficient about how  we fulfil our legal and  

    contractual duties and  

    manage our relationship  

    with you 

    • Keeping our business  records up to date  

    • Developing and improving  our business 

    • Developing our products  and services, and what we  charge for them 

    • Developing relationships  with business partners, to  enhance our product and  

    service offering  

    • Preserving our legal  

    position, seeking to detect  and prevent crime and anti social behaviour and  

    seeking to promote health  and safety 

    • Enabling us to provide safe  passenger transport  

    services


    1. 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. 

    1. 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. 

    1. Who will we share your personal data with? 

    We may share your personal data with: 

    • other National Express Group companies; 
    • our suppliers and sub-contractors who help us to provide our 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; 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. 

    In addition, if you follow a link to any of the websites of advertisers and affiliates on our  websites or apps, 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. 

    1. Do we make international transfers of personal data? 

    There may be occasions where it is necessary for us to transfer your personal data to a  country outside of the European Economic Area (“EEA”). 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 EEA. 

    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 EEA that  are not deemed to provide a similar level of protection for individuals’ rights in relation to their  personal data as in the EEA, we have entered into appropriate contracts with those National  Express Group companies and/or third parties based on the standard contractual clauses  approved by the European Commission, a copy of which can be found here: here 

    1. 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, we will process such personal data until you withdraw that consent.  

    We may also retain your personal data for longer if we cannot delete it for legal, regulatory or  technical reasons. 

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

    You have a number of rights under the Data Protection Law 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. 

    1. 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

    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/