Privacy Policy

VIA Metropolitan Transit Privacy Policy

VIA Metropolitan Transit (“VIA”) is committed to ensuring VIA’s customer privacy and security. Specifically: (1) VIA will not provide personal identifying information (“PII”) from VIA Accounts to any third party without express customer consent, except as described in this Privacy Policy or required by law; (2) PII from VIA accounts will not be provided to advertisers for their use; and (3) VIA will maintain a secure environment for customer PII.

This Privacy Policy is intended to provide an understanding of how VIA handles PII collected by VIA. Among other things, this policy explains the types of information collected from VIA customers and specifies the third parties with whom VIA, Trapeze, and Moovel (the “VIA Contractors”) may share this information.

The VIA Privacy Policy provides that by creating an account with VIA and using the transit system, a customer allows VIA, VIA Contractors, and other third parties referenced herein to process PII according to the provisions set forth in this VIA Privacy Policy.

Definitions

The following definitions apply:

• Personal Identifying Information (PII): PII identifies or describes a person or can be directly linked to a specific individual.  Examples of PII include, but are not limited to, a person’s name, mailing address, billing address, business name, alternate contact information (if given), telephone number, email address, fax number, VIA card number, credit or debit card number, security code and expiration date, and information related to a customer’s mobile device and location if a customer uses the VIA goMobile Application or other VIA trip booking or planning tools.
• Aggregate Data or Aggregate Information: Aggregate Data or Aggregate Information is statistical information that is derived from collective data that relates to a group or category of persons from which PII has been obtained or collected. Aggregate Data reflects the characteristics of a large group of anonymous people. VIA may use Aggregate Data and provide Aggregate Data to others to generate statistical reports for the purpose of managing VIA operations.
• Location Data or Location Information: Location Data or Location Information is mobile device geo-location data, including but not limited to geolocation data from GPS, cellular, WiFi services, your mobile device IP address, or other similar technology. Location Data also includes the user’s current, past, or future location based on app usage or any route planning, trip planning tools, or multi-modal tools accessed by the user. If you permit VIA to access Location Data VIA may collect, store, and use this data in conjunction with the provisioning of ticketing or multi-modal services. If you permit VIA to access location services through your mobile device’s operating system’s permission mechanism VIA may collect, store, and use this data when the VIA app is active in the foreground or background.
• Transaction Data or Transaction Information: Transaction Data or Transaction Information are details relating to the ticket transactions made to access VIA services, including but not limited to ticket purchase, activation, validation, access, and usage.

Collection of Personal Identifying Information (PII)

If a customer registers a VIA Account, VIA collects personal identifying information from applications and other forms submitted by VIA customers to VIA Customer Service by telephone, mail, facsimile transmission, in person, or by electronic submission through VIA website or VIA goMobile Application. VIA also considers data developed as a byproduct of a customer’s use of VIA system (e.g., a registered user’s travel routes and times traveled) to be PII if a VIA Account is registered.

Additionally, VIA goMobile Application may collect certain information automatically, including, but not limited to, the type of mobile device being used, a mobile device’s unique device ID, the IP address of a mobile device, the type of mobile operating system, the type of mobile Internet browsers used on the mobile device, and information about the way a customer uses VIA goMobile Application. When a customer uses VIA goMobile Application, VIA may use Location Data to determine a customer’s location in order to provide certain services available through the VIA goMobile Application and other online trip planning tools. VIA may also use Location Data, Transaction Data, or a combination of Location Data and Transaction Data to provision or improve the VIA system.  If you do not want your location being used for such purposes, you must take all necessary steps to turn off the location services for your mobile device in your account settings.

How VIA Uses Personal Identifying Information

VIA uses PII provided by customers in order to provide services through VIA website and VIA goMobile Application, to effectively and efficiently process enrollments, manage accounts, respond to questions, send customer emails about VIA program updates, and otherwise communicate with VIA customers.

PII is only utilized as described in this Privacy Policy.

Third Parties with Whom VIA May Share Personal Identifying Information

VIA may share PII with any current or future VIA employee or contractor for the purpose of operating and managing VIA programs. VIA may also disclose PII to another transit agency or the Federal Transit Administration (FTA). If another transit agency or party is added to VIA program, VIA will notify their customers via amendment to this Privacy Policy and on VIA website. In addition, VIA may disclose PII to third party service providers for the purpose of operating and maintaining VIA system, such as managing customer accounts and collecting revenue. Any such contractors are provided only with the PII they need to deliver the service being provided. VIA requires service providers to maintain the confidentiality of the information and to use it only as necessary to carry out their duties under VIA program.

VIA requires outside law enforcement and regulatory agencies to obtain a subpoena for VIA records containing PII, including location data, unless otherwise required by law, or the law enforcement or regulatory agency articulates the existence of a bona fide emergency requiring immediate access to specific records. Additionally, VIA may disclose PII without request to appropriate law enforcement where necessary to protect customers’ rights, property or safety.

VIA may provide a VIA customer’s PII to a third party as necessary to process any retail transaction using a VIA goCard or goMobile app that a customer may conduct with retail merchants other than with VIA. As with any credit or debit card payment, if a VIA customer conducts a transaction with a retail merchant using a VIA goCard, VIA goMobile Application, or any other VIA program media, VIA needs to share some information (for example, the customer’s name and credit or debit card number) with the banks and other entities in the financial system that process credit or debit card transactions. VIA is not responsible for third party use of PII provided to retail merchants at which customers use their VIA goCard, VIA goMobile Application, or any other VIA program media to conduct transactions, regardless of whether the transaction was conducted in person or online by VIA customer.

Besides these entities, PII will not be disclosed to any other third party without express customer consent, except as required to investigate and respond to consumer complaints and to comply with laws, such as the Texas Public Information Act, or legal process served on any current or future VIA or VIA Contractors.

Retention of Personal Identifying Information

VIA, and VIA Contractors, will only store the PII of a VIA customer that is necessary to perform account functions such as billing, account settlement, or enforcement activities.

Security of VIA Personal Identifying Information

VIA is committed to the security of customer PII. VIA, and VIA Contractors, store the PII provided by VIA customers on computer servers that are located in secure, controlled facilities. Servers are designed with software, hardware and physical security measures in place intended to prevent unauthorized access.

Access to PII is controlled through administrative, technical, and physical security measures. By contract, third parties with whom VIA share PII will be  required to implement adequate security measures to maintain the confidentiality of such information.

VIA Customer Obligations and Legal Disclaimer

VIA customers are responsible for safeguarding personal mobile devices, usernames, passwords, personal identification numbers (PINs), and other authentication information that may be used to access a VIA account. VIA customers should not disclose authentication information to any third party and should notify VIA of any unauthorized use of their usernames, passwords or accounts. VIA cannot secure PII that is released by VIA customers to others or PII that customers request VIA release to others. In addition, there is a risk that unauthorized third parties may engage in illegal activity, such as hacking into VIA’s security systems or VIA Contractors’ security system, or by intercepting transmissions of personal information over the Internet. VIA is not responsible for any data obtained in an unauthorized manner, and besides the customer, VIA is the only entity that may authorize obtaining data from VIA program by a third party.  VIA is not responsible for any data or PII obtained by a third party as a result of a VIA cardholder’s negligence or misuse of VIA fare media, products, or equipment.  If a VIA cardholder’s fare media is lost, stolen, or damaged, VIA is not responsible for any data or PII that is obtained by a third party.

Account Access and Controls

Registering a VIA Account is solely within the customer’s discretion and is not required for use the VIA system. The information required to register an account or to obtain other convenience benefits provided by VIA includes PII such as name, mailing address(es), billing address, email address, telephone number, and, for certain convenience benefits, credit or debit card number, expiration date and VIA account security code. VIA may request other information as required by law.  VIA may request other optional information, such as alternate contact information, but in such instances VIA will indicate that providing such information is optional.

Customers who have registered their VIA Accounts can review and update personal information at any time, and are also able to modify, add, or delete any optional account information. PII and optional account information can be reviewed and edited as discussed below under “Updating Personal Identifying Information.” VIA customers can close their account(s) at any time by contacting VIA Customer Service at 210-362-2020.

Aggregate Data

VIA may also combine the PII provided by VIA customers in a non-identifiable format with other information to create Aggregate Data that may be disclosed to third parties. Aggregate Data is used by VIA to improve VIA program and for the marketing of VIA. Aggregate Data does not contain any information that could be used to contact or identify individual VIA customers or their accounts. For example, VIA may inform third parties regarding the number of VIA accounts within a particular zip code.

Location Data and Transaction Data

VIA may also combine Location and Transaction Data provided by VIA customers in a non-identifiable format that may be disclosed to third parties. This combined data is used by VIA to improve the VIA program and system. This combined data does not contain any information that could be used to contact or identify individual VIA customers or their accounts.

Cookies

VIA websites, including www.viainfo.net, stores “cookies” on the computer systems of users of the website. Cookies are small data elements that a website can store on a user’s system.

The cookies used by VIA web site facilitate customers’ use of the website (e.g., by remembering login names and passwords until the session has ended). VIA website does not require that users of the website accept these cookies.

If a user visits a third party website via a link provided on VIA website, the privacy policies of those other websites will apply and customer is solely responsible for and should review these other websites to understand how these external sites utilize cookies and how the information that is collected through the use of cookies on those websites is utilized.

VIA does not knowingly engage in business with any company or vendor that uses Spyware or Malware. VIA does not market detailed information collected from web sessions that can be directly tied to personal information. VIA does not provide VIA customers with downloadable software that collects or utilizes any PII.

Third Party Websites and Applications

VIA’s website contains links to third party websites. These web links may be referenced within content, or placed beside the names or logos of the other entities. VIA does not disclose PII to these third party websites except as described in this VIA Privacy Policy.

WARNING: VIA IS NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF EXTERNAL WEBSITES OR APPLICATIONS, REGARDLESS OF WHETHER THEY ARE ACCESSED THROUGH A SERVICE OR CONTENT LINK. PLEASE REVIEW THE PRIVACY POLICIES OF EXTERNAL WEBSITES OR APPLICATIONS BEFORE PROVIDING ANY INFORMATION TO THEM.

Personal Information of Children Under the Age of 13

Pursuant to the Children’s Online Privacy Protection Act, 15 U.S.C. 6501 et seq,children under 13 years of age must have permission from a parent or legal guardian before providing personal information on a Web site or application. VIA complies with the requirements of the Children’s Online Privacy Act (COPPA) and the FTC’s Rule interpreting COPPA (16 CFR § 512). VIA’s website and VIA goMobile Application are not directed to children, and do not knowingly collect any personally identifiable information from children under the age of 13, without parental consent. If VIA learns that it has personal information on a child under the age of 13 without parental consent, access to that information by the child or any third party will immediately be denied and the information removed from the system.

Updating Personal Identifying Information

Customers can review and edit their PII online, from the goMobile Application, or by calling VIA Customer Service at 210-362-2020.

Complaints or problems regarding updating personal information should be submitted by contacting VIA Customer Service at 210-362-2020. VIA Customer Service will either resolve the issue or forward the complaint to an appropriate VIA staff member for a response or resolution. VIA strives to answer all queries within 48 business hours, but it may not always be feasible to do so.

Changes to VIA Privacy Policy

VIA reserves the right to modify this Privacy Policy at any time without notice.  When VIA revises VIA Privacy Policy, the “last updated” date at the bottom of the VIA Privacy Policy will reflect the date of the most recent change. We encourage VIA customers to review the VIA Privacy Policy periodically. Continued use of VIA program constitutes the customer’s agreement to the then current VIA Privacy Policy and any updates.

E-mails Sent to VIA

VIA Privacy Policy does not apply to the content of emails transmitted directly to VIA. Please do not send PII in an email directly to VIA. 

Contact Information

Questions or comments regarding this VIA Privacy Policy may be directed to VIA Customer Service at 210-362-2020.