Navigator App Privacy Policy

Introduction

Thank you for using the Capital District Transportation Authority ("CDTA") Navigator App ("App"). This app makes it easier for Capital District residents and businesses to access public transit information and services provided by CDTA. We understand your concerns about privacy, and we are committed to protecting your privacy when you use this app.

Our privacy policy ("Policy") is in line with the Internet Security and Privacy Act, the Freedom of Information Law, and the Personal Privacy Protection Law. This policy explains how we handle the information we collect from app users. We may make changes to this policy, so it's a good idea to review the privacy policy of any other app or website you access through this app.

BY ACCESSING OR USING the Navigator App, YOU CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. Please read this policy carefully before using the app or providing personal information to us. This Policy is incorporated into and subject to the Terms of Use at CDTA Terms & Conditions.

Changes to this Policy

We reserve the right to make changes to this Policy at any time. In the event we make material changes to the Policy, we will provide notice through the app. Changes will be effective immediately upon posting to Navigator and will apply to your use of the App after the “effective date” listed above.

You understand and agree that your continued use of the Navigator App after the effective date means that the collection, use, and sharing of your personal information is subject to the updated Policy.

Except to the extent we receive your authorization or as permitted or required by applicable law, we will handle your data in accordance with the terms of the Policy in effect at the time we collect your information.

Information We Collect.

We collect personal information you voluntarily submit when you register for an account, visit any cdta.org website or use the Services including purchasing tickets. We collect information when the Navigator App is installed on your device or you connect with the App using your existing account. The Navigator App will also passively or automatically collect information from your browser or device. We use this information to operate the App, provide the Services, carry out our business, comply with laws, and for other purposes described in this Policy. 

You do not need to register for an account to use other features on the App. If you choose to use the Navigator App and Services without setting up a registered Account, the App will still link your information with a User ID generated for you, which is necessary in order for us to provide you with the core features of our Services. 

Information you provide.

The information you choose to provide may include your name, email address, work address, specific points of destination or favorite destinations. When you sign up for an account, you submit your phone number and email address. In order to purchase passes, you submit your credit card or payment information and billing information. 

Information collected from App installation.

When the Navigator App is installed on your mobile device, CDTA will set up a user account associated with that mobile device and create a User ID for you. This is a unique identifier generated by us in accordance with this which is necessary in order for us to provide you with our Services. After installation of the App, we will collect and use the User ID, together with certain other information including geolocation information and certain device information which may include your device ID or other unique identifier, advertising ID, unique device token, device type, operating system (including version and settings), as well as your device screen resolution and keyboard language, all in accordance with this Privacy Policy. We may link this information with the account created in connection with your mobile device and User ID. 

Statistical Data.

To monitor utilization of the Navigator App and improve its quality, we may compile statistical information through analytics services. This might include collecting and analyzing the number of visitors to the App, patterns of traffic flowing through CDTA.org, and information regarding your clicks, and your referral URL to reflect data collected in CDTA.org. The analytics services may transfer this information to third parties in case of a legal obligation or if a third-party processes data on behalf of that service. We may use this information to generate aggregate statistics about visitors to our App. Please check your web browser if you want to learn what information your browser sends or how to change your settings. 

Other Usage Data.

The Navigator Appwill also collect information when you access and use the Navigator App and Services such as tokens of social networks you choose to connect to your account, your public transit historical searches on the Services, your saved routes and most used stations as well as you your in-app settings and in-app scores (“points”). We will use this to provide the Services, enhance your experience, and personalize the Services we provide to you. 

Geolocation Data.

We will collect location information such as your geolocation, route, and travel information to provide you with services. When you use the App, we collect detailed location, including GPS signals and other device sensor data such as gyro/oscilloscope, sent by your mobile device on which the Service is installed and activated. This enables us to provide you with the Service and to create a detailed location history of your public transit trips. 

PLEASE NOTE THAT WE COLLECT YOUR LOCATION DATA IN THE BACKGROUND EVEN WHEN YOU ARE NOT USING THE APP TO PERSONALIZE THE SERVICES AND MAXIMIZE YOUR USER EXPERIENCE AND TO DEVELOP AND ENHANCE OUR PUBLIC TRANSIT INFORMATION SERVICES. YOU MAY CHOOSE TO DISABLE AND OPT-OUT FROM THIS BACKGROUND COLLECTION OF DATA UNDER THE APP’S PRIVACY SETTINGS SCREEN. 

Personal information collected from other sources.

In certain circumstances, we may collect personal information about you from third parties who have assured us that they have either obtained your consent to share such information or that you have freely and publicly provided such information. We may use this information to make your experiences with us more personal and social or share and use it as described elsewhere in this Policy. 

Information we derive.

We may derive information or draw inferences about you based on the information we collect. For example, we may infer your location based on your IP address, or we may make inferences about your preferences and activities you may enjoy based on, among other things, your past location searches and other usage of CDTA.org. 

Cookies and Similar Technology 

We use certain cookies and similar technologies on the Navigator App to collect some of the data described above. A cookie is a small file consisting of letters and numbers that automatically collects certain information from you. This file uniquely identifies and recognizes your browser or device and transmits information back to the server. Depending on the cookie type, it may perform functions such as remembering your user preferences, improving the quality of your visit, remembering the name or address you entered during a visit, or allowing us and our analytics partners to collect information about the pages and screens you view, the links or ads you click, and other actions you take when using our Services. Some of this information may also be collected from your device or software, when the Services are running in the background, i.e., when they have been launched but are not actively used. 

You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. Most browsers will allow you to block or refuse cookies. However, you may need to manually adjust your preferences each time you visit a site. For more information, see the Help section of your browser. Please note that if you block certain cookies, some of the services and functionalities of our Site may not work. 

Embedded Content. The Navigator App contains embedded content (e.g., videos). Embedded content may place third party cookies on your device that track your online activity to enhance your experience or assess the success of their application. We have no direct control over the information these cookies collect, and you should refer to their privacy policy for additional information. 

Controlling cookies. You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. Most browsers will allow you to block or refuse cookies. However, you may need to manually adjust your preferences each time you visit an App. For more information, see the Help section of your browser. Please note that if you block certain cookies, some of the services and functionalities of our App may not work. 

IMPORTANT: By using the Navigator App, you consent to the processing of any personal information for the analytics purposes and other functions described above. 

Ticketing Service Users 

The Navigator App utilizes third party services for ticketing and to help you purchase passes. Those entities have their own terms, conditions, privacy policies, data collection, and use and disclosure practices which can be located at Privacy Policy . To process your requests, we will collect your name, billing address, and payment details such as your credit card number. Please see our Terms of Use at CDTA Terms & Conditions for additional information and terms related to these services. 

Transportation on Demand (TOD) Users 

In some cities, CDTA may offer transportation-on-demand services. If you elect to use such on-demand services through the Navigator App, you will be subject to additional terms and conditions as provided in the FLEX Terms of Service and FLEX Privacy Notice (the “FLEX Services”). 

To provide FLEX Services, CDTA may partner with third-party transport operators who offer on-demand transportation services (“FLEX Operators”). At your express direction, we will share certain personal information about you with these FLEX Operators. To use the FLEX Services, you will also be subject to the terms of carriage and privacy policies of the applicable FLEX Operators. We are not responsible for the privacy or other practices of third-party transport operators and cannot guarantee the security of personal information that you provide or is collected by such these operators. We encourage you to review the privacy policies and terms and conditions on those third-party transport operators. 

How We Use Your Personal Information 

In general, we use the personal information we collect only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, and as otherwise provided in this Policy. For example, we may use your personal information in the following ways: 

• To enable your use of the Navigator App and Services. 
• To determine and ascertain user accounts, verify user identity and enable users, to transfer or receive payments which may include calculation of the costs for such services.
• To provide information, products or services that you request including tracking your trips and aiding you with navigation and personalizing Services and content for you or connecting you with third party operators.
• To communicate with you, including sending messages about the availability of our App, Services, security, or other service-related issues. (You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.)
• For statistical and research purposes and to create and use aggregated anonymous data which is necessary to maintain, develop and improve our Services, including to determine navigation and routes, connect riders, and, at times, calculate costs of trips.
• For other everyday business purposes such as contract management, IT and App administration and security, payment processing, fulfillment, fraud prevention, corporate governance, reporting and legal compliance.
• To communicate with you in social media concerning our products and services.
• To carry out our obligations and enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
• To provide customer service and engage in quality control activities concerning our products and services.
• To use the information to create statistical, aggregated or anonymous data which may be used at our discretion for any purpose.
• For testing, research, analytics and product and service development.
• To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes; for public safety purposes.
• As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
• To engage in marketing and advertising activities. This includes sending users communications about features, promotions, sweepstakes, studies, surveys, news, updates and events. We may also send communications to our users to provide promotional information and participation in the promotions, as well as information regarding offers, discounts and promotions related to our services and the services of our collaboration partners.
• To allow us, and our selected third parties (as further detailed in this Privacy Policy), to provide you with personalized interest-based advertisements, which may be served either on the Services and/or on other websites, apps, and services, and to better understand your activity.
• We may also use the information we collect to send users communications about products and services offered by our partners, but we do not sell your email address, name, or other identifying information to, or share such information with, such partners or others for purposes of their own direct marketing or advertising, except as set forth in this Privacy Policy. 

Disclosure of Information. 

We may share your personal information for the reasons that we may use it as described in this Policy, which includes disclosing it to our affiliates and non-affiliated third parties, as we deem necessary to carry out those purposes. For example,

• Third Party Vendors. We may need to share this information with a member of our group partners, vendors, or service providers with your consent or as you direct; to manage the Navigator App and provide Services; for cloud storage hosting, database and server co-location services, data and cyber security services, payment processors, fraud detection and prevention services, App analytics tools including session replay records for usability and functionality monitoring and analysis, services for measuring our Services attribution and the efficacy of our publication and marketing efforts (such as Apps flyer), sending notices and communications, e-mail distribution and monitoring services, and our business, legal and financial advisors. These service providers may receive or otherwise have access to our users’ personal information, depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes.

We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data. 

• Third Party Services. We may offer you the option to link the Navigator App to third party services that may be useful to you, such as ride hailing services. Where we detect that an integration may be available (either because a third-party service attempts to link to CDTA.org, the Navigator App detects an installed service on the device which has an integration option or you request a particular integration), the Navigator App will ask for confirmation to connect the accounts. If you choose to connect the accounts, the Navigator App will ask for your permission to share data with the third-party service. You should only agree to connect accounts if you are comfortable with the third-party service receiving the data set out at the time of connecting the accounts. We are not responsible for the privacy or other practices of such third-party services and cannot guarantee the security of personal information that you provide or is collected by such. You can disconnect the Navigator App and the third-party service at any time and the Navigator App will cease sharing data with that service from the point of disconnection onwards.
• Governmental/Law Enforcement Agencies and Legal Requests or Duties. We may disclose or otherwise allow access to your personal information pursuant to a legal request, such as a subpoena, search warrant or court order, or otherwise in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud or other wrongdoing.
• Protecting Rights and Safety. We may also disclose your information to protect, establish or defend our interests and legal rights. We may share your personal information with others, with or without notice to you, if we have a good faith belief that this will help protect the rights, property or personal safety of CDTA, any of our users or any member of the public.
• Change in Control or Sale. We can share, sell, assign, or license your personal information in connection with certain business transactions, such as a sale, acquisitions, merger, or change in control, or in preparation for any of these events. In such cases, we will take appropriate steps under the circumstances and to the extent possible to ensure that the recipient agrees to provide privacy protections substantially similar to those established by this Policy. Any entity that acquires all or all of the CDTA’s assets will have the right to continue using your data consistent with this Policy or as otherwise agreed to by you. 

We may transfer, share or otherwise use anonymized, aggregated or non-personal information in our sole discretion and without the need for further approval. 

In no case will we sell or license your data to third parties, except as set forth above or as required or permitted by law. 

Safeguarding of Information

We employ reasonable and appropriate administrative, physical and technical measures designed to protect the security of personal information we collect from you. However, no system for safeguarding personal or other information is 100% secure and although we have taken steps to protect your personal information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal information. 

Your Choices Regarding Your Personal Information

You can always limit the information you provide to us, but if you choose not to provide certain requested information, you may be unable to access some of the services, offers, and content on CDTA.org. 

Links to Third Parties’ Apps and Third-Party Integrations

We provide links to websites or resources outside of the Navigator App for your informational purposes only. We may also provide links to third party integrations. Third party integrations are websites or platforms that synchronize with the Navigator App to provide you with additional functionality, tools, or services such as maps, sending requested information, etc. 

You acknowledge and agree we are not responsible for the availability of third-party apps, resources, or integrations and do not endorse and are not responsible or liable for any content, advertising, goods, services, or other materials on, available through, or provided by such apps, resources, or integrations. We are not responsible for the privacy or other practices of such apps, resources, or integrations and cannot guarantee the security of personal information that you provide, or is collected by, such apps. We encourage you to review the privacy policies and terms and conditions on those linked apps, resources, or integrations. 

Promotional and Surveys Messages 

In addition to communications that are an inherent part of our Services, occasionally we may use your contact information to notify you about new services and special opportunities or promotions we think you will find valuable. We may also contact you in connection with surveys we conduct with respect to our services or in connection with general public transportation issues, either on our own behalf or on behalf of our partners. We may contact you through e-mail, push notifications, through notices on the Services themselves or through any other contact methods available to us, including with the help of our service providers. 

If you do not wish to receive such promotional messages or calls, you may notify the Navigator App at any time by e-mailing us at Contact CDTA, or by following the “unsubscribe” or “stop” instructions contained in the promotional communications you receive. As for messages we send through push notifications, you may opt-out of receiving such notification by changing your device or App settings. 

Information on Children 

the Navigator Appis not directed to children as the products and services on this App are intended for persons 13 years of age and older. We do not knowingly collect, use or disclose any personal information from children. If we learn that personal information of persons less than 13 years-of-age has been collected through our App, we will take the appropriate steps to delete this information. 

Applicable law 

This Policy is governed by the internal substantive laws of New York without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Policy shall lie exclusively with the state and federal courts within New York. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect. 

Contact us 

If you have any questions about this Policy or how we collect and use your personal information, please contact us at Contact CDTA .

Contact Information

For questions regarding the Privacy Policy please contact: mobilesupport@cdta.org

Policy Reviewed: January 1, 2023