Compliance with Children’s Online Privacy Protection Act
Valley Metro complies with the requirements of the Children’s Online Privacy Protection Act of 1998 (COPPA) and the FTC’s Rule interpreting COPPA (16 CFR §512). The Service is not directed to children and we do not knowingly collect any personal information on the Service from anyone under the age of 13 years. If we learn that a child under 13 years of age has provided us with personal information, we will delete this information from our databases. By using the Service, you represent that you are 13 years of age or older and you agree and consent to the information collection and use practices described herein.
Changes to this Policy
Personal Identifying Information (“PII”): PII generally means information that specifically identifies an individual (including, but not limited to, a user's name, address, telephone number, email address, geolocation, credit card or other account number) or information that is associated with an identifiable person (including, but not limited to, device information, demographic information or information about a person's activities when such information is linked to PII). PII does not include "aggregate" information, which is data Valley Metro collects about the use or users of the Service, from which any personal information has been removed.
Personal Identifying Information Valley Metro Collects
Valley Metro collects PII in connection with registration of the Service and purchase of mobile passes for transit service. In this regard, you will be asked to provide contact information (including, but not limited to, a name, address, email address, phone number, device type/model number and billing address) and financial information (including, but not limited to, a credit card number, expiration date and security code). This information is used for billing purposes and to complete orders. If Valley Metro has trouble processing an order, the information may be used to contact you. Information that you provide may also be aggregated and used for purposes of analysis and improvement of the Service once it is stripped of your personal information and it may then be shared with others.
Additionally, the Service may collect your Global Positioning System (GPS) location or your device’s unique identifier for the purposes of trip planning, security incident reporting, ticket validation, route planning. It might also collect information regarding the type of mobile device you are using or the version of the operating system your computer or device is running. This information may be maintained for purposes of technical support services. This information may also be aggregated and used for purposes of analysis and improvement of the Service once it is stripped of your personal information and it may then be shared with others.
Valley Metro may conduct online and other surveys that customers may elect to complete on a voluntary basis. Information collected through the surveys will only be used for the purpose of marketing or improving the Service unless you expressly agree otherwise.
When you use the Service, some information is also automatically collected through the use of log files, like your mobile device’s Internet Protocol (IP) address, operating system and/or your activity on the Service, which may include the time and geolocation data of pass purchases and activations, fare type purchased and pass expiration data. We use this information to analyze trends, administer the Service, improve customer service, diagnose problems, track user movement and gather broad demographic information for aggregate use.
Usage and Disclosure
To send periodic emails
The email address you provide may be used to send you information and updates, if any, in addition to occasional Valley Metro news, updates, related product or service information, etc. You will be given an opportunity to opt out of such emails.
To respond to your requests, provide our service, process payments
Valley Metro does not sell, rent, share, or disclose any personal information to others in ways different from what is disclosed in this Policy without first obtaining your consent, although we may provide aggregate information or other non-personal information to independent third-parties without your authorization.
With Third Parties
Valley Metro will not sell or provide any PII or aggregate information to other third parties for the purpose of targeted advertising, marketing or sales.
For compliance purposes
Valley Metro may disclose PII in connection with legal proceedings (such as false reimbursement claims made by Valley Metro patrons); or contemplated legal proceedings, that directly relate to such information; or in response to a subpoena or court order specifically requiring production of such information. And, we may disclose PII to protect our customers’ rights, property or safety; to protect our customers from fraudulent, abusive, or unlawful use of the Service; or in cases involving threat of imminent harm to you or others, in order to prevent or mitigate the threat. In any such case, we will seek to limit the scope of the disclosure and restrict such disclosures only to appropriate authorities and will disclose only such personal information as is reasonably required to fulfill the purpose of the disclosure. In addition, unless instructed otherwise by a court or other authority with appropriate jurisdiction, we will undertake reasonable efforts to notify you of such disclosure or request for disclosure, and to provide you with this notice as far in advance of the disclosure as is reasonably practicable.
WARNING: Valley Metro 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.
Retention and Security [of the information]
Public Records Law
Valley Metro is a public agency and is subject to public records laws. Personal information provided by you may be subject to disclosure pursuant to public records laws unless the information sought is considered confidential or protected from public disclosure under certain statutory requirements. You should not provide personal information if you are concerned about disclosure of your information under those laws.
Protection of Your Information
Valley Metro endeavors to secure your personal information from unauthorized access, use or disclosure by putting into place physical, electronic and managerial procedures to safeguard the information we collect through the Service. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable. Due to the nature of Internet communications and evolving technologies, we cannot provide and disclaim assurance that the information you provide to us will remain free from loss, misuse, or alteration by third parties, who, despite our efforts, obtain unauthorized access. If we detect an intrusion or other unauthorized access to or use of personal information, we will use commercially reasonable efforts to notify the individual(s) whose personal information has been compromised. You should also note that email is not secure and you should not send any confidential or sensitive information to us via an unsecured email.
Choice of Law and Jurisdiction
This Policy is executed, delivered and will be performed in the State of Arizona, and the substantive law of Arizona (without reference to choice-of-law principles) governs its interpretation and enforcement. Any action brought to interpret or enforce any provisions of this Policy, or otherwise relating to or arising from this Policy, shall be commenced and maintained in the Superior Court of the State of Arizona in Maricopa County.
Correct and Update Your Personal Information or Obtain Additional Information
If you have any questions or comments about this Policy or the practices relating to the Service, or you wish to verify, correct or delete any personal information we have collected, please email us at email@example.com or contact us at Valley Metro, 101 N. 1st Ave., Suite 1300, Phoenix, AZ 85003, telephone 602.253.5000.