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Privacy Policy

Privacy Policy

1. Introduction
Transvision BV (hereinafter: Transvision) considers it essential that the personal data of its customers and relations are processed and secured with the greatest possible care. Transvision complies in all cases with the requirements of the General Data Protection Regulation (GDPR) and the EU Traveler Regulation 1371/2007.
Transvision is the intermediary between national clients and the local transport offer. Examples of this are the collaborations with almost 300 taxi and bus companies throughout the Netherlands.
The implementation of Valys for the Ministry of Health, Welfare and Sport is fully entrusted to Transvision, whereby public transport (OV) in combination with the taxi is part of the travel options. Transvision also provides train replacement bus transport for the NS in the eastern part of the Netherlands. In addition, Transvision carries out transport on behalf of various mobility cards, traffic emergency services and health insurers, among others.
When using online services, please note that your username and password are always strictly personal. Do not provide it to third parties (in any form). This may harm your privacy.
When you sign up for one of our services, we ask you to provide personal information. This data is only used to be able to perform the service. We will not combine this information with other personal information that we may have.

1.1 Structure of the privacy statement
Information about Transvision can be found in the introduction to this document. In some cases, Transvision as an organization is the Data Controller for the processing of your data. In other cases, Transvision carries out processing for a client. In that case, the client is the Controller and Transvision Processor. In the paragraphs below we describe which personal data we process and for what purposes we do this. We also explain for which services we process the data and on what basis we are allowed to do this. The sharing of data with other parties is discussed, as well as the processing of personal data outside the EU. The security of personal data is discussed together with the handling of the retention periods.

1.2 What is personal data?
Personal data is all data that can be traced back to an identifiable natural person. Examples of this are your name, address, telephone number and account number.

1.3 Is it necessary to provide personal data?
For the complete execution of your trip it is necessary that we have your personal data. In this way it is possible, for example, to inform the taxi driver which journey must be carried out and we can make declarations.
In addition, we have to keep customers informed for Valys about, among other things, the Personal Kilometer Budget. It is also possible that we use your data for a satisfaction survey. We are not allowed to use your personal data, which we have received for booking a ride, for sending the newsletter. This is because you have provided the personal data for a purpose other than sending a newsletter. To make it possible to keep you informed, we ask you to give separate permission for sending the newsletter. This consent is voluntary.

1.4 Data collected from others?
Transvision sometimes receives your data from a third party. For example, when we book the rides for one of our clients. In addition, we may receive personal data from, for example, the health insurance company.

1.5 Who is the controller for the processing of personal data?
Transvision is in some cases the legal Controller for the processing of personal data. This is the case, for example, for the processing of personal data of our own employees. In addition, we are Data Controller for our additional products and services such as the newsletter.
In many cases, Transvision is not responsible for the processing of your personal data on the basis of the law. In this case, Transvision is the Processor. This means that another organisation, for example a client of Seated Patient Transport, is the party that is responsible on the basis of the law. This client has asked Transvision for support in providing the service.
This distinction is relevant to you if you want to contact us or make use of one or more customer rights. If we are the Data Controller, you can contact us. If it concerns a product of one of our clients in the context of the Chain Services, Seated Patient Transport, Business Transport, Target Group Transport or a client for Transvision Passenger Transport, you can contact these specific clients.
If you are not sure who to turn to, it is always possible to ask us. We will help you in that case. You can contact Ms. K. Sterk via the e-mail address compliance@transvision.nl or the number 010 30 35 600.

1.6 Who is the Privacy Officer?
Transvision has chosen a Compliance & Privacy Officer to fulfill its duties in the context of privacy. This position is held by Ms K. Sterk. She can be reached via the e-mail address compliance@transvision.nl or the number 010 30 35 600.
What personal data do we use for our services and products?
Personal data can be divided into categories for convenience. The following categories of personal data are used within Transvision.

2.1 (category 1) Name and contact details:
These are your first and last name, address, date of birth, e-mail address and telephone numbers. This can also be information about your contact person.

2.2 (category 2) Payment details:
This is your account number and the ascription.

2.3 (category 3) ID and photo:
This is the (partial) copy of the proof of identity and possibly the extra passport photo.

2.4 (category 4) Unique numbers and signatures:
These are your signature, citizen service number (BSN) and the numbers we create for applying for a pass. These can also be card numbers or client numbers.

2.5 (category 5) Medical data:
These are data about, for example, a specific handicap that makes a specific means of transport necessary. This includes a wheelchair, assistance dog or walker.
This is also data for Valys that you can provide yourself for your traveler profile. This concerns data about, for example, your walking speed or the number of transfers you can make when traveling by train. If you do not provide this information, an average traveler profile will be created. This can be further personalized based on your travel details. You can always view and adjust your traveler profile yourself.

2.6 (category 6) Location data:
This is data about your location such as when you make which trips with Transvision.

3. For what purposes do we use your data?
We use the aforementioned personal data for various purposes. One of our goals is to provide transport for which we take various steps. Think, for example, of transport such as Valys, the Chain Services, Seated Patient Transport, Business Transport, Target Group Transport or Transvision Passenger Transport. For transport, we may have to register you in our system. We process your pass request for Valys. We also process data when booking rides and providing customer service. Phone calls are recorded for quality purposes. You will be informed about this when you contact Transvision by telephone. The conversations are kept for a period of 3 months. It is also possible that a legal dispute arises in which we have to process personal data.

4. On what basis do we use your data?
Transvision only processes personal data based on one of the 6 legal bases. The legal basis is the basis that is necessary to process personal data. For example, consider the ‘agreement’ basis that we use when you have a Valys card. Another example is the ‘consent’ basis that we use for our newsletter.

5. Existence of automated individual decision-making
Transvision does not use automated individual decision-making, because this is not necessary for our services.

6. Do we share the data with other parties?
Transvision shares personal data with organizations that are involved in the execution of the agreement. Think, for example, of the clients we have or the carriers who carry out the journeys.
Transvision ensures that data exchange with third parties falls within the legal framework. This means, among other things, that we make agreements with third parties to ensure that they take appropriate organizational and technical measures to ensure customers that privacy is guaranteed. For this, Transvision concludes Processor Agreements with these third parties. We will never exchange personal data if this is not allowed. We think it is important to be transparent about this.
In addition, Transvision uses a number of suppliers, such as your taxi driver. We ensure that the suppliers we choose have sufficient guarantees in the context of privacy. Transvision has made agreements with these suppliers.
When you apply for a Valys Reispas (an OV chip card with which you can travel by public transport and by taxi), Transvision provides personal data to Trans Link Systems BV (hereinafter: Translink). This concerns your Valys customer number, name and address details, passport photo, date of birth, gender, telephone number and email address. The provision of personal data to Translink is necessary for the production of the Valys Reispas in the form of an OV chip card and for the management of the OV chip card by Translink. Translink is responsible for creating, issuing and functioning of the OV-chipkaart and handling the transactions you do with the OV-chipkaart. Translink itself is responsible for the processing of personal data for the OV chip card. For more information, see: www.ov-chipkaart.nl.
The provision of personal data by Transvision to Translink for the Valys Reispas takes place on the basis of the implementation agreement.
When you apply for the Valys Travel Pass, you agree to the terms and conditions Valys/Transvision and the General Terms and Conditions of the OV-chipkaart.
Sometimes Transvision is obliged to provide personal data to investigative authorities on the basis of legal obligations. We only do this if we are specifically requested to do so.

7. Will your data be transferred outside the EU?
Transvision’s starting point is to only process personal data within the EU. Since the privacy regulation applies within the EU, an appropriate level of protection can in principle always be ensured.

8. How do we secure your data?
Because the security of personal data is very important, Transvision has drawn up an Information Security Management System that is certified according to ISO 27001 and NEN 7510 standards. As made clear under Article 7 of this privacy statement, in principle we only process personal data within the EU. Transvision has various measures in place to ensure that the personal data cannot be misused or otherwise end up in the hands of the wrong person. In addition to technical measures, organizational measures are also taken. An example of these measures is training our employees in the field of privacy awareness. We ensure that, if we forward your personal data to other organizations such as the processors, these organizations hold the same standards. Processor Agreements are concluded for this.

9. How long do we keep your data?
We keep the personal data that you process for as long as this is necessary for the product or service. Sometimes a statutory retention period is prescribed for this, such as the administration for the tax authorities. If there is no statutory retention period, we use a self-defined retention period. We ensure that we do not store personal data longer than necessary.

10. What rights do you have based on the processing of personal data?
Transvision believes it is important that the customer can properly exercise its rights under the law. That is why it is very easy to contact us via the website, among other things. Under the heading ‘contact’ you can fill in the web form so that we can help you further. You can also contact our Compliance and Privacy Officer Ms. K. Sterk via the e-mail address compliance@transvision.nl or the number 010 30 35 600.
You can use the following rights:

        • The right of access: you have the right to inspect which personal data we process about you;
        • The right of correction: if the personal data that we process about you is incorrect, you have the right to have it corrected;
        • The right to erasure: if we no longer need your personal data for the purpose for which we obtained it, you have the right to ask us to delete it. There are a number of exceptions to this, such as our obligation to keep certain data for the tax authorities, among others;
        • The right to restriction: during the period that we are in the process of determining whether your data needs to be rectified, determining the unlawfulness of data processing, determining whether data should be deleted or you have objected to the processing, you have the right to request the restriction of processing;
        • The right to data portability: At your request, we must transfer any personal data we hold about you to you or another organization of your choice. You can only exercise this right if the data is processed on the basis of permission or agreement;
        • The right to object: if we process data on the basis of legitimate interest or public interest, it is possible to object, after which a weighing of interests will follow. In the case of direct marketing, you always have the right to object.

    As mentioned under 1.5 of this statement, you can contact Transvision to exercise your rights if Transvision is the Controller. If you have a question or want to exercise a right when it comes to a product from one of our clients, please contact these specific clients.
    If you are not sure who to turn to, it is always possible to ask us. We will help you in that case. This can be done with Ms K. Sterk via the e-mail address compliance@transvision.nl or the number 010 30 35 600.

    11. Cookie Policy
    Transvision does not use cookies that require consent. The website uses functional cookies to optimize the website. These types of cookies are such a limited invasion of privacy that privacy legislation does not apply.
    In addition, the website uses Google Analytics cookies. Transvision has set these cookies in a privacy-friendly manner according to the manual of the Dutch Data Protection Authority. This means that Transvision:

12. Submit a complaint to the competent authority: Dutch Data Protection Authority
Transvision believes it is important to have satisfied customers. Even though we do everything we can to achieve this, it is possible that you as a customer are not satisfied. It is possible to submit a complaint to the Dutch Data Protection Authority if it concerns the protection of personal data. This can be done via: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons.

13. Change of privacy statement
Since we always want to improve our services and website, the privacy statement may be amended from time to time. We publish the modified versions on the website and include a timestamp.

14. How can you contact us?
If you have any questions, complaints or comments, please contact our Compliance & Privacy Officer Ms. K. Sterk via the e-mail address compliance@transvision.nl or the number 010 30 35 600.

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