This privacy policy explains how personal data is being collected from the end user (henceforth referred to as the “Customer” or “Data Subject”) and processed in the Skanpark system.
The purpose of processing personal data for the Skanpark application:
The provider og Skanpark, WTW AS (“Service provider”) and the companies providing their parking services via Skanpark (“Parking providers”), have a shared responsibility as Data Controllers for the personal data being processed in the Skanpark system.
The Service provider is the Data Controller for all information being stored in the Customers (“The Data Subjects”) user profile. The processing of the information in the Customers user profile is necessary for the performance of the contract between WTW AS and the Data Subject, entered into by the Data subject when accepting the terms of use prior to registering in the Skanpark app.
The Parking Providers determine the purposes and means of processing the Personal Data connected to each purchase, hence the Parking Provider acts as the Data Controller for all data being processed in direct connection with offering and purchasing their services. The Service Provider, WTW AS, is in this case the Data Processor, processing your personal information on behalf of the Data Controller based on a separate data processing agreement; ref. section 6.
The Skanpark app is an optional service. If you choose not to use it, you may purchase parking permits via alternative channels.
Fulfilling the agreement
We need to process your personal data in order for you to use the app and fulfil the service level agreement you enter into when accepting the terms of use, hence fulfilling the purpose of the Skanpark service.
Before registering in the app you will be informed that your personal data will be processed in accordance with this privacy policy.
The app processes the following general personal information about you:
Mobile number and password: This information must be registered to your user profile to enable us to offer a service with secure and verified log-in. Your mobile number is required to ensure that you can access your active season tickets or receipts for past purchases. Your mobile number serves as your unique user ID when using the app and is the only personal information required for your user profile.
Email address: Adding your email address to your user profile is optional. We only need your email address if you want to have your receipts emailed to you. You can delete or amend this information at any time under “Settings” in the app.
Sales documents: All sales documents are stored in accordance with the Norwegian Bookkeeping Act. The travel information associated with your ticket purchase is only retrieved when there is an error or other incident that generates an absolute need to look more closely at all the details of your specific purchase. It will also be retrieved when there is an initiative taken by the registrant, e.g. when submitting a complaint or other query.
Payment methods:
Credit and debit cards: When you pay with a credit or debit card, a connection with the payment service provider is created to allow you to register your card in the Skanpark without storing your full card details in the app.
If you choose to save one or more cards to your profile, only the payment service provider has access to your full card details.
The app will only store the first six and last four digits of the card number along with the expiry date.
This information is essential in order to allow you to recognise your card, to enable us to generate the information that should be included on your receipt, and to allow us to respond efficiently to any refund entitlements.
Technical information: When you use Skanpark, your IP address, the time of your query, info about your mobile phone, the version number and mobile platform for the app, including your chosen language, will be stored in the application log. This information is required in order for the app to work on your particular platform/mobile and is stored to ensure that the service works as intended. It also provides us with necessary information to help resolve any faults. We do not use analytical tools (e.g. Google Analytics) that identify and log the behaviours of identifiable users. The only analytical function is crash reporting using the HockeyApp, which provides completely anonymous crash reports and helps us swiftly rectify the problem if the app were to crash.
Location data: When you grant the app access to your phone's GPS, the positioning data will only be used locally on your handset. No positioning data logged in the app is shared with the backend system. The only travel information to be processed is the information about the parking zone required to document the purchase and work out the correct price. The data of the chosen parking zone is associated with your purchase and processed together with the rest of the sales documentation.
The Service Provider and the Parking Providers collects information about the ticket purchases made via Skanpark. Information used for statistical purposes is de-identified and therefore cannot be linked to you personally. Anonymized statistics are used to improve and develop new services for our customers. Examples of what the statistics can tell us include how many people park in different zones, the number of ticket purchases for each Parking Provider, and how many people purchase tickets via the mobile platform (Android or iOS). The travel information associated with your ticket purchase will not be used in conjunction with personal data in order to generate statistics.
WTW AS, the supplier of Skanpark, acts as data processor on behalf of the Parking providers. A data processing agreement has been entered into by WTW AS and each Parking Provider. The data processing agreement ensures that WTW processes all personal data in accordance with the provisions given by the Parking Providers.
The Parking Providers and WTW AS is obliged to process personal data in accordance with Norwegian law, including the Personal Data Act, relevant accounting legislation and the industry standard for e-ticketing.
Skanpark will not share personal information of the Data Subjects with systems other than those belonging to WTW AS, the Parking Providers and the payment service provider(s) you choose to use.
All personal data processed by Skanpark is uploaded or generated by you. No information is obtained from external registers or services.
The processed personal data is only accessible on a need-to-know basis to authorised personnel with the Parking Providers and their sub-contractors, including parking enforcement officers, payment service providers, WTW AS and the server operator.
No information will be disclosed to any third parties either in Norway or abroad not mentioned in this privacy policy.
You should be informed on how your personal data is processed. This privacy policy can therefore be accessed from the app's menu at any time. As a user of Skanpark, you have the right to:
All data is stored in WTW's server center in Norway. The servers are operated by personnel in Norway. All data stored in the back end system is kept in accordance with prevailing legislation. Your personal data will not be stored for longer than is necessary to fulfil the purposes for which the app is intended. Both the data controller and the app developer, WTW AS, have put in place information security measures and internal procedures to ensure that no personal data goes astray or is used for purposes other than those described in this privacy policy.
Both the Service Provider, The Parking Providers and their data processors observe the principles of privacy by design and privacy by default. This implies that your personal data should not be stored for longer than is necessary in order to fulfil the purpose of the service.
Profile information: Your profile information will be stored for as long as you remain an active customer. The profile of inactive Customers will be deleted after 3 years of inactivity. You may request your user profile to be deleted from the Skanpark at any time. You must then register again if you wish to use the service at a later date. Your mobile number will be verified when logging in for the first time on a new device. If you have entered other personal data in the app, you may edit this data in your profile at any time under “Settings”.
Transaction history and sales documents: All sales documents are stored for 5 years from the end of the financial year in line with prevailing accounting legislation, including the Bookkeeping Act and associated regulations. Receipts for your most recent purchases can always be accessed through the app. After 20 months the sales documents will be archived and anonymised so that it is no longer possible for you or anyone with authorised access to Skanpark to retrieve information directly linked to the user.
Technical information and application log: Parts of the application log are stored for an appropriate period of time to ensure that the service works as intended and that customers receive the service they are entitled to. In the event of a complaint about a fault with service, for instance, the relevant application log may be kept for longer to enable it to monitor the time period in question and complete the processing of the complaint.
All communication between the solution and the applications on the end user's handsets is encrypted. All access to the online system is encrypted. All internal data transfers between the various components in the system are encrypted. Data may only be retrieved via APIs that have been encrypted and made secure with access keys. Access to the data via the Parking Provider's interface is role-based and personal with incident logging to ensure traceability. The administration interface for the solution has been designed with different access levels so that individuals who require access through the Parking Provider or WTW will be able to access only the amount of information they need.
If you require further information about how your personal data is processed in relation to your purchase history, please contact the Parking Provider in question. You can find an overview of the parking providers and their contact information on Skanpark.com. If you require further information on how your personal data is being processed in the Skanpark system, please contact post@skanpark.com.
Please note that this privacy policy will be updated as and when changes are made to the system. The latest version of the privacy policy is always available in the Skanpark app, allowing you to keep up-to-date with how your personal data is processed.
| Published: | 14.09.2018 |
| Updated: | 14.09.2018 |