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Privacy policy for the metropolitan network app

Introduction

This document contains the privacy and protection policy for the personal data processed in the application and in the services offered by the RED digital platform – hereinafter also “RED App”, the “application” or the “platform” – depending on the source of digital infrastructure through which it is accessed: mobile application or browser, respectively, or, plain and simple “RED” to refer to any functionality of its services and regardless of the digital source of access developed by and for the Ministry of Transport and Telecommunications (“MTT”), Rol Único Tributario Nº 61.979.750-7, domiciled at Calle Amunátegui Nº 139, in the commune and city of Santiago, Metropolitan Region, Chile.

App RED is the application for metropolitan public transport that allows, among other functionalities, to plan transfers on buses, Metro and MetroTrenNos, as well as to load the bip! card, the bip! QR code and use the Automatic Recharge service.

For the operation of the RED digital platform and, in particular, of App RED, it is necessary to collect, process and communicate personal data of users, in the manner specified in this privacy policy.

In the processing of personal data, MTT undertakes to guarantee and protect the exercise of the rights to privacy and the protection of personal data, recognized in numeral 4 of article 19 of the Political Constitution, obliging itself to carry out the corresponding processing in accordance with the applicable regulations.

In short:

  • We process your personal data in our app.
  • If there are any changes to this policy, we will let you know.
  • We collect and process personal data such as your username, e-mail address, bip! card number, beep! QR, geographical location, among others.
  • All the processing that is carried out is intended for the application to work and provide the contracted service.
  • If we wanted to use the information for something else, we’re going to ask you.
  • We are not responsible for what other websites we may link to do.
  • We will take the necessary security measures to prevent data breaches.
  • You can exercise your rights in http://pocae.tstgo.cl

 

The same but drafted by lawyers:

  • About this policy

App RED provides multiple services and has various functionalities associated with the use of public transport on buses, Metro and MetroTren Nos (hereinafter, the “Services”), which are offered subject to the Terms and Conditions and the following Privacy Policy.

MTT reserves the right to modify and/or update this Privacy Policy at any time, unilaterally.

All changes will be posted on our website (the “Site”). You can consult the latest version of the Privacy Policy at any time in https://www.red.cl/política-de-privacidad-app-red-metropolitana

By continuing to use the Service, the RED App or the site after such changes and/or updates have been made, you are deemed to have accepted the new Privacy Policy.

MTT has the utmost interest in protecting the security of the personal data that will be collected and processed through the applications or the website, informing through this privacy policy about the treatment we make of them.

App RED may eventually include links to third-party websites or platforms, plug-ins and applications. By clicking on those links or enabling those connections, you may allow such third parties to collect or share your data. MTT does not control third-party websites and assumes no responsibility for their data protection policies. When you leave our website or app, we recommend that you read the personal data protection policy of each of the websites you visit, including the sites of the Freight Service Operators.

App RED collects non-personal information automatically and information that the user voluntarily submits.

  • Validity and modifications of this policy

MTT reserves the right to modify this privacy policy to adapt it to legal changes or jurisprudential decisions, as well as other modifications that may be introduced in applications or on the website. A record of previous privacy policies and their temporary validity will be available in this https://www.red.cl/política-de-privacidad-app-red-metropolitana

  • Data Controllers and Data Processing

App RED is operated from Santiago de Chile by MTT, a legal entity under public law, legally constituted in accordance with the laws of the Republic of Chile, whose legal representative is the one who holds the position of Undersecretary of Transport.

  • What data do we process and from whom

By installing App RED, the user will be informed of this policy and must expressly accept it in order to continue with its installation.

For the purposes of this Privacy Policy, it distinguishes between registered and unregistered users; “Registered user” is understood to be the person who, having installed App RED, creates a user account, uses true personal data and optionally associates them with a means of payment. Meanwhile, an “unregistered user” is a person who freely accesses the information available online without registering personal information.

Registered users accept the processing of personal data necessary for the provision of services at the time of using App RED, such as: username, email, telephone number, data of the associated means of payment, geographical location, and other derived information, as specified below.

Accordingly, with respect to registered and unregistered users, MTT may automatically collect and generate information from other areas of use of its services, such as service metadata, login data, device information, IP addresses, third-party data, and information obtained from cookies.

MTT may collect, use and share aggregated data, e.g. statistical or demographic data for any purpose. Aggregated data may be derived from your personal data, but under the law, it is not considered personal data as it does not directly or indirectly reveal your identity. We do not collect any special categories of personal data concerning you (including information about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, and your health, genetic, or biometric data). We do not collect any information about criminal convictions or crimes.

  • Purposes of data processing and anonymised processing

MTT will use your personal data for legitimate interests and purposes.

The personal data recorded by users through App RED are those necessary to provide the services and functionalities described above, by virtue of which App RED has been downloaded and installed on a device, or for the optimization of its operation, including data on the effective use of the services, which may incorporate sensitive personal data, such as the user’s geographical location or displacement.

The personal data provided may be integrated into automated databases in accordance with Law No. 19,628 on the Protection of Private Life and with the provisions of Article 1 of Law No. 21,083, which adopts security and control measures in means of payment for public passenger transport.

Personal data will also be processed for the purpose of offering products or services of and related to public transport on buses, Metro and MetroTren, and with other private means of transport with which the MTT may sign agreements, contracts or agreements. In addition, they may be processed in aggregate form for statistical purposes, in which case the identification data of the users will be duly anonymised.

By accepting this privacy policy, the user expressly accepts the processing of these data, which could eventually be considered sensitive personal data, such as those already indicated.

  • Special purposes and processing

In the case of using the Automatic Recharge functionality of a means of Access (bip! card or bip! QR), the user must carry out a transaction with a charging network operator through a digital acquirer or operator of means of payment (credit, debit or prepaid cards), by subscribing to a mandate. Neither MTT, nor its technology or charging network operators, will store any data relating to the means of payment chosen by the User. In this case, a user’s data will be stored and processed, including the identity card number, name, email, along with the data of the means of access that are registered in Automatic Recharge, this being a special purpose.

In the case of using the bip! QR, the user must create a transport account, using the Unique Key as an authentication factor, and then enroll in App RED, where they must generate a PIN for the use of the user. Then, to load the bip! QR: the user must make a transaction with a charging network operator through a digital acquirer or operator of means of payment (credit, debit or prepaid cards). Neither MTT nor its technology operators will store any data relating to the means of payment chosen by the user. In this case, the user’s data, including the identity card number, name and email, will be stored and processed, together with the data of the bip! QR.

  • Additional consent to data processing

In addition, your data may be processed in order to offer you information about products or services based on your profile or location, in which case the user expressly authorises the MTT to carry out the storage and processing.

  • How we process data

Aware of the need to promote maximum respect for the privacy and protection of personal data of App RED users, and in accordance with the legal regulations already indicated, the processing of personal data is governed by the following rules:

  • MTT will take appropriate measures to preserve the confidentiality of its users’ personal data. Users’ personal data will only be used for the fulfilment of the purposes indicated above.
  • MTT will not communicate or transfer to third parties the personal data of its users without their express consent, except for those communications or transfers necessary for the provision of the services, to our legal successor or in case of being legally required to do so, in which case it will proceed to deliver the requested information.
  • MTT may communicate to third parties statistical information prepared from the personal data of its users or visitors, without their express consent, when it is not possible to identify them individually from such data;
  • Data processing

MTT and its technology operators have adopted the necessary technical and organisational measures to prevent the loss, misuse, alteration, unauthorised access and theft of the personal data provided, taking into account the state of technology, the nature of the data and the risks to which they are exposed.

The personal data processed in App RED will be incorporated into an automated database and on which the necessary security measures have been implemented to protect personal data as well as to prevent alteration, loss, processing or unauthorized access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed.

  • Exercise of rights by users and contact

The owner of the personal data may at any time exercise the rights granted by Law No. 19,628 and its subsequent amendments. Specifically, you will be able to:

  • Request information about what personal data is recorded;
  • Request that your personal data be modified when it is not correct or up-to-date;
  • Request the deletion or cancellation of the data provided when you wish, as long as there is no other legal basis for its processing or affect the normal provision of services.
  • Object to your personal data being used for statistical purposes.

To exercise their rights, the user must contact the MTT Parts Office or on the http://pocae.tstgo.cl site clearly indicating their request and the corresponding user identifiers. Additional information may be requested from the applicant.

Version 1.0, January 22, 2022

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