The privacy statement clarifies how personal data is processed by Møre and Romsdal County Authority through FRAM.
Fundamental requirements for processing personal data
Møre and Romsdal County Authority through FRAM is responsible for the storage and use of your personal data (data controller).
The information is processed in accordance with regulations in the Personal Data Act as well as industry norms for privacy protection and information security in electronic ticketing.
Regulations in force for the processing of personal data by Møre and Romsdal County Authority through FRAM
The Personal Data Act contains rules on how personal data collected is to be processed, including how it is to be secured, who is to have access and whether it can be disclosed to others.
Internal control in Møre and Romsdal County Authority
According to the Personal Data Regulations, all companies that process personal data are required to establish an internal control system. Møre and Romsdal County Authority has such an internal control system.
The objective for personal data processing through FRAM
The objective for processing personal data is to adhere to conditions in the agreement between Møre and Romsdal County Authority through FRAM and our users. These include being able to produce tickets, charge you the right price in relation to usage, print various tickets, replace any tickets or credit on registered cards that are lost, carry out refunds and more easily identify sources of error in complaints or other conditions that may occur in our service.
How we process personal data in the various services
The website and travel planner
This service provides customers (public transport passengers) with a channel to find travel information and for Møre and Romsdal County Authority through FRAM to inform, communicate and promote FRAM's public transport service. Møre and Romsdal County Authority, through FRAM via data processors, collects common visitor statistics for its website using the Monsido analysis tool. Information will be only be used in conjunction with the operation and further development of FRAM's website.
No information is sent or stored outside the EU, as Monsido operates in accordance with the current version of the EU's personal data protection regulation and also the law on the processing of personal data. Monsido has a self-developed statistics and analysis tool that anonymises IP addresses to ensure compliance with the GDPR. Any information that Monsido receives is subject to their guidelines for privacy protection.
For the travel planner Google Analytics is used for statistics. The statistics are anonymised.
All the information that is collected is anonymized and cannot be used to identify the user. The data processors for these services are ACOS AS, Entur and AtB.
The travelcard and online store
These services provide customers the opportunity to use an electronic ticket (travelcard) and purchase tickets on the internet (online store). Møre and Romsdal County Authority, through FRAM via the data processor, collects information and contact data from the registration form in the online store, information about the date the card was produced, the date of purchase for tickets and the travelcard number. This information is stored in a separate customer database with the data processor.
When using the travelcard and tickets on the card, information is stored such as the zones travelled and the stop your journey started at, the time and date of travelcard usage, which ticket you used and the travelcard number.
This information is collected in the database each time the travelcard is read by a card reader.
Personal information will not be used to provide you with customized marketing information without this being ticked off on the consent form in the online store.
Møre and Romsdal County Authority, through FRAM via the data processor, complies with information security requirements in the Personal Data Regulations chap. 2 and industry standards. Møre and Romsdal County Authority through FRAM may use travel information together with customer information if this is initiated by your use of the travelcard, usually through a complaint or other request made by you as a customer.
Møre and Romsdal County Authority, through FRAM via the data processor, will not use travel information together with customer information to produce statistics, to settle accounts with partner companies and normally not when troubleshooting. The data processor for this service is Entur and AtB.
The FRAM app
This service provides customers with the ability to plan journeys and purchase tickets for public transport on their mobile phones. Møre and Romsdal County Authority, through FRAM via the data processor, stores your phone number in the app to identify you with the profile. If Møre and Romsdal County Authority through FRAM wants to use the information registered for other purposes, for example, to send you advertisements or information beyond what is necessary to keep to the agreement, the County Authority will obtain your consent when entering into the agreement.
The app uses BugSnag to collect information about error situations and usage patterns, in order to more easily identify and correct errors as wells as defects. The information that is collected during error situations includes the status of the unit, unique identifiers of the unit, hardware and operating system of the unit, information related to the how the application is functioning and the location of the unit at the time the error occurred. For usage patterns, information is gathered on when and how long the app is in use.
Firebase Authentication is used for login and user information is stored on Firestore. In addition, Google Cloud Platform (GCP) is used.
Google Analytics is used for statistics. The statistics are anonymised.
All the information that is collected is anonymized and cannot be used to identify the user, but is shared with third parties who provide services in the app. The data processors for this service are AtB and Entur.
Contact form and e-mail
This service provides customers (public transport passengers) with a channel for written electronic communication with Møre and Romsdal County Authority through FRAM. In the first instance, it is staff in the FRAM Customer Service Centre who have access to the information you submit to Møre and Romsdal County Authority through FRAM using e-mail/the contact form. Information associated with the processing of inquires may be shared with the customer service desk (Pureservice; data processor) that Møre and Romsdal County Authority uses, and through e-mail with other staff in FRAM and others that Møre and Romsdal County Authority through FRAM have agreements with to process inquires (e.g. bus operators and shipowning companies). The information will only be used for the administration of inquires. Personal information will be deleted from the inquiry and the rest of the information will be anonymized after the inquiry is processed, so it can be used for statistics. This service is managed by Møre and Romsdal County Authority.
We request that you not send sensitive or confidential information using the form or email.
Travel guarantee form
This service provides customers (public transport passengers) with rights in cases where public transport falls short. In the first instance, it is staff in the FRAM Customer Service Centre who have access to the information you submit to Møre and Romsdal County Authority through FRAM using e-mail/the travel guarantee form. Information associated with the processing of the form may be shared with the customer service desk (Pureservice; data processor) that Møre and Romsdal County Authority uses, and through e-mail with other staff in FRAM and others that Møre and Romsdal County Authority through FRAM have agreements with to process forms (e.g. bus operators and shipowning companies). The information will only be used to process the form. Personal information will be deleted and the rest of the information will be anonymized after the form is processed. That way it can be used for statistics to improve public transport. This service is managed by Møre and Romsdal County Authority.
We request that you not send sensitive or confidential information using the form or email.
Refund form
This service provides customers (public transport passengers) with a channel to request a refund in writing for a ticket purchased from Møre and Romsdal County Authority through FRAM. In the first instance, it is staff in the FRAM Customer Service Centre who have access to the information you submit to Møre and Romsdal County Authority through FRAM using e-mail/the the refund form. Information associated with the processing of the refund may be shared with other staff in Møre and Romsdal County Authority to process the request by e-mail or through the customer service desk (Pureservice; data processor). The information will only be used for the administration of requests. Personal information will be deleted from the request and the rest of the information will be anonymized after the request is processed, so it can be used for statistics. This service is managed by Møre and Romsdal County Authority.
We request that you not send sensitive or confidential information using the form or email.
Telephone
This service provides customers (public transport passengers) with a channel to contact Møre and Romsdal County Authority through FRAM to get information about public transport over the phone. All calls made to telephone +47 71 28 01 00, as well as telephone 177 in Møre og Romsdal, will be answered by FRAM Customer Service Centre staff. When ringing, only the information required to answer or follow up inquires will be collected. This may be contact information, what the inquiry concerns as well as the date, time and the length of the call. After responding to the inquiry, personal data will be removed for use in statistics. The statistics are used to better manage inquires. This service is managed by Møre and Romsdal County Authority.
Letter
This service provides customers (public transport passengers) can contact contact Møre and Romsdal County Authority in a written, analog manner. All letters sent to FRAM Customer Service Centre by using the address; FRAM Kundesenter, Postboks 743, 6501 Kristiansund N, Norway, will be processed by staff at the customer service centre. By making contact the information you send will only be used for answering or processing the requests. It can be the name, address and other information you provide in the letter. Personal information will be deleted from the request and the rest of the information will be anonymized after the request is processed, so it can be used for statistics. This service is managed by Møre and Romsdal County Authority.
Disclosure of personal data
Møre and Romsdal County Authority through FRAM does not disclose personal data to anyone other than the data subject, unless there is a court order or authorized by law. Anonymous travel data can be used for statistical purposes and can thus be disclosed to others.
Consent
If Møre and Romsdal County Authority's through FRAM processing of personal data takes place on the basis of consent, this can be withdrawn at any time, and the county authority will then terminate the relevant processing of the personal data.
Access to own information
It is possible to request access to what personal data processing does. You can ask to see the information we have registered about you at any time.
Correction/deletion of information
If you find that the information about you is inaccurate or incomplete, you may require to have the information corrected/deleted. When the personal information is no longer needed, it will be deleted in accordance with the regulations.
Limited processing
In some situations, you can ask Møre and Romsdal County Authority through FRAM to limit the processing of information about you.
Protest against processing of personal data
If Møre and Romsdal County Authority through FRAM deals with information about you based on our tasks or on the basis of a weighing of interests, you have the right to protest against our processing of information about you.
Data portability
If Møre and Romsdal County Authority through FRAM processes information about you on the basis of consent or a contract, you can ask us to transfer information about you to you or to another processing manager.
Data Protection Officer
If you believe Møre and Romsdal County Authority through FRAM does not comply with the rules in the Personal Data Act, or have questions about our processing of personal information, you can contact our Data Protection Officer Interkommunalt Arkiv for Møre og Romsdal.
Complaint about our processing of personal data
You can also complain about Møre and Romsdal County Authority's through FRAM processing of personal data. You do this to Datatilsynet (Norwegian Data Protection Authority).
Contact
If you require access, correction/deletion of information or you have questions concerning the processing of personal data by Møre and Romsdal County Authority through FRAM, please contact the FRAM Customer Service Centre via the contact form on the website or send a letter to this postal address: FRAM Kundesenter, Postboks 743, 6501 Kristiansund N, Norway.