COTA//Plus App Privacy Policy

Last modified: September 9, 2021

1. Introduction

Central Ohio Transit Authority (“COTA”, “us” or “we”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (“Policy”). This Policy describes:

• The types of information we may collect or that you may provide when you download, access, or use the COTA Plus App (the “App”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies only to information we collect in this App and in email, text, and other electronic communications sent through or in connection with this App.

This policy DOES NOT apply to information that:

• We collect offline or on any other COTA apps or websites, including websites you may access through this App.
• You provide to or is collected by any third party (see Third-Party Information Collection).

Our websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this Policy means you accept those changes, so please check the Policy periodically for updates.

2. Children Under the Age of 13

The App is not intended for children under 13 years of age without parental consent, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at:

William J. Lhota Building
c/o Customer Service
33 N. High St.
Columbus, Ohio 43215
Requests@cota.com
Customer Service: (614) 228-1776
TTY/TTD: (614) 275-5878

3. Information We Collect and How We Collect It

We collect information from and about users of our App:

• Directly from you when you provide it to us.
• Automatically when you use the App.
• From publicly available sources or other third-party sources.

When you download, register with, or use this App, we may collect, use, store and transfer several types of information from and about you which we have grouped together as follows:

• Identity Informationincludes first name, maiden name, last name, username or similar identifier.
• Contact Informationincludes billing address, email address and telephone numbers.
• Financial Informationincludes payment card details.
• Transaction Informationincludes details about payments from you, other details about your order, date and time the service was provided, amount charged, and distance traveled.
• Device Informationincludes device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, mobile network, time zone setting and location, and other technology on the devices you use to access the App.
• Profile Information includes your username and password, orders made by you, your interests, and preferences.
• Usage Informationincludes information about how you use the App.
• Communications Information includes your communication preferences, including marketing from us.

Information by which you may be personally identified and any other identifier by which you may be contacted online or offline is considered “Personal Information.”

Information You Provide to Us 

The information that you provide includes:

• Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App, subscribing to our service, posting material, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App.
• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through the App and of the fulfillment of your service request. You may be required to provide financial information before placing an order through the App.
• Your search queries on the App.

Automatic Information Collection

When you download, access, and use the App, it may use technology to automatically collect:

• Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.
• Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
• Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
• Location Information. Depending on the App’s settings or device permissions, this App collects real-time information about the location of your device as determined through data such as GPS, IP address and Wi-Fi. We collect location information when the App is running in the foreground. We also collect this information when the App is running in the background of your device if this collection is enabled through your app settings or device permissions.

We also may use these technologies to collect information about your activities over time and across third-party apps or other online services (behavioral tracking).

Information Collection Technologies

The technologies we use for automatic information collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.
• Web Beacons. Pages of the App may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit COTA, for example, to count users who have visited those pages and for other related App statistics (for example, recording the popularity of certain App content and verifying system and server integrity).
  

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties include:

• Advertisers, ad networks, and ad servers.
• Analytics companies.
• Your mobile device manufacturer.
• Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use this App. We do not control these third parties’ tracking technologies or how they may be used. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites.

4. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

• Provide you with the App and its contents, and any other information, products or services that you request from us.
• Verify your identity.
• Process or facilitate payment for our services.
• Give you notices about your account.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when App updates are available, and of changes to any products or services we offer or provide though it.
• Investigate and address any customer services concerns and direct your questions to the appropriate customer support person.
• Fulfill any other purpose for which you provide it.

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our App according to your individual interests.
• Speed up your searches.
• Recognize you when you use the App.
• Solve operational problems and troubleshoot software bugs, conduct testing and research, and perform other internal operations necessary to provide our services.

5. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:

• To our subsidiaries and affiliates.
• To contractors, service providers, cloud storage providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of COTA’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by COTA about our App users is among the assets transferred.
• To research partners, including those performing surveys or research projects in partnership with COTA or on COTA’s behalf.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including the App’s Terms of Use and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of COTA, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6. Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
• Location Information. You may use the App without enabling COTA to collect your location information, however, this may affect the functionality of the App.

7. Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the App and visiting your account profile page.

You may send us an email at Requests@cota.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

8. Device Permissions

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. For example, the iOS platform will alert you the first time the COTA App wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the COTA App seeks before you first use the App, and your use of the App constitutes your consent. 

9. Data Security

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

10. Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated

The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting this privacy policy to check for any changes.

11. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

William J. Lhota Building
c/o Customer Service
33 N. High St.
Columbus, Ohio 43215
Requests@cota.com
Customer Service: (614) 228-1776
TTY/TTD: (614) 275-5878