Privacy Statement
Effective March 25th 2024
Chrono is a free iOS or Android application (“Application”), developed by the Autorité régionale de transport métropolitain (“ARTM,” “we,” “us” or “our”), which allows you to use the ARTM’s exclusive software services to find information on public transit services in the Greater Montreal metropolitan area, plan your trips and use various associated features (“Services”). The term Application also extends to any updates or upgrades to the Application that the ARTM may provide to you or release, or that you may obtain after the date on which you obtained your initial copy of the Application, insofar as such items are not accompanied by a separate privacy statement.
This Privacy Statement (“Statement”) describes how the ARTM uses, discloses and retains personal information collected in connection with your use of the Application. Personal information collected and retained by the ARTM through the Application is subject to the Act respecting Access to documents held by public bodies and the Protection of personal information (CQLR, c. A-2.1).
The Statement does not apply to personal information collected by the ARTM other than in connection with the operation of the Application. To learn more about the ARTM’s practices regarding the treatment of personal information in the context of its other activities, please consult the ARTM’s Privacy Statement (in French only) at https://www.artm.quebec/enonce-confidentialite/.
This Statement does not apply to the processing of personal information by third parties, including third-party websites or services that you choose to access through the Application or the Services or links contained therein (“Third-Party Websites”), or by any person who is not managed or employed by the ARTM. While we aim to facilitate access to or provide links to only those Third-Party Websites that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Websites. We encourage you to carefully review the privacy policies of any Third-Party Website you access. We have named and provided links to the most important of these Third-Party Websites later in this Statement, insofar as is feasible and appropriate.
What constitutes personal information?
Personal information is any information about a natural person that can be used to identify them, separately or in combination with other information. This may include, for example, a person’s name, email address, contact information and any information of a similar nature provided to the ARTM. Information that is rendered anonymous and cannot be associated with a natural person is not considered personal information when it is at all times reasonable to expect that it will irreversibly no longer allow the person to be identified directly or indirectly.
What type of personal information do we collect?
The ARTM may collect the following personal information when you download, access or use the Application:
- Account information. When you create an account on the Application to be able to use certain functions of the Services, we collect your email address and login details. This account information is used to manage your account, verify your login information for aspects of Services requiring an account, and communicate information about your account to you. Provision of this account information is strictly voluntary; however, if you do not provide it, certain functions of the Services may not be accessible.
- Location information. When you enable geolocation functions, we collect, but do not store, your location information to allow you to find information on nearby public transit services and to help you plan your trips. The submission of this location information is strictly voluntary; however, the Services may not provide the best results without this information. Please see How the Application accesses your device (“authorizations”) below for more information on the Application’s location functions.
- Information about your use of the Application. We may collect certain information about your transit preferences, such as your frequently used routes and favourite stops, if you voluntarily choose to save your schedule and address favourites, in order to improve our Services and generate statistics about demand for public transit.
- Payment information. We may collect certain information pertaining to payment, such as your payment details, and, without storing it, forward it to a service provider, in order to allow you to purchase transit fares via the Application.
- Information related to a customer service request. When you communicate or interact with us, we collect information that you voluntarily provide, including information submitted via the Customer Service Form.
Why does the ARTM need this personal information and how does it obtain your consent?
The collection of certain personal information described in this Statement may be mandatory in order for us to operate Chrono, respond to your requests and/or offer the Services. Therefore, the ARTM may not be able to provide you with certain Services if you choose not to disclose the necessary personal information to the ARTM or if you withdraw your consent to the use or disclosure of such information.
By providing us with your personal information when you install or use the Application, you consent to its collection, use and disclosure in accordance with this Statement and as permitted or required by law. You may also have explicitly consented to the processing of your personal information in accordance with this Statement following your installation of the Application and launch of the Application for the first time. If you have downloaded the Application and do not agree to your personal information being processed in accordance with this Statement, you must delete the Application from your device.
Please refer to the What are your choices regarding the use of your personal information? section for information on how you can exercise your right to withdraw consent to certain uses or disclosures of your personal information.
For what purposes does the ARTM use your personal information?
Personal information collected via the Application is used for the following purposes:
- To manage the Application and allow you to access the Services;
- To confirm your identity and help you reset your password or any other method of connecting to your Chrono account;
- To track your location in order to provide you with certain Services, when you have enabled this function;
- To provide you with information about the Application and its features;
- To process your payment for transit fares;
- To send you marketing communications about other services offered by the ARTM or its partners, when you have enabled this function;
- To understand how users make use of the Application, resolve technical issues and improve the Services;
- To meet our legal obligations and our commitments to our partners and subcontractors;
- To produce aggregated and anonymous data and statistics about the Services and their users. We use this information for internal purposes, specifically to better understand the needs of our users and to improve our Services and public transit services in general. No user of the Application will be identifiable from these aggregated or anonymous data and statistics;
- To respond to or follow up on requests concerning our Services, the Application and its functionalities, as well as questions or comments you send us.
We typically obtain your consent when we want to use personal information for a new purpose or for a purpose other than those indicated in this Statement, in accordance with applicable laws.
To whom may your personal information be disclosed?
Within the ARTM, only those employees, representatives, subcontractors, officers, agents or assigns of the ARTM who are involved in the management and development of the Application and Services and who require such information in order to provide the Application and Services have access to the personal information collected by the Application. Such employees, representatives, subcontractors, officers, agents or assigns are all bound by confidentiality obligations.
In addition, we may share your personal information with the following third parties with your consent or with other third parties when required or permitted by applicable law.
- Service providers – We may share your information with third-party suppliers, consultants and other suppliers of services we employ to develop, manage and improve the Application, including cloud storage providers, email service providers, payment processing service providers, applications to monitor the Application’s performance and agencies specialized in application development.
- Partners – We may share your information with certain organizations that are partners of the Application, including Bixi and Communauto, as well as with:
- transit organizations, that is, the Société de transport de Montréal (STM), the Réseau de transport de Longueuil (RTL), the Société de transport de Laval (STL) and the Réseau de transport métropolitain (exo);
- and the Réseau express métropolitain (REM).
We may also share aggregated and anonymous data and statistics about the use of the Services with some of these ARTM partners, who will use the data only to better understand their users, in aggregate form, and to improve their public transit services.
- Public authorities – We may share your information with the police or other authorities responsible under the law for the prevention, detection or repression of crime or statutory offences, when we deem the information is necessary for the prosecution of an offence or there is an emergency situation endangering the life, health or safety of the individual concerned.
We typically obtain your consent when we want to disclose personal information to third parties other than those indicated in this Statement, in accordance with applicable laws.
Can your personal information be disclosed or transferred outside Quebec?
The information collected via Chrono is stored on the servers of our cloud storage service provider located in Canada. We use contractual measures to provide adequate protection for personal information when it is stored or transferred outside Quebec. However, when your personal information is processed in a jurisdiction other than the one in which you reside, it may be subject to the law of that foreign jurisdiction, including any law authorizing or requiring disclosure of the information to government authorities, courts and law enforcement and national security agencies in that jurisdiction.
How long do we keep your personal information?
Personal information of users of the Application is kept only for as long as is reasonably necessary to fulfil the purposes set out in this Statement or for a longer period as may be required by law. The ARTM may, however, retain aggregated data for a longer period (even after an account has been deleted), but only following an anonymization process designed to reduce the residual risk of re-identifying individuals to a very low level, in accordance with applicable law.
How do we protect your personal information?
Your privacy is important to the ARTM, and we strive to protect the personal information of users of the Application. As such, we take care to implement reasonable administrative, technical and physical safeguards to protect personal information in our custody, including when personal information is entrusted to service providers acting on our behalf.
What are your choices regarding the use of your personal information?
By contacting us at the address indicated in the How can you connect with us? section, you may withdraw or modify your consent to the ARTM’s use and disclosure of your personal information, or even refuse to participate in certain uses and disclosures, subject to legal or contractual restrictions. If you refuse to provide us with your personal information or to give us the consents required to process said information, it may be impossible for us to respond to your request or to provide you with the services you request.
Geolocation – As described in theHow the Application accesses your device (“authorizations”) section, your authorization is required for the Application to access your device’s location functions in order to determine your location. You can enable or disable location-based notifications in the Application settings.
Electronic communications – You may opt out of receiving promotional or marketing electronic communications at any time by clicking the unsubscribe link that appears in each message or by emailing us at the address indicated in the How can you connect with us? section. If you choose to no longer receive promotional or marketing email communications from us, you may still continue to receive messages from us for other purposes in accordance with applicable laws. For example, we may need to contact you to answer your questions or provide you with information you have requested.
How the Application accesses your device (“authorizations”)
The following is a complete list and description of the functions on your device that can be accessed by the Application. The list also indicates those that can be used only with the user’s express permission. You acknowledge that denying explicit permission may affect or reduce your user experience with the Services.
IOS application:
- Location services. This function allows the Application to determine your location through network and GPS services (user permission required). It is not enabled by default.
- Notifications. The Application may send you notifications (user permission required).
- Background refresh. This function allows the Application to refresh information from the Internet while running in the background.
Android application:
- Location services. This function allows the Application to determine your location through network and GPS services (user permission required). It is not enabled by default.
- Access to network services. The Application may access your Wi-Fi or cellular services to display your network connection and exchange data (including personal information) with servers controlled by the ARTM. In general, this function makes it possible to retrieve and send information from and to the Internet.
- Storage. This function allows the Application to read and write to your device’s memory.
Using your device settings and uninstalling the Application
You can access and change certain user settings for the Application from the settings menu on your device. You can also uninstall the Application. Uninstall methods may vary depending on your device or iOS or Android version.
How can you access or correct your personal information?
You have the right to consult the personal information we hold about you, to obtain a copy of it and/or to request that it be corrected if it is inaccurate, incomplete, ambiguous or collected in violation of the law, by sending a written request to the address indicated in the How can you connect with us? section.
Can this Statement be changed and, if so, how will you be notified?
We may make changes or additions to this Statement at any time; as such, we encourage you to reread it periodically. If we make any changes to this Statement, we will notify you by changing the date indicated at the top of the Statement. The effective date at the top of this Statement indicates the date on which it was last updated. If we make major changes, you will receive a notice in accordance with applicable laws.
How can you connect with us?
If you have a question, concern or complaint about the protection of your personal information or our privacy practices, you may contact the Access to Documents and Privacy Officer at the following address:
ARTM Privacy Officer | accesinfo@artm.quebec
or:
ARTM Privacy Officer
1001 Robert-Bourassa Blvd.
Suite 400
Montreal, Quebec
H3B 4L4