Metro Flex Privacy Notice

What Information Is Collected

When you use the Via Services, we may collect personal information about you, including information that you provide to us, information that is automatically collected, and personal information about you from other sources and third parties.

A. Personal Information You Provide to Us

User Account Information: To use the Via Services, you may be required to maintain an account with us, which may differ depending on whether you are a Rider, Driver, Delivery User, or Enterprise Platform User (together, these are “User Accounts”). We collect information from you whenever you create or update a User Account, or when one is created on your behalf by an authorized agent. 

Depending on your User category, and the type of Via Services you are using, the information you provide to create or update a User Account may include: your name, email address, telephone number, a photograph or profile image, login credentials, physical address, payment methods or banking information, driver’s license and other government identification documents or numbers (which may include social security numbers), insurance and vehicle-related information, demographic information, information about your employment or corporate affiliation (including your employer identification number, company, and/or title). 

You may also have an opportunity to provide additional information to us related to your User Account, including information about a disability, service animal, a guardian or personal care attendant, an emergency contact, a home or work address, or other information that may be relevant to your preferences or your use of the Via Services. In certain jurisdictions, and as permitted by law, we may also collect additional background check and identity verification information for Drivers, including drug and alcohol test records and results, driving history, and credentials or certifications required for the specific purposes for which you would be using the Via Services. In cases where an Enterprise Customer requests additional information from Users (e.g., eligibility for certain services), we may collect that additional information for the service provided to that Enterprise Customer, and we will do so in accordance with all applicable laws.

Note that we do not directly collect or store full debit or credit card numbers for Riders, Drivers, or Delivery Users. All payments are provided directly to third-party payment processors, and their use of your information is governed by their privacy notices. We may collect and maintain information about your payment methods and the last four digits of a payment card number.

‍Visitor Contact Information: If you are a Visitor and did not create a User Account, you may be given the opportunity to provide us with contact information or other characteristics, including your name, email address, physical address, telephone number, and occupational and employer information. We collect this information when you provide it to us, and we may use it for marketing purposes and to communicate with you, consistent with applicable law.

‍Your Communications with Us: Whenever you contact us (for example, by seeking support using your User Account, by responding to one of our messages, leaving feedback or ratings using the Via Services, or notifying us of an incident involving the Via Services), we will collect any information you provide (including the content of any attachments). We will also collect information which is apparent from your communication (for example, the email address or phone number from which you contacted us). If you communicate with us by telephone, we may record the audio of our communications, consistent with applicable law. In certain instances, we may provide you an opportunity to indicate your preferences for our future communications, and we will collect any preferences you indicate. Please note that our systems may record personal information that you type even if you do not ultimately submit it.

‍Survey Information: We may offer you the opportunity to participate in surveys, quizzes, contests, interviews, or promotions. You may be asked to provide personal information (including demographic information) to participate in such opportunities.

B. Personal Information Collected When You Use the Via Services

Location Information: We collect information about your location in different ways depending on how you use the Via Services.
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• When Riders or Delivery Users are using one of the Via Apps, we collect location data (including GPS and WiFi data) from your mobile device when the Via Apps are running in the foreground of your mobile device (when the application is open and on-screen). We may also collect location data in the background (when the application is open but not on screen) if you authorize us to do so through your mobile device settings. If you are a Rider who is aboard a Driver-operated vehicle, we may also indirectly receive information about your location based on the data we receive about the Driver’s use of the Via Services. 
• When Drivers are using one of the Via Apps, we collect location data (including GPS and WiFi data) from your mobile device whenever the Via Driver App is running in the foreground (when the application is open and on-screen) or the background (when the application is open but not on-screen) of your mobile device. You may have opportunities to adjust location-sharing preferences on your mobile device.
• For all other uses of the Via Services, we may collect general location data based on any automatically collected Device Information and Usage Information, as defined below.

‍Device Information: We may collect information about the devices and browsers you use to access the Via Services. This may include your internet protocol (IP) address, operating system, browser type, browser language, screen resolution, the URL you entered and any relevant referring page/campaign, as well as information about the mobile devices you may use to access the Via Apps (including your hardware model, version, unique device identifiers, operating system, battery level and charging status, and screen size).

‍Usage Information: We collect information about how you interact with the Via Services, including your User Account transactions and automatically collected log data. Usage Information may include, but is not limited to, information about when and how you downloaded any of the Via Apps or created your User Account; your access and login activity; your preferences; details about any transportation or delivery services you request or participate in through the Via Services; your transactions; the specific components of the Via Apps, Via Website, or any other aspect of the Via Solution you visit or use, along with details about your views or use of these components; any alerts or communications we send you in connection with your use of the Via Services; and any errors that may have occurred during your use of the Via Services.

‍Communications Between Riders and Drivers: As noted in the “How We Share Or Disclose Personal Information” section, when we facilitate phone calls between Riders and Drivers, we may use a third-party service to enable these Users to call one another through masked phone numbers without revealing their personal contact information to the User they are contacting. If you make a phone call through this tool, we will collect metadata regarding your communications, including the date, start and end times of the call, and the unmasked phone numbers that participated in the call.

‍In-Vehicle Recordings: In certain cases, vehicles operated by Drivers may be equipped with devices that use video camera and/or sensor technology to record events inside and outside the vehicle. If such devices are installed by one of our service providers, we may collect video images of Drivers and Riders, along with telematics data that includes vehicle location, speed, braking, relative proximity to other vehicles, and collision events that may occur during your ride. In certain limited instances, and subject to notice or consent requirements in accordance with applicable law, we may also collect audio recordings. Certain devices may employ artificial intelligence to process images of a Driver in real-time in order to identify or alert the Driver to safety-related events such as indicators of distracted driving or unsafe distances between moving vehicles. To the extent that such images would be considered biometric information under applicable laws, the devices do not store or transfer such information and we do not disclose biometric information to third parties for any commercial purposes. In cases where we collect data from in-vehicle recording devices, we work with our service providers to provide notice to both Drivers and Riders that there is a recording device in their vehicle; such notice may be provided through physical signs on the exterior and/or interior of the vehicle.

‍Cookies and Third-Party Analytics Data: Like most providers of online services and platforms, we collect information about the electronic path you take to the Via Services, through the Via Services and when exiting the Via Services, and your usage and activity on the Via Services, such as the links, objects, products and benefits you view, click, or otherwise interact with. We and our third-party service providers and business partners may collect and store information through “cookies,” related technologies (such as pixels and web beacons), and third-party analytics services (such as Google Analytics). We collect this information for purposes that include remembering User preferences and settings, analyzing the effectiveness of certain features of our Via Services, and designing and delivering marketing campaigns. For details about how analytics information is automatically collected and used, as well as the choices you may have in relation to those practices, please review our Cookie Notice. 

C. Personal Information Collected from Other Sources and Third Parties

Although we generally collect the personal information described above directly from you, we may also collect this information through service providers and other third parties that collect it on our behalf, as noted below. To learn about the privacy practices of any third party, please review their respective privacy notices.

‍Enterprise Customers: Enterprise Customers may provide us with your name, contact information, demographic information, and any of the other personal information that may be included in “User Account Information” (defined above) to enable us to offer the Via Services to you. For example, if an Enterprise Customer is a transit agency that wishes to provide the Via Services to paratransit passengers, we may receive Riders’ contact information and information about their eligibility for paratransit services through that Enterprise Customer. In another example, if the Enterprise Customer is a business that uses the Via Services to request transportation services for its employees, the Enterprise Customer may provide us with your name and contact information so that we may notify you of the status of your ride or send you other communications. Additionally, if you are an Enterprise Platform User who needs to access the Via Services to manage a transit network, your employer may provide your personal information to us so that we may authorize you as a User. 

‍Referrals: We may use referral promotions to encourage Riders, Drivers, or Delivery Users to tell friends, relatives, or others they know (“Referred Persons”) about the Via Services. We may ask Riders, Drivers, or Delivery Users to provide personal information about Referred Persons. We use personal information collected in connection with these referrals to communicate with the Referred Person, including to invite them to create a User Account. As explained in the “How We Share or Disclose Personal Information” section, we may also share certain personal information about a Referred Person with the Rider, Driver, or Delivery User who referred them.

‍Service Providers and Business Partners: We work with a wide range of third-party service providers and business partners who make it possible for us to make the Via Services available and also help us to improve the Via Services. These service providers include data storage and processing services, mapping services; customer support services; background check providers; fraud prevention, security, and troubleshooting services; communications services; translation and accessibility services; insurance providers; research and analytics providers; professional service providers; video recording and telematics service providers; payment processing services; and marketing and social media services. In certain contexts, we may work with business partners including vehicle leasing partners, telehealth services, in-vehicle advertising providers, and insurance providers, among others, which make products or services available to Users who wish to participate. These service providers and business partners may collect your personal information when you provide it to them or automatically when you interact with them, and they may share that information with us.

‍Social Media: If you decide to interact with Via through social media, we may collect personal information about you that you have chosen to make available to us through your social media account and social media platform settings. We use personal information collected in connection with your social media account and activity to communicate with you and better understand your interests and preferences.

‍Other Sources of Information: We may collect personal information from publicly available sources (including government records or public websites) or from other third parties (including data and mailing list providers, regulators, law enforcement, the media, or insurers), including to correct or supplement personal information we have collected about you from other sources.

How We Use Personal Information

We use the personal information that we collect through the Via Services, including through third-party sources, to:

Provide the Via Services: We use personal information, including location information, to make the Via Services available – both to you and to other Users.

• For example, we may use Users’ contact information to create and maintain User Accounts, we use Riders’ location information to make it possible for them to match with Drivers offering transportation services and to then track the progress of their rides, and we may use Drivers’ banking information to enable them to receive compensation for the transportation or delivery services they provide to other Users through the Via Services.

Personalize the Via Services: We may use personal information to personalize aspects of the Via Services. 

• For example, Riders can input personal preferences to enable accessibility features or save a “home” address in the Via Apps to serve as a shortcut when making new ride requests.

Improve the Via Services: We use your personal information to help us continue to improve the Via Services and develop new products and features. We may also aggregate personal information to help understand Users’ needs and improve our services and offerings.

• For example, we may use your personal information to identify software bugs and troubleshoot errors, to improve our algorithms, to test any aspect or configuration of the Via Services, to identify potential new processes, features, or initiatives, to prevent fraud and misuse, and to conduct general research and development. 

Safety, Security, and Fraud Prevention: We use personal information to offer the Via Services safely and securely, and to deter fraudulent, harmful, unauthorized, unethical, or illegal activity in the Via Services. 

• For example, we may use personal information to authenticate users and verify accounts, identify or investigate unsafe behaviors, and to perform background checks on certain Drivers before we authorize them to use the Via Services to connect with Riders.

Customer Support: We use personal information to provide support to individual Users as well as Enterprise Customers, respond to feedback and inquiries, to investigate or otherwise address incidents, claims, or disputes relating to the use of the Via Services, and to monitor and improve our customer support processes.

• For example, if you submit a photograph related to an incident that occurred on a ride you arranged through the Via Services, we may use it to review your report. We may also use an email message or a recording of a phone call between you and our customer support staff to monitor and improve our responses to User inquiries.

Communications: We use personal information to communicate with you about your use of the Via Services and for marketing purposes. 

• For example, we may use your personal information to alert you about the status of transportation services arranged through the Via Services, to provide receipts for payments, to send announcements and security alerts, and to provide updates about our policies and any element of the Via Services. We may also use your personal information to deliver marketing communications, news, and advertisements about the Via Services or products or services offered by business partners. 

Compliance and Lawful Requests: We use your personal information as necessary or appropriate to comply with applicable laws, lawful requests, and legal processes. 

• For example, we may be required to provide information in response to a subpoena or we may receive lawful requests for information from law enforcement, regulators, government officials, insurance companies, Enterprise Customers, or other third parties authorized to make such requests. In these circumstances, we may use and disclose personal information as required or permitted by applicable law.

How We Share Or Disclose Personal Information

Via does not sell your personal information to third parties. We take your privacy seriously, so when we do share information with third parties, we try to disclose anonymized or aggregated data wherever possible. We also take reasonable and appropriate steps to limit the scope of information that is disclosed and to ensure that the third party is required to comply with data protection laws. We may share and disclose personal information in the following ways: 

‍Within Via: Via’s employees and affiliates work together to provide the Via Services. We share your personal information among staff and affiliates which are responsible for various aspects of the Via Services. We limit access to your personal information to employees and affiliates that need access to this information in order to perform their job functions.

‍With Drivers, Riders, or Delivery Users: In order to help Users request, receive, and provide transportation or delivery services by using the Via Services, we may share certain categories of their personal information with Drivers, Riders, or Delivery Users for limited purposes. In addition to any information that you request or explicitly authorize us to disclose, we will share information with Drivers, Riders, and/or Delivery Users as follows:
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• Rider or Delivery User Information  
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  – If you are a Rider or Delivery User using the Via Apps for on-demand transportation services, we may share your first name and last initial, your requested pick-up and drop-off locations, and service-related information (such as a note that the Rider requires a wheelchair accessible vehicle or is traveling with a companion), with a Driver. We use a third-party service to mask or otherwise conceal a Rider’s or Delivery User’s phone number when they contact a Driver through one of the Via Apps; we will not share a Rider’s or Delivery User’s contact information with a Driver without their consent.
  
  – If you are a Rider or Delivery User using certain services, including but not limited to pre-scheduled transportation, paratransit and similar specialized accessible transportation, or delivery services, we may share additional personal information with a Driver to enable them to provide services to you. For example, pre-scheduled paratransit services may require Drivers to communicate with a care provider to serve a Rider, so Drivers may have access to a Rider’s full name, contact information, and notes made about a Rider’s service requirements (e.g., information about a personal care assistant, service animal, or detailed pick-up requests).
  
  – After a ride or delivery has been completed, we may share a Rider’s or Delivery User’s anonymous feedback with a Driver. We take precautions not to reveal a Rider’s identity in any incidents alleging misconduct by a Driver. Nevertheless, a Driver may be able to deduce the identity of the Rider or Delivery User who submitted feedback about their experience based on the details included in the feedback.
  
  – When a Rider shares a ride with another Rider, each Rider may be able to determine certain limited information about the other (e.g., their pick-up or drop-off location) over the course of their ride.When a Rider or Delivery User receives transportation or delivery services that have been arranged by another Rider or Delivery User, some or all of the personal information we collect about the individual who received the services will be shared with the individual who arranged the services.
• Driver Information
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  – If you are a Driver, after you receive a request for transportation or delivery services, we may share your name, photograph, location, information about your vehicle, and any other information as may be required by statute or regulation (in some instances, this may include a government-issued identification number), with the Rider.
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  – In most instances, we use a third-party service to mask or otherwise conceal a Driver’s phone number when they contact a Rider or Delivery User through the Via Apps. In certain instances, we may share a Driver’s phone number with a Rider or Delivery User, for example to facilitate the return of an item left by a Rider in a Driver’s vehicle. 
  
  – If you are a Driver and you or your vehicle is involved in an accident, we may share certain personal information, including your automobile insurance information, with third parties, including Riders, who may wish to submit a claim.
  
  – If you are a Driver who has been referred to Via by another Driver, we may share with your referrer certain information related to your use of the Via Services as it may be relevant for their eligibility to receive any benefits, incentives, or rewards as a result of the referral.
• Other Users’ Information
  
  – We do not share Enterprise Platform Users’ or Visitors’ information with Riders, Drivers, or Delivery Users except to the extent they also use the Via Services as Riders, Drivers, or Delivery Users.

With Enterprise Customers: Where we provide the Via Services in connection with an Enterprise Customer, we may share Riders,’ Drivers,’ or Delivery Users’ personal information with that Enterprise Customer. This personal information may include names and contact information, geolocation information, payment information, driver’s license number, vehicle information, transaction history, customer support communications, and feedback. This information enables Enterprise Customers to assist in managing or monitoring aspects of the Via Services or to arrange for transportation or delivery services. Please note that Enterprise Platform Users may be able to view one another’s contact information and usage activity. For example, a transit planner using Remix’s planning tools may be able to share a proposed design with another colleague, and a customer support agent’s communications may be visible to other authorized Users of the Enterprise Platform. Additionally, an Enterprise Platform User with administrator privileges may be able to create User Accounts for other authorized Users of the same Enterprise Customer and view their usage activity.

‍With Service Providers: We may share some or all of your personal information with our service providers who perform services on our behalf. Some of the categories of our service providers include:
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• Data storage and processing services: The Via Services are hosted on cloud servers and we use third-party vendors for assistance with data collection, processing, storage, retrieval, and aggregation.
• Mapping services: We use third-party software to assist with mapping functions used in our Via Services.
• Customer support services: We work with third parties to provide us with support services, including through call centers, email, and chat support.
• Background check providers: In certain instances, and consistent with all applicable laws and regulations, we may engage with third parties who provide background check and identity verification services.
• Fraud prevention, security, and troubleshooting services: We use vendors to assist us in detecting and preventing fraudulent use of our Via Services, in preserving the data security of our systems and Via Services, and in identifying and resolving errors or incidents that may affect the Via Services. In certain cases, we may work with video recording and telematics service providers to promote safe use of the Via Services and assist in incident response.
• Communications services: We use vendors to provide communications services for functions such as sending in-app notifications, masking User telephone numbers, and managing and sending emails, text messages, or telephone calls.
• Marketing and Social Media Services: We use marketing vendors, including analytics software, advertisement networks, social networks, and marketing communication providers and consultants to assist in targeting our marketing to specific audiences. 
• Translation and accessibility services: We work with translation vendors to make the Via Apps accessible to users who speak a variety of languages, and we consult with accessibility experts to help us actualize our commitment to increasing access to transportation services.
• Insurance providers: We work with insurance companies, adjusters, brokers, and claims administrators to help provide insurance and process claims on implicated insurance policies.
• Research and analytics providers: We may use service providers to aggregate personal information and receive insights about how the Via Services are used.
• Subcontractors: We may contract with transportation operators and other subcontractors to help provide services to Enterprise Customers, and we may need to share personal information with these subcontractors to enable them to complete their contracted tasks.
• Professional service providers: We may consult with or retain lawyers, accountants, government affairs or subject matter experts, and other professionals.

With our Business Partners: We engage with business partners to support the Via Services and provide you with additional opportunities to use the Via Services. Business partners may include vehicle leasing partners, telehealth services, in-vehicle advertising providers, and insurance providers, among others. Note that the processing of your data will be subject to that business partner’s privacy notices. We may also share aggregated demographic information with third parties interested in advertising on our online services, but this information would be designed not to be identifiable to a specific individual.

‍With Academic Researchers: We may share de-identified information with academic researchers. We take care to ensure that any information provided to researchers is disclosed confidentially and is not subject to re-identification.

‍With Payment Processors: We use payment processors, online payment system providers and billing agents to process transactions related to the services you arrange or provide through the Via Services.

‍In a Business Transaction, Transfer, or Reorganization: We may disclose personal information to a third party in connection with, or during negotiations of, a business transaction such as a merger, acquisition, joint venture, financing or sale of company assets, or in the event that a service we provide is transitioned to another provider. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.

‍Pursuant to Legal Obligations and Rights:  We may disclose personal information to third parties, such as law enforcement, government authorities (such as regulators or public health officials), issuers of licenses and permits (such as airport authorities), insurers, claimants, and other third parties as we determine to be necessary to (i) respond with civil, criminal, or regulatory inquiries and legal process (including search warrants, subpoenas, summonses, or court orders), (ii) comply with licensing, regulatory, and other legal obligations, (iii) enforce our policies and agreements, (iv) establish, exercise, or defend legal claims, or (v) protect the rights, safety and property of Via, third parties, or the public.

‍With Users’ Consent and at Their Request: With your consent or at your request, we may disclose your personal information publicly or to any third parties not otherwise mentioned in this Privacy Notice.

How We Store And Protect Personal Information

We retain your information for as long as necessary to provide you, other Users, and Enterprise Customers, where appropriate, with the Via Services, or as long as required to fulfill our legal obligations. We retain transactional information such as payments and information about rides or deliveries you make and receive to ensure we can perform legitimate business functions, such as accounting for tax obligations. If you request account deletion, we will delete your information as set forth in the “Updating or Deleting Your Information” section. 

Via takes the security of your personal information and our data very seriously. We take reasonable and appropriate measures designed to protect your personal information. Please remember that no method of storage or transmission is 100% secure and that we cannot guarantee the security of your information, including against unauthorized intrusions or acts by third parties. Additionally, you are solely responsible for protecting your User credentials and limiting access to your devices.

Your Communication Preferences

In connection with the Via Services, we may send you email messages, direct mail offers, SMS messages, push notifications or other communications, including telephone calls, regarding the Via Services.

You may ask us not to send you marketing communications by:
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• Following any opt-out instructions that are made available in our marketing communications.
• Sending a written request to support@ridewithvia.com clearly stating the nature of your request and identifying the email address or number at which we contacted you.
• You may also be able to use your mobile device or in-app settings in the Via Apps to opt out of marketing communications and push notifications.

If you request to opt out of marketing communications, please note that we may continue to send you non-marketing communications, which may include account verification and maintenance, status updates regarding specific transactions (such as transportation or delivery services you arranged using the Via Services), changes or updates to the Via Services or our ongoing business relationship, and any technical, administrative, legal, or security-related notices.

Please see our Terms of Use for additional information about how we communicate with you and your options with respect to these communications.

Updating or Deleting Your Information

If you would like to update, delete, or correct any information that you have provided to us through your use of the Via Services or otherwise, please send an email to support@ridewithvia.com. Certain Via Apps may also have an in-app deletion function, which you may use to delete your account information. Upon your request, we will comply with all applicable laws governing such requests. If you request deletion of your account, we may retain certain information as permitted or required by statute, rule, or regulation, and we will also keep a record of the fact that your request was made and fulfilled.

Children’s Personal Information

No part of the Via Services is directed to children and we do not knowingly collect or solicit personal information from children. When we use the word “children,” we refer to children under the age of 13 (or any other applicable age of consent for privacy purposes in relevant individual jurisdictions). If you are a child, please do not use the Via Services or otherwise provide us with any personal information either directly or by other means.

Protecting the privacy of children is important to Via. If we learn that we have collected personal information from a child without appropriate parental consent, we will take steps to delete it and may close the relevant account without notice. If you believe that a child has provided personal information to us, please contact us at support@ridewithvia.com.

Third-Party Websites

Our websites and online services may include links to or redirect you to third-party websites, plug-ins and applications, including social media services where you may connect with us.  Third-party websites may also reference or link to our websites and online services.  Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please review their respective privacy notices or policies.

Cross-Border Transfers

When transferring your personal information across borders, we ensure compliance with all applicable legal requirements. Where appropriate, we rely on standard contractual clauses and closely monitor regulatory developments with respect to cross-border data transfer.

Via complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce (collectively, the “DPF”). We have certified our participation in the DPF and our adherence to the DPF Principles to the U.S. Department of Commerce. This certification relates to Via’s and its affiliates’ processing of personal data received from the European Union, as well as from the United Kingdom and Gibraltar. If there is any conflict between the terms in this privacy policy and the DPF Principles, the Principles shall govern. To learn more about the DPF program, and to view our certification in the DPF list of participants, please visit https://www.dataprivacyframework.gov/.

Please review our Privacy Notice, including the United Kingdom & European Economic Area Notice, and any other policies associated with the certified data categories, for details about:

• The types of personal information processed
• The purposes for which we collect and use personal information 
• The types of third parties to which personal information is disclosed and the purposes of such disclosures
• Your rights to access your personal information
• Any choices and opportunities by which you can limit the use and disclosure of personal information
• The possibility that personal information may be disclosed in response to lawful requests from public authorities

Via’s compliance with the DPF is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Pursuant to the DPF, we may have liability for onward transfers to third parties if they process applicable personal information in a manner inconsistent with the DPF and if Via is responsible for the event giving rise to any alleged damage.

Via takes all inquiries and concerns about privacy and use of data very seriously, and shall endeavor to reply to you promptly if we receive a complaint. Please see the “Contact Us” section of the Privacy Notice for information on how to get in touch with us. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact JAMS, our U.S.-based third party dispute resolution provider (free of charge). You may also have the right to invoke binding arbitration under certain circumstances specified in the DPF.

Updates To This Privacy Notice

We will update this Privacy Notice from time to time, including to address changes in the Via Services, clarify or update our processes, and to comply with changing laws and regulations. When we make changes to this Privacy Notice, we will change the “Last Updated” date at the beginning of this Privacy Notice. If the changes apply to only one section of the Privacy Notice, we may update only that section’s “Last Updated” date.  If we make material changes, we will notify you including through a pop-up notification on the Via Apps, Via Websites, or elsewhere in the Via Solution, or by other means, including email or a prominently posted notice at the beginning of this Privacy Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification. We encourage you to review this Privacy Notice periodically. By using the Via Services after an update, you agree to the updated version of the Privacy Notice.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to support@ridewithvia.com. Alternatively, inquiries may be addressed by certified mail to the relevant address listed here "Addresses for Notice".

Processor Notice to End Users

We provide Via Services to Enterprise Customers, including on a SaaS basis, with or without supplemental enabling services. Where the Enterprise Customer acts as the data controller, Via will act as a processor or service provider to the Enterprise Customer. Via will collect, use, share, disclose, and otherwise process personal information of its users only as directed by the Enterprise Customer under its contract with Via. In those instances, this Privacy Notice will not be determinative of how your information will be used by Via and we encourage you to consult the relevant Enterprise Customer’s privacy notices instead. 

Via is not responsible for the privacy or security practices of its customers, including Enterprise Customers, which may differ from those set forth in this Privacy Notice. Please direct your privacy inquiries – including any requests to exercise your data protection rights or to change your communication preferences – to the relevant Enterprise Customer. 

Please note that in the event that Via processes data on behalf of an educational agency or institution in the United States, Via will process student personal information in accordance with the Family Educational Rights and Privacy Act and its contractual arrangement with that entity.

King County’s Metro Flex Privacy Statement

King County Metro (the “County”) contracts with Via to provide the Metro Flex service. The term “Metro Flex” refers to all services facilitated by the Metro Flex app or the Via call center as contracted by the County, including, but not limited to, transit and mobility services. 

Via’s collection and processing of personal information is described in Via’s Privacy Notice, above. Consistent with Via’s Privacy Notice, certain personal information that Via collects in relation to Metro Flex may be shared with the County. 

To the extent the County receives any personal information related to Metro Flex, it shall process it according to the County’s own privacy policies and practices. See this Metro Flex Privacy Statement ("Privacy Statement") for details about the County’s policies and practices with respect to the processing of personal information related to Metro Flex.

‍How King County Metro Uses, Shares, and Discloses Personal Information‍

‍Within the County: The County plans to use and share all personal information collected through or generated by Metro Flex for the purposes of fare reconciliation, monitoring the functionality and performance of the service, developing the service, making reports on service performance, and for any other County purposes. The County will only share personal information with County employees, officials and contractors on a “need to know” basis for purposes of fulfilling their duties and responsibilities.

• Satisfy an applicable law or regulation.  
• Respond (voluntarily or involuntarily) to a subpoena, court order or other legal process and requests by a governmental agency; and to protect the County from any kind of potential harm (as the County perceives that potential in its discretion).  
• Enforce County terms of use and other provisions, including investigation of potential violations thereof.
• Detect, prevent, or otherwise address fraud, security or technical issues.  
• Protect against harm to the rights, property or safety of the County, the users of their services, or the public, as required or permitted by law.
• Persons or entities that receive information from the County may be able to combine such information with other information they independently possess. The County is not responsible for combining or any later use that may be made of information provided to others in accordance with this Privacy Statement.

With Researchers: The County may share personal information related to or generated by Metro Flex with researchers for purposes of academic or industry research and performance evaluation.

With Users’ Consent and at Their Request: With your consent or at your request, the County may disclose your personal information publicly or to any third parties not otherwise mentioned in this Privacy Statement.

As Required by Public Records Laws: The Washington Public Records Act (Chapter 42.56 RCW) (“Act”) applies to all records related to the County and the Metro Flex program. Generally, public records are available for inspection and copying by the public but the Act exempts some records from mandatory disclosure. For example, the Act contains certain information relating to public transportation under RCW 42.56.330. The County reserves its discretion, if any, to release or withhold records in accordance with the Act. The County reserves the right to impose fees in accordance with the Act for responding to requests for inspection and copying of records. In the event of a conflict between this Privacy Statement and the Public Records Act or other law governing the disclosure of records, the Public Records Act or other applicable law will control.  

How the County Retains Personal Information: The County may retain personal information related to or generated by the Metro Flex program on both active databases and in archive systems, and in electronic as well as hard copy form. The County will store all information related to the Metro Flex program, including personal information, for as long as it believes it useful or required by applicable law.  

No Warranties
‍THE COUNTY HAS ADOPTED PROCEDURES AND MEASURES IT BELIEVES TO BE COMMERCIALLY REASONABLE TO PROTECT ANY PERSONAL INFORMATION PROVIDED TO THE COUNTY BY VIA FOR THE METRO FLEX PROGRAM. HOWEVER, THE COUNTY DOES NOT GUARANTEE INFORMATION SECURITY OR WARRANTS THAT THE INFORMATION (INCLUDING BUT NOT LIMITED TO PERSONAL INFORMATION) COLLECTED IN CONNECTION WITH THE METRO FLEX PROGRAM WILL REMAIN FREE FROM UNAUTHORIZED ACCESS OR DISCLOSURE, LOSS, MISUSE, ALTERATION OR THEFT AND THE COUNTY EXPRESSLY DISCLAIMS ANY SUCH OBLIGATION.  

Governing Law and Venue
‍This Privacy Statement shall be construed in accordance with the laws of the State of Washington, without regard to any conflict of law provisions. Any dispute arising between you and the County under this Privacy Statement shall be resolved exclusively by the state or federal courts sitting in King County, Washington that have jurisdiction over the matter.