Last Updated – 5/2025

1. Introduction

We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy outlines our practices regarding the collection, use, and protection of your information across our digital platforms and services. By continuing to use our website, applications, or services, you consent to the practices described here.

We may update this Privacy Policy at any time. The Last Updated date above will reflect the most recent revision. You are encouraged to review this policy periodically to stay informed.

2. Information Collection

2.1 Personal Data

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable individual. It does not include publicly available governmental data.

2.2 Information You Provide to Us

You may provide data when you:

• Register for an account
• Sign up for newsletters or promotions
• Purchase transit passes or fare media
• Apply for reduced fares or special programs
• Complete website forms
• Contact customer service
• Participate in contests or surveys

This may include:

• Contact details (name, email, address, phone)
• Account credentials (username, password)
• Payment information (card numbers, billing address)
• Demographics (age, gender, location)
• Health data (for accessibility or reduced-fare services)
• Employment data (for employer transit benefits)

2.3 Information Automatically Collected

When you use our website or apps, we may collect:

• IP address
• Browser type & version
• Operating system
• Pages visited & time spent
• Referring website addresses
• Device information (type, ID, settings)
• Geographic location (if enabled)

2.4 Sensitive Data

We recognize certain personal data as sensitive, such as racial or ethnic origin, religious beliefs, health diagnosis, sexual orientation, citizenship status, genetic/biometric data, and precise geolocation. We will only process sensitive data with your explicit consent or as required by law.

2.5 Cookies & Tracking Technologies

We use cookies and similar technologies to enhance your experience. Cookies are small data files placed on your device when you visit our site. You can configure your browser to refuse cookies or alert you when they are set, though some site features may not function without them.

3. Use of Information

We use collected information to:

• Provide, operate, and maintain services
• Process transactions
• Send service announcements & updates
• Respond to inquiries & offer support
• Send marketing & promotional communications (with opt-out options)
• Personalize your experience
• Monitor usage patterns & trends
• Protect against fraud or unauthorized activity
• Comply with legal obligations

4. Disclosure of Information

We do not sell or rent your personal information. We may share data with:

4.1 Service Providers

Third-party vendors, contractors, or agents who perform services on our behalf.

4.2 Business Transfers

In connection with, or during negotiations of, any merger, sale of assets, financing, or acquisition.

4.3 Legal Requirements

To comply with applicable law, governmental requests, judicial proceedings, or legal process.

5. Consent

By using our services, you consent to our collection and use of your information as described. You may withdraw consent at any time by contacting us; this may affect your ability to use certain services. We will obtain explicit consent for processing sensitive data unless otherwise permitted by law.

6. Security

We implement technical and organizational measures to protect your information from unauthorized access, alteration, disclosure, or destruction. While we strive for robust security, no method is 100% impenetrable.

7. Location Data

If you use our mobile apps, we may collect and process your device’s actual location. You can enable or disable location services in your device settings.

8. Advertising & Analytics

We may use third-party analytics and advertising partners who employ cookies, web beacons, and similar technologies to analyze service use. You have the right to opt out of targeted advertising—please contact us via the “Contact Us” section to do so.

9. External Links

Our services may contain links to external sites. We are not responsible for their privacy practices. We encourage you to review any external site’s privacy policy before providing personal information.

10. Children’s Privacy

Our services are not intended for children under 13. We do not knowingly collect personal information from children under 13; if we learn we have, we will delete that data.

11. Your Rights & Choices

Under laws like the VCDPA and CCPA, you may have rights including:

• Access: Confirm and access your personal data
• Correction: Correct inaccuracies in your data
• Deletion: Request deletion of your data
• Portability: Receive your data in a portable format
• Opt-Out: Opt out of targeted advertising, sale of data, or profiling

To exercise any rights, submit a request via Contact Us. We’ll respond within 45 days, with a possible 45-day extension for complex requests. We will not discriminate against you for exercising these rights.

Appeal Process

If we deny your request, we’ll explain our decision and how to appeal. Appeals will be addressed within 60 days. If denied, we’ll provide contact information for the Attorney General.

12. California Privacy Rights

California residents have additional rights under the CCPA, such as knowing what data we collect, requesting deletion, and opting out of the sale of personal information. We do not sell personal information for monetary consideration.

13. Changes to This Policy

We may update this Privacy Policy periodically. The Last Updated date at the top will reflect any changes. Please review this page regularly.

14. Contact Us

If you have questions, comments, or wish to exercise your privacy rights, contact us at foia@gltconline.com with:

Your Organization Name

Address

Phone Number

Email Address