Privacy Statement for Digital Travel Services

Statement updated 13 June 2023.

Oy Matkahuolto Ab

Business identity code 0111393-9

(Hereinafter “Matkahuolto” or “We”)

This privacy statement describes how Matkahuolto processes the personal data of its customers that Matkahuolto collects in order to provide its digital transport services and related customer service and communications. Matkahuolto offers customers a variety of ticket products and related services through its physical and digital sales channels.

Matkahuolto is the controller of the personal data that our customers, such as you, provide us in order to purchase and use the tickets and related services we offer. As the controller, Matkahuolto is responsible for all personal data provided by you and the processing of this data. As data protection is about trust, the protection of your privacy and personal data is of great importance to Matkahuolto. This is why Matkahuolto only collects personal data to the extent necessary to be able to offer you first-rate service.

A more detailed description of the ways in which your personal data is processed and the purposes of such processing is provided in this privacy statement. When we process your personal data for the purposes described below, you are the data subject referred to in the privacy statement and have, for example, the rights laid out in section 9.

If you want more information about how your personal data is processed when sending or receiving parcels or official documents carried by Matkahuolto or parties acting on its behalf, please refer to Matkahuolto’s Privacy Statement for Parcel Services.

If you would like more information about how your personal data is processed by Matkahuolto or by carriers and agents acting on our behalf, when providing assistance services to people with reduced mobility and disabilities at bus stations in accordance with EU Regulation No. 181/2011, please refer to the Privacy Statement for Assistance Services.

Some of Matkahuolto’s service outlets have recording camera surveillance, and customer information is also stored on camera surveillance recordings. For more information on the processing of personal data collected through camera surveillance, see our Privacy Statement for Camera Surveillance.

What is described in this privacy statement only applies to the ways in which Matkahuolto or the parties acting on its behalf process data. Please note that Matkahuolto’s electronic services may contain links to third-party websites or social network services and that Matkahuolto has no control over the activities of such third parties, and is not responsible for the privacy policies of such third-party services or their content. Therefore, we recommended that you read the privacy and data protection terms of such third-party services.

Oy Matkahuolto Ab
Customer Service Centre
P.O. Box 100
00101 Helsinki
tietosuoja@matkahuolto.fi

2. What data do we process?

Personal data is collected from customers who have purchased tickets and travel rights and requested demand responsive transport services, the processing of which is necessary for Matkahuolto to provide services to the data subjects and to develop its services.

In connection with the provision of digital travel services, Matkahuolto processes the following personal data:

Registration information required for any electronic account, such as username, pseudonym, password, or other unique identifier.
Demographics such as age, gender, rank or profession, mother tongue.
Customer relationship information, such as your contacts with Matkahuolto customer service, including recorded customer service calls and customer feedback you provide.
Billing and collection information.
Basic ticket information: travel card or ID number. The travel card number is also stored on the data subject’s travel card.
Other information about the ticket: payment and billing information, date and place of purchase, ticket product, validity of the right to travel and information on any refunds.
Information on the use of the ticket: date and time of use (reading) of the travel card or mobile ID, the means of transport on which the ticket is used, ID no. of the reader device, the bus operator and service, and information on the boarding stop or location.
Other information received from the data subject, such as complaints, messages and replies to Matkahuolto’s inquiries and surveys.

Matkahuolto also processes any changes to the personal data collected from the data subjects as well as any additional information provided.

When you use Matkahuolto electronic services, we may collect metadata related to your use of the services, such as, where you accessed the services, the duration of your visit, the amount of data transferred, the type of web browser, IP address, operating system and user interface, as well as the browser version and language. If you visit the electronic services without registering or logging in, Matkahuolto will only process the above metadata. These metadata cannot be used to identify an individual user unless you register or log in to the service. These data are collected with the help of cookies or other similar technologies. For more information about Matkahuolto’s cookie policies, see our cookie statement.

In addition, other personal data, as described in more detail below, is collected on the users of Subsidised School Trip Tickets for upper secondary students, personal travel cards subsidised by municipalities or cities and Employee Ticket products in order to provide relevant services.

a. Subsidised School Trip Tickets for upper secondary students

The subsidised school trip ticket for upper secondary students is a ticket offered by Matkahuolto and subsidised by the Social Insurance Institution of Finland (Kela) for upper secondary students whose studies meet the criteria specified in the Subsidised School Trips Act (48/1997). Matkahuolto processes the following personal data of upper secondary students who purchase subsidised school trip tickets:

Name, phone number and email address (information collected in the Trips and Tickets app).
More precise identification data of the data subject: personal identity code.
Information on the granting of the right to purchase a subsidised school trip ticket.
Other ticket information such as ticket product, ticket validity period, ticket purchase details.

This information is collected in order to identify the customer uniquely and to verify the entitlement to a subsidised school trip ticket at the time of purchase.

b. Personal tickets subsidised by municipalities or cities

Personal tickets subsidised by municipalities or cities are tickets downloaded to the mobile app or personal travel card, as well as tickets for comprehensive school pupils and service voucher products. The issuance of these tickets is based on the data subject’s residence within the limits of a given municipality or city or region. A further criterion for the issuance of the tickets for comprehensive school pupils is their personal status (comprehensive school pupil).

Matkahuolto processes the following personal data of holders of personal tickets subsidised by municipalities or cities:

Name, phone number and email address (information collected in the Trips and Tickets app).
In the case of comprehensive school pupils, Matkahuolto also processes the month and year of birth.
Other ticket information such as ticket product, ticket validity period, ticket purchase details.

This information is collected in order to identify the customer and verify their entitlement to use the subsidised ticket.

c. Employee Ticket products

An employee ticket is a subsidised ticket (season or series ticket) offered by an employer based on the data subject’s employment with the company involved. Matkahuolto processes the following personal data of holders of employee ticket products:

Name, phone number and email address (information collected in the Trips and Tickets app).
More precise identification data of the data subject: personal identity code.
Information on the workplace of the person entitled to such a work-related benefit.
Other ticket information such as ticket product, ticket validity period, ticket purchase details.

This information is collected in order to identify the customer and verify their entitlement to use the subsidised ticket.

3. Purposes and legal bases for the processing of personal data

Matkahuolto processes the personal data of its digital transport services customers

to implement and develop services and products and travel related services, including the verification of the right to travel, blocking lost cards and transferring unused travel validity to a new travel card, identifying the owners of lost travel cards, verifying usage transactions and investigating errors, as well as
to manage, administer, analyse and develop the customer relationship, e.g. by providing customer service and sending customer communications, such as newsletters and informative messages.

Additionally, Matkahuolto may process personal data for the purpose of conducting customer analyses, such as customer satisfaction surveys, and for direct marketing purposes to the extent permitted by law and in accordance with section 4 of this privacy statement.

The processing of data subjects’ identifying data is necessary to verify their transactions, their right to buy a personal ticket as well as their personal communications and visits. The identification data required depends on the ticket product.

The identifying information and personal identity codes are used for the following purposes:

verification of the right to buy the ticket;
blocking of a lost card and transfer of the remaining travel right to a new card;
identification of the owner of a lost and found card;
verification of usage transactions;
investigation of errors.

As far as single tickets are concerned, the processing of identification data is necessary in order to verify the right to travel and deliver the receipt by email.

The legal basis for processing personal data is either compliance with the agreement between Matkahuolto and the data subject, Matkahuolto’s legitimate interest based on the customer relationship, or the data subject’s consent given to Matkahuolto. In order for Matkahuolto to be able to implement the agreement it has entered into with you, it is necessary to process your personal data, for example, to verify your right to travel or be able to invoice the subsidising party when you wish to purchase subsidised tickets. Processing based on Matkahuolto’s legitimate interest refers, among other things, to situations in which Matkahuolto processes your data for administrative purposes or in order to prevent or investigate misuse, as well as to develop and target direct marketing. The purpose of processing based on consent is always clearly stated when consent is sought.

The data subject’s obligation to disclose personal data as provided in this privacy statement is partly a statutory obligation and partly a precondition for the conclusion of an agreement between the data subject and Matkahuolto. For example, under section 12.1 of the Subsidised School Trip Act (48/1997), the data subject is required to disclose his/her personal identity code to the seller when buying a ticket eligible for school trip subsidies. If the data subject refuses to disclose his/her personal data to Matkahuolto, as explained in this privacy statement, Matkahuolto is unable to verify the data subject’s right to buy the ticket and cannot therefore issue the travel card to the data subject. In addition, under the Accounting Act (1336/1997), Matkahuolto is obliged to retain documents that may contain personal data.

When you register as a user of our electronic services, you are obliged to provide us with certain personal data for the purposes of the processing specified in this privacy statement, except in certain cases where the provision of data is not necessary, as specifically indicated (e.g. disclosure of interests). Failure to provide personal data may prevent us from fulfilling our contractual obligations, which may result in, for example, you not being able to create a customer account for our electronic services or us not being able to provide you with the services described in this statement.

How do we merge customers’ personal data?

Matkahuolto merges personal data collected in connection with the use of our various services in order to provide you with services that are more user-friendly. However, your information collected in connection with the use of various services will only be combined if you have registered as a user of electronic services and use several services, such as buying tickets, or otherwise deal with Matkahuolto through your electronic customer account, in which case the merging of your data is based on your consent.

If you have not enabled Matkahuolto electronic services or accessed services through your electronic customer account, we will not merge the personal data collected in connection with your use of various Matkahuolto services, in which case your data will only be processed as described in the privacy statements of individual services or other Matkahuolto privacy statements. 

4. Electronic direct marketing

Matkahuolto will not use your personal data for the purposes of direct electronic marketing without your prior consent. If you have given your consent to direct electronic marketing, you have the right to withdraw your consent at any time and prohibit Matkahuolto from using personal data for direct electronic marketing. You can prohibit the use of your personal data for direct electronic marketing by contacting Matkahuolto’s Customer Service Centre.

Matkahuolto does not need to ask for your consent to direct electronic marketing if the information has been obtained on the basis of a previous customer relationship and in connection with a previous purchase. Information obtained on the basis of a previous customer relationship or a previous purchase transaction will only be used for the direct marketing of products or services belonging to the same product group and only for direct marketing by Matkahuolto. Even in such a situation, you have the right at any time to prohibit Matkahuolto from using your personal data for direct marketing purposes.

5. Regular sources of data

Matkahuolto collects information from the data subject when selling and issuing tickets and at other times when the data subject interacts with Matkahuolto, either through its physical or digital channels. Matkahuolto may also collect information from you when you participate in marketing campaigns or customer feedback surveys.

Data on ticket usage is collected according to use. Matkahuolto collects, through a technical interface, information on the use of tickets from the carriers on whose means of transport the data subject travels with tickets purchased from Matkahuolto.

Matkahuolto collects information on single tickets and demand responsive transport orders from the data subjects themselves.

The right to buy a subsidised school trip ticket can be obtained from the Social Insurance Institution of Finland (Kela) through strong authentication.

In the case of comprehensive school pupils, the school will provide the pupil’s details.

The employer of the person entitled to the Employee Ticket notifies Matkahuolto of validity data.

6. Transfers of personal data

Matkahuolto transfers the personal data of data subjects to the following recipients and groups of recipients as needed:

In our digital sales channels, we use third parties as payment service providers. In addition to the personal data transferred by Matkahuolto (name, email address), payment service providers may request additional information depending on the payment method chosen. This additional information will not be processed or stored by Matkahuolto. Instead, it will be handled by the payment service provider in accordance with its own privacy statement.
Bus operators: Matkahuolto transfers personal data to a limited extent to bus operators for the purpose of providing digital transport services. The card readers used by bus operators make it possible to elicit the following information from the season, series or value ticket: Travel card or mobile ID number, ticket product and the period of validity of the right to travel. For single tickets, the bus operator will be provided with the name given by the passenger or an identifier of his/her choice. In the case of demand responsive transport orders, the bus operator will be provided with the name and telephone number of the passenger.
Information system vendors and other service providers: Matkahuolto may transfer personal data to information system vendors and other service providers for the purpose of providing services or completing tasks they have been assigned to carry out, such as IT system maintenance or other data processing tasks.

In addition, Matkahuolto will disclose the personal data of the holders of its subsidised tickets to the recipients specified below. The purpose of the disclosures is to enable the invoicing of subsidised tickets and to verify Matkahuolto’s invoicing basis and the appropriateness of invoicing.

Subsidised school trip tickets for upper secondary students: Matkahuolto discloses information to the Social Insurance Institution of Finland (Kela) as needed for it to grant school trip subsidies and credit the amount to Matkahuolto on a monthly basis. Provisions on the disclosure of information are set out in section 1 of the Decree on School Trip Subsidies for General Upper Secondary and Vocational School Students (425/2004).
Personal travel cards subsidised by municipalities or cities: Matkahuolto discloses information to the municipality or city as needed for it to grant the subsidy and credit the amount to Matkahuolto on a monthly basis.
Employee ticket products: Matkahuolto provides employers with information on tickets purchased by employees and subsidised by the employer.

When transferring personal data, Matkahuolto has ensured, for example, through contractual arrangements, that the processor acting on its behalf processes such data only in accordance with the written instructions issued by Matkahuolto for the performance of the processor’s tasks and exclusively for the purposes indicated in this privacy statement. Also, Matkahuolto has ensured that access to personal data is limited to persons who need to access it for work-related reasons.

The data is primarily stored in the territory of the Member States of the European Union or the European Economic Area, but processors outside the EU or EEA may have access to personal data when providing their services to Matkahuolto. In cases where such disclosure of information occurs, Matkahuolto must ensure that the European Commission has determined that there is an adequate level of protection of personal data in the country in question, use standard contractual clauses or other equivalent arrangements approved by the European Commission and comply with other appropriate safeguards for the disclosure or transfer of personal data outside the EU or EEA. A copy of the applicable safeguards is available on request from Matkahuolto.

In addition to the above, Matkahuolto will disclose personal data to third parties in the cases set forth below:

Matkahuolto may disclose customer data to third parties if you have given your consent.
Matkahuolto may disclose your personal data as required by the competent authorities or other parties or as required by applicable law, in accordance with current legislation.
If Matkahuolto sells, buys, merges, or otherwise reorganises its business, Matkahuolto or a party acting on its behalf may disclose your personal data to the buyers and their advisors.
When Matkahuolto sells HSL mobile tickets, personal data related to the purchase will be transmitted to HSL. HSL is responsible for processing the disclosed information in accordance with its own privacy policy.
When Matkahuolto resells Waltti’s mobile tickets, personal data related to the purchase will be transmitted to Waltti. Waltti is responsible for processing the disclosed information in accordance with its own privacy policy.
When Matkahuolto resells Onnibus.com mobile tickets, personal data related to the purchase will be transmitted to Onnibus.com. Onnibus.com is responsible for processing the disclosed information in accordance with its own privacy policy.
When Matkahuolto resells VR mobile tickets, personal data related to the purchase will be transmitted to VR. VR is responsible for processing the disclosed information in accordance with its own privacy policy.

7. Personal data protection policy

Manually processed data is kept in locked rooms at Matkahuolto outlets.

Electronic data is stored in a database that may only be accessed by specifically designated staff members of the controller or a party acting on its behalf who need to access such data for work-related reasons, have received adequate training and are bound by a statutory or contract-based non-disclosure obligation.

The machine-readable service is located in a protected and locked computer room accessible only by technical personnel with access badges. The servers are protected through technical means.

All the data communications between the browser and the server environment are encrypted.

Access to servers and applications is restricted through role-based access control management.

8. Storage period and erasure of personal data

The retention period of the data is determined by the type of data involved and its intended purpose. Matkahuolto or the processors who carry out the processing of such data on behalf of Matkahuolto in connection with digital transport services retains the personal data of data subjects in accordance with applicable legislation for only as long as the retention of data is necessary to achieve the purpose of the processing of personal data.

Matkahuolto determines the storage periods of personal data according to the following criteria:

Your personal data will be retained for the duration of your active customer relationship. The activity of your customer relationship is determined on the basis of your use of Matkahuolto electronic services or your communication with Matkahuolto.
Information about your direct marketing consent will be deleted if you withdraw your marketing consent or object to the processing of your personal data for direct marketing purposes.
Your data will be deleted if you have requested the deletion of your data and Matkahuolto has no other basis for processing your personal data.

The communication sections of some of Matkahuolto services, such as your public feedback, will still display your pseudonym and related content even after your customer relationship has ended.

Matkahuolto is required to retain some of your personal details contained in your purchase, delivery and payment data in order to comply with accounting or other mandatory legislation even after the end of your customer relationship or other basis for processing personal information.

In some cases, the retention period of personal data is also determined by the terms and conditions of the agreement made with the subsidising party or legislation Matkahuolto is bound by. For instance, Matkahuolto is obligated to retain information contained in accounting material for the period of time specified in accounting laws (up to 10 years).

As far as single tickets are concerned, the name, if any, of the data subject is retained and receipts stored in the system for the period of time required under the Accounting Act, and the email address of the data subject is always stored in the system for the previous financial year.

When Matkahuolto no longer needs the personal data for the original purposes, the data is erased from Matkahuolto’s and its processors’ IT systems and other files, or the data is irrevocably anonymised.

9. Rights of data subjects

The EU General Data Protection Regulation guarantees data subjects a number of rights that they can exercise to determine how their personal data is processed. You may exercise the following rights in respect of Matkahuolto insofar as Matkahuolto serves as the controller of your personal data.

Right of access: The data subject has the right to receive a confirmation from Matkahuolto as to whether Matkahuolto processes his/her personal data and the right to check such data. Matkahuolto may request the data subject to formulate his/her request in more detail regarding the procedure for the delivery of the data, etc.
Right to correct personal data: The data subject has the right to correct any errors in the personal data processed by Matkahuolto or complete any incomplete data. When requesting a correction, the data subject needs to be aware that all information cannot be changed retroactively by such a request. For example, the contents of the decisions concerning the data subject’s benefits cannot be amended. Specific appeal procedures exist for such decisions as explained in each individual decision.
Right to be forgotten: If there is no longer any legal basis for the processing of personal data or the statutory or contractual provision obligating Matkahuolto to retain personal data ceases to apply, the data subject has the right to demand that Matkahuolto erase his/her personal data and Matkahuolto is required to comply with the request.
Limitation of processing: In certain cases stipulated by law, the data subject may have the right to demand that Matkahuolto limit the processing of his/her personal data.
Right to transfer personal data: Subject to certain statutory provisions, the data subject may have the right to receive from Matkahuolto the personal data concerning him or her in Matkahuolto’s possession in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from Matkahuolto.
Right to object to the processing of one’s personal data: In addition, the data subject may have the right to object to the processing of his/her personal data in certain situations. In particular, the right to object to the processing of personal data applies to situations in which processing is based on Matkahuolto’s legitimate interest, and Matkahuolto is required to comply with the request of the data subject unless Matkahuolto demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Direct marketing and the right to forbid the processing of personal data for direct marketing purposes: The data subject has the right to forbid the processing of his/her personal data for direct marketing purposes.
If the data subject has given his/her consent to receiving direct marketing material from Matkahuolto, he or she may cancel such consent at any time.

If you have registered as a user of Matkahuolto’s electronic services, you can check and correct your information in the electronic services provided by Matkahuolto. If you have not registered as a user of the electronic services, or if you do not want to use the electronic services to check or correct your information, you can check and correct your information by contacting Matkahuolto Customer Service Centre referred to in section 1 of this privacy statement. Any requests for the erasure or transfer of the data or any objection to direct marketing must always be submitted to the Matkahuolto Customer Service Centre.

Matkahuolto will take prompt action in response to the data subject’s request and will provide the data subject with information on the exercise of rights normally within one month of receipt of the request.

Additionally, the data subject has the right to lodge a complaint concerning the processing of personal data by Matkahuolto with the data protection authority. Any complaint must be filed with the competent authority, in Finland with the Data Protection Ombudsman in accordance with the instructions they provide. Data Protection Ombudsman’s website

10. In conclusion

Matkahuolto reserves the right to update and revise this privacy statement. Matkahuolto will notify any changes in the processing of personal data in an appropriate manner. [Rivityskohta]Matkahuolto is not generally obliged to individually notify data subjects of any changes, for example, when the provision of such information proves impossible or would require unreasonable effort (for instance, when there are no up-to-date contact details on the data subject). Therefore, the data subjects are occasionally encouraged to check this statement for any changes.