Data privacy statement of BLS Ltd
Table of contents
B. Customer promise
Public transport operators treat customer data confidentially.
You decide how your personal data will be processed.
We offer you added value when we process your data.
We will not sell your data.
We guarantee the security and protection of your data.
C. The processing of data by BLS
1. Who is responsible for data processing?
2. Why do we collect personal data?
3. What data do we store and what do we use it for?
3.1 When selling our services
- Personal photo
- Gender, name, email address of the purchaser/passenger
- Other information such as postal address, date of birth
- Phone number
- Means/method of payment
- Consent to our general terms and conditions
- Type of product or service purchased
- Place, date and time of purchase
- Sales channel (internet, vending machine, ticket counter, etc.)
- Date of travel or period of validity and time of Departure
- Place of departure and destination and travel itinerary
3.2 When using the website www.bls.ch:
- The IP address of your computer
- The date and time of access
- The URL of the linking web page with, if applicable, the search term used
- The name and URL of the files accessed
- The search queries carried out (timetable, general search on website, products, etc.)
- Your computer's operating system (provided by the user agent)
- The browser you are using (provided by the user agent)
- The type of device, if access is via a mobile phone
- The communications protocol used
3.3 When using our apps:
"lezzgo" ticketing app
The BLS Mobil timetable and ticketing app
3.4 When contacting our Customer Service via a contact form or by email
- Title, last name and first name
- Email address
3.5 When contacting our Customer Service by phone
3.6 Communication via chatbot
The BLS chatbot is your digital assistant. It helps you around the clock in submitting your enquiries and answering your questions.
Depending on the issue, when you use the chatbot, you will be asked for your re-quest, your name, e-mail address and telephone number as well as further data, e.g. regarding your online ticket or points card.
The data shared with the chatbot as well as the chat history are stored in the solution of knowhere GmbH, Steinhöft 9, D-20459 Hamburg for 90 days, after which they are deleted. Further information on data protection can be found directly at knowhere moin.ai Chatbot: Data privacy and GDPR compliance.
he contact details enable us to reach you in case of queries.
Data on the online ticket and the points card enable us to find the necessary docu-ments in our systems to help you.
The chatbot will be further developed using the questions you enter. For example, we can develop new answers for the chatbot or improve existing answers.
3.7 Contacting us in the context of a BLS social media campaign
- Title, last name and first name
- Email address
3.8 When registering as a customer on BLS websites
- Email address
- Consent to our general terms and conditions
3.9 When creating a SwissPass login/customer account at www.swisspass.ch.
- Surname and first name
- Date of birth
- Address (street, postcode, city and country)
- Customer number (if you are an existing public transport season ticket hold-er)
- Email address and password (login data)
3.10 When using our rolling stock and railway stations
In accordance with Art. 55 of the Passenger Transport Act (PTA) and Art. 16b of the Railways Act (RailA), as well as the Implementing Provisions of the CCTV Surveillance of Public Transport Ordinance (PT-CCTVO), BLS and BLS long-distance traffic Ltd monitor their trains, Busland AG its buses and BLS Netz AG its railway stations in the form of CCTV surveillance. Furthermore, BLS also uses CCTV surveillance to monitor its administration building and workshops. The CCTV surveillance serves to protect customers, operations and infrastructure.
CCTV surveillance involves recording picture signals which make it possible to identify individuals. The recordings are predominantly stored on-site in vehicles, whereas recordings of facilities and properties are stored in a central location. All recordings are stored for a maximum of 10 days and then automatically deleted. Recordings are only backed up if incidents are detected. Backup orders and backup may only be triggered or carried out by clearly defined business units within BLS.
Backed up recordings containing personal data are generally evaluated on the next working day. By way of exception, it may be carried out within two additional working days for operational or technical reasons. Evaluations are conducted in the following cases:
- In case of security and vandalism incidents on or in the vehicles, in or on the rolling stock and on infrastructure;
- based on official decisions;
- on information requests of data subjects (cf. Chapter 10 below).
The evaluation is only conducted by the competent and authorised business units within BLS.
Backed up recordings are stored in such a way that they are protected against unauthorised access. Recordings will be destroyed no later than 100 days after the date on which they were created, unless they are disclosed in accordance with the following explanations.
Recordings are only disclosed to the following authorities:
- responsible authorities of the Confederation and cantons;
- the authorities with whom the companies file a complaint or assert legal claims.
The disclosure only takes place to the extent that this is required for the process. In case of a disclosure, the recordings are stored until such time as the proceedings have been legally completed.
3.11 When contacted by BLS for marketing purposes
- Each email you receive from us or other public transport operators contains an unsubscribe link that you can click to unsubscribe from further messages.
- If you have a SwissPass login, you can sign in to your user account here https://www.swisspass.ch/oevlogin/login at any time to manage the message settings in your user account.
- You can also subscribe or unsubscribe at any ticket counter or by phoning 058 327 31 32 or using the contact form here.
3.12 In connection with market research
3.13 Participation in competitions, prize draws and similar events
4. Will your data be shared with third parties?
We will not sell your data. We will share your personal data only with selected service providers and only to the extent necessary to provide our service. In particular, the following service providers are involved here:
- IT service providers
- Issuers of season tickets
- Delivery companies (such as Swiss Post)
- Address management service providers to ensure address quality and possibly to enhance additional features like household size, home ownership, age, in-come group, etc.
- Leisure partners in the context of using joint offers
- External service providers in Switzerland and abroad in the context of travel agency services (e.g. via BLS Travel Centres)
- Service providers commissioned to distribute the income from fares among the transport operators involved (in particular for the purpose of calculating the distribution model in accordance with the Swiss law (PBG) governing the carriage of passengers)
- Our hosting provider (see the section titled "Use of website")
- The providers mentioned in the sections on tracking tools, social plug-ins and advertisements.
BLS shall be entitled to bring in third parties to render the services and for market research and market processing purposes at home and abroad. If BLS brings in third parties, the customer agrees to customer data being passed on and processed by these third parties if necessary for the cooperation. BLS is obliged to carefully select, instruct and control the service providers.
Please refer to the section "Will your data be disclosed abroad?" for more information on service providers domiciled abroad.
Your data may also be shared if we are legally obliged to do so or if it is necessary to safeguard our rights, in particular to enforce claims arising from our relationship with you.
If you book a cross-border journey, your data will be shared with the foreign companies providing this service. However, the personal data shared will be limited to what is needed to check the validity of the tickets and to prevent misuse.
Our legitimate interest forms the legal basis for processing this data.
Your personal data will not be disclosed to third parties outside the public transport industry. The only exceptions to this are (to the extent described below) SwissPass partners and companies authorised by public transport operators to sell public transport services on the basis of a contractual agreement. These sellers will only be given access to your personal data if you wish to obtain a public transport service through them and you have given them your consent to use your data. Even under these circumstances, they will be able to access your data only for the purpose of determining whether you already have tickets or season tickets for the period during which you intend to travel that are valid for your journey or for the service you have asked the third party to provide.
The legal basis for processing this data is therefore your consent. You can withdraw your consent at any time with future effect (see Section 8 above).
If you use your SwissPass to obtain services from a SwissPass partner (see overview here), personal data on any services you have purchased from us (such as a GA travelcard, half-fare travelcard or season ticket) may be shared with our SwissPass partners in order to ascertain whether you could benefit from a specific offer from the SwissPass partner (such as a discount for GA card holders). If your ticket is lost, stolen, misused, falsified or replaced after a service has been purchased, the partner concerned will be informed. We need to process your data so that we can fulfil the contract on the use of the SwissPass and this is therefore the lawful basis for processing. You will find further information on this in the data privacy statement on swisspass.ch (see here) and in the data privacy statement of the SwissPass partner concerned.
5. What does "shared responsibility in public transport mean"?
BLS is responsible for processing your data. As a public transport operator, we have a legal obligation to collaborate with other transport operators and partners in the provision of certain passenger transport services ("Direct Service").
For this purpose, and for other purposes described in this data privacy statement, we share data at national level within the "National Direct Service" (NDS), an association of over 240 transport operators and public transport partner companies. The individual TSPs and partners are listed here. Data acquired from customers who purchase services or supply contact details are stored in a central database which is managed by SBB on behalf of NDS and for which we are jointly responsible with the other NDS companies and partners (the DS database).
When services are purchased by customers using the SwissPass login, the data is stored in another central database (the SwissPass database) which is managed by SBB on behalf of NDS and for which we are jointly responsible with the TSP and the NDS community. Data used in conjunction with the acquisition of BLS-specific services (e.g. leisure activities). These are only stored in BLS’s customer database.
To improve service efficiency and streamline the working relationship between the companies involved, data from the different databases may be merged in the SwissPass database. To enable single sign-on (SSO) (a system that enables SwissPass users to access multiple services with just one login), we share login, card, customer and service data with the central SwissPass login infrastructure during the authentication process.
Access by individual TUs and partners to the shared databases is regulated and limited by a contractual agreement. The sharing and processing by the other TSPs and NDS partners who use the central database is normally limited to contract processing, ticket control, after-sales service, the Customer information and revenue distribution. Data collected during purchase transactions for NDS services (cf. product overview here) is also used for marketing purposes in certain cases. These include analysing the data to improve and promote public transport services in line with customer needs. If you are contacted for this purpose, it will normally be by us at BLS. The other TSPs and partner companies associated with NDS will contact you only in exceptional circumstances and under strict conditions, and only if an analysis of the data shows that a particular public transport service would be beneficial for you as a customer. Contact by SBB is the one exception to this rule. SBB handles the marketing of NDS services (such as GA and half-fare travelcards) on behalf of NDS and may contact you at regular intervals in connection with these services.
Our legitimate interest forms the legal basis for processing this data.
6. Are your data processed by means of automated decision-making?
You will be informed if we process your data by means of automated decision-making. Under certain conditions, you have the right to demand to be excluded from automated decision-making. You will be informed if these conditions are not met.
7. Will your data be disclosed abroad?
In principle, your data will be stored in databases within Switzerland. However, in some cases listed in this data privacy statement, the data will also be passed on to third parties based in the EU. The EU countries have an adequate level of data protection compared to Switzerland.
8. How long is your data kept for?
- to provide the services described in this data privacy statement that you have requested or for which you have given your consent;
- to use the tracking services described in this data privacy statement within the scope of our legitimate interest.
9. How are tracking tools used?
The following tracking tools are used on our websites:
- Google Analytics
- Sitecore Analytics
We use the web analysis services of Google Analytics, ClickDimensions, Hotjar and Sitecore Analytics to help us configure and continuously optimise our website, apps and emails according to need. Our legitimate interest forms the legal basis for the data processing described below.
• Website tracking:
When you visit our website, we create a pseudonymised user profile and save small text files ("cookies") on your computer (see Section 12 below "What are cookies and when are they used?"). The information generated by these cookies about how you use our website is sent to the servers of the companies who provide these services, where it is stored and processed for us. In addition to the data listed above (see Section 3.2 ("What data is processed when you use our website?"), through this we obtain the following information:
- The visitor's navigation path through the website
- The time spent on the website or subpage
- The subpage from which the visitor leaves the website
- The user's access location (country, region or city)
- The accessing device (type, version, colour depth, resolution, width and height of the browser window)
- Whether the visitor is a returning or new Visitor
- The browser type/version
- The operating system used
- The referrer URL (the previously visited website)
- The hostname of the accessing computer (IP address) and
- The time of the server request
This information is used to evaluate how our website is being used.
- Tracking when sending emails:
When sending emails, we make use of email marketing services provided by third parties. Our emails may therefore contain a web beacon (tracking pixel) or similar technology. A web beacon is an invisible 1x1-pixel image that is as-sociated with the user ID of the particular email subscriber.
For each newsletter/mailing we send, we have information on the address file used, the content, the email subject and the number of newsletters sent. In addition, we can see which addresses have not yet received the email, which addresses it has been sent to, and the addresses to which delivery was unsuccessful. We can also see the open rate, including information on which addresses have opened the mailing and which addresses have unsubscribed from the distribution list.
We make use of specialist services to enable us to evaluate the above information. These also allow us to also record and evaluate click behaviour. We use this data for statistical purposes and to optimise the content of our messages. This allows us to tailor our email content and our offers so that they are more likely to be of interest to the recipients. The pixel image is deleted when you delete the email.
If you wish to prevent the use of web beacons in our emails, please set your email program to disable display of messages in HTML format, if this is not already the default setting. You will find instructions on how to do so here, for example.
Below is more information about our tracking tools:
Our website uses Google Analytics, a web analysis service provided by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA and Google Ireland Limited, Gordon House Barrow St, Dublin 4, Ireland. To enable it to analyse website usage, Google Analytics uses technologies such as cookies (see Section 12 below, "What are cookies and when are they used?"). The information generated by a cookie about your use of this website, as explained above, is sent to servers in the United States belonging to Google, a company of the holding company Alphabet Inc., and stored there. Because IP anonymisation has been activated on our website, your IP address will be truncated by Google if you reside in a member state of the European Union, or any country party to the Agreement on the European Economic Area, or Switzerland. Google will not associate the anonymised IP address supplied by your browser to Google Analytics with any other data held by Google. Only in exceptional cases will the full IP address be sent to Google servers in the USA to be shortened. In these cases, Google offers a contractual guarantee that it will maintain an adequate level of privacy protection.
This information is used to monitor traffic on our website, compile reports on how visitors use our website and provide additional services in connection with the use of the website and the internet for purposes of market research and improving our website. The information may also be shared with third parties if this is required by law or if the third parties are processing the data on our behalf. According to Google, the user's IP address will never be associated with other data relating to the user.
Users can prevent Google from using cookies to collect and process data relating to their use of our website (including their IP address) by downloading and installing the browser plug-in here.
You can object to Hotjar storing a user profile and information about your visit to our website and the placement of Hotjar tracking cookies on other websites if you click on this opt-out link.
ClickDimensions is a service integrated in Microsoft Dynamics 365 CRM and the data are processed in the EU. . Among other things, it enables professional e-mail marketing and automated campaigns. ClickDimensions enables the analysis, planning, organisation, conduction and monitoring of marketing measures. The main function of ClickDimensions is email marketing. Emails can be created, sent and traced via ClickDimensions. Performance statistics flow back into Microsoft Dynamics 365 during this process. After a marketing email is sent, real-time information is available which allows conclusions to be drawn as to which recipients visited a website and what interested them, for example.
We use the Tracking Tool and associated Sitecore Analytics cookie primarily for the purpose of linking page hits to specific user profiles. It is also used so that we can individually adapt the presentation of the website for you and provide you with per-sonalised advertising. We store the page hits per session and evaluate these in order to offer you appropriate and personalised content. The Sitecore Analytics Cookie identifies you anonymously and remains in place over several sessions. Following a SwissPass login, use of a contact form or a visit to a newsletter page, you can be identified via user data so that the above-described information is available not only across multiple sessions but also multiple devices. We store the date and time as well as the pages accessed on our website. In addition, the cookie also helps us to analyse the behaviour of website users and adjust content to the needs of users. The data are processed in Switzerland or the EU.
10. What are cookies and when are they used?
Disabling cookies may mean that you cannot use all of our website’s functions. The legal basis for processing this data is our legitimate interest.
11. Social plug-ins
Integrating social plug-ins enables website operators to use certain services of social networks like Facebook, Twitter, etc. on their own websites. With the help of the Facebook’s Like button, for example, website visitors can share the website on their Facebook profile with a single click of the mouse. The website operators hope that this will quickly lead to higher visitor numbers for their site. The integration is also used to receive detailed statistical information about website users.
Social plug-ins are disabled on our websites.
12. Advertisements on our website and in our apps
13. Data security
We use appropriate technical and organisational security measures to protect your personal data stored by us from manipulation, partial or complete loss and unauthorised access by third parties. Our security measures are continually improved to keep pace with technological developments. We also take internal data protection very seriously. Our staff and external service providers are themselves required to observe secrecy and to comply with data protection regulations. We take all necessary steps to ensure the safekeeping of your data. Sending information via the internet and other electronic means, however, always involves a degree of risk and we cannot guarantee the security of sent information in this way.
14. What rights do you have over your personal data?
- You can request information about your stored personal data.
- You can request that your personal data be corrected, supplemented, blocked or deleted. Your data will be blocked rather than deleted if there are legal obstacles to its deletion (e.g. legal storage obligations).
- If you have set up a customer account, you can delete the account or ask for it to be deleted.
- You can object to the use of your data for marketing purposes.
- You can withdraw your consent at any time with future effect
- You can ask for your data to be transferred to a third party.
Requests for information from the information system on passengers without a valid ticket in accordance with Art. 20a of the Swiss Federal Law on Passenger Transport (Bundesgesetzes über die Personenbeförderung, PGB) should be sent to the operator of the system at the following address:
PostAuto AG, 'SynServ', Pfingstweidstrasse 60b, CH-8080 Zurich
or via e-mail to: email@example.com
15. Changes to the data privacy statement
Amendments to this data privacy statement may be required from time to time, for example due to the further development of our digital presence, new offers or changes in legislation. BLS reserves the right to amend the data privacy statement at any time with future effect. We therefore recommend that you read this data privacy statement on a regular basis.
Last amended in July 2021