1. Introduction

Thank you for expressing interest in Invisible Tickets pilots being conducted by ING Bank N.V in association with various public transport operators.

If you visit our website or in any other way contact us, we may process your personal data. By “processing” we mean everything we can do with this data such as collecting, recording, storing, adjusting, organising, using, disclosing, transferring or deleting that data.

This Privacy Statement aims to explain in a simple and transparent way what personal data we gather about you and how we process it.

As Invisible Tickets is a part of ING Bank N.V., please also refer to the ING Privacy Statement located at ing.com for further information about how ING processes data and your privacy rights and obligations. 

2. Personal data

Personal data refers to any information that tells us something about you and that we can link to you. If you contact us, we will process personal data that you provide to us, such as your full name and email address.   

3. Legitimate purposes

We only use your personal data for legitimate business reasons.

This includes:

• validating interest in proposed goods and services to be offered by Invisible Tickets;

• contacting you about Invisible Tickets our proposed initiative and any upcoming pilots; and

• if necessary, to comply with our legal obligations.

4. Data transfer to third parties

We may disclose personal data to third parties like regulators if required to do so by law. When we use other service providers we only share personal data that is required for a particular assignment. Service providers support us with activities like:

• performing certain services and operations

• designing and maintenance of internet-based tools and applications; and

• preparing reports and statistics, printing materials and designing products.  

5. Data retention

We are only allowed to keep your personal data for as long as it’s still necessary for the purpose we initially required it. After this we look for feasible solutions, like archiving it.

6. Your rights

It is possible for you to access or correct your personal data that we hold. Please find below your rights and how you can adjust your data. 

a. Right to access personal data: if you want to know which personal data we process, you can use your right to access your personal data by sending an email to hello@invisible-tickets.com 

b. Right to correct personal data: if your personal data is not correct, you can request us to adjust your personal data by sending an email to hello@invisible-tickets.com 

c. Right to complain: Should you not be satisfied with the way we have responded to your concerns you have the right to submit a complaint to us. If you are still unhappy with our reaction to your complaint, you can escalate it to the ING Bank Data Protection Officer. You can also contact the data protection authority in your country.

Please refer to the ING Privacy Statement for a full overview of your rights and how to exercise them.

7. Changes

We can change our Privacy Statement. The date of the last adjustment was 4 June 2018. Please check our Privacy Statement regularly for the latest version. 

8. Regulatory information

ING has its statutory seat in Amsterdam at Bijlmerplein 888, 1102 MG, The Netherlands, Trade Register number 33031431. ING is regulated and licensed by the De Nederlandsche Bank (‘DNB’) and the European Central Bank (‘ECB’) for payment services. ING is also regulated and licensed by the Autoriteit Financiële Markten (‘AFM’) and regulated by the Autoriteit Consument & Markt (‘ACM’). Information regarding supervision of ING can be obtained from DNB (www.dnb.nl), AFM (www.afm.nl) or ACM (www.acm.nl).

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