1. Introduction


This pilot version of the Invisible Tickets App ("App") provided by ING Bank NV ("we", "us" or "ING") is a hardware free, digital ticketing solution. We carefully safeguard the information we hold about you. This Statement tells you about what information we might have, what we can use it for, and when we may need to share it with others. Related details are set out in our App Terms and Conditions, which should be read alongside this s.

As the Invisible Tickets initiative 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. The type of personal data we collect


Personal data refers to any information that tells us something about you and that we can link to you.

We may collect and use the following information about you:


• Information you give us: You may give us information about you by filling in forms on, or interacting with, the App, or by corresponding with us by phone, email or otherwise. The information you give us may include your name, address, email address and phone number.


• Information from others: Although we will not collect your IBAN or credit card account details, which you will provide directly to Acapture, we will receive a copy of the direct debit mandate as is required by law.


• Information we collect from you: During the pilot, we will collect GPS based location data of the smartphone on which you have installed the App, along with data from other sensors on your phone. Also, when you use the App we may automatically collect technical information (including device details and your login information) and information about each use of the App (such as configuration changes and duration of use).


3. What we do with your personal data


We only use your personal data for legitimate business reasons.

We may use the personal data about you to:

• deliver the App services to you during the Pilot – these are described in the App Terms and Conditions;

• improve and assess the use of the App;

• perform research and trend analysis;

• manage your user experience and provide you with support;

• take action if we need to rely upon our rights under the App Terms and Conditions; and

• comply with laws and regulations, as well as any sector-specific guidelines and regulations.



4. Who we share your personal data with and why


We will only share your information with a very limited group of people. This will happen either where we have a duty to disclose it, or we need to disclose it to provide the App to you, or law or regulation allows us to disclose it for other legitimate purposes. 


This includes disclosure to:


• Our service providers and agents (including their sub-contractors). This may happen where they help us run the technology systems that are needed to develop and operate the App and performing other services and operations (such as customer resource management and mailing list management).


• Regulators in connection with their duties, such as crime prevention or carrying out regulatory oversight of what we do.



5. Google Analytics


Invisible Tickets uses Google Analytics to perform statistical analyses about the way you use the App. Google Analytics collects first party cookies, data related to the device, IP address of your device and on-site/app activities. Identifiers such as cookies and app instance IDs are used to measure user interactions with a customer’s sites and/or apps, while IP addresses are used to provide and protect the security of the service, and to give the customer a sense of where in the world their users come from.

Google Analytics collects an app-instance identifier — a randomly generated number that identifies a unique installation of an app. Whenever a user resets their Advertising Identifier (Advertising ID on Android, and ID for Advertisers on iOS), the app-instance identifier is also reset.

For more information about Google Analytics and how it collects and processes data please visit https://policies.google.com/technologies/partner-sites



6. Crashlytics


Invisible Tickets uses Crashlytics, which is a service provided by Google Ireland Limited. Crashlytics provides us with information about crashes and malfunctions relating to the App. In order to provide their services to us, Crashlytics collects data such as: device state information, unique device identifiers, location data and usage data.

For more information about the Crashlytics service and how it collects and processes data please visit https://fabric.io/terms?utm_campaign=crashlytics-marketing&utm_medium=natural

As this is a pilot version of the app, by downloading and using the App you consent to the transfer to Crashlytics of the data referred to above. If you do not consent to the transfer of your data in this manner, you cannot use the App.



7. Marketing


While we may use your personal data to contact you about Invisible Tickets and any future pilots, we will not use your personal data for other marketing or promotional purposes. If you don’t want to participate in any future pilots, then please let us know.


8. 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.


9. Your rights


We respect your rights to determine how your personal information is used. These rights include:


a. Right to access personal data: You have the right to ask us for an overview of your personal data that we process by sending an email to hello@invisible-tickets.com.


b. Right to rectify personal data: if your personal data is not correct, you can ask us to rectify 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.


10. Changes

We may change our Privacy Statement from time to time. The date of the last adjustment was 19 Nov 2019. Please check our Privacy Statement regularly for the latest version.


11. Regulatory information

The Invisible Tickets initiative is part of ING Bank N.V. (‘ING’). 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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