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Privacy Policy

As required by EU Regulation 2016/679 (“GDPR”) and the Data Protection Act 2018 (“DPA”), the information below describes the processing operations and the purpose of the processing of the personal data of passengers (“Passengers”) at Flix.

All terms used in this Privacy Policy that are not explicitly defined shall have the meaning set in the GDPR.

1. Contact details of the controller

The data controller is Flixbus UK Ltd

Registered Office: First Floor, Templeback, 10 Temple Back, Bristol, United Kingdom, BS1 6FL
Business address: WeWork, 123 Buckingham Palace Road, London, SW1W 9SH

(“Flix” or “Controller”).

2. Contact details of the data protection officer

The Controller has designated a Data Protection Officer (DPO). The DPO is located at the offices of Flix SE, Friedenheimer Brücke 16, 80639 Munich, Germany, and can be contacted via the following e-mail-address:

data.protection@flixbus.com

3. Categories of personal data that are processed

Personal data includes all information that refers to a specific or identifiable natural person. The personal data of passengers processed in connection with the processing purposes mentioned in section 4 below are the following:

a) identification data and contact details of the passenger

b) travel data, type of service.

c) Payment data

The additional data may also be processed specifically for the processing of complaints:

d) date of receipt of any complaints and the reasons for the complaint indicated in the form filled in by the passenger.

e) any additional information provided by the passenger together with a complaint, including, if applicable, special categories of personal data (e.g. data on health).

The provision of personal data by passengers is voluntary. There is no legal or contractual obligation for the passenger to provide Flix with personal data. However, Flix may only be able to provide certain services to a limited extent or not at all, if the passenger does not provide the data required for this purpose.

Insofar as the personal data may not have been provided directly by the passenger, Flix has generally received this data from Flix SE as part of the booking process on the Flix-website. Flix SE’s privacy policy can be found on the website.

4. Purposes of processing and legal basis

The Controller shall process the categories of personal data referred to in Section 3 in order to:

a) fulfil the contractual obligations entered into with the passengers or certain contractual obligations towards the passengers or special requests of the passengers made before conclusion of the contract.

The legal basis for processing data for this purpose is that it is necessary for the fulfilment of a contractual obligation. This is lawful under Article. 6 (1) b GDPR.

b) investigate and appropriately deal with complaints filed by the passenger in all its stages, including any litigation.

The legal basis for the processing of data for this purpose is as follows:

(i) processing is necessary for the fulfilment of a contractual obligation. This is lawful under Article 6.1(b) GDPR.

(ii) processing is necessary for compliance with a legal obligation. This is lawful under Article 6.1©

(iii) processing is necessary for the purposes of the legitimate interests pursued by the Controller, i.e. the right to establish, exercise or defend legal claims. This is lawful under Article 6.1(f) GDPR.

c) sell tickets to the passenger on board in individual cases.

The legal basis for the processing of data for this purpose is as follows:

(i) processing is necessary for the fulfilment of a contractual obligation or for the implementation of pre-contractual measures. This is lawful under Article 6.1(b) GDPR

(ii) processing is necessary for the legitimate interests pursued by the controller, i.e. in particular the forwarding of payment data to the payment service provider for processing the payment you have arranged. This is lawful under Article 6.1(f) GDPR.

5. Categories of recipients

a) Internal controllers

Under certain conditions, we share personal data about you for the purpose of internal management within the companies of FlixBus, as far as this is permissible.

For example, personal data can also be forwarded to Flix SE for the purpose of internal management on the basis of the legitimate interest of the controller of the processing - e.g. the need for correct data and appropriate processing and handling of passenger complaints. Further details can also be found in the Flix SE privacy policy at the following link Data Privacy → FlixBus

b) External controller

As with any major company, we also use external domestic and foreign service providers to handle our business transactions and work with partner companies at home and abroad.

These include, for example:

  • sales partners
  • shop operators
  • security companies
  • other partners engaged for our business operations (e.g. auditors, banks, insurance companies, payment service providers, lawyers, supervisory authorities, other parties participating in company acquisitions)

c) Internal Processors

  • customer service providers (internal)
  • (IT) service providers

d) External Processors

  • customer service providers (external)
  • (IT) service providers
  • operating partners (you can find an overview of the current carriers here)

To the extent that the recipients work for us as processors, we enter into a contract with them and they must provide guarantees that appropriate technical and organizational measures are in place, that the processing meets legal requirements and that the rights of the data subjects are respected.

Passenger personal data is only accessible to persons acting on behalf of the controller or Processor.

We may also transmit personal data to public bodies and institutions (e.g. police, public prosecutor’s office, supervisory authorities) if there is a corresponding obligation/authorization.

6. Transfer of data abroad

In connection with the processing referred to in section 4, personal data may be transferred to a third country (in particular the USA). A third country is a country outside the European Union (EU) and outside the European Economic Area (EEA). In this case, we ensure through suitable measures that the level of data protection of the recipient/recipient country is not lower than the level of protection applicable in the EU/EEA. Suitable measures can be, for example:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data to a third country.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Duration of data storage and deletion

Passengers’ personal data will be stored only as long as necessary for the purposes according to section 4 for which the data is collected and subsequently processed.

In any case, the Controller may be obliged and/or entitled to keep the passengers’ personal data, in whole or in part, for a longer period of time - for example, but not exclusively, for the establishment, exercise or defense of legal claims within the respective applicable limitation period.

9. Rights of affected persons

The passenger as an affected person according to the GDPR has the following rights:

Right to information

The passenger may request information under Art. 15 GDPR about their personal data processed by Flix. In the request for information, passengers should clarify their concern in order to make it easier for the Controller to compile the necessary data. The Controller may require information to confirm the passenger’s identity to ensure they have the right to access the personal data.

Passengers will not have to pay a fee to access their personal data (or to exercise any of the other rights). However, Flix may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive. Flix may also refuse to comply with such a request.

Right to rectification

If the information concerning the passenger is not (or no longer) accurate, the passenger may request a correction in accordance with Art. 16 GDPR. If the passengers’ data is incomplete, the passenger may request its completion.

Right to deletion

The passenger can demand the deletion of his personal data under the conditions of Art. 17 GDPR. This right to erasure depends, among other things, on whether the data concerning the passenger is still needed by the controller to fulfill his legal duties.

Right to restriction of processing

Within the framework of the requirements of Art. 18 GDPR, the passenger has the right to request a restriction of the processing of the data concerning the passenger.

Right to data portability

Under the specifications of Art. 20 GDPR, the passenger has the right to receive data that the passenger has provided to the controller in a structured, common and machine-readable format or to demand that it is transferred to another responsible party.

Right to object

In accordance with Art. 21 (1) GDPR, the passenger has the right to object at any time to the processing of data relating to them for reasons arising from the passengers’ particular situation. Processing of that passenger’s data can then only take place if Flix is able to prove that there are legitimate reasons for the processing, which take precedence over the interests, rights and freedoms of the passenger, or in the case that the processing serves for the establishment, exercise or defense of legal claims by Flix.

In accordance with Art. 21 (2) GDPR, the passenger can object to being approached by advertising at any time with effect for the future (objection to advertising in the case of direct advertising).

Right of complaint

If the passenger is of the opinion that the controller has not complied with data protection regulations when processing their data, the passenger may make a complaint to the Information Commissioner’s Office.

Guidance on how to make a complaint can be found here:

https://ico.org.uk/make-a-complaint

Right to revoke consent (where provided)

The passenger can revoke their consent to the future processing of their data at any time. The lawfulness of the processing based on the consent prior to its revocation remains unaffected by the revocation.

This also applies to declarations of consent given before the GDPR came into force, i.e. before 25.05.2018.

The passenger may assert their rights as an affected person against the Controller at any time, in particular by using the contact details provided in sections 1 and 2 above.

10. Amendment

This Privacy Notice may be amended from time to time due to the introduction of new purposes and methods of processing. The Controller, at their own discretion, will inform the passengers in a timely and appropriate manner of any such amendments.

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