Effective: June 7, 2021
- An introduction to our privacy practices
- A description of the personal information TriMet collects
- An overview about how TriMet uses your personal information
- Information about when TriMet shares your personal information with third parties
- A summary of the security measures we’ve implemented
- Information on options you have regarding our use of your personal information
- TriMet’s Do Not Track policy
TriMet operates a variety of online and electronic services to further our mission of providing a safe, dependable and easy-to-use transit system. We collect your personal information in various ways through our Services. We protect your personal information and generally do not share it with unaffiliated third parties, except as detailed below.
TriMet operates public transportation services in the Portland metro area. In cooperation with Clark County, Washington’s C-TRAN and the City of Portland’s Streetcar, TriMet connects people with their community. As part of TriMet’s mission to provide a transit system that is safe, dependable and easy to use, TriMet offers various services, including our Website, Apps and other electronic offerings comprising our Services. Some of the Services require you to provide personal information directly, such as your name and contact information, and some of the Services automatically collect information from your device, such as geolocation and browser information.
We take commercially reasonable efforts to protect your personal information and will only provide it to third parties (1) as stated in this notice; (2) to provide you with Services or products you order; and (3) as permitted or required by law.
- You use our Websites, including trimet.org and myhopcard.com.
- You use our Apps, including the Hop Fastpass® app.
- You use a Hop Fastpass electronic fare card, tap a registered fare card or contactless bank card on one of our card readers on vehicles or at stations.
- You apply for reduced fare or paratransit services.
- You make a purchase of gear, posters or accessories from our Store.
2. Information Collected
We collect your personal information when you interact with TriMet through our services. In addition, certain information — such as location information, device details and cookie data — is transmitted to us automatically when you use our services. Aggregate and non-personal information, which cannot be used to identify you individually, helps us deliver relevant and responsive services — this notice does not restrict how we use such non-identifiable data. We do not knowingly collect personal information from users under the age of 13.
2.1. When you (or someone on your behalf like an employer, educational institution, or the TriMet Customer Service Center) apply for Services or create an account with TriMet to enable access to certain features of the Services, we may require that you provide us with your name, email address, mobile number, address, and birthday. You will then create a username, password and four-digit PIN, information that allows us to confirm your identity on subsequent visits and makes it easier to use our Services. Additional information, including health related or financial information, may also be required to take advantage of certain reduced fare or paratransit Services we offer.
Payment Card Information
2.2. When you buy fares or products, or load your Hop Fastpass® card via the Services, you will be asked to provide payment card details. TriMet uses a third-party payment processor to handle payment card transactions and does not store or process your payment card information.
Third Party Advertising
Interacting with TriMet
2.5. You also provide personal information when you interact with TriMet. For example, when you contact TriMet by email, we will collect your email address and any other personal information you provide. When you subscribe to one of our electronic newsletters, you must provide your name and a valid email address. If you participate in a TriMet promotion, you may be required to provide certain contact information. You may also provide your address, telephone number and organizational affiliation. If you participate in a voluntary survey, you may choose to provide us with demographic information. If you apply online for a job with TriMet, we will collect personal information such as your name, address, resume details and other employment-related information you provide. This applicant information is only used by us for consideration of your employment.
Using the Services
2.6. TriMet collects certain information automatically when you use the Services. For example, if you use our TransitTracker or Trip Planner, your device’s geolocation information (provided location services are enabled on your device) may be collected so we can alert you when your bus, train or streetcar is arriving. This geolocation information is encrypted and generally not subject to public records requests. We also receive the internet protocol (IP) address of your computer, mobile-device or the proxy server or router that you use to access the internet, operating system details, type of web browser, mobile device details (including your mobile device identifier provided by your mobile device operating system) and search data. This information is used by us to provide a streamlined user experience and ensure the security of the Services.
Cookies and Web Beacons
Aggregated and Anonymized Information
Information from Children Under 13
2.9. TriMet complies with the requirements of the Children’s Online Privacy Protection Act (“COPPA”) and the Federal Trade Commission’s rule interpreting COPPA (16 CFR § 512). The Services are not directed at individuals younger than age 13, and we do not knowingly collect any personal information through the Services from anyone under 13. If we learn that we have personal information of an individual under age 13 has been provided to us without parental or legal guardian consent, we will delete this information from our databases.
3. How TriMet Uses Your Personal Information
Submission to TriMet
Communications from TriMet
3.2. We communicate with you through email, notices posted through the Services, and other means available through the Services, including mobile text messages (where you opt-in) and push notifications (where enabled by you). Examples of these communications include:
- Service communications: Informing you how to use the Services, including any new features of the Services, alerting you about the availability of the Services and transit systems, confirming purchases and providing information about other issues related to our Services. You cannot opt out of receiving service messages from us.
- Promotional communications: Sharing information about TriMet’s products and services, including notifying you that you may be eligible for certain benefits.
- Response communications: Responding to an inquiry by you, either through the Services, social media or other channels.
Providing, Developing and Customizing the Services
3.3. TriMet uses your personal information to provide you with the Services you have requested. For example, if you sign up for an electronic newsletter, we use your name and email address to send you the newsletter. If you use our trip planning features (TransitTracker or Trip Planner), we may use your location information. We may also use your personal information to improve features of the Services, such as when you provide feedback to TriMet customer service agents. We also use this information to track potential problems and trends and to customize our support responses to better serve you.
TriMet may combine personal information you provide through your various interactions with TriMet and TriMet’s service providers in order to provide a more customized and relevant experience. For example, if you contact us from an email address we have on file, we will make a note of that communication in your customer profile.
When you register for a Service, TriMet uses your personal information to set up your account. TriMet also uses personal information to enforce and protect its rights, including in connection with electronic citation processing.
4. How TriMet Shares Your Personal Information
We do not sell, rent or disclose personal information to any unaffiliated third party, with the limited exceptions of service providers, our transit partners C-TRAN and Portland Streetcar, and recipients who are entitled to the information for legal or safety reasons.
Service Providers and Transportation Partners
4.1. TriMet may share personal information with service providers and transportation partners that assist TriMet in providing, improving and marketing the Services. For example, TriMet may engage an email service provider to manage our electronic newsletters and promotional communications, a technology company to build software or apps, a payment processor to process purchases on the Store or to reload Hop Fastpass cards, or an analytics provider to study user habits. TriMet may also share your personal information with transportation partners to provide you with a service you requested through a partnership or promotional offering made by a third party or us. These third parties have limited access to your information only to perform these tasks on our behalf.
C-TRAN and Streetcar
4.2. If you use the Hop Fastpass® system in connection with C-TRAN or Streetcar services, TriMet may share your personal information with C-TRAN or Streetcar so that C-TRAN and Streetcar may provide and improve their own services. C-TRAN or Streetcar may only use your personal information for those purposes. Information that you provide directly to C-TRAN or Streetcar is governed by their respective privacy policies.
Disclosures Required by Law or for Compliance Reasons
4.3. We may need to disclose your personal information to law enforcement agencies, but only when compelled by law, subpoena or other legal process. In addition, we may disclose certain personal information if we have a good faith belief that disclosure is reasonably necessary to:
- Enforce the Terms of Service or the TriMet Code, investigate and defend against any third-party claims or allegations, or protect the security or integrity of our Services.
- Exercise or protect the rights, property or safety of TriMet personnel, users of our Services, or the public.
We’ll attempt to notify you about legal demands for your personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. Unless compelled by law, TriMet will not provide personal information to the U.S. Immigration and Customs Enforcement (ICE) or any similar agency for immigration enforcement purposes.
Public Records Laws
4.4. You should be aware that TriMet is a public agency and is subject to public records laws. Personal information provided by you may be subject to disclosure pursuant to public records laws, unless the information is exempted by law. You should not provide personal information if you are concerned about disclosure of your information under those laws.
We understand your security concerns and strive to take appropriate precautions. However, given the inherently vulnerable nature of the internet, we cannot guarantee absolute security.
We take commercially reasonable precautions to protect your personal information from unauthorized or unlawful access or destruction. For example, we encrypt certain communications through our Services. However, no method of transmission over the internet or form of electronic storage is 100 percent secure. Therefore, we cannot guarantee the absolute security of your personal information.
If you have any questions about the security of our Services, you can send a message to firstname.lastname@example.org.
6. Your Choices
We offer various ways to opt out of certain information sharing and communications.
6.1. If you create a Hop Fastpass® account, you may update or change your information by logging into your account and accessing your profile. If you create an account for rider news and service updates at trimet.org/email, you may update or change your information by logging into your account and accessing your profile.
6.2. If you no longer wish to receive communications from TriMet, you can do so by:
- Clicking the “Unsubscribe” link within the promotional email you received or by (with regards to Hop Fastpass® communications) calling 1-844-MYHOPCARD.
- Preferences for communications you have opted into at trimet.org can be changed at trimet.org/email or by clicking the link in the email.
- Replying STOP to the applicable text message.
Note that you cannot opt out of initial or service communications.
6.3. Most mobile devices allow you to turn off or disable location services which will prevent real-time location data from being sent to us. If you turn off location services, not all features of the Services will function.
Contacting TriMet for Changes
6.5. You may also contact us at email@example.com to find out what personal information we have about you and to change your personal details.
7. Do Not Track
Some browsers offer a “Do Not Track” (“DNT”) privacy preference. Generally, when a user turns on the DNT signal, their browser sends a message to websites requesting that the user not be tracked. TriMet’s Website does not currently respond to DNT signals.
8. Important Information
Links to Other Websites
Notification of Changes
Services Provided in the United States
8.4. TriMet is a municipal corporation of the State of Oregon and a public body and as such, is not subject to certain U.S. state privacy laws including the California Consumer Privacy Act.