Privacy Policy

Thank you for visiting STA’s Websites and reviewing our Privacy Policy. Your privacy is one of our top priorities. We view this Privacy Policy as a privacy partnership between STA and you, our valued customer. The following policy applies to the use of all STA’s Websites (“Website”), mobile applications (“Apps”), online pass store, Connect Fare Collection System (“Connect”), and other electronic offerings (collectively referred to as the “Services”). External websites may have different policies. We strongly suggest that you read the privacy policies for each website that you visit, and any external site that you visit through a link appearing in the Services.

We seek to protect your privacy to the maximum extent possible. However, because information that we receive through the Services is subject to the Washington State Public Records Act, except for personally identifying information in fare media (RCW 42.56.330(5)), and due to the nature of Internet communications, we cannot ensure absolute privacy. Information that you provide to us through the Services may be made available to members of the public under that law. This Privacy Policy is designed to explain the specific privacy protections we provide to you resulting from your use of the Services. This Privacy Policy informs you of the information that we collect from you through your use of the Services, what we do with it, to whom it may be disseminated, and how you can access it. Based on this information, you can make an informed choice about your use of the Services. You can maximize the benefits of your privacy partnership with STA by making informed choices about whether to share personally identifiable information with us through the Services.

Acceptance of this Privacy Policy

By using the Services, you agree to the terms and conditions of this Privacy Policy. Without limitation of the foregoing, you understand and agree that (1) the information collected by STA may be stored indefinitely, (2) STA may store, access and use the information in any jurisdiction, including jurisdictions in which the privacy laws may be different and less protective than those in your home jurisdiction, and (3) STA will not share any information submitted to the Services with any other organization or individual unless required by law to do so. Please do not use the Services ifyou do not agree to the terms and conditions of this Privacy Policy.

Changes to this Privacy Policy

STA reserves the right to change this Privacy Policy at any time and will post the modified Privacy Policy on our Website. We encourage you to review our Privacy Policy whenever you visit our Website to make sure you understand how your information will be used. Legislative changes to the Washington State Public Records Act may also cause changes to how your information will be used.

Information Collected

A. Account Information

When you (or someone on your behalf like an employer, educational institution, or STA’s Customer Service Center) apply for Services or create an account with STA 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 birthdate. You will then create a username, password and four-digit PIN, and 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 discounted fares or paratransit services we offer.

B. Payment Card Information

When you buy fares or products, or load your Connect card via the Services, you will be asked to provide payment card details. STA uses a third-party payment processor to handle payment card transactions and does not store or process your payment card information.

C. Social Media

We may collect personal information about you from third parties, such as online social networks, if you take part in a forum, for example, or follow STA on Facebook or Instagram. We may collect personal information when you click “Share This” or “Like” buttons or otherwise use social media buttons, plug-ins, or refer to us using hashtags. Note that any personal information collected by a third party, such as a social networking site, is handled based on their privacy practices rather than this Privacy Policy.

D. Third Party Advertising

STA uses certain third parties to promote our services and serve ads on our behalf through the internet. These third parties may use cookies to collect information about your visits to our Website or use of our Apps, as described in Section F below. They also may use information about your visits to our Website and Apps to serve targeted advertisements that are relevant to you. Those advertisements may appear on other sites that you visit.

E. Interacting with STA

You also provide personal information when you interact with STA. For example, when you contact STA by email, we will collect your email address and any other personal information you provide. If you participate in an STA 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 STA, 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.

F. Using the Services

STA collects certain information automatically when you use the Services. For example, if you use our STALinked 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 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.

G. Cookies and Web Beacons

We may also automatically collect certain information through the use of “cookies”. Cookies are small data files that are stored on a user's computer or device and downloaded to the computer or device when visiting a website. Cookies then send information back to the originating website on each subsequent visit or to another website that recognizes that same cookie. Cookies can store certain information such as customer preferences, including language, and navigation history. We may use cookies to aggregate personal information collected automatically with data (including personal information) previously stored from other interactions with our Website or Apps and third-party sites. We examine metrics, such as which pages you visit or features you use, which links you click on and resources you view, the performance of our marketing efforts, and your response to those marketing efforts. This allows us to offer relevant and useful information to users of our Services. If you wish to opt out of allowing certain cookies, you may do so by changing your browser settings so that cookies from our Website cannot be set. Please note that if you delete, block, or otherwise restrict cookies, or use a different computer or internet browser, you will need to renew your cookie management choices.

H. Aggregated and Anonymized Information

STA collects certain information that is aggregated and anonymized, including statistical information, about how users as a whole access and interact with the Services (e.g., which Service features and web pages are most accessed, which bus routes are most used, how many people open our newsletters, which technical issues affect our users, etc.). This aggregated and anonymized information cannot be used to identify you individually and is not considered personal information. This Privacy Policy does not limit how STA may use aggregated and anonymized information.

I. Information from Children Under 13

STA 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 which has been provided to us without parental or legal guardian consent, we will delete this information from our databases.

How STA Uses Your Personal Information

A. Submission to STA

When you provide your personal information to STA either when you create or update your account or interact with the Services, you agree to our use and processing of your personal information as set out in this Privacy Policy. You can update your preferences associated with our use of your personal information by changing your account settings, closing your account, and/or deleting the Apps from your device(s). Any personal information STA collected prior to a change in preferences or deletion of your account will be retained in accordance with our data retention policies and applicable laws.

B. Communications from STA

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:

1) 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 the Services. You cannot opt out of receiving service messages from us.

2) Promotional communications: Sharing information about STA’s products and services, including notifying you that you may be eligible for certain benefits.

3) Response communications: Responding to an inquiry by you, either through the Services, social media, or other channels.

C. Providing, Developing, and Customizing the Services

STA uses your personal information to provide you with the Services you have requested. For example, if you sign up for electronic rider alerts, we use your name and email address to send you alerts the about routes you select. If you use our trip planning features (STALinked 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 STA customer service agents. We also use this information to track potential problems and trends and to customize our support responses to better serve you.

STA may combine personal information you provide through your various interactions with STA and STA’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, STA uses your personal information to set up your account. STA also uses personal information to enforce and protect its rights, including in connection with electronic citation processing.

How STA 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, transportation contractors, and recipients who are entitled to the information for legal or safety reasons.

A. Service Providers and Transportation Contractors

STA may share personal information with service providers and transportation contractors that assist STA in providing, improving, and marketing the Services. For example, STA may engage an email service provider to manage our promotional communications, a technology company to build software or apps, a payment processor to process purchases on the Store or to reload Connect cards, or an analytics provider to study user habits. STA may also share your personal information with transportation contractors 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.

B. Disclosures Required by Law or for Compliance Reasons

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:

1) Enforce the CONNECT General Terms of Service or STA’s Rules of Conduct, investigate and defend against any third-party claims or allegations, or protect the security or integrity of the Services.

2) Exercise or protect the rights, property, or safety of STA personnel, users of the Services, or the public. We will 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, STA will not provide personal information to the U.S. Immigration and Customs Enforcement (ICE) or any similar agency for immigration enforcement purposes.

C. Public Records Laws

You should be aware that STA 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.

How You Can Opt-Out

If, at any time, you wish to have your name and other personal information removed from our database, please let us know by writing to us at STA, 1230 West Boone Avenue, Spokane, WA, 99201, Attention: Customer Service.

A. Opting Out

If you no longer wish to receive communications from STA, you can do so by:

• Promotional communications: Opt out of promotional messages by unsubscribing from the email you received, or changing your preferences via the Website.

• Text messages: Replying STOP to the applicable text message.

Note that you cannot opt out of initial or service communications.

B. Location

Most mobile devices allow you to prevent real-time location data from being sent to us. If you turn off location services, not all features of the Services will function.

C. Cookies

If you do not want to receive cookies, you can change your browser settings on your computer or other device. Note that the Services will not work properly without cookies.

D. Contacting STA for Changes

You may also contact us at STA, 1230 West Boone Avenue, Spokane, WA, 99201, Attention: Customer Service, to find out what personal information we have about you and to change your personal details.

Do Not Track

The Do Not Track (“DNT”) signals are a feature offered by various browsers, which sends a signal to a website not to track the user when he or she leaves that website. STA does not respond to DNT signals at this time.

How is your personal information stored and protected?

The personal information you provide when you use the Services is retained indefinitely by STA and electronically stored in secure environments that are made as inaccessible to the public as is reasonably possible. When you place orders or access your account information, we offer the use of a secure server. You may review, update or correct your personal information at any time by writing to us at STA, West 1230 Boone Avenue, Spokane, WA, 99201, Attention: Customer Service.

Links to Other Websites

Links from the Services are provided for your convenience only. STA is not responsible for the content of any third-party website or the privacy practices of such third parties. In addition, any link from the Services to another website does not indicate that STA endorses the services or policies of such third party website. You should always investigate the information practices of all websites that you access and carefully examine the privacy policies, if any, of any websites appearing on or linking to or from the Services. Personal information collected from the linked websites will be subject to the information practices of those websites.

Use of this Website by Minors

STA does not intend to collect information from individuals who identify themselves as under thirteen (13) years of age, unless for the explicit purpose of purchasing and transacting for fare products via STA Services. If you are under thirteen (13), you should ask your parent or authorized guardian to assist you with any initial fare product purchase or registration. STA will not collect information from those individuals who identify themselves as less than thirteen (13) years of age without verifiable consent from a parent or other authorized guardian, except as noted above. Credit card transactions initiated by minors are governed by your cardholder agreement.

Questions or Concerns

If you have any questions or concerns about this Privacy Policy or how your personal information is used, please write to us at STA, 1230 West Boone Avenue, Spokane, WA, 99201, Attention: Customer Service.

Does STA share the information with anyone?

Unless a user consents to such distribution, STA will not sell, lease, or give away personally identifiable information to other governments, organizations, or private businesses within the limits of the law.

It is important to know the law, as state and federal laws place a special burden on public entities, such as STA, to assure the public’s right to access public records and information. Public information (as opposed to private information) involves information about activity that is regulated. For example, in purchasing a birth certificate online, a person’s name and birth date is public information (because births are regulated by the state), but the fact that you bought it with a certain credit-card number is not (because the means of purchasing is not regulated). Furthermore, public information would include correspondence with other agencies, including e-mails and website comments about shared processes, policies, activities and other types of general correspondence. However, certain subjects fall under exemptions of the State’s public disclosure act, including employee benefit questions, welfare information, and other types of client-specific data.

For details, see the Washington State Public Records Act and the federal “Freedom of Information Act.”

Outside of legal requirements and extreme emergencies, information in the Services will not be released to anyone without the consent of the user.

Disclaimer Notice

STA makes no claims, promises, or guarantees about the accuracy, currency, completeness, or adequacy of the contents of the Services and expressly disclaims liability for errors and omissions in its contents. In the event of a conflict between this Privacy Policy and the Public Records Act or other law governing the disclosure of records, the Public Records Act or other applicable law will control.

Warranty

No warranty of any kind, implied, express, or statutory, including but not limited to the warranties of non-infringement of third-party rights, title, merchantability, fitness for a particular purpose, and freedom from computer virus, is given with respect to the Services or its links to other Internet resources. Although we have put in place security systems (as described in this Privacy Policy) that are designed to prevent unauthorized disclosure of your personally identifiable information, due to the nature of Internet technologies, we cannot provide firm assurances as to the security of this information, and we expressly disclaim any such obligation.

Service Privileges

You agree to refrain from activity that imposes an unreasonable burden on the Services, and we reserve the right, at our discretion, to limit the order quantity on any item and /or to refuse service to any customer who violates these provisions.

Choice of Law and Jurisdiction

The Services are controlled and operated by STA from its location in Spokane, Washington. This Privacy Policy shall be construed in accordance with the laws of the State of Washington, without regard to any conflict of law provisions. Any dispute arising under this Privacy Policy shall be resolved exclusively by the state or federal courts sitting in Spokane County, Washington.