privacy policy

Introduction

This privacy policy sets out how Carriage Return Transport Solutions Limited (Company Number 14601046) uses and protects your personal data.

1. Important information and who we are

Any reference within this document to “Platform” means the application named ‘mymango’ (the “App”) and/or our website: https://mango.crtransport.solutions.

This privacy policy gives you information about how Carriage Return Transport Solutions Limited collects and uses your personal data through your use of the Platform, including any data you may provide when you register with us, create an account on the Platform, purchase a service from us or sign up to our newsletter.

We will collect personal data regarding children, through the Platform, if a child registers an account with us and uses the App. In addition, we will collect personal data regarding the parent/guardian who has authorised the account registration for said child.

Controller

Carriage Return Transport Solutions Limited is the controller and is responsible for your personal data (collectively referred to as "Carriage Return Transport Solutions Limited", "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the information set out in the contact details section at the end of this policy.

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, date of birth and employee or student reference number (if registering for a scheme such as Blue Light).
  • Contact Data includes billing address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details and transaction information (for example when you topped up your balance)
  • Transaction Data includes details about payments to and from you, your journey history, and other details of products and services you have purchased from us.
  • Device Data includes the type of device you use, your unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, IP address, and time zone setting.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Platform.
  • Profile Data includes your username and password, purchases made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you interact with and use the Platform. We also capture some information about your device, such as a device identifier, type and details of the operating system and version of the Platform you are using
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific Platform feature in order to analyse general trends in how users are interacting with the Platform to help improve the Platform and our service offering.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Your interactions with us. You may give us your personal data by filling in online forms (including feedback forms) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • create an account on the Platform;
    • undertake a journey and use the Platform to pay for that journey;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • sign up to a promotion or scheme (for example, a Blue Light discount travel scheme); or
    • give us feedback or contact us and/or provide us supporting evidence in relation to some types of refunds.

Please note that if you contact us via telephone, our conversation with you may be monitored or recorded.

  • Automated technologies or interactions. As you interact with the Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies.
  • Third parties. We will receive personal data about you from various third parties as set out below:
  • Technical Data is collected from the analytics providers such as Google based outside the UK.
  • Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as GPUK LLP (trading as Global Payments) based inside the UK.
  • Identity and Contact data is collected from third party service providers who operate the transport that you use, to undertake a journey paid using the Platform (such as Trent Motor Traction Limited, based inside the UK).
  • Identity and Contact data is collected from third party scheme providers, who run a travel scheme, that you choose to be involved in (for example, a school, college or university who offer reduced fares for journeys undertaken by a student registered at that school, college or university).

4. How we use yout personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use

Type of data

Legal basis and retention period

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you, so that we can register you as a user of our Platform, to enable you to benefit from the Platform’s services.

We will retain this data while your user account remains active and for up to 2 years after your last use of the Platform unless you request that it be deleted before that date (provided that you are not in debt to us).

To authorise the registration of a child’s account

(a) Identity

(b) Contact

(c) Financial

Performance of a contract with you, so that we can register the child as a user of our Platform, to enable the child to benefit from the Platform’s services. Ultimately, we are entering into the contract with the parent/legal guardian who authorised the registration and use of the child’s account.

We will retain this data while the child’s user account remains active and for up to 2 years after the child’s last use of the Platform unless you or the child request that it be deleted before that date (provided that you, though the child’s account, are not in debt to us).

To permit you to install the App

(a) Identity

(b) Contact

(c) Device

Legitimate interests, so that you can use the App on your device.

Performance of a contract, so that you can use the App to pay for services.

We will retain this data for the duration that your (or a minor’s account) remains active.

To process and perform our services including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us or a third-party transport services provider, who you have used to undertake a journey

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Device

(f) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

For example, processing payments made by you (or an authorised child) via the Platform to access transportation services and/or in connection with topping up your account (or the authorised child’s account) with credit.

We will retain this data (in an anonymised form) indefinitely. Once your, or the child’s, account is either closed or remains inactive for more than 2 years, this data will be deleted.

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Dealing with your requests, complaints and queries

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you, for example, to answer any queries you have in respect of the Platform and use of the services available on the Platform.

(b) Necessary to comply with a legal obligation, as we must inform you if the terms upon which we process personal data change

(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you

We will retain this data while your account remains active or for 2 years after your last use of the Platform (provided that you are not in debt to us).

To enable you to sign up to a travel scheme/promotion or complete a survey

(a) Identity

(b) Contact

(c) Device

(d) Profile

(e) Usage

(f) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

We will retain this data while the relevant prize draw, competition travel scheme/promotion or survey remains active, and for a maximum of 60 days after it becomes inactive.

To administer and protect our business and the Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(d) Device

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

We will retain this data indefinitely in the case of suspected fraud. In relation to system failures, bug fixes or similar issues, this data will be retained (in an anonymised form) for a maximum of 60 days.

To use data analytics to improve our Platform, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy)

We will retain this data for a maximum of 60 days.

To send you relevant marketing communications and make personalised suggestions and recommendations to you about products or services that may be of interest to you based on your Profile Data

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business)

We will only send you marketing emails where we have obtained your consent to receiving direct marketing communications

We will retain this data while your account with us remains active. Once your account becomes inactive, this data will be retained indefinitely in an anonymised form.

To carry out market research through your voluntary participation in providing feedback and completing surveys via the Platform.

(a) Marketing and communications

(b) Identity

(c) Contact

Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).

For example, a feedback form will be available within the Platform for completion by users on a voluntary basis.

We will retain this data while your user account remains active.

To respond to your requests to exercise your legal rights under this privacy policy.

As relevant to your request.

Necessary to comply with a legal obligation (complying with data subject access requests under data protection regulations).

We will retain this data for a period of two years from the date of the request being made

Direct marketing

You will receive marketing communications from us if you have requested information from us or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes. Please note where you undertake a journey and pay for that journey using the Platform, we will share your personal data with the third-party transport service provider who serviced that journey. We do this so that we can facilitate payment to the third-party transport service provider and answer any queries they might have in respect of your journey.

You will receive marketing communications from us about our third-party transport operators’ products and/or services, if you have consented to receive that marketing from us.

Opting our of marketing

You can ask us to stop sending you marketing communications at any time by logging into your account via the Platform and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links within any marketing communication sent to you or by contacting us.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates to our Terms and Conditions or checking that your contact details are correct.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table purposes for which we will use your personal data above.

  • We may disclose your personal data to our service providers who accept the App for travel on their services. These service providers may include bus and coach companies providing transport services; for example, Trent Motor Traction Company Limited (Trent Barton). Where you use the App to travel with more than one transport service provider, please note limited personal data about your journey may be shared with another transport service provider to assist that transport service provider with answering a query you may have in respect of your account and/or transaction history.
  • We may disclose your personal data to your app store provider (for example, the Apple App Store or the Google Play App Store) and mobile network operator to allow you to install the App on your device.
  • We may contact your service providers that you have appointed as necessary to fulfil your requests, such as your banking or payment card provider to process your transactions.
  • We may disclose your personal data to HM Revenue and Customs, regulators, law enforcement, public authorities or other third parties based in the UK where necessary to exercise our rights or comply with a legal obligation.
  • We may disclose your personal data to a travel scheme provider, in respect of a travel scheme that you choose to be involved in. For example, a school, college or university who offer reduced fares for journeys undertaken by a student registered at that school, college or university or, a Blue Light promotional scheme.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the UK.

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. Data retention

How long will you use my personal data for?

Details of retention periods for different aspects of your personal data are set out in the table above.

Notwithstanding the retention periods set out in the table, we will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where (a) we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests), or (b) the processing is for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
    • If you want us to establish the data's accuracy;
    • Where our use of the data is unlawful but you do not want us to erase it;
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us using the details set out at the end of the policy.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact Details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

  • Email address: support@crtransport.solutions
  • Postal address:
    Carriage Return Transport Solutions,
    88a Mansfield Road,
    Heanor,
    Derbyshire,
    DE75 7BG
  • Telephone number: 01773 536 328

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was implemented on 1st April 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. Third party links

The Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.