1. Introduction

This Privacy Policy (hereinafter Privacy Policy), is intended to inform users who visit our website about the conditions that the Empresa Municipal de Transportes de Madrid, SA applies to all personal data processed, as well as about the rights that belong to the interested parties (holders of these data), and the way in which they can exercise these rights.

2. Data Processing Manager

 The Municipal Transport Company of Madrid, SA, as the personal data controller, has the following identification and contact information:

  1. Identity of the Data Controller: Empresa Municipal de Transportes de Madrid, S.A. (hereinafter 'EMT')
  2. NIF / CIF: A-28046316
  3. Registered as Entry 1, Page 19260, Sheet 20, Sect. 3, General 2132, Volume 2808 of the Companies Book of the Madrid Companies' Register.
  4. Address: C/ Cerro de la Plata, 4 | 28007 Madrid
  5. e-mail: atencioncliente@emtmadrid.es
  6. URL: www.emtmadrid.es

3. Data Protection Delegate


 

The contact information for the Data Protection Delegate for the Empresa Municipal de Transportes de Madrid, S.A. is the following:

Address: C/ Cerro de la Plata, 4 | 28007 Madrid Email: dpd@emtmadrid.es4. Data processing


 

The Empresa Municipal de Transportes de Madrid, S.A, SA undertakes to treat your data confidentially and in accordance with the requirements established in the applicable legislation on data protection, fundamentally Regulation 2016/679 of the European Parliament and Council of 27 April 2016 relating to the protection of individuals with regard to the processing of personal data and the circulation of said data (GDPR), Organic Law 15/1999, of December 13, the Personal Data Protection Act (PDPA) and its implementing regulations, as well as Law 34/2002, of July 11, the Information Society and Electronic Commerce Services Act (ISECSA).

Personal data will be treated in a fair, legal and transparent manner in relation to the interested party, and will be collected for specific, explicit and legitimate purposes, and therefore cannot be treated in a manner incompatible with said purposes.

The data collected from each interested party will be adequate, relevant and not excessive in relation to the corresponding purposes for each case, and will be updated whenever necessary.

In cases where it is mandatory under the applicable legislation, the consent of the interested parties must be obtained before collecting their data.

4.1. Purposes, legitimation, recipients and origin of the data


The personal data whose processing EMT is responsible for, come from different sources, as described throughout this Privacy Policy, for the purposes indicated below, to the extent that there is a legal basis for such processing.

BiciMAD App Form


Purpose: a) Contract and manage the fulfilment of the BiciMAD bicycle rental service contract. b) The sending of promotional and advertising communications about our products or services, including by electronic means (email, SMS, WhatsApp, or any other equivalent means), if the interested party has ticked the acceptance box.

Legitimation: a) The execution of a contract to which the interested party is a party b) In case of having agreed to receive commercial communications, the consent granted for this purpose.

Recipients: The data provided will be given to Booster-bikes SL, a company that provides EMT with technological support to adequately process their data. The data may be transferred to the Plataforma Integral Movilidad Madrid, AIE, for the provision of services related to surface mobility in Madrid, in accordance with the processing described in the Specific Technical Specifications and in the document "Procedure for Managing Access to the City of Madrid Mobility Platform" of the "Comprehensive Mobility Contract for the City of Madrid "(No. 145/2013/02944), awarded by Madrid City Council. International transfers of data are not planned.

ElectroEMT App form


 

Purpose: a) Contract and manage the fulfilment of the fast electric vehicle charging service contract in its parking lots. b) The sending of promotional and advertising communications about our products or services, including by electronic means (email, SMS, WhatsApp, or any other equivalent means), if the interested party has ticked the acceptance box.

Legitimation: a) The execution of a contract to which the interested party is a party b) In case of having agreed to receive commercial communications, the consent granted for this purpose.

Recipients: No data will be transferred to third parties, except under legal obligation.

EMT and Naviluz Shop Form


 

Purpose: a) Contract and manage the fulfilment of the purchase contract and, where appropriate, the delivery of your order and the performance of administrative tasks associated with it; b) The sending of promotional and advertising communications about our products or services, including by electronic means (email, SMS, WhatsApp, or any other equivalent means), if the interested party has ticked the acceptance box.

Legitimation: a) The execution of a contract in which the interested party is a part b) In case of having accepted to receive commercial shipments, the consent granted for this purpose.


Recipients: No data will be transferred to third parties, except under legal obligation.


Form for car parks of concessionaires without a Residents' Community (Elvira, Marqués de Samaranch, Pradillo II, Ginzo de Limia, Francisco Altimiras, Jacinto Benavente).


 

Purpose: The data is collected with the purpose of contracting, maintaining and complying with the concession contract for the use of a municipal parking space with Madrid City Council, as managed by EMT. Profiles are not drawn up and no other automated decision is made about the person.

 


Legitimation: The execution of a contract in which the interested party is a party.


 

Recipients: The data may be transferred to the municipal body responsible for the car parks in the City of Madrid in order to meet the conditions of the concession, statistical data, as well as to perform any informative activity related to parking. International transfers of data are not planned.

 


Form for car parks of concessionaires with a Residents' Community (Avenida de Portugal)


 

Purpose: The data is collected with the purpose of contracting, maintaining and complying with the concession contract for the use of a municipal parking space with Madrid City Council, as managed by EMT. Profiles are not drawn up and no other automated decision is made about the person:

(http://www.emtmadrid.es/Aparcamiento_Avenida_Portugal/documentacion/solicitud_Portugal.pdf)  
Legitimation: The execution of a contract in which the interested party is a party.


 

Recipients: The data may be transferred to the municipal body responsible for parking in the City of Madrid for the purpose of meeting the conditions of the concession, statistical data, as well as for the performance of any informative activity related to parking. In the event that a User Community is set up, the EMT will transfer the data to the Administrator appointed by said Community, for the sole purpose of parking management, including within this concept the communications that may be sent to convene the Community meetings and the issuance of the receipts corresponding to the monthly maintenance fees approved by said community. International transfers of data are not planned.

 


Form for long-term resident car parks (Barceló, Agustín Lara, Montalbán, Plaza España and Plaza Mayor)

 


Purpose: The data is collected with the purpose of contracting, maintaining and fulfilling the resident contract for the parking spaces managed by EMT. Profiles are not drawn up and no other automated decision is made about the person:


 


http://www.emtmadrid.es/aparcamiento_agustin_lara/documentacion/solicitud_Agustin_Lara.pdf
https://www.emtmadrid.es/Aparcamiento_montalban/documentacion/solicitud_Montalban_web1.pdf
https://www.emtmadrid.es/Aparcamiento_plaza_espana/documentacion/solicitud_Espana_web.pdf
https://www.emtmadrid.es/Aparcamiento_barcelo/documentacion/solicitud_barcelo_web.pdf
http://www.emtmadrid.es/Aparcamiento_plaza_mayor/documentacion/solicitud_plaza_mayor.pdf
 
Legitimation: The execution of a contract in which the interested party is a party.


 


Recipients: The data may be transferred to the municipal body responsible for parking in the City of Madrid in order to comply with the car park's Organisation and Operation Conditions, statistical data, as well as to perform any informative activity related to parking. International transfers of data are not planned.

 


Form for short-stay car parks (Almagro, Villa de París, Orense, Nuestra Señora del Recuerdo, San Epifanio, Pedro Zerolo, Avenida Portugal, Marqués de Salamanca, Recoletos, Plaza España, Montalbán, Plaza Mayor).


 


Purpose: The data is collected with the purpose of contracting, maintaining and fulfilling the payment contract for short-stay parking spaces managed by EMT. Profiles are not drawn up and no other automated decision is made about the person.

 


Legitimation: The execution of a contract in which the interested party is a party.

 


Recipients: The data may be transferred to the municipal body responsible for parking in the City of Madrid in order to comply with the car park's Organisation and Operation Conditions, statistical data, as well as to perform any informative activity related to parking. International transfers of data are not planned.


EMT Madrid App form

 


Purpose: Manage the subscription for sending communications with information about incidents in the EMT service depending on the geographical location of the interested party.


Legitimation: The consent of the interested party when subscribing to the sending of information through our form.

 


Recipients: No data will be transferred to third parties, except under legal obligation.

 


OPEN DATA form 

Purpose: Manage the delivery of requested information about the different services provided by EMT (bus, public bike, mobility, parking), as well as instructions on how to perform technical integrations in third-party applications (http://opendata.emtmadrid.es/ ).

Legitimation: The consent of the interested party when subscribing to the sending of information through our form.


 


Recipients: No data will be transferred to third parties, except under legal obligation.


 


EMT BLOG form


 

Purpose: Manage subscriptions and requests that are sent through the blog, as well as their publications (http://blog.emtmadrid.es/).

Legitimation: The consent of the interested party to subscribe to the blog.


Recipients: No data will be transferred to third parties, except under legal obligation.


 


Suggestions and complaints form


 

Purpose: Manage and resolve the suggestions and complaints sent by interested party (https://www.emtmadrid.es/AtencionAlCliente/Reclamaciones).

Legitimation: The consent of the interested party.

 


Recipients: No data will be transferred to third parties, except under legal obligation.

 


Queries and Acknowledgements form

 


Purpose: Manage queries or acknowledgements sent by the interested party (https://www.emtmadrid.es/AtencionAlCliente/Acknowledgments).

 


Legitimation: The consent of the interested party to process their requests.

 


Recipients: No data will be transferred to third parties, except under legal obligation.

 


Service Request Form

Purpose: Manage requests for informative talks on EMT to certain groups, to accompany these groups on our buses on their journeys through Madrid, and to visit the EMT facilities (https://www.emtmadrid.es/AplicationAcompanamiento)

Legitimation: The consent of the interested party to process their requests.


 


Recipients: No data will be transferred to third parties, except under legal obligation.


 


Job application form


 

Purpose: Manage the application and participation of candidates in EMT recruitment processes and in future job offers and/or vacancies that may occur. (https://www.emtmadrid.es/Empresa/Empleo)

 


Legitimation: The consent of the interested party.


 


Recipients: No data will be transferred to third parties, except under legal obligation.


Employee portal

Purpose: Manage the supply of information and services of interest to EMT employees, including access to personal information, such as payroll, certificates of income and deductions, or control of signing, among others (https://miestacion.emtmadrid.es/).

Legitimation: The execution of a contract in which the interested party is a party and the legitimate interest of EMT.

 


Recipients: No data will be transferred to third parties, except under legal obligation.

 


Social networks

Purpose: Manage the registration of users and applications that may be presented through social networks, manage the presence of EMT on social networks, reporting activities, products or services, and any other purpose that the regulations of social networks allow (Twitter , Facebook, Instagram, YouTube). In no case will the accounts or profiles of followers or users of social networks be used to send commercial communications individually.

Legitimation: The consent of the interested party.


 


Recipients: No data will be transferred to third parties, except under legal obligation.


Internet access through WiFi on board buses

 

Purpose: Manage the registration process and the relationship with the users who access the internet through the WiFi on board buses.

Legitimation: The consent of the interested party when registering using our portal or the login of the social profile account (Facebook, Twitter).

Recipients: The data is shared with Telefónica SA, to the extent that it provides EMT with services strictly necessary for the execution of the activity.


4.2. Rights of the interested parties


 

Any interested party may withdraw their consent at any time when it has been granted for the processing of their data. Under no circumstances does the withdrawal of this consent condition the execution of the contracts to which it is a party or the relationships generated previously.

 


In the case of commercial communications, the interested parties may withdraw their consent automatically by accessing the link or by ticking the advisory box in each of these communications, or by means of the corresponding form in the EMT apps or website.


The interested party may also revoke the consent given, as well as exercise their rights of access, rectification, deletion, opposition, portability and limitation, and in general consult all questions relating to the processing of their personal data, before EMT's Data Protection Officer, by sending an email to proteccion.datos@emtmadrid.es (A/A. Data Processing Manager / General Secretariat), or by mail to C/ Cerro de la Plata, 4, 28007 Madrid, for which you must attach a copy of your ID or official document to prove your identity or the representation by means of which you are acting, specifying where appropriate the right you wish to exercise.

You can also address your request or query to the EMT Data Protection Delegate, especially when you consider that you have not obtained full satisfaction in the exercise of your rights, by sending an email to the address dpd@emtmadrid.es, or by mail to the address C/ Cerro de la Plata, 4, 28007 Madrid, attaching a copy of the document proving your identity or representation.


You can also file a complaint with the Spanish Data Protection Agency, for which the necessary information is available on: http://www.agpd.es.


4.3. Data retention period

 

The personal data processed will be kept as long as they are necessary to fulfil the purpose for which they were collected, and then during the retention periods legally required to meet possible responsibilities that may arise from said purpose and the processing of the data, during which time they will remain blocked, only being kept at the disposal of the Public Administrations and Judges and Courts, to attend to these responsibilities. Once these deadlines have expired, the data will be destroyed.

 


5. Browsing data and Cookies Policy


 

Visits to the EMT website are made anonymously. Users will only be required to supply personal data essential for the provision of a requested service in order to access some of the web services that have specific management or processing actions.

EMT does not use cookies to collect information from users, nor does it register access IP addresses. Only its own session cookies for technical purposes are used (those that allow the user to browse through the website and use the different options and services that exist in it).

The web portal contains links to third-party web pages, whose privacy policies are alien to it. By accessing such websites you can decide if you accept their privacy and cookies policies. In general, if you browse the internet you can accept or reject third-party cookies from the settings of your browser.


You can also access the internet using the WiFi on board our buses. If you do this from your session in a social network, please note that you are sharing the username and password of your social profile with us. Visit the platform of the social network in question and review its privacy policy to find out how your personal data is shared and used in this context.

 


6. Minors


 

In the case of children under fourteen, the consent of the parents or guardians is required for the processing of their personal data, so if you are under fourteen years old and have accessed this website without notifying your parents or guardians do not fill out any form, or provide personal data by any other means.

 


7. Data provided by the user


 

The personal data requested in the forms are necessary to manage your requests and/or provide the services that are the object of the contract, unless expressly indicated otherwise, so, if you do not provide or not accept this Privacy Policy, we cannot serve you correctly nor can we provide you with the requested service.


It is important, so that we can keep your personal information updated, that you inform us whenever there has been any modification of them.

The data provided by the interested party will be presumed correct, and therefore, if errors occur, EMT will not be liable for the incorrect execution or non-execution of their requests or of the contract to which they are party.

In addition, the interested party is responsible for the veracity of the data provided, EMT reserving the right to exclude from the services provided any interested party who has provided false information, without prejudice to any other actions that may be required by law.

We are not responsible for the privacy policy regarding personal data that you may provide to third parties through the links available on our website.


 


8. Special categories of data


 

You must not provide us in the free text fields of the forms on our website or our apps, with any personal data that may be classified as specially protected, such as personal data that reveal race, ethnic or racial origin, political opinions, religious or philosophical convictions or beliefs, or union affiliation, genetic data, biometric data, data relating to physical or mental health, data relating to sexual life or sexual orientations of a natural person, data relating to convictions or criminal offences.

In the event that EMT requires this information at any time, it will request the express consent of the owner of that data (either through a declaration or a clear affirmative action), to collect and use that information, communicating to the same, previously and unequivocally, the purpose of the collection and processing of said information. 

In the event that, without having been requested by EMT, such information is voluntarily communicated by the user to the aforementioned entity, said communication will constitute an explicit act by the user that implies the existence of a manifestation of express consent by the user regarding the processing of their data by EMT.

9. Modification of the Privacy Policy

This Privacy Policy may vary depending on legislative requirements or self-regulation, so users of our website are advised to visit it periodically and, at least, every time they provide their information.