1. Who processes data and the scope of this Policy
The personal data controller is individual entrepreneur Шевченко Юлія Миколаївна, РНОКПП 3150904822 (hereinafter ATBway or the Controller). This Policy covers https://atbway.com, passenger accounts, searches, arranging bus, rail and air services, and support requests.
Registered address (sole proprietor’s place of business): Ukraine, 28034, Kirovohrad Oblast, Oleksandriia District, village of Protopopivka, Kozatska Street, building 101 A.
RedRay and ATBway are separate services. Passenger accounts and profiles are not automatically merged on the basis of a shared email address or phone number; data is transferred between the services only where there is a separate lawful basis.
Contact for personal data matters: support@atbway.com.
2. Data that may be processed
- contact and account data: first name, last name, phone number, email and profile information;
- order and journey data: route, date and time, offer, carrier, seat, ticket number and status;
- passenger details required for the particular transport service: date of birth, citizenship or identity document details, only if required by the selected carrier or route;
- payment and service information: amount, currency, payment or refund identifier and status, and the history of requests concerning an order;
- technical data: IP address, browser, device, language, cookies or local storage, and security and website operation logs.
ATBway does not ask users to send support CVV/CVC, PINs, passwords or full payment details. Card data during payment is processed by the payment partner under its own rules.
3. Sources and purposes of processing
Data comes directly from the user, passenger, a person lawfully acting on their behalf, or from the carrier, booking system or payment partner in connection with the order.
Data is used to create and protect accounts; search for, book, pay for, issue and deliver tickets; change or refund orders; provide support and handle complaints; meet accounting, tax and other legal requirements; ensure security, prevent fraud and resolve technical errors.
Marketing messages are sent only with an appropriate basis and, where necessary, separate consent. Opting out of marketing does not prevent service messages necessary for an order or security.
4. Lawful bases
Depending on the purpose, processing is based on the need to enter into or perform an agreement with the user or passenger, meet a legal requirement, protect the parties' lawful rights and security, or on consent where it is required for a particular optional function. Consent to optional messages or technologies is not a condition of booking a ticket unless the law or the relevant function requires otherwise.
5. Recipients of data
Data necessary to fulfil an order may be shared with the relevant carrier, booking system or ticketing partner. Data for payment, refunds and payment confirmation is shared with the payment partner. Limited technical data may be processed by providers of hosting, communications, message delivery, technical maintenance and service protection, solely to provide the relevant services.
Data may be provided to public authorities in the cases and manner expressly prescribed by law. ATBway does not make passengers' personal data publicly accessible or sell it.
6. Transfers outside Ukraine
An international route, foreign carrier or booking system may require the transfer of data necessary for the order to a recipient outside Ukraine. Such transfers are made only for a defined purpose and on a lawful basis, with the safeguards prescribed by law. The specific recipients for an order can be clarified with support using the order number.
7. Retention and protection
Data is retained no longer than necessary for the purposes of this Policy and fulfilment of lawful obligations. Profile data is retained while the account is used; order, payment, refund and complaint information is retained for the periods necessary to provide services, maintain records, protect rights and comply with the law. Technical logs are retained for a reasonable period for security and troubleshooting.
ATBway applies organisational and technical measures proportionate to the nature of the data and processing risks, including access restrictions and protection of transmission. No method of transmission or storage guarantees absolute security.
8. Cookies and local storage
The Website may use cookies and local storage for sessions, login, settings, retaining selections and operating functions. Optional analytics or other technologies are used in accordance with consent requirements where consent is necessary. Users can manage cookies in their browser; blocking necessary technologies may affect login, search or booking. Deleting cookies does not delete data about an order already placed.
9. Children's data
A child's data for booking a ticket is provided by their legal representative or a person with appropriate authority. Provide only the information required by the particular ticket or law; children's data is not used for marketing profiling.
10. Individual rights and requests
Within the limits established by law, a person may learn about the source, purpose and place of data processing, access their data, require inaccuracies to be corrected, and request restriction, cessation or deletion of processing, withdraw consent or lodge a complaint with a competent authority or court. Deletion may be limited by an obligation to retain particular documents or a need to protect rights in a dispute.
Send a request to support@atbway.com with the subject “Personal data”. Describe the action requested and include the order number if there is one. To prevent disclosure to an unauthorised person, ATBway may request reasonable confirmation of identity or authority. Do not send document copies or payment secrets unnecessarily.
11. Policy updates
A new version takes effect after publication on the Website. The revision date is stated at the top of the document. If the purposes or material conditions of processing change, ATBway will notify users in the manner prescribed by law; consent is requested separately where required for new processing.
Controller: ФОП Шевченко Юлія Миколаївна, РНОКПП 3150904822. Website: https://atbway.com. Contact: support@atbway.com. Phone: +380755657197.