Privacy Policy

This Privacy Policy explains how The Sixth Collection, LLC, trading as Conductor ("Conductor", "we", "us", or "our"), collects, uses, shares, and protects your personal information when you use the Conductor mobile application, website, and related services (the "Service").

We are committed to handling your data lawfully and transparently. Where applicable, this policy reflects the requirements of the UK General Data Protection Regulation and Data Protection Act 2018 ("UK GDPR"), the EU General Data Protection Regulation ("GDPR"), and the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA").

If you have any questions about this policy or how we handle your data, contact us at legal@conductorapp.co.uk.

The data controller is: The Sixth Collection, LLC, 100 N Howard St, Suite R, Spokane, WA 99201, United States. Privacy enquiries: legal@conductorapp.co.uk.

For users in the United Kingdom and European Economic Area: we are in the process of formally designating a UK/EU representative as required by UK GDPR Article 27 and EU GDPR Article 27 respectively. Until that designation is published on our website, all data subject enquiries from UK and EU residents should be directed to legal@conductorapp.co.uk and will be handled within the statutory timeframes.

Account Information. When you register, we collect your name, email address, and any profile details you provide. If you sign in via a third-party provider (such as Sign in with Apple), we receive only the information that provider makes available under your privacy settings.

Journey Data. To deliver core functionality we collect information about the journeys you save, search for, or track: origin and destination stations, scheduled and actual departure and arrival times, delay information, platform numbers where available, operator codes, and service identifiers. This data forms your personal journey history and is used to provide tracking, delay analysis, and journey statistics.

Ticket and Booking Import. If you use our email import feature, you forward booking confirmation emails to a Conductor processing address. We extract structured data (route, date, booking reference, seat details) from those emails, store the resulting journey record in your account, and do not retain the original email content beyond what is necessary to complete the import.

Location Data. With your permission, we access your device location to support features such as nearby station lookup, live journey monitoring, and background arrival detection. Location is processed on your device or transmitted to our servers only to the extent necessary for the requested feature. You can withdraw location permission at any time in your device settings, though this will limit certain functionality.

Push Notification Tokens. If you enable push notifications, we store your device's push token to deliver real-time journey alerts including delay updates, platform changes, and departure reminders.

Usage and Diagnostic Data. We collect information about how you use the Service — including app version, device type, operating system version, feature interactions, and crash reports — to maintain, diagnose, and improve the Service.

Support Communications. If you contact us, we retain your messages and contact details to respond and improve our support quality.

We use the information we collect to: provide, operate, and maintain the Service including journey tracking, delay intelligence, and routing features; personalise your experience and remember your preferences; process your subscription and manage billing through Apple; send you push notifications and service communications about your journeys; detect, prevent, and investigate fraud, abuse, and security incidents; improve and develop the Service, including evaluating the performance of delay prediction capabilities using aggregated de-identified operational data; comply with our legal obligations; and enforce our Terms of Service.

We do not use your personal data to serve you third-party advertising, and we do not sell your personal data to advertisers or data brokers.

If you are located in the UK or European Economic Area, we rely on the following legal bases to process your personal data:

Performance of a contract: processing necessary to provide the Service to you, including account management, journey storage, tracking, subscription processing, and push notifications.

Legitimate interests: processing necessary for our legitimate interests in operating and improving the Service, preventing fraud and abuse, and maintaining security — where those interests are not overridden by your rights and interests.

Legal obligation: processing necessary to comply with applicable law, including responding to valid legal requests.

Consent: where we ask for your consent (for example, to access your precise location or to send marketing communications), we process data on that basis. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

We do not sell your personal information. We share information only in the following circumstances.

Infrastructure and Service Providers. We share data with companies that help us operate the Service under data processing agreements, including: cloud infrastructure and database providers; authentication services; and crash analytics providers. These providers may only use your data as necessary to provide services to us.

Mapping Services. The map features of the Service are powered by Mapbox. When you use map-based features, your approximate location and map interaction data may be transmitted to Mapbox to render map tiles and calculate routes. Mapbox processes this data in accordance with their Privacy Policy (mapbox.com/legal/privacy).

Operator Logo Display. To display train operator logos, the Service may fetch logo images from a third-party content delivery service using the operator's public domain name (for example, 'gwr.com'). No personal data is transmitted in this process.

Rail Data Infrastructure. To deliver live train information the Service queries licensed national rail data feeds and APIs. We transmit station codes and service identifiers to retrieve timetable and live status data. We do not share your personal journey data with these providers beyond what is inherent to a query (for example, a station code used to look up departures).

Routing Services. Journey planning for certain routes uses MOTIS, an open-source routing engine operated by us. Queries include origin, destination, and requested travel time. This processing occurs on infrastructure we control.

Legal Requirements. We may disclose your information where required by law, court order, or governmental authority, or where we reasonably believe disclosure is necessary to protect our rights, your safety or the safety of others, or to investigate fraud.

Business Transfers. If we are involved in a merger, acquisition, or sale of assets, your information may transfer to the acquiring entity. We will notify you by email or prominent in-app notice before your data becomes subject to a different privacy policy.

With Your Consent. We may share your information with third parties where you have given us explicit consent.

We are based in the United States, and some of our infrastructure and service providers are also located outside the UK and EEA. When we transfer personal data from the UK or EEA to countries not deemed adequate by the relevant authority, we rely on Standard Contractual Clauses approved by the UK ICO (International Data Transfer Agreements) or the European Commission, as applicable.

You can request details of the transfer safeguards in place by contacting legal@conductorapp.co.uk.

We retain your personal data for as long as your account is active and for a reasonable period after closure to allow account reinstatement, resolve disputes, and comply with legal obligations.

Journey history is retained for the lifetime of your account. When you delete your account, we delete or anonymise your personal data within 30 days, except where retention is required by law or to resolve outstanding matters.

Raw operational data used for real-time features is subject to automated retention limits and purged on a rolling basis. Aggregated, de-identified statistical data derived from operational data is retained indefinitely for service improvement purposes and does not identify you.

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, and disclosure. This includes encryption of data in transit using TLS and encryption of stored data at rest, access controls, and regular security reviews.

No method of internet transmission or electronic storage is completely secure. While we take data security seriously, we cannot guarantee absolute security. In the event of a security breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by applicable law.

Depending on where you are located, you may have the following rights regarding your personal data. To exercise any of them, contact us at legal@conductorapp.co.uk. We will respond within the timeframe required by applicable law (generally within one calendar month for GDPR requests) and may need to verify your identity before processing your request.

Access and Portability: the right to request a copy of your personal data and, in some circumstances, to receive it in a structured, machine-readable format.

Rectification: the right to request correction of inaccurate or incomplete personal data.

Erasure: the right to request deletion of your personal data in certain circumstances, such as where it is no longer necessary for the purpose for which it was collected.

Restriction: the right to request that we restrict processing of your personal data in certain circumstances.

Objection: the right to object to processing based on our legitimate interests. We will stop unless we have compelling grounds that override your interests.

Withdrawal of Consent: where processing is based on consent, you may withdraw that consent at any time.

UK and EEA Residents — Supervisory Authority Complaints: if you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority. In the UK this is the Information Commissioner's Office (ico.org.uk). In Ireland it is the Data Protection Commission (dataprotection.ie). You can find your local EU authority at edpb.europa.eu.

California Residents (CCPA/CPRA): you have the right to know what personal information we collect, use, and disclose; the right to delete your personal information; the right to correct inaccurate personal information; and the right not to be discriminated against for exercising these rights. We do not sell or share your personal information for cross-context behavioural advertising as defined under CCPA/CPRA, and we have no actual knowledge that we sell or share the personal information of consumers under 16 years of age. To submit a CCPA request, contact legal@conductorapp.co.uk.

The Service is not directed at children under 13, or under 16 in jurisdictions where that higher age applies under GDPR (including most EEA member states). We do not knowingly collect personal data from children below the applicable age threshold without verified parental consent.

If you believe we have inadvertently collected data from a child below the applicable age, contact legal@conductorapp.co.uk and we will promptly delete it.

The conductorapp.co.uk website may use cookies and similar technologies for essential functionality (such as session management) and analytics. A cookie banner on the website provides you with choices about non-essential cookies in accordance with UK PECR and EU ePrivacy requirements.

The Conductor iOS app does not use browser cookies. The app may use on-device identifiers for analytics and crash reporting purposes as described in Section 3.

We use Apple Push Notification Service (APNs) to deliver real-time journey alerts. We store your device push token solely for this purpose. You can disable push notifications at any time in your iOS Settings > Notifications > Conductor. Disabling notifications does not delete your account or journey data.

We may update this Privacy Policy to reflect changes in our practices, the Service, or applicable law. For material changes we will notify you through the app or by email at least 14 days before the change takes effect (or such longer period as required by law).

The date at the top of this policy shows when it was last updated. We encourage you to review it periodically.

For questions, requests, or complaints about this Privacy Policy or how we handle your data, contact our privacy team at legal@conductorapp.co.uk.

By post: The Sixth Collection, LLC, Attn: Privacy, 100 N Howard St, Suite R, Spokane, WA 99201, United States.

We aim to respond to all privacy enquiries within 30 days.