WisGo WisGoPrivacy Policy

Effective: April 1, 2023

Your privacy is important to us. This Privacy Policy explains how we collect, share, use, and protect information when you visit or use this online service and any other online services offered by Cubic Inc. (“Cubic”), the operator of the WisGo System (“WisGo”) that link to or reference this policy (collectively, our “online services”). This policy covers Cubic’s many online services, including the WisGo websites, WisGo mobile services, and Cubic- and WisGo-branded social media sites or pages.

As you review this Privacy Policy, here are a few general principles to keep in mind:

• Our online services are intended for a U.S. audience. If you visit or use one of our online services, your information may be transferred or processed in the United States. For non-U.S. online services, please review the privacy policy applicable to that service to understand how your information will be treated and safeguarded.

• Our online services are not intended for children under 13. We do not knowingly collect personal information from children under 13 without parental consent.

• If you have a WisGo account or Milwaukee County Transit System (MCTS) account with us, we will use and share any information that we collect from or about you in accordance with this Privacy Policy.

• The WisGo Mobile App and our social media sites or pages also adhere to this Privacy Policy.

Information We Collect

Personal Information

When you visit or use our online services, we may collect personal information from or about you such as your name, email address, telephone number(s), WisGo Card serial number, location information (for example, an address to help you find the nearest bus stop or train station), and password. We may also collect payment card information including your card number, expiration date, card security code and billing address when you provide such information while using our online services and where we believe it is reasonably required for ordinary business purposes.

Usage and Other Information

In addition to the personal information described above, we may collect certain information about your use of our online services. For example, we may capture the IP address of the device you use to connect to the online service, the type of operating system and browser you use, and information about the site you came from, the parts of our online service you access, and the site you visit next. We or our third-party partners may also use cookies, pixel tags or other technologies to collect and store other information about your visit to, or use of, our online services. In addition, we may later associate the usage and other information we collect online with personal information about you.

WisGo Mobile Services

For your convenience, Cubic offers you the ability to access some of our services through mobile applications and mobile-optimized websites (“WisGo mobile services”). When you interact with us through WisGo mobile services, we may collect information such as unique device identifiers for your mobile device, your screen resolution and other device settings, information about your location, and analytical information about how you use your mobile device. We may ask your permission before collecting certain information (such as precise geo-location information) through the WisGo mobile services.

Additional Sources of Information

We may also collect information about you from additional online and offline sources including from commercially available third-party sources, such as credit reporting agencies and identity authentication companies. We may combine this information with the personal and other information we have collected about you under this Privacy Policy.

Use of Information

We use the information discussed above in a number of ways, such as:

• Processing WisGo Account applications and transactions;

• Providing you tailored content;

• Verifying your identity (such as when you access your account information);

• Operating, evaluating and improving our business (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions);

• Managing your preferences;

• Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies;

• Preventing fraud and enhancing the security of your account or our online services;

• Responding to your requests and communicating with you;

• Performing analytics concerning your use of our online services; and

• For any other purposes that we may specifically disclose at the time you provide or we collect your information.

We may also use data that we collect on an aggregate or anonymous basis (such that it does not include any personally identifying information (PII) about you for various business purposes, where permissible under applicable laws and regulations.

Disclosure of Information

We may share the information we collect from and about you with certain parties that use our or provide support to our services. For example, we may share your information with:

• Transit agencies that subscribe to use WisGo;

• Cubic third-party service providers;

• Third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of Cubic businesses; and

• Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties.

We may share anonymous or aggregated information with third parties to help deliver products, services, and content that are better tailored to the users of our online services and for other purposes.

Understanding Cookies and Other Tracking Technologies

We, or our service providers, and other companies we work with may deploy and use cookies, pixel tags, and other tracking technologies for various purposes, such as fraud prevention and monitoring the performance of promotional pricing of an MCTS pass. Some of these tracking tools may detect characteristics or settings of the specific device you use to access our online services.

• “Cookies” are small amounts of data a website can send to a visitor’s web browser. They are often stored on the device you are using to help track your areas of interest. Cookies may also enable us or our service providers and other companies we work with to relate your use of our online services over time to customize your experience. Most web browsers allow you to adjust your browser settings to decline or delete cookies, but doing so may degrade your experience with our online services.

Online Advertising

You may see advertisements when you use our online services. These advertisements may be for new or existing products or services provided by us or by third parties. Which advertisements you see is often determined using the information we or our service providers, transit agencies and other companies that we work with have about you, including information about your relationships with us (e.g., types of fare products held, transactional information). To that end, where permitted by applicable law, we may share with others the information we collect from and about you.

Security

We use reasonable physical, electronic, and procedural safeguards that comply with federal standards to protect and limit access to personal identifiable information (PII).

Administrative:

• Access to PII is limited only to certain operations and technical employees for limited, approved purposes based on their specific work responsibilities necessary to the maintenance and operation of the Cubic platform.

• Privacy and security training is required for employees with access to PII, upon hire. In addition, regular periodic refresher training may be required for those employees.

Technical:

• Cubic’s network is protected with firewalls.

• All PII is protected using role-based access control.

• Sensitive PII (e.g. payment account information) is encrypted when stored and when transmitted over public networks.

• Electronic connections to and from the WisGo website are encrypted whenever PII data is exchanged.

• Vulnerability and penetration tests are conducted on the Cubic system.

• All uses of Cubic customer databases are monitored.

Physical:

• Physical access to Cubic servers is restricted to authorized, administrative and technical personnel.

• Data center access to approved administrative and technical personnel is restricted via passcode authentication and other security protocols.

Please note that information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information (such as your Social Security number) to us.

Updating Your Information

Keeping your account information up-to-date is very important. You may review, or update certain account information by logging in and accessing the “My Account” section.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. When we do, we will let you know by appropriate means such as by posting the revised policy RideMCTS.com/Policies. Any changes to this Privacy Policy will become effective when posted unless indicated otherwise.