General information – what is the Flowly Trial?

Wi-Fi sensor technology is being trialled onboard on a number of Sydney Light Rail vehicles in operation on the network as part of the “Flowly Trial”.

The purpose of the Flowly Trial is to collect data to help improve the network, for example by having more insights about patronage numbers.

We will be collecting data using Wi-Fi sensor technology which we will then convert into statistical information.

The Wi-Fi sensor technology we will be using detects passive signals from electronic devices such as smartphones, tablets and other devices.

To deliver the trial we are working with an organisation called FLOWLY SAS (838 864 908 RCS Saint-Denis) (‘Flowly’). Flowly will be responsible for processing and the receipt of the data collected.

If the Wi-Fi function of your device is disabled, you will not be able to participate in the trial. So, in order to participate in and contribute to the success of this trial, we invite you to leave the Wi-Fi function of your device(s) enabled.

What information is being collected?

The Wi-Fi sensors will collect Media Access Control (‘MAC’) addresses, route and travel times and log data which includes date, time, the Signal Strength Indicator (RSSI), device type and Wi-Fi sensor identification (‘Trial Data’).

The Trial Data once collected will be filtered, anonymized and aggregated.

Please note the MAC address from your device may, if collated with other information about that person be capable of identifying an individual. However, a MAC address on its own is not capable of revealing a person’s ‘real world’ identity.

We will not collect any of the following data: your name, your browsing history or your contacts (e.g., phone numbers).

To anonymise the Trial Data we encrypt your MAC addresses within 3 hours of collection. Once encrypted we will delete your MAC address from the data set. Then, any data gathered from your encrypted MAC address will be aggregated with data collected from other (encrypted) MAC addresses of other participants in the trial. As a result of the above steps (sometimes referred to as ‘pseudonymisation’) we will not be able to determine your 'real world' identity.

How do we use the information we collect?

The Trial Data collected will be processed and aggregated into statistical information (i.e., graphs, numerical data etc) which will then be shared by Flowly with Transdev (the Operator of the Sydney Light Rail), ALTRAC and TfNSW .

Those parties will then analyse that aggregated data to distil information and statistics about the use of the Sydney Light Rail, with the intent to use that information to help inform network improvements.

How do we store and protect your information?

Flowly will retain any data collected in line with Flowly’s data protection policies and with Australian and NSW Privacy laws and principles. This means that Flowly will not hold information for longer than is reasonably necessary and for a purpose other than what Flowly obtained the Trial Data for. Any data collected as part of the Flowly Trial will be stored at a secure data centre in NSW, Australia.

We take the privacy of our customers very seriously, and accordingly, a range of technical and organisational measures are in place to control and safeguard access to and use of the Trial Data..

How to opt out of the Flowly Trial

To opt out you can turn off your wifi during your light rail trip or you will need to send us the details of your MAC address, in order for us to be able to identify it within those collected as part of the Trial Data.

We understand you may object to the collection of your MAC address if you do not wish to participate in the Flowly Trial. Your MAC address will then only be kept for the implementation and actioning of your opposition.

A MAC address, sometimes referred to as a hardware or physical address, is a unique, 12-character alphanumeric attribute that is used to identify individual electronic devices on a network. An example of a MAC address is: ‘00-B0-D0-63-C2-26.’

To find out your device’s Wi-Fi Address information, including the MAC address;

If you wish to object, please complete the form below by submitting your MAC address to us for identification purposes.

After submitting the form, we will remove your MAC address from the trial data and it will no longer be collected, further any Trial Data linked to that MAC address (that has not yet been anonymized) will also be deleted.

If you would like to access, review, correct or update your MAC address, you will have three (3) hours from collection of the Trial Data to make a request to do so. After the 3 hours, your MAC address will have been made entirely anonymous (will no longer be ‘personal information’) and we will not be able to identify it in our records.

You will not have to pay a fee to access your MAC address (or to exercise any of the other rights under the Australian Privacy law). However, we may charge a reasonable fee if your request for access is unfounded or excessive.

In order to action or investigate your request, we may need to request specific information from you to help us confirm your identity (this is so we can check your right to access the requested MAC address or to exercise any of your other rights). We may also contact you for further information in relation to your request in order to provide a timely response to your request.

We aim to respond to all legitimate requests within one month of receiving them. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated about our timing for response.

Contact us

You can also request further information or exercise your right of access, rectification, erasure or limitation of the processing of your data by email at contact@flowly.re, in line with the terms of this collection statement.