Privacy Policy

1.    General information

1.1    Definition of terms

This privacy policy is based on the following definitions of terms, as outlined in Art. 4 GDPR:

  • personal data” is all information that relates to an identified or identifiable natural person (“data subject”). A person is identifiable if he/she can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or by means of information concerning their physical, physiological, genetic, mental, economic, cultural or social identity characteristics (Art. 4(1) GDPR). Identifiability can also be provided by linking such information or other additional knowledge. This does not depend on the occurrence, form or physical embodiment of the information (photos, video or sound recordings may also contain personal data).
  • processing” is any operation in which personal data is handled, whether or not by automated means (i.e. technology-supported). This includes in particular the collection (i.e. the procurement), the recording, the organisation, the structuring, the storage, the adaptation or alteration, the retrieval, the consultation, the use, the disclosure by transmission, the dissemination or otherwise making available, the alignment, the combination, the restriction, the erasure or destruction of personal data as well as the change of definition of a target or purpose that was originally used as a basis for data processing (Art. 4(2) GDPR).
  • controller” is the natural or legal person, public authority, agency or other body that decides alone or together with others on the purposes and means of processing personal data (Art. 4(7) GDPR).
  • processor” is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller, in particular in accordance with its instructions (Art. 4(8) GDPR).
  • third party” is any natural or legal person, public authority, agency or other body other than the data subject, controller, processor and persons who under the direct authority of the controller or processor are authorised to process the personal data; this also includes other legal entities belonging to the group (Art. 4(10) GDPR).
  • consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her; (Art. 4(11) GDPR).

1.2    Name and address of the controller

The person responsible for the processing of your personal data (Art. 4(7) GDPR) is:


183 Northern Road,




Telephone: (+44) 0333 772 2622

Email: [email protected]

1.3    Contact details of the data protection officer

Our company data protection officer is available to you at any time to answer all your questions and as a contact person on the subject of data protection.

Her contact details are:


183 Northern Road,




For general questions about TOPBUS®, please contact [email protected].

1.4    Legal basis of data processing

The processing of personal data is permitted if at least one legal basis listed below is complied with:

  • Art. 6 para. 1(a) GDPR: the data subject has given his/her consent to the processing of the personal data concerning him/her for one or more specific purposes;
  • Art. 6 para. 1(b) GDPR: the processing is necessary for the performance of a contract to which the data subject is a contracting party, or for the implementation of pre-contractual measures which are carried out at the request of the data subject;
  • Art. 6 para. 1(c) GDPR: the processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a statutory retention obligation);
  • Art. 6 para. 1(d) GDPR: the processing is necessary to protect the vital interests of the data subject or another natural person;
  • Art. 6 para. 1(e) GDPR: If the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or;
  • Art. 6 para. 1(f) GDPR: the processing is necessary to safeguard the legitimate interests pursued by the controller or a third party, unless the opposing interests or rights of the data subject prevail (in particular where the data subject is a child).

For processing carried out by us, we specify the applicable legal basis under Clause 2. Processing can also be based on more than one legal basis.

1.5    Categories of recipients

Under certain conditions, we transmit your personal data to our subsidiaries, or personal data from our subsidiaries is transferred to us, to the extent that is permissible.

As with any major company, we also use external domestic and foreign service providers to handle our business transactions and work with partner companies at home and abroad. These include, for example:

  • carriers (you can find an overview of the current carriers)
  • (IT) service providers
  • financial institutions and payment service providers
  • sales partners
  • customer service providers (internal/external)
  • shop operators
  • security companies
  • (travel) insurers
  • other partners engaged for our business operations (e.g. auditors, banks, insurance companies, lawyers, supervisory authorities, other parties participating in company acquisitions)

The service providers and partner companies must provide guarantees that suitable technical and organisational measures are implemented by them in such a way that the processing meets legal requirements and the rights of the data subjects are safeguarded.

We transmit personal data to public bodies and institutions (e.g. police, public prosecutor’s office, supervisory authorities) if there is a corresponding obligation/authorisation.

For processing carried out by us, we specify the categories of the data recipients under Clause 2.

1.6    Requirements for the transfer of personal data to third countries

As part of our business relationships, your personal data may be shared with or disclosed to third parties, who may also be located outside the European Economic Area (EEA), i.e. in third countries.

Insofar as it is necessary, we will inform you in the relevant sections of Clause 2 about the respective details of the transfer to third countries in connection with the processing carried out by us.

The European Commission certifies that some third countries have data protection that is comparable to the EEA standard by means of so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be downloaded from:

However, in other third countries to which personal data may be transferred, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is adequately guaranteed.

This is possible, for example, via binding company regulations (referred to as “binding corporate rules”), standard contractual clauses of the European Commission for the protection of personal data, certificates and recognised codes of conduct.

Insofar as it is necessary for your booking and the associated providing and processing of transport services, the transmission of personal data required for this to third countries is permitted in accordance with Art. 49 para. 1(b) GDPR.

Please contact our data protection officer if you would like more detailed information on this topic.

1.7    Storage duration and data erasure

The storage period of the personal data collected depends on the purpose for which we process the data. The data will be stored for as long as this is necessary to achieve the intended purpose.

In the case of processing carried out by us, we specify in Clause 2 how long the data will be stored by us. If no explicit storage period is specified below, your personal data will be erased or blocked as soon as the purpose or legal basis for the storage no longer applies.

However, storage can take place beyond the specified time in the event of a(n) (imminent) legal dispute with you, or if other legal proceedings are initiated, or if storage is stipulated by statutory provisions to which we as the controller are subject. If the storage period prescribed by statutory provisions expires, the personal data will be blocked or erased unless further storage by us is required and there is a legal basis for this.

1.8    Automated decision making (including profiling)

We do not intend to use any personal data collected from you for any processes involving automated decision-making (including profiling). If we wish to implement these procedures, we will inform you of this separately in accordance with statutory provisions.

1.9    No obligation to provide personal data

We do not fundamentally make the conclusion of contracts with us dependent on you providing us with personal data beforehand. In principle, there is also no statutory or contractual obligation to provide us with your personal data; however, we may only be able to provide certain offers to a limited extent, or not at all, if you do not provide the data required for this.

1.10    Statutory obligation to transmit certain data

Under certain circumstances, we may be subject to a special statutory or legal obligation to provide personal data to third parties, in particular public bodies.

1.11    Data security

We use suitable technical and organisational measures to collect your data, taking into consideration the latest technology, the implementation costs and the nature, the scope, the context and the purpose of the processing, as well as the existing risks of a data breach (including the probability and effect of such an event), in order to protect the data subject against accidental or intentional manipulation, partial or complete loss or destruction, or against unauthorised access by third parties (e.g. we use TLS encryption for our websites). Our security measures are continuously being improved to take into account technological developments.

We will be happy to provide you with further information about this upon request. Please contact our data protection officer or our CISO (chief information security officer) in this regard.

His contact details are:


183 Northern Road,




Email: [email protected] 

1.12    Your rights

You may assert your rights as a data subject regarding your personal data at any time, in particular by contacting us using the contact details provided in Clause 1.2. Data subjects have the following rights under the GDPR:

Right to information

You can request information in accordance with Art. 15 GDPR about your personal data processed by us. In your request for information, you should clarify your concern to make it easier for us to compile the necessary data. Upon request, we will provide you with a copy of the data that are the subject of the processing. Please note that your right to information may be limited under certain circumstances in accordance with statutory provisions.

Right to rectification

If the information relating to you is not (any longer) correct, you may request a correction in accordance with Art. 16 GDPR. If your data is incomplete, you may request completion.

Right to erasure

You may request the erasure of your personal data in accordance with the provisions of Art. 17 GDPR. Your right to erasure depends, among other things, on whether the data relating to you are still required by us to perform our statutory duties.

Right to restriction of processing

In accordance with the provisions of Art. 18 GDPR, you have the right to demand a restriction of the processing of the data relating to you.

Right to data portability

In accordance with the provisions of Art. 20 GDPR, you have the right to receive the data that you have provided to us in a structured, commonly-used and machine-readable format, or to request the transmission to another controller.

Right to object:

In accordance with Art. 21 para. 1 GDPR, you have the right to object to the processing of your data at any time for reasons relating to your particular situation. You can object to receiving advertising at any time with effect for the future, in accordance with Art. 21 para. 2 GDPR (objection to advertising in the case of direct marketing).

Right to appeal

If you are of the opinion that we have not complied with the provisions of data protection regulations when processing your data, you can complain to a data protection supervisory authority about the processing of your personal data, such as to the data protection supervisory authority to whom we are responsible:

Bavarian State Office for Data Protection Supervision, Promenade 18, 91522 Ansbach

Right to withdraw consent

You can withdraw your consent to the processing of your data at any time with future effect. This also applies to declarations of consent that were issued before the GDPR came into force, i.e. before 25/05/2018.

2.    Special information

2.1    Visiting our websites

Information about TopBus® and the services we offer can be found in particular at / including the associated subpages (hereinafter referred to jointly as “website” or “websites”). When you visit our websites, your personal data is processed.

2.1.1    Provision of websites

When using the websites for information purposes, we collect, store and process the following categories of personal data:

Log data: when you visit our websites, a log data record (referred to as “server log files”) is saved on our web server. This consists of:

  • the page from which the page was requested (referred to as referrer URL)
  • the name and URL of the requested page
  • the date and time of the access request (in the time zone of the server)
  • the version of the web browser used
  • the IP address of the requesting computer
  • the amount of data transferred
  • the operating system
  • the message whether the call was successful (access status/Http status code)
  • GMT time zone difference

We use IT service providers for hosting our websites and for statistical evaluations of the log data.

The processing of the log data serves statistical purposes and improves the quality of our websites, in particular the stability and security of the connection.

The legal basis is Art. 6 para. 1(f) GDPR. Our legitimate interest is to be able to make the websites available to you properly.

2.1.2    Contact forms

When using contact forms, the data transmitted in this way are processed (e.g. title, surname and first name, address, company, email address and the time of transmission, subject matter of the enquiry).

The processing of contact form data takes place in order to process enquiries, and depending on the basis and the subject matter of your enquiry, either on the legal basis of Art. 6 para. 1(b) GDPR, if it concerns a contract-related enquiry, or in other cases on the legal basis of Art. 6 para. 1(f) GDPR, our legitimate interest is to process contact enquiries.

We use customer service providers for job processing to answer enquiries made via our contact forms.

In addition, we store the contact form data as well as the respective IP address in order to comply with our obligations to provide evidence, to ensure compliance with and documentation of legal obligations, in order to be able to clarify any possible misuse of your personal data and to ensure the security of our systems.

The legal basis is Art. 6 para. 1(c) or (f) GDPR.

2.1.3    Booking, providing and processing of transport services

When booking tickets for transport services, we collect, store and process the following categories of personal data:

  • email address
  • surname and first name
  • connection data
  • payment data
  • date of birth (for transport services where children have a special price)
  • consent to the respective terms and conditions
  • advance seat reservation information
  • baggage details
  • language of the booking domain
  • booking channel (web or app)

You also have the option of providing a contact telephone number in case of delays or changes in the itinerary of your trip (optional).

These data are processed for the booking, providing and processing of transport services, including customer service, as well as for the fulfilment of legal obligations.

The legal basis is Art. 6 para. 1(b), (c) GDPR.

We also use some of these data for product recommendations, see Clause 2.1.4 and for the newsletter, see Clause 2.1.5 and the customer account, see Clause 2.1.6.

When booking tickets for international transport services, the following categories of personal data are also collected depending on the place of departure and arrival:

  • information on gender
  • identity document, passport or ID number
  • information in connection with measures to contain the COVID-19 (coronavirus) pandemic (for more information on this topic, see

These data are processed for the booking, providing and processing of transport services, including customer service, as well as for the fulfilment of legal obligations.

We pass on the above-mentioned data to the respective carrier or carriers, as well as to public bodies if there is a corresponding obligation/authorisation.

The legal basis is Art. 6 para. 1(b) or (c) GDPR.

The necessary payment data will be transmitted to a payment service provider for the secure processing of the payments initiated by you.

Our payment service providers are:


Payment service providers

Payment options

Adyen N.V.

Simon Carmiggeltstraat 6-50, 1011 DJ, Netherlands

Privacy policy:


Credit Card


Google Pay

Apple Pay




PayU Bilgi Teknolojileri A.S.

Otakcilar Cad. No: 78, Flat Ofis D-Blok 34050, Eyup - ISTANBUL

Privacy policy:

Credit Card

Paymill Plus GmbH

St.-Martin-Straße 63, 81669 München

Privacy policy:


PayPal (Europe) S.à r.l. et Cie, S.C.A.

22-24 Boulevard Royal 2449 Luxembourg

Privacy policy:


The legal basis is Art. 6 para. 1(b) or (f) GDPR.

For certain bookings, we also use the technologies and services of Distribusion Technologies GmbH as processors (Wattstrasse 10, 13355 Berlin, telephone: +49-30-3465507-50, email: [email protected]).

2.1.4    Product recommendation

To the extent permitted, we may use the email address received in connection with the booking or transport service to send you regular offers by email for products from our range similar to those already purchased.

We use external customer service providers as processors to send product recommendations.

You will receive these product recommendations from us regardless of whether you have subscribed to a newsletter or have consented to marketing communication by email. We would like to provide you in this way with information about products from our range that you might be interested in, based on your recent purchases with us.

The legal basis is Art. 6 para. 1(f) GDPR; our legitimate interest is to inform you about our product range and to suggest certain products to you.

You can object to the use of your email address for this purpose at any time by using the unsubscribe link of the product recommendation, or by sending a message to [email protected]

2.1.5    Newsletter

If you also register for the newsletter via our registration link, we ask you to consent to the processing of your data (email address, first and last name, place of residence) in order to send you our newsletter by email on a regular basis.

As part of your subscription to the newsletter, we also obtain your consent that we may personalise the content of our newsletter according to your needs and interests.

To register for our newsletter, we use the so-called double opt-in procedure. This means that after you have registered we will send an email to the email address you provided, asking you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically erased after one month.

The newsletter may concern all goods, services, products, offers and promotions provided by the controller (Clause 1.2) and/or by companies affiliated with the controller, or by partner companies.

The legal basis is Art. 6 para. 1(a) GDPR.

In addition, we store the IP addresses you use and the times of registration and confirmation. The purpose of the procedure is to prove that you are registered and, if necessary, to be able to clarify any possible misuse of your personal data. If we process your personal data for this purpose, this is done on the basis of our legitimate interests in ensuring compliance with and documentation of legal requirements.

The legal basis is Art. 6 para. 1(f) GDPR; our legitimate interest is to be able to prove consent.

You can revoke the use of your email address at any time by using the unsubscribe link of the newsletter or by sending a message to [email protected]. The legality of the data processing operations already carried out remains unaffected by the revocation.

We use external IT service providers who act as processors to distribute the newsletter.

2.1.6    Customer account

You have the option of creating a personal customer account with us. In the password-protected area of the customer account, you can manage your bookings conveniently and have your data stored for future journeys.

To create a customer account, the following mandatory information is collected:

  • email address
  • first and last name
  • password (self-selected)

We use this data to manage your customer account and to create invoices.

In addition, you can also enter a mobile phone number in your customer account so that we can contact you in the event of a delay or a change in the itinerary of your trip (optional).

You may also choose to store the following additional data in your customer account (optional):

  • title
  • date of birth
  • address (post code, city and country)
  • payment methods

These data are used to manage your customer account and to issue invoices, and can also be used to send personalised product recommendations (Clause 2.1.4) and – if you have registered for this purpose – to send newsletters (Clause 2.1.5).

The legal basis is Art. 6 para. 1(a), (b) or (f) GDPR.

If you have given your consent, so-called persistent cookies are stored on your device with the function “remain logged in”, their purpose is to ensure that you do not have to log in again during subsequent visits to our website. This function is not available to you if you have deactivated the storage of such cookies in your browser settings.

The legal basis is Art. 6 para. 1(f) GDPR.

You can update or delete the customer account – and thus also your stored personal data – at any time in your personal customer account.

2.1.7  Use of cookies, plugins and other services

When you visit our website, information in the form of a cookie (small text file) is saved on your terminal. It saves information about how you use the website (identification ID, visit date, etc.). With the use of cookies, we make it easier for you to use our site with various service functions (such as the recognition of previous visits), and consequently, we can better adapt the site to your needs.

The use of technically necessary cookies is based on Art. 6 (1) lit. f GDPR. Our legitimate interest is to provide you with the specific functionalities of our websites, to improve them, and to ensure the security and integrity of our websites.

You can prevent cookies from being saved and to delete cookies already existing by changing your browser settings accordingly. The help function of most browsers tells you how to make these settings. However, if you do not accept cookies, the service features of the Internet offer may be impaired. Therefore, we recommend leaving the cookie function turned on.

Comprehensive information on how this can be accomplished on a number of browsers can be found on the following websites: youronlinechoices, Network Advertising Initiative and/or Digital Advertising Alliance. You can also find information there about how to delete cookies from your computer as well as general information about cookies. We use different types of cookies:

Transient cookies, which are also known as in-memory cookie or "session cookies", are cookies that are deleted after you leave our website and close the browser. E.g. these cookies usually save language settings or the content of the order.


Persistent or permanent cookies remain stored even after the browser is closed. This enables e.g. saving the login status or any search terms that were entered. We use such cookies, among other things, to measure the reach or for marketing purposes. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. However, you can delete these cookies at any time in the security settings of your browser.

In addition to so-called "first-party cookies", which we set as controllers for data processing, "third-party cookies" are also used, which are offered by other providers.

As part of consent management (consent banner), we give you the opportunity to decide between the use of cookies and the use of comparable technologies. You can find a detailed overview with comprehensive information about the services used and access to your consent settings, including the possibility of revocation.

2.2    Customer service

When you contact our customer service, we collect the personal data that you provide to us on your own initiative. For example, you can send this to us by email, telephone or letter. Your personal data will only be used in order to contact you, or for the purpose for which you have provided us with this data, e.g. for processing your enquiries, technical administration or customer administration.

This data (including information on means of communication such as email address, telephone number) is provided on a voluntary basis. We use the data to process your concern, to fulfil legal obligations if necessary, and for administrative purposes.

The legal basis is Art. 6 para. 1(b), (c) or (f) GDPR.

In the case of a telephone enquiry, your data is also processed by telephone applications and in part also via a voice dialogue system in order to support us in the distribution and processing of enquiries.

For our customer service, we use external customer service providers as processors.

2.3    Presence on social media channels

We have a presence on social media (currently: Facebook). To the extent we have control over the processing of your data, we ensure that the applicable data protection regulations are complied with.

In addition to us, the following are responsible for the company’s presence within the meaning of the GDPR and other data protection regulations:

Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland)

We would like to point out that your data may be processed outside the European Union.

The legal basis for the processing of your personal data by us is Art. 6 para. 1(f) GDPR. Our legitimate interest is effective information and communication.

Further information about data protection laws in relation to our corporate presence on social media channels can be found here: