Introduction

In this privacy notice, when we refer to “Trainline”, “we”, “us” or “our” we mean Trainline plc and its subsidiary companies, and when we refer to “you” or “your”, we mean visitors to this website.

Trainline respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we process your personal data when you visit our website. This privacy notice will also tell you about your rights and how the law protects you.

It is important that you read this privacy notice together with any other privacy notice or fair processing notices we may provide on specific occasions.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us.

Please note that Trainline processes the personal data of its customers in different ways to those contemplated by this Site and, as such, the consumer website (https://www.thetrainline.com) has its own privacy notice. This can be accessed here.

  1. The data we collect about you
  2. How is your personal data collected
  3. How we use your personal data
  4. Disclosures of your personal data
  5. International transfers
  6. Data security
  7. Data retention
  8. Your legal rights
  9. Contacting us

1.  The data we collect about you

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you when you use our site or interact with us; which we have grouped together as follows:

  • Identity Data includes first name and last name.
  • Contact Data includes company name and email address.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website.
  • Communications Data includes all communications we have with you whether by email, post, phone or otherwise.

We may also process Aggregated Data such as statistical data EG number of visitors to our site over a defined period.

2.  How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
    • Technical Data from the following parties:
      • Analytics, storage, tools and media providers based in and outside the EU;
      • IP tracking service providers based within the EU;
      • automated quality control tools based within the EU;
      • automated security and compliance tools based outside the EU;
      • social media and media networks such as Twitter, LinkedIn, Instagram, YouTube and Vimeo based outside the EU; and
      • email distribution and survey providers based outside the EU;
  • Identity and Contact data from providers of data feeds and hosting services provided inside the EU and outside of the EU.

3.  How we use your personal data

We will only process personal data where we ave a genuine need to do so and in line with our obligations under data protection laws.  Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform a contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or your legitimate interests or those of a third party).
  • With your consent.
  • Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

1. To manage our relationship with you

This includes:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
(c) Answering any queries you may have

Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Communications

2. To administer and protect our business and this website

This includes troubleshooting, data analysis, testing, security, fraud, system maintenance, support, reporting and hosting of data)

Type of data
(a) Identity
(b) Contact
(c) Technical

3. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data
(a) Technical
(b) Usage

4. To provide news/updates via an automated email alert service

Type of data
(a) Identity
(b) Contact

Opting out of communications

You can ask us to stop sending you messages at any time by contacting us.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site about aspects of your visit. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.  Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out above.

  • Internal Third Parties
  • External Third Parties:  Digital service providers acting as processors, who provide a number of services, including but restricted to data feeds, hosting, SSL, data analysis, CRM, video streaming, social media and sharing services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.  International transfers

Wherever possible we do not transfer your personal data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data may sometimes involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure an appropriate  level of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • We rely on standard contractual clauses as approved by the EU Commission.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA (and a copy of those safeguards).

6.   Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

7.  Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data.  In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8.  Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee where we are permitted to do so by law.  

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a necessary measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request, in order to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month, as prescribed by law. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Contacting us

If you’ve got any questions that haven’t been covered, please contact our Data Protection Officer.  Email us at investorprivacy@thetrainline.com, or write to us at Data Protection Officer, PO Box 23972, Edinburgh, EH3 5DA.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We will amend this policy from time to time to comply with applicable laws and regulations or to meet our changing business requirements. You are encouraged to periodically review this page for the latest information on our privacy practices and amendments to this policy.

Version control: 16 August 2019 v2