Privacy Policy
Section 1 — Introduction
TrainTravelDeal (together “we”, “our”, or “us”) are committed to respecting your privacy and value the trust and confidence you place in us. We are committed to safeguarding your privacy while you are using TrainTravelDeal.com; m.TrainTravelDeal.com; TrainTravelDeal applications for iOS or Android (referred to collectively as the “Site” or “Sites”); or Personal Data you provide to us in-person or over the phone in order to use our services. This privacy policy (referred to on this page as the “Policy”) describes our commitment to your privacy. When you use the Site, we may process Personal Data about your visit to the Site, your usage of the Site, and Personal Data that you provide.
If you plan to enroll as a member in the TrainTravelDeal Guest Rewards program, please read this Policy and also carefully read Section 9 of this Policy, which provides additional information related to the Personal Datathat you provide to us to become a member in the TrainTravelDeal Guest Rewards program.
This Policy describes:
- The responsible entity for the processing of your Personal Data
- What Personal Data we process and the purposes for which we process the Personal Data.
- With whom your Personal Data may be shared and Your California Privacy Rights.
- What security precautions we implement to protect against the unlawful destruction, loss, alteration, unauthorized disclosure of or access to your Personal Data, including your credit card information.
- How you can access, update, correct, or request the deletion of the Personal Data we process from you.
- What choices you have regarding the processing of your Personal Data, including your ability to choose to receive promotional information by email.
- How you can contact us regarding this Policy and our privacy practices.
- What special privacy practices and rules are in place regarding the TrainTravelDeal Guest Rewards program web site.
- Information about California consumer’s privacy.
- Further information for users in the EU/EEA.
“Personal Data” means any information relating to an identified or identifiable natural person. This typically includes your name, gender, date of birth, email address, phone number, but can also include your bank account information, IP address, browser type, or previously visited websites.
Please note that this Policy only addresses TrainTravelDeal privacy practices concerning Personal Data we process from your use of the Site, and not other third-party sites, mobile applications, or other sources. To the extent you are interacting with other sites, mobile applications, or sources, you should review their privacy policies, which will inform you as to how they process your Personal Data. This Policy addresses how certain Personal Data processed from you is used by us when you visit other sites that are not affiliated with TrainTravelDeal.
A Note About Changes to This Policy
We reserve the right to update and change this Policy from time to time in order to reflect any changes to the way in which we process your Personal Data or changing legal requirements. Any changes we may make in the future will be posted on this page. The last update to this Policy shall also be its effective date. In case of substantial changes to this Policy, we will inform you about these changes consistent with applicable law.
Section 2 — Responsible Entity Processing Your Personal Data
National Railroad Passenger Corporation d/b/a TrainTravelDeal, 1 NewYork Avenue, N.W., Washington, DC 20001, USA is responsible for processing your Personal Data. You can find our contact information in Section 8 below.
Section 3 — The Personal Data We Process from You and the Purposes for Which We Process Your Personal Data
We process Personal Data in several ways from several different parts of the Sites. We ask for and process Personal Data in the following circumstances:
A. When you join TrainTravelDeal Guest Rewards
U.S. and Canadian residents can join our TrainTravelDeal Guest Rewards program. When you join TrainTravelDeal Guest Rewards, we process the following Personal Data:
1. TrainTravelDeal Guest Rewards Data
Personal identifiers and personal details, such as:
- Name
- Addresses (home, billing) (optional)
- Telephone number (optional)
- Email address
- Account status
- Favorite departure and arrival stations (optional)
- Password
- Membership number
- Loyalty points and redemption awards
- Information about trip reservations, including routes and schedules
- Preferred passenger discount type (optional)
- Rail Passengers Association (RPA) membership numbers (optional)
- Employee passrider information (optional)
- Date of birth (optional)
- Gender (optional)
- Purpose of trips (optional)
Financial information, such as:
- Payment card, e-wallet or digital payment information (optional)
2. Direct Marketing Data
Personal identifiers and personal details, such as:
- Whether you want to receive offers by email or postal mail
- Email address
- Postal address
We process your Direct Marketing Data to provide personalized offers by TrainTravelDeal or our partners to you and we provide updates about your account in a Monthly Statement.
You may choose to stop receiving our marketing emails by following the unsubscribe instructions in these emails, accessing the marketing settings in your Guest Rewards Account or contacting us as described in Section 8 of this Policy.
We also analyze your interaction with our marketing emails in order to further optimize them and better personalize them based on your interests. We process the following Personal Data:
- Whether you have opened our marketing emails
- Which contents you have clicked on
3. Accommodation Data
In case of a disability, personal details such as information about the type of disability, accommodation preferences and service animals.
We process the Guest Rewards Data, Direct Marketing Data and Accommodation Data to provide better service when you make reservations on the Site. This permits us to pre-populate information for you during the reservations booking process, so you will not have to re-enter it each time you book a reservation. We also process the Guest Rewards Data, Direct Marketing Data and Accommodation Data to provide rewards to you and send news about our products and services to you.
B. When you purchase tickets and make a reservation through the Site, in person, or over the phone
We process Personal Data about you (and, if necessary, your traveling companions) to process your order, whether you purchase tickets while logged into your TrainTravelDeal Guest Rewards account, or while not logged in (i.e., as a guest). We may also process this Personal Data if you purchase your ticket in person or over the phone, and subsequently load it online to allow you easier access to your reservations. We use this Personal Data to fulfill your booking requests. This Personal Data includes (Purchase Data):
Personal identifiers, such as:
- Your name
- User name and password
- Email address
- TrainTravelDeal Guest Rewards membership number
- Mailing address (if necessary)
- Billing address
- Telephone number
- National ID card number, passport number or driver’s license number for cross border crossing
Financial information, such as:
- Credit card type, number, expiration date, and security ID
- Information related to your digital payment account, such as Apple Pay (if you use a digital payment account to purchase tickets or services)
- Personal details, such as:
- Travel and reservation information (departure and arrival points, dates of travel, train number, accommodations, names and number of travelers in your party, fares)
- Passenger discount types (if any)
- Ticket pick-up/delivery options
- Promotional codes used (if any)
- Information regarding trip insurance
- Information regarding products brought to travel (bicycle, golf clubs, or guns)
- Accommodation Data as listed in Section 3.A of this Policy
If you purchase tickets for more than one person, we may also ask for the name of each person traveling so that we may issue a ticket in each passenger’s correct name. We do not use the names of these other passengers for any other purpose. We may also ask for your telephone number so that we can contact you in the event that there is a major scheduling change or cancellation of your train.
In addition, when you purchase tickets while logged into your TrainTravelDeal Guest Rewards account, we also save information about your canceled reservations, if any. Also, if you choose, we can save trip information regarding trips that you have researched, but have not yet booked. You also have the option to view a list of confirmed reservations you made online, as well as any canceled trips.
C. When you purchase TrainTravelDeal merchandise
We process Personal Data from you when you make purchases through our online store for the purpose of fulfilling your order. This Personal Data includes (Merchandise Purchase Data):
Personal identifiers, such as:
- Name
- Address
- Email address
Financial information, such as:
- Details of the order
- Credit card type, number, expiration date
- Information related to your digital payment account, such as Apply Pay (if you use a digital payment account to purchase TrainTravelDeal merchandise)
- Dollar amount purchased
D. When you purchase a gift card or someone purchases a gift card for you
We process the following Personal Data when a gift card is purchased on our Site (Gift Card Data):
Personal identifiers, such as:
- Name of purchaser and recipient of gift card
- Address of recipient of gift card
- Email address of recipient of gift card
Financial information, such as:
- Credit card type, number, expiration date
- Billing address
Personal details, such as:
- Amount of the gift card
- Gift card number
- Personalized message for recipient
E. When you request travel and promotional information
When you request information, such as brochures, timetables and gift catalogs, we process Personal Data from you that is necessary to fulfill our service obligations to you. This Personal Data includes (Promotional Data):
Personal identifiers, such as:
- Your name
- Postal address
- Telephone number
Communication content, such as:
- Information included in your request
F. When you subscribe to our (non-Guest Rewards) marketing emails
When you subscribe to our (non-Guest Rewards) personalized marketing emails, we process the following Personal Data (Marketing Data):
Personal identifiers, such as:
- Name
- ZIP code
- Email address
You may choose to stop receiving our marketing emails by following the unsubscribe instructions in these emails or contacting us as described in Section 8 of this Policy.
G. When you contact us
If you contact TrainTravelDeal through the Site, such as through our Contact Us page or via phone, we process the following Personal Data to respond to your inquiry (Contact Us Data):
Personal identifiers, such as:
- Name
- Email address
- Phone number
- TrainTravelDeal Guest Rewards Number
Communication content, such as:
- Subject of your inquiry
- Any information you provide to us in your correspondence
H. When you use the Site
We process the logfiles of our server to provide the Site to you, make the Site more enjoyable and ensure IT security. Logfiles are records on our server about (i) which users have visited our Sites, (ii) when have they visited our Sites, and (iii) how have they used our Sites. This Personal Data includes (Logfile Data):
Online identifiers, such as
- IP address
- Operating system
- Browser type
We also use cookies and similar technologies on our Site. For more information, please review our Cookie Policy.
I. When you use TrainTravelDeal mobile applications
Each time you access an TrainTravelDeal mobile application we process the following Personal Data automatically about your use of the application to optimize the application (Application Data):
Information automatically collected, such as:
- Screens viewed and navigation through the application
- Application version
- Stations selected as favorites
- Train Status search method
- Operating system and version
- Device model
- Network service provider
- Information about the device used to run the application.
Geolocation data, such as:
Information about your usage and device is processed in the aggregate and cannot be tied to a specific individual.
If an application has access to additional information on your phone, such as contacts or calendars, we do not automatically process that information. This access is to allow you to interact with your information from within the TrainTravelDeal application.
J. Our policy towards children
COPPA
We strive to comply with the Children’s Online Privacy Protection Act. Neither our services nor the Site are directed at persons under the age of 13 and we do not knowingly process Personal Data from children under 13. If you become aware that your child has provided us with their Personal Data, without your consent, then please contact us using the details in the Section 8 of this Policy so that we can take steps to remove such information and terminate any account your child has created with us.
GDPR
We also strive to comply with the EU General Data Protection Regulation. The Sites are not intended for children and we do not knowingly process Personal Data relating to children under the age of 16 in cases where GDPR is applicable.
Section 4 — With Whom We Share Your Personal Data
General
We work with certain reputable service providers who perform certain tasks for TrainTravelDeal. These tasks include storing and managing customer Personal Data and providing advice about and support for our products and services. By using these service providers, we can more efficiently process your transactions and better offer you a variety of products and services. A partial list of the services we contract for includes the following:
- TrainTravelDeal Guest Rewards program management
- TrainTravelDeal email services
- Customer data storage and processing
- Application development
- Order fulfillment
- Payment processing, including processing your credit card or digital payment account information to facilitate your payment between TrainTravelDeal and your bank
- Hotel reservations
- Car rental reservations
- Travel insurance
- Other transportation options
- TrainTravelDeal-sponsored market research studies
- Gift card(s)
We have carefully selected these service providers and entered into data processing agreements, if required by applicable law.
In addition to our contractors, we also have relationships with advertisers or other trustworthy business partners to provide you with information about various products and services that we believe would be of interest to you. Further, we may share Personal Data with social media companies to help us with our online marketing and advertising activities and with third-party analytics services to help us understand and improve the usage of our Site and the effectiveness of our marketing efforts (although we do not use Facebook Custom Audience for users from the EU/EEA). Note that the information that is processed from you by our use of third-party cookies may be shared with certain third-party technology vendors in order for us to enable the delivery of targeted ads about our products and services, including the products and services of our partners, when you visit non-affiliated web sites after visiting the Site. You may choose to opt-out of our re-target advertising for certain participating companies who are voluntary members of the Digital Advertising Alliance by visiting the DAA website located at www.digitaladvertisingalliance.org. Not all of our partners may be participants of the DAA so we encourage you to contact these partners directly through their own web sites if you wish to request that you have yourself removed from their targeted ads.
To the extent necessary, we may also share your information with courts, law enforcement authorities, regulators, government officials or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim.
If you make a request for information about, subscribe to or make an online purchase of, goods or services offered by one of our business partners on the Site, you are giving us your express permission to share your Personal Data with that business partner so that your request, subscription, or purchase can be fulfilled under that partner’s own online privacy policies and practices. If you enter an TrainTravelDeal sweepstakes or contest, your Personal Data may be shared with the TrainTravelDeal business partners who are co-sponsors of the sweepstakes or contest and who are likely to have different privacy policies and practices than TrainTravelDeal.
Data in the Aggregate
We may disclose to prospective partners, advertisers and other selected third parties aggregated user statistics data (for example, a statistic indicating that 45 percent of our users are female) in order to describe our services to these third parties, and for other lawful purposes.
Reservation of Rights
We reserve the right to disclose Personal Data when we have reason to believe that disclosing this information is necessary to identify, contact, bring or defend against legal action involving someone who may be violating this Policy or who may be causing injury to or interference with (either intentionally or unintentionally) TrainTravelDeal’s rights or property, other TrainTravelDeal users or anyone else who could be harmed by such activities. We may disclose or access account information for administrative or other purposes that we deem necessary to maintain or improve our products, services or the operation of the Site, for law enforcement purposes, or when we believe in good faith that the law requires it.
Other Sites May Collect Information
Please also be aware that when you click on an advertisement on another site that is linked to the Sites, or when you otherwise use web sites that link to the TrainTravelDeal.com site, your Personal Data may be collected by those sites. This Policy does not cover the privacy practices of any such other web sites, and we cannot accept responsibility or liability for the privacy practices of those other sites. Please refer to those sites’ privacy policies for information about their practices.
Special Note for TrainTravelDeal Guest Rewards Program Members
When you join the TrainTravelDeal Guest Rewards program, you agree to allow TrainTravelDeal to share with participating business partners of the TrainTravelDeal Guest Rewards program your Personal Data for the purpose of providing you with information and promotions. Please refer to Section 9 of this Policy to learn about how the TrainTravelDeal Guest Rewards program processes your Personal Data.
Special Note for Customers of Other Carriers and Travel-Related Service Providers Using the Site for Reservation and Ticketing Services
TrainTravelDeal provides reservation and ticketing services for other carriers and travel-related service providers. By using the Site for reservation and/or ticketing for the products or services of another carrier or travel-related service provider, you expressly give permission to share your Personal Data with that carrier or service provider, who shall treat your Personal Data in accordance with its own privacy policies and practices. For information about the privacy policies and practices of another carrier or service provider, please contact that carrier or service provider directly.
Section 5 — What Security Precautions We Have in Place to Protect Against the Unlawful Destruction, Loss, Alteration, Unauthorized Disclosure of or Access to Your Personal Data
When you make reservations, place orders, or access account information from the Site, we use encryption technology to safeguard the confidentiality of your Personal Data as it travels over the Internet. We protect against the unlawful destruction, loss, alteration, unauthorized disclosure of or access to your Personal Data by means of firewalls and other security measures.
Your TrainTravelDeal Guest Rewards membership account information (should you enroll in the TrainTravelDeal Guest Rewards program) are password protected. We recommend that you do not divulge your password to anyone. Also remember to sign out of your TrainTravelDeal account and close your browser window or the mobile application when you have finished.
When you give TrainTravelDeal Personal Data about you, that Personal Data may be sent electronically to servers outside and separate from TrainTravelDeal and outside of the state where you originally entered the Personal Data. In addition, that Personal Data may be processed outside of TrainTravelDeal and outside of the state where you entered that Personal Data. Whenever we process Personal Data as described above, regardless of where this occurs, we take steps to ensure that your Personal Data is treated securely.
Unfortunately, no data transmission over the Internet can be guaranteed to be absolutely secure. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to TrainTravelDeal.com, and you do so at your own risk. Once we receive your transmission, we make our best effort to ensure its security on our systems. However, we cannot accept liability for disclosure of any Personal Data due to errors in transmission or unauthorized ads or errors and omissions of third parties.
Section 6 — Our Policy on Allowing You to Access, Update, Correct or Delete Your Personal Data
When you join TrainTravelDeal Guest Rewards, you can choose not to receive information and offers by email.
You may change your preferences regarding whether you want to receive mail or email at any time by accessing and updating your TrainTravelDeal Guest Rewards Profile. You may access your Profile by clicking on the ‘My Profile’ link under the My Account drop-down menu on the header of most pages of the TrainTravelDeal.com web site.
Within the TrainTravelDeal Mobile App you may access your user profile by going to the Account section.
You may make changes to your TrainTravelDeal Guest Rewards program information by accessing your TrainTravelDeal Guest Rewards account information online at www.TrainTravelDeal.com or, by contacting the TrainTravelDeal Guest Rewards Service Center at 1-800-307-5000. If you have processed a request to delete, correct or update any part of your TrainTravelDeal Guest Rewards membership account, we will make every reasonable effort to see that your instructions to delete and/or make revisions are also communicated to and/or accessed by our contract service providers who may have received your Personal Data and that they too have either deleted and/or revised the information in accordance with your latest instructions.
Please note that our contract service providers require a reasonable amount of time to update, correct or delete the Personal Data in accordance with your instructions.
Section 7 — Your Choices Regarding Processing of Personal Data, Including Your Ability to Choose Not to Receive Promotional Information by Email
If you have made a purchase with us and used a U.S. billing address, we will send you email correspondence regarding TrainTravelDeal products and services. You may choose to stop receiving these emails by following the unsubscribe instructions in these emails or contacting us as described in Section 8 of this Policy.
Section 8 — Contacting Us Regarding This Policy
If you have questions or concerns regarding this Policy or our privacy practices, you may use the form on the Contact Us page or contact us via email at Privacy@TrainTravelDeal.com.
If you are a California resident, select California Privacy Rights from the “Subject” drop-down menu on the page. Be certain to provide your complete mailing address on the form. You may access the Contact Us page by clicking the link at the bottom of most pages on this site.
If you are a user from the EU/EEA, you may also contact our local representative at: RAe Niedermeier+Teichmann PartmbB, Maximilianstr. 13, 80539 Munich, Germany, phone: +49 (0) 20 300 6422, fax: +49 (0) 89 20 300 6450, email: niedermeier@cyberprivacy.legal.
Section 9 — Special Privacy Practices and Rules for the TrainTravelDeal Guest Rewards Program
If you enroll as a member of the TrainTravelDeal Guest Rewards program, there are special supplemental privacy practices and rules that apply to the Personal Data that you provide. These special privacy practices and rules, which you understand and expressly agree to when you join the TrainTravelDeal Guest Rewards program, are presented below. Please note that these special practices and rules pertain only to the TrainTravelDeal Guest Rewards program. They do not apply to the Personal Data that you provide to us elsewhere at TrainTravelDeal.
In the event of any inconsistency between any portion of Section 9 and any other portion of this Policy, that portion of Section 9 that is inconsistent with any other portion of this Policy supersedes and governs over the inconsistent Policy term(s) with respect to the privacy practices and rules of the information collected under the program.
When you become an TrainTravelDeal Guest Rewards member, we collect and process the personal identifiers, personal details, and financial information listed in Section 3(A) above. We use this Personal Data to operate the TrainTravelDeal Guest Rewards program and offer its benefits. We reserve the right to refuse membership in the program to you if you do not follow the enrollment procedures and/or do not provide the Personal Data required for enrollment.
TrainTravelDeal may also receive Personal Data about you from participating business partners of the TrainTravelDeal Guest Rewards program.
As part of the TrainTravelDeal Guest Rewards program, we may offer price or service differences and other financial incentives such as coupons, discounts, upgrades, and special access in exchange for the points you obtain and our use of your personal information. The value we place on the Personal Data obtained in connection with the program is calculated by determining the approximate additional spending per member per year compared to individuals who are not enrolled in the program, the anticipated expenses which might be incurred in the collection, storage, and use of Personal Data in the operation of the program, and other relevant factors related to the estimated value of Personal Data to our business. We are entitled to use and/or disclose the Personal Data we receive during the enrollment process and during your membership in the program in exchange for providing the financial incentives offered by the program.
Choices are available to you regarding the use and sharing of your Personal Data. By joining the TrainTravelDeal Guest Rewards program, you expressly give us your permission that the Personal Data that you have provided to us by joining the TrainTravelDeal Guest Rewards program may be accessed by or shared with our program’s trustworthy business partners through our reputable contract service providers under that partner’s own policies and practices.
In addition, you agree that we may update and/or revise database information that we currently have about you. You may also agree that we may send you by email or mail information about the program, and other information, including information provided by our program’s participating business partners. These practices are necessary to administer the program and its services. We will also inform you about special offers and promotions regarding products and services that may be of interest to you.
When you enroll in the program, you may elect not to receive special information and offers by email, mobile or mail. You may also at any time change your preferences regarding whether you want to receive email, mobile or mail by accessing your membership account at TrainTravelDeal.com, by contacting the TrainTravelDeal Guest Rewards Program Service Center at 1-800-307-5000 or changing your settings in the mobile application. Your preferences can be customized based on the type of communications you wish to receive from TrainTravelDeal Guest Rewards.
You may terminate your membership in the TrainTravelDeal Guest Rewards program at any time by contacting the TrainTravelDeal Guest Rewards Program Service Center at 1-800-307-5000. If you terminate your membership, any accumulated points will be forfeited and you may not have access to other program benefits. If you later re-join the TrainTravelDeal Guest Rewards program, any forfeited points will not be reinstated.
Section 10 — California Privacy
This section applies only to Personal Data of consumers who are California residents.
As a California consumer, we will honor your: request for additional information about our data collection, use, disclosure, and sales practices in connection with the your Personal Data; request for the specific Personal Data collected about you during the previous 12 months; and request for the deletion of the Personal Data we have about you (subject to reasonable exceptions as typically recognized by law). We will not discriminate against you for making any of these requests, or for opting out of the “sale” of your Personal Data.
If you are a resident of the state of California, under the California Civil Code § 1798.83, you are entitled to request information regarding which third parties TrainTravelDeal has shared Personal Data in the immediately preceding calendar year for direct marketing purposes. To do so, send a request for information indicating your preference as to how you would like us to respond to your request (i.e., email or postal mail).
To make a request, select California Privacy Rights from the “Subject” drop-down menu on the Contact Us page, through our phone number at 1-800-Rail-trecks or via postal mail, proper postage pre-paid, at:
All requests sent via postal mail must be labelled “California Privacy” on the envelope or post card and must be clearly stated on the actual request. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.
In most cases, you will be required to provide your name and email address or your name and street address (if you would like a response via postal mail), city, state, and zip code so that we can verify your request, and in some cases additional information may be required. However, the verification steps we take may differ depending on your jurisdiction and the request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so. We will respond to your request within a 45-day time period. However, we may not always be able to fully comply with your request, and we will notify you in that event.
You may use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that demonstrates authorization to submit a request for the California consumer. An authorized agent must follow the process described above to make a request, and we will also (a) require the authorized agent to verify the agent’s own identity and (b) confirm the agent’s authority with the California consumer about whom the request was made.
Section 11 — Further Information for Users in The EU/EEA
The following information and rights apply if you use our Sites from a member state of the EU/EEA:
1. Legal bases for the processing of your Personal Data
We process your Personal Data based on the following legal justifications:
A. When you purchase tickets and make a reservation through the Site, in person, or over the phone
We process the Purchase Data for the performance of the contract (Article 6(1)(b) GDPR).
We process your Accommodation Data based on your consent (Article 9(2)(a) GDPR).
B. When you purchase TrainTravelDeal merchandise
We process the Merchandise Purchase Data for the performance of the contract (Article 6(1)(b) GDPR).
C. When you purchase a gift card or someone purchases a gift card for you
We process the Gift Card Data for the performance of the contract (Article 6(1)(b) GDPR), if you order a gift card for yourself or legitimate interests (Article 6(1)(f) GDPR), if someone orders the gift card for you, in order to provide the gift card to you.
D. When you request travel and promotional information
We process the Promotional Data for the performance of the contract (Article 6(1)(b) GDPR).
E. When you subscribe to our (non-Guest Rewards) marketing emails
If you subscribe to receive the (non-Guest Rewards) marketing emails, the Marketing Data are processed based on your consent (Article 6(1)(a) GDPR).
F. When you contact us
We process the Contact Us Data for the performance of the contract (Article 6(1)(b) GDPR).
G. When you use the Site
We process your Logfile Data based on our legitimate interests (Article 6(1)(f) GDPR) to provide the website to you, make the Site more enjoyable, and ensure the IT security.
H. When you use TrainTravelDeal mobile applications
We process your Application Data based on our legitimate interests (Article 6(1)(f) GDPR) to optimize the applications.
We process your geolocation with your consent (Article 6(1)(a) GDPR). You can always switch off the processing of your geolocation in the settings for the TrainTravelDeal mobile application in the general settings section of your phone.
2. Retention of your Personal Data
We retain your Personal Data as follows:
A. When you purchase tickets and make a reservation through the Site, in person, or over the phone
We retain your Purchase Data as long as you continue purchasing tickets. We will delete your Purchase Data if you have not purchased anything for three years and, where applicable, retain it longer as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
We retain your Accommodation Data as long as you have not withdrawn your consent and, where applicable, as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
B. When you purchase TrainTravelDeal merchandise
We retain your Merchandise Purchase Data as long as you continue purchasing merchandise. We will delete your Merchandise Purchase Data if you have not purchased anything for three years and, where applicable, retain it longer as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
C. When you purchase a gift card
We retain the Gift Card Data until we have sent the gift card to you or the recipient, and where applicable, as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
D. When you request travel and promotional information
We retain the Promotional Data as long as you continue requesting travel and promotional information. We will delete your Promotional Data if you have not requested any travel and promotional information for three years and, where applicable, as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
E. When you subscribe to our (non-Guest Rewards) marketing emails
We retain your Marketing Data as long as you have not withdrawn your consent and, where applicable, as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
F. When you contact us
We retain the Contact Us Data for the time required to respond to your inquiry and, where applicable, as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
G. When you use the Site
We retain the Logfile Data for the time required to ensure IT security of the Sites and, where applicable, as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
H. When you use TrainTravelDeal mobile applications
We retain the Application Data for the time required to to optimize the applications and, where applicable, as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
We retain your geolocation as long as you have not withdrawn your consent and, where applicable, as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
3. International transfers
Our sharing of your Personal Data in accordance with this Policy may involve transferring your Personal Data outside the EU/EEA. Whenever we transfer your Personal Data out of the EU/EEA, we ensure an adequate level of protection is afforded to it by ensuring, where required by law, at least one of the following safeguards is implemented:
- Transferring Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the EU Commission, or
- Using specific contracts approved by the EU Commission which give Personal Data the same protection it has in Europe.
You may be entitled, in accordance with applicable law, to request a copy of the specific safeguard by contacting us as described in Section 8 above.
4. Your rights
In furtherance to Section 7 above, as a data subject located in the EU, you have the following rights regarding your Personal Data in certain circumstances and subject to the associated preconditions as set forth under the General Data Protection Regulation
Right of access: You may ask us to confirm whether we are processing your Personal Data and, if so, to provide you with a copy of that Personal Data (along with certain other details).
Right to rectification: If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to ask for rectification or completion.
Right to erasure: You may ask us to delete or remove your Personal Data in some circumstances, e.g., if you believe we no longer need it or if you withdraw your consent (where applicable).
Right to restrict processing: You may ask us to restrict the processing of your Personal Data in some circumstances, e.g., if you object to us processing it.
Right to data portability: You have the right to obtain Personal Data you have provided to us in a structured, commonly used and machine-readable format for reuse under certain circumstances.
Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so under appropriate circumstances, if we (i) rely on legitimate interests to process your Personal Data, except if we can demonstrate compelling legal grounds for the processing, or (ii) process your Personal Data for direct marketing.
Rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision when it is based solely on automated processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
Right to withdraw consent: If we rely on your consent as legal basis for processing your Personal Data, you have the right to withdraw that consent at any time.
You may exercise your rights by contacting us as described in Section 8 of this Policy.
You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State where you reside, work or suspect an infringement, if you believe that the processing of Personal Data concerning you is not in compliance with GDPR requirements.
