At Great Rail Journeys, we will always respect your privacy, and we are committed to protecting your personal data. This notice explains what we do with your personal data when you visit our website, download our App or call us to provide personal data when researching or booking a holiday with us, and tells you about your privacy rights and how the law protects you.
It also explains the effect this has on your privacy rights and how the law protects your data.
There is a lot of information here, so we've broken it down into different sections - click on the section you want to access on the menu below to find out more.
To download a pdf version of this Privacy Notice click here.
We've also created a handy Glossary at the end of the Notice, to explain some of the terminology in case it's unfamiliar to you.
- IMPORTANT INFORMATION
- THE DATA WE COLLECT ABOUT YOU
- HOW YOUR PERSONAL DATA IS COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- HOW WE DISCLOSE YOUR PERSONAL DATA
- WHEN AND WHY WE TRANSFER YOUR DATA OVERSEAS
- HOW WE KEEP YOUR DATA SAFE
- HOW LONG WE HOLD YOUR DATA FOR
- YOUR LEGAL RIGHTS
This notice aims to give you information on how Great Rail Journeys collects and processes your personal data. This includes both data you provide via our website and data you provide via other methods such as by telephone when you:
- Book travel arrangements with us
- Sign up to our newsletter
- Take part in a competition
- Complete a survey
- Use the 'Manage My Booking' portal
- Use our On-Tour App
This website is not intended for children and we do not collect data in relation to children It is important that you read this privacy notice together with any other privacy notice or fair processing notice we provide on specific occasions when we are collecting or processing personal data about you. This is so you're fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
When we say 'we' we mean Great Rail Journeys Limited
We are "Great Rail Journeys Limited", a company registered in England & Wales with company registration number 03208093 and registered office address at 4th and 5th Floors, HQ Building, Hudson Quarter, Toft Green, York, North Yorkshire, YO1 6JT. We trade as "Great Rail Journeys" and this is the data controller that is responsible for your personal data. The company is collectively referred to as "Great Rail Journeys" "we", "us" or "our" in this privacy notice.
If you have any questions about this privacy notice, including any requests to exercise ￼your legal rights, please contact us using the details set out below.
Great Rail Journeys Limited
4th and 5th Floors
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (ico.org.uk). If, however, you are unhappy with how we have handled your data, we would really appreciate the chance to deal with your concerns before you approach the ICO. Please contact us directly in the first instance - we'll do everything we can to resolve the issue.
Changes to the privacy notice and updating us of any changes
This version of the privacy was last updated on ￼4th October 2021. If you want to update your details or would like a previous version of this notice, please email MyData@greatrail.com or call us on 01904 521940.
Information you provide
Personal data, or personal details, means any information about you that means you could be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you. This data can be categorised as follows:
Data relating specifically to your identity, such as your name, previous names, gender, date of birth or similar identifier.
Data relating to how we may contact you, such as your address, email address and telephone numbers.
Financial and transaction data
Data relating to your means and methods of payment, such as your method of payment and data about the transactions you have carried out with us, such as payments to and from you and details of holidays and services you have purchased from us.
Data relating to your communications preferences, and whether you want to receive marketing from us.
Information we collect or generate about you
Data collected when you use our website, such as the device or software you use for example its IP address, technical specification your login data, time zone setting and location. For more information about how we collect this see our Cookie Notice
Data that we receive when you create a profile on our website, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Data and information about how you use our website, products and services.
This includes more technical data that we may obtain when you make use of our website or App, such as your internet protocol (IP) address, your device type and version, 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.
We may also use GPS technology to determine your current location if you allow us to do so. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling the location settings either on the App or via the settings on your device.
We also collect, use, and share Aggregated Data such as statistical or demographic data for many different reasons. Aggregated Data may be derived from your personal data but is not legally considered personal data, as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users that access a specific website feature.
Sometimes, we may combine or connect Aggregated Data in a way that could identify you, directly or indirectly. In these instances, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
If you choose not to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you, and you don't provide that data, we may not be able to carry out our end of the contract.
This means that if you don't provide us with the detail we need for your chosen travel arrangements, we can't provide the services you are attempting to book.
In this case, depending upon when you fail to provide the necessary date, we may either not be able to process your booking or we may have to cancel your booking. In these cases, we will treat cancellation as 'cancellation by you', as outlined by your relevant Booking Terms & Conditions. We will notify you if we can't process a booking or are required to cancel a booking for this reason.
Special categories of personal data
Certain types of sensitive personal data are subject to additional protection under the GDPR, these are referred to as special categories. When you book a holiday with us, we sometimes have to collect data that that falls under this classification. This includes details about your health and dietary requirements which may disclose your religious or philosophical beliefs.
We only collect and process these special categories of data when it is strictly necessary to deliver the holiday you have purchased - and we will only do so with your explicit consent.
You are not under any obligation to consent to us collecting your sensitive personal data. However, without your consent, we won't be able to make travel arrangements needed to complete your booking. As a result, if you do not provide your consent, we won't be able to proceed with your booking.
If you are happy to consent to our use of your sensitive personal data, you can withdraw your consent at any time. However, as this will prevent us from providing the holiday you have booked, we will need to treat any withdrawal of consent as a cancellation of your booking, which may mean you need to pay cancellation charges as described in your Booking Terms & Conditions.
How we collect your personal data
We use different methods to collect data from and about you, including:
You may share your personal details, contact and financial data with us by filling in forms or by corresponding with us by post, phone, email or on our websites. This includes personal data you provide when you:
- make a booking for travel arrangements
- use the "manage by booking" portal on our website
- subscribe to our newsletter or other publications
- request that marketing to be sent to you
- enter a competition, promotion or survey;
- or give us feedback
Automated technologies or interactions
Information we collect from other sources (third parties)
We may receive personal and technical data about you from various third parties as set out below:
(i) analytics providers such as Google based outside the EU and
Experian based outside the UK
(ii) Identity and Contact Data from publicly available sources such as Royal Mail, Companies House and the Electoral Register based inside the UK.
Our website may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
How we'll use your information
We will only use your personal data where we have consent or we have a lawful reason for using it. Most commonly, we will use it in the following circumstances:
- when it's necessary for the contract we are about to enter into or have entered into with you
- when it is necessary to pursue our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests
- where we need to comply with a legal or regulatory obligation
- to improve our products and services including through analysing how you use them
- market our products and services to you, and to people like you, e.g. through traditional and online marketing
- where we need to use your information for insurance purposes
Generally, we don't ask for or need consent to process your personal data, except when we'd like to send you marketing materials. You can change or withdraw consent to marketing at any time by contacting us via email MyData@greatail.com or call us on 01904 521940.
When and why, we'll use your personal data
The table below describes all the ways we may use your personal data, and which legal bases we rely on to do so. We have also identified what our legitimate interests are, so you know why we use your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer or enquirer.||(a) Identity;
|Performance of a contract with you.|
To process and deliver your booking including:
(a) Manage payments, fees and charges;
(e) Marketing and Communications.
|(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or policies;
(d) Marketing and Communications.
|(a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
|To enable you to partake in a prize draw, competition or complete a survey.||(a) Identity;
(e) Marketing and Communications.
|(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||(a) Identity;
|(a) Necessary for our legitimate interests (for running our
business, provision of administration and IT services, network
security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise);
(b) Necessary to comply with a legal obligation.
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To fulfil our obligations with the third party suppliers we use to provide your booking||(a) Identity
|Necessary for the performance of a task carried out in the public interest (to provide these details to the NHS for Track and Trace purposes)|
We may process your personal data for more than one lawful activity depending on the original reason for collecting your data. Please ￼contact us via email MyData@greatail.com or call 01904 521940 if you need details about the legal basis for processing your data where more than one has been set out in the table below.
Tracking or recording what you say or do
We may record details of your interactions with us, including conversations you have with us including phone calls, letters, emails, live chats and any other kinds of communication. We may use these recordings to check your instructions to us, assess or analyse and improve our service and train our people. We may also capture additional information about these interactions e.g telephone numbers that you call us from and about the devices or software you use.
Promotional offers & marketing from us
We may send you marketing messages by post, email, phone or text and use your data to create an informed picture of the products, services and offers we think you might be interested in. You will only receive marketing from us if you have consented to receive these specifically.
Updating your marketing preferences
You can ask Great Rail Journeys to stop sending you marketing messages at any time by following the opt-out links on the emails you receive or by contacting us via email MyData@greatail.com or telephone 01904 521940.
When you opt out of receiving these marketing messages, this applies to marketing messages only. We may still collect, process, and use any personal data you shared when booking a holiday, or other such transactions.
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 that is compatible with this original purpose. If you would like us to explain how this new purpose is compatible with the original purpose, please ￼contact us via email MyData@greatail.com or call us on (01904 521940. If we need to use your personal data for a purpose that isn't related to the original purpose, we will get in touch to explain our legal reasons for doing so.
If Great Rail Journeys becomes insolvent, we, or an appointed insolvency practitioner, may share your personal information with the CAA and/or ABTA, so that they can assess the status of your booking and advise you on the appropriate course of action under any financial protection schemes. The CAA's General Privacy Notice is at https://www.caa.co.uk/Our-work/About-us/General-privacy-notice/. ABTA's Privacy Notice is at https://abta.com/privacy-notice.
Who we might share your information with
We may need to share your personal data with the parties set out below for the purposes set out in the table above.
(A) Internal Third Parties as set out in the ￼Glossary
(B) External Third Parties as set out in the ￼Glossary
(C) Third party organisations to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy notice.
(D) Microsoft collects or receives (non-personally identifiable) data from you to provide Microsoft Advertising based on your interactions with our website. You can view Microsoft's Privacy Statements here
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 allow them to process your personal data for specified purposes, in accordance with our instructions.
Transferring your information overseas
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Where you have requested a booking for travel arrangements outside the UK, we will have to transfer your personal data to the suppliers fulfilling or providing these arrangements to complete your booking.
Whenever your personal data is transferred outside the UK, we ensure it receives a similar degree of protection as it would internally by making sure at least one of the following safeguards is followed:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
- Where we use certain service providers, we may use specific contracts approved by the European Commission. These give personal data the same protection it has in Europe
Please contact us via email MyData@greatail.com or telephone (01904 521940) if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
How we keep your data safe
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of [the App]/[our website], you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
Certain services on the App include chat features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users. Please be aware that internet transmissions are never completely private or secure and that any message or information you send using the App or any Service may be read or intercepted by others, even if there is a special notice that a particular transmission is encrypted.
We have put appropriate security measures in place to prevent your personal data from being altered, disclosed or accidentally lost, used or accessed in an unauthorised way. We also limit access to your personal data strictly to employees, agents, contractors and other third parties with business 'need to know'. They will only process your personal data on our instructions, and they are also subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach. We will notify you and any relevant regulator of a breach where we are legally required to do so.
How long we will keep your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for any personal data, we consider:
- the amount, nature, and sensitivity of that 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 addition, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for legal and tax purposes. In some circumstances you can ask us to delete your data. See ￼Request erasure below for further information.
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 this case, we may use this information indefinitely without providing further notice to you.
Your legal rights
In some circumstances, data protection laws give you rights in relation to your personal data. Please click on the links below to find out more about these rights:
(A) ￼Request access to your personal data
(B) Request correction of your personal data
(C) Request erasure of your personal data
(D) Object to processing of your personal data
(E) Request restriction of processing your personal data
(F) Request transfer of your personal data
(G) Right to withdraw consent
If you want to exercise any of these rights, please contact us via email MyData@greatrail.com or call us on 01904 521940.
Accessing your data
You will not have to pay a fee to access your personal data or to exercise any of the other rights outlined above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 security measure to ensure that personal data is not disclosed to anyone who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer 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.
- Legitimate Interest means the interest of our business in conducting and managing our business to give you the best service and most secure experience. We make sure we balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can find out more about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us via email MyData@greatail.com or call us on 01904 521940.
- Performance of Contract means processing your data when it is needed to complete or carry out actions specified in a contractual agreement between you and Great Rail Journeys - for example, the completion of a holiday booking.
- Comply with a legal or regulatory obligation means processing your personal data to comply with laws or industry regulations we are subject to.
- Performance of a task carried out in the public interest means processing your data to perform specific tasks carried out in the public interest.
- Internal Third Parties
Internal third parties are companies in the Great Rail Journeys Group acting as joint controllers. They are based in the USA and provide IT and system administration services alongside leadership reporting.
- External Third Parties
External third parties covers:
i. Suppliers of travel services outside of the UK such as airlines, hotels, destination management companies, rail operators, transport providers and ground handlers acting as processors, who provide the travel services for any booking that you make with us.
ii. Travel agent partners based in the UK who make bookings with us on your behalf, acting as our retail agent.
iii. Service providers based in the USA acting as processors, providing IT and system administration services.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party), and you object to processing in a particular situation as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data's accuracy
- where our use of the data is unlawful but you do not want us to erase it
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially consented for us to use, or where we used the information to perform a contract with you.
- Withdraw consent at any time where we need your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.