Privacy Policy

This privacy policy aims to give you information on how Train Air Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website or deal with us otherwise.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you. This policy supplements other notices and is not intended to override them.

Controller

We have appointed a data protection officer (the DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please use the contact details below.

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 (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 policy

We keep our privacy policy under regular review. This version was last updated on 2 August 2022. Historic versions can be obtained by contacting us. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links 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.

Personal data means any information about an individual from which that person can 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, grouped as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as it will not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or genetic and biometric data), nor any information about criminal convictions and offences.

If you fail 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 fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. We will notify you if this is the case at the time.

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

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise — for example when you apply for or use our services, create an account, subscribe to our publications, request marketing, enter a competition or survey, or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data using cookies, server logs and similar technologies.
• Third parties or publicly available sources. We may receive Technical Data from analytics providers, advertising networks and search information providers; Contact, Financial and Transaction Data from providers of technical, payment and delivery services; and Identity and Contact Data from data brokers, aggregators and publicly available sources.

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you. You may opt out of receiving this advertising by visiting app.retention.com/optout.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where we need to perform the contract with you, where it is necessary for our legitimate interests (or those of a third party), or where we need to comply with a legal obligation.

Purposes for which we will use your personal data

The table below sets out the ways we plan to use your personal data and the legal bases we rely on.

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

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

If your data is displayed on our website as a “training provider” we will share your personal details with those third parties who access our website. Otherwise, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and adjusting your marketing preferences, by following the opt-out links on any marketing message sent to you, or by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.

Cookies

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.

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 we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

We may share your personal data with the parties set out below for the purposes described above:

• Other companies in the Train Air Ltd Group acting as joint controllers or processors, based in the UK, providing IT and system administration services and leadership reporting.
• Service providers acting as processors based in the UK, who provide IT and system administration services.
• Professional advisers acting as processors, including lawyers, bankers, auditors and insurers based in the UK, who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK, 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.

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.

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. Whenever we transfer your personal data out of the UK, we ensure a similar degree 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 personal data. For further details, please contact us at p.evans@thetm.com.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

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 they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances we will 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.

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

• Access — request a copy of the personal data we hold about you.
• Correction — have any incomplete or inaccurate data we hold about you corrected.
• Erasure — ask us to delete or remove personal data where there is no good reason for us continuing to process it.
• Object — object to processing where we are relying on a legitimate interest, including direct marketing.
• Restrict processing — ask us to suspend the processing of your personal data in certain scenarios.
• Data portability — request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format.
• Withdraw consent — withdraw consent at any time where we are relying on consent to process your personal data.

No fee is 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 if your request is clearly unfounded, repetitive or excessive.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests.

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and 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).

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.