Railtours Ireland First Class Ltd. is committed to protecting our customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This Policy sets out the following:
What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, online services;
Where we obtain the data from;
What we do with that data;
How we store the data;
Who we transfer/disclose that data to;
How we deal with your data protection rights;
And how we comply with the data protection rules.
All personal data is collected and processed in accordance with Irish and EU data protection laws.
Railtours Ireland First Class Ltd. is the “data controller” of all personal information that is collected and used about Railtours Ireland customers for the purposes of [the Irish Data Protection Act 2018]. Railtours Ireland First Class Ltd. is registered in Ireland with registration number 282140 and registered offices at Railtours House, 16 Amiens Street, Dublin, D01 XD21, Ireland.
What personal data we collect:
Personal data means any information relating to you which allows us to identify you, such as your name, contact details, booking reference number, payment details and information about your access to our website.
We may collect personal data from you when you book a tour with us (either directly or indirectly through our trusted third-party partners), use our website, or when you contact us.
Specifically, we may collect the following categories of information:
a. Name, home address, e-mail address, telephone number, credit/debit card or other payment details;
b. Medical conditions for passengers who have special medical requirements and/or dietary requirements;
c. Information you provide about you and your companions’ travel preferences;
d. Information about your use of our website;
e. The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media.
f. Location, including real-time geographic location of your computer or device through GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, if you use location-based features and turn on the Location Services settings on your device and computer.
Personal details about your physical or mental health, are considered “sensitive” personal data under applicable data protection laws. We will process any such data only if you have given your explicit consent, or it is necessary (for instance if you request special assistance), or you have deliberately made it public.
What do we use your personal data for, why and for how long:
Your data may be used for the following purposes:
a. Providing products and services you request: we use the information you give us to perform the services you have asked for in relation to your tour, including requested tour changes;
b. Contacting you with relevant and necessary information regarding your tour(s): we send you communications about the services you have asked for and any changes to such services. These communications are not made for marketing purposes and cannot be opted-out of;
c. Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
d. Administrative or legal purposes: we use your data for statistical and marketing analysis, or in order to deal with a dispute or claim. Note that we may use the data we collect from you for statistical and marketing analysis purposes.
e. Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us;
f. Marketing: from time to time we will contact you with information regarding promotions via e-communications. You will have the choice to opt in or opt out of receiving such communications by indicating your choice at the booking stage. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material.
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.
In most cases, we will need to process your personal data so we can enter into our contract with you.
We also process your personal data for one or more of the following:
a. You have consented to us using your personal data (e.g. for marketing related uses);
b. To protect your vital interests or those of another person (e.g. in case of a medical emergency);
c. It is in our legitimate interests in operating as an tour operator (e.g. for administrative purposes).
We do not deliberately seek to do business with chlidren (under 18 years). Only children aged 16 or over can provide their own consent. For children under this age, consent of the children’s parents or legal guardians is required.
We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
We must also consider periods for which we might need to retain personal data in order to meet our legal and taxation obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Security of your personal data:
We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.
All payment details are transmitted over SSL across dedicated network infrastructure and stored in compliance with Payment Card Industry Data Security Standards (PCI DSS).
International Data Transfer:
We will not transfer your data outside off the EEA.
We require all services providers and data processors to process your information in a secure manner and in accordance with Irish and EU law on data protection.
Sharing your personal data:
Your personal data may be shared with other companies.
a. Trusted agents through which you book your Railtours Ireland tour with;
b. Partner suppliers required to deliver the services you have asked for, such as our hotel partners and coach operators;
c. Credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment and tour booking to process payment or ensure the security of your payment transaction;
d. Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in in order to enforce our legal rights in relation to our contract with you;
Certain data may be collected by “cookies”, which are temporary internet files placed on your computer’s hard drive by your web browser. This allows us to collect information such as time spent on our website and the pages visited. This information is held anonymously.
Third Party Cookies in embedded content on this Website’s pages:
When you visit some of our pages with content embedded from, for example, Google, YouTube, you may be presented with cookies from these websites. We do not control the dissemination of these cookies. You should check the third party websites for more information about these.
If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; the Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers.
Data Protection Officer:
We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this policy. You have the right to make a complaint at any time to a supervisory authority. The Irish Data Protection Commissioner is the lead data protection supervisory authority for Railtours Ireland First Class Ltd. as an Irish data controller.
Your Data Protection Rights
Under certain circumstances, by law you have the right to:
Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. This may prevent us from fully providing the service you have requested from us.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please submit a request in writing by email, or contact our DPO by post at Railtours Data Protection Officer, Railtours House, 16 Amiens Street. Dublin D01 XD21, Ireland.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.