Published on: 25 March, 2019

Welcome to TrainPal! This Privacy Statement, together with our Terms Of Use, sets out the approach that we at TrainPal take with regards to the collection and handling of any identifiable information about you.

We understand that providing information online involves a great deal of trust on your part. We take this trust very seriously and make it a high priority to ensure the security and confidentiality of the personal information you provide us when you visit our website or use our Services. Before providing us with your personal information, please read this Privacy Statement carefully to learn about our privacy practices.

About This Privacy Statement and TrainPal

When Does This Privacy Statement Apply?

This Privacy Statement applies to information about you as an identifiable person that TrainPal’s mobile application and/or website (together the “Applications”) collects from, or about you. This Privacy Statement does not apply to anonymous data that cannot identify you in any way.

The Applications may contain links to third-party websites. TrainPal is not responsible for the privacy practices or the content of these third-party websites. We recommend that you carefully read the privacy statements of such sites.

Data Controller

The data controller of any and all information provided to or gathered by TrainPal and its Applications is Ctrip.com (Hong Kong) Limited, a limited company registered in Hong Kong with office at Unit 3003, 30/F, Paul Y. Centre, 51 Hung To Road, Kwun Tong, Kowloon, Hong Kong.

Ctrip.com (Hong Kong) Limited also trades under Trip.com. You can contact us at en_trainpaldata@trip.com

About Your Personal Information and Uses

What Personal Information Does TrainPal Hold on Me and Others?

Information You Provide Us Directly

TrainPal collects and uses the information you provide to us directly in order to provide you with the services you request. For example, you may provide us your name, email, passcode, fingerprint as passcode, and other information when you register a TrainPal account. When booking train tickets you may provide passenger names, email and delivery address, as well as other information such as age and gender. When paying for train tickets, you may provide your bank card number, CVV on back cardholder name, expiry date, etc.

In order for us to customize the services we provide you, we may also collect information about your travel plans and preferences which includes your departure date, departure city and arriving city, seat choice, ticket choice, provided by TrainPal.

If you need to get in touch with our customer service team, or reach out to us through other means (such as through social media) we will collect information from you there too, such as your name and contact information.

You may be travelling with other guests or make a booking on someone else’s behalf, in which case you will provide similar details to TrainPal. However, we would like to remind you that it is your responsibility to ensure that the person or people whose personal information you have provided are aware that you’ve done so, and have agreed to your sharing of their personal information with TrainPal for these purposes.

Information We Collect Automatically

TrainPal collects some information about you automatically. Specifically:

1. Log information, which refers to information that the system may automatically collect through cookies, a web beacon, or other channels when you use our website, including:

2. Use of Cookies. We use cookies on our website. A cookie is a text file that a web server puts on your device with the following general purposes:

You are not obligated to accept cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies or how to disable cookies altogether. Please note that if you refuse to accept cookies, you may not be able to access many of the travel services offered on our website.

Information We Receive Through Other Sources

We will also obtain your information from affiliates and business partners. For example, we allow you to log into TrainPal with your social media account, and with your consent (you grant authorization to the social platform), your personal information will be shared with us through that social platform.

Additionally, we may integrate calling services into our platforms to enable you to connect with us, and when we do, we receive metadata about the call activities (such as where you called from, who you are, and the date and length of the call).

How Does TrainPal Use My Personal Information and What are Related Lawful Bases?

TrainPal will generally collect and use your personal information for the following purposes:

1. To fulfil a contract, or take steps linked to a contract: The use of your information may be necessary to perform the contract that you have with us, including:

2. To conduct our business and pursue our legitimate interests. In particular:

3. Where you give us consent:

4. For purposes which are required by law:

Duration of Processing of Personal Data.

TrainPal 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. TrainPal may retain your personal data for a longer period in the event of a complaint or if TrainPal reasonably believes there is a prospect of litigation in respect to TrainPal’s relationship with you.

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

Where will My Personal Data be Processed?

TrainPal operates both inside and outside of the European Economic Area (the “EEA”). It also cooperates with third-party vendors located both inside and outside of the EEA. Therefore, TrainPal may transfer your personal information to countries outside of the EEA, including to countries which may not have in place laws that apply the same level of data protection as within the EEA. Whenever such transfer occurs, it is based on the Standard Contractual Clauses (according to EU Commission Decision 87/2010/EC or any future replacement) in order to provide your personal information a level of data protection that applies within the EEA.

How Does TrainPal Share My Information?

We may share your booking information, account information, and device information with affiliate companies within our corporate family and third parties, such as the partners detailed below, to ensure the successful provision of services to you. Our partners include the following types:

We may also share your information in the context of complying with legal obligations, to protect our or your interests in legal matters, and in the case of a merger or acquisition.