Privacy policy

Grand Central is committed to protecting your privacy. This privacy policy explains what personal data we collect about you, how and why we use it, and how we protect your privacy. To make it easy to use this privacy policy we have outlined the key sections in the table below which you can use to navigate the policy.

This notice (together with our Terms and Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by Grand Central or our processing partners. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.grandcentralrailway.com or buy.grandcentralrailway.com or providing your information in the circumstances described below, you are accepting and consenting to the practices described in this policy.

1. Who is responsible for your data?
2. What personal data do we collect?
3. Cookies
4. How we use your personal data and the legal basis for such processing?
5. Who do we share your information with?
6. Data Retention
7. Information security
8. Transferring Information Internationally
9. Updates to this Privacy Policy
10. Your Data Protection Rights
11. Questions about this Privacy Policy

1. Who is responsible for your data?

For the purpose of the Data Protection Laws, the data controller is Grand Central Railway Company Ltd (“Grand Central”) and the data processors are Journeycall Ltd ("Journeycall"), Acteol Ltd ("Acteol"), XC Trains Ltd ("CrossCountry") and The Chiltern Railway Company Ltd ("Chiltern Railways").

Individuals are advised that when using the “Website” those pages with a web address prefixed by www.grandcentralrailway.com these pages are managed by Grand Central as the data controller, (a company registered in England and Wales with registration number 03979826 and registered to 1 Admiral Way, Doxford International Business Park, Sunderland SR3 3XP).

2. What personal data do we collect?

Information provided by you

You may give us information about you by filling in forms, emailing us, contacting our staff in person or otherwise on www.grandcentralrailway.com or buy.grandcentralrailway.com. This includes information you may provide when you:;

• Register and consent to receive marketing information
• Register to buy ticket(s) or open a Grand Central account
• Purchase ticket(s)
• Enter a competition, promotion or survey
• Provide answers to a promotion or survey
• Make a complaint
• Claim compensation
• Request a refund
• Book passenger assistance
• Download our app
• Register to use our on-train Wi-Fi service
• Contact us via social media channels
• Report a problem with our sites
• Purchase food and drink from our on-board portal

The information you may give us may include:

• First name and last name
• Date of birth
• Address details including postcode
• Email address
• Phone number – mobile, home or work
• Disability details (Passenger assistance)
• Transaction meta data (e.g. journey details)
• Relevant rail discount or loyalty cards
• Limited amount of personal data of any other passengers you are booking tickets for
• Personal descriptions and photographs
• Reason for travel
• Financial and credit card information
• Data regarding your mobile phone or PC (especially when you register to use our on-train Wi-Fi service)

Information you may provide via our website(s)

• Geographical location
• IP or MAC address or details regarding use of your mobile device or PC

Analytics

We may collect and process anonymous information about your use of the Website or Booking Service, such as some of the pages you visit and some of the searches you perform. Such information is used by us to help us improve the contents of the Website or Booking Service and to compile, for internal market research purposes, aggregate statistics about individuals using it. This kind of anonymous information can be obtained by our use of "cookies" as well as other means. Please see Section 3, 'Cookies' for more information on our use of cookies. We may also share anonymous information about your use of the Booking Service with third parties for analytical purposes.

Information we collect about you

With regard to each of your visits to either www.grandcentralrailway.com or buy.grandcentralrailway.com or if you register to use our Wi-Fi services we may automatically collect the following information;

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, time zone setting, browser plug-in types and versions, and platform.
• Device: what type of device you are using (TV, smartphone, laptop, desktop)
• OS (Operating system): what operating system your device has (iOS, Android, Windows, Linux, Mac OS)
• Browser & browser version: which web browser you are using (Internet Explorer/Edge, Opera, Chrome, Firefox, Safari)
• Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our sites (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number
• Details  of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access (this is used to help track the performance of our website)
• We may also collect information about your computer, including where available your IP address, operating system and browser type for system administration, to improve the structure and content of our site and to report aggregated information to our advertisers and marketing agencies. This is statistical data about your browsing patterns which in turn enables us to track the performance of our site and advertising efforts. It also allows us to serve relevant advertising that is likely to be of interest to you and does not identify any individual. For this reason, we may collect this information even if you do not register with us on our website.

Information we receive from other sources

We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

We may receive information from other sources if you have provided permission for this to happen or if there is a legal reason for it to occur .

Sensitive personal data 

We will not intentionally or systematically seek to collect, store or otherwise use information about you classed as ‘special categories of data’ or ‘sensitive data’.

If you require any extra assistance to help you make your journey, we offer our Travel Assistance service. This may involve you providing us with sensitive personal data.

3. Cookies

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our sites. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

4. How we use your personal data and the legal basis for such processing?

The collection of the personal data described in Section 2, “What personal data do we collect?” is usually mandatory and, if such personal data is not provided, we will not be able to provide the information, products and services to you. Where the collection of any personal data is not mandatory, we will inform you of this prior to collection, as well as the consequences of failing to provide the relevant personal data.

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally process your personal information only:

• Where we have your consent to do so
• Where the processing is necessary to perform our contract with you; or
• Where the processing is in our legitimate interests or those of a third party and such interests are not overridden by your data protection interests or fundamental rights and freedoms; and
• Where we have a legal obligation to process your personal information.

Information provided by you

We use your personal information as follows:

Information provided by you for Safety purposes

Area	Purpose of Processing	Legal Basis for Processing
Accidents, Incidents, Assaults or Dangerous Occurrences	To meet our statutory obligations for the reporting of accidents, incidents, assaults or dangerous occurrences. For the reporting and investigation of safety related events for the purpose of preventing or reducing the risk of their recurrence. Sharing with other organisations with a direct responsibility for maintaining or improving railway safety.	The processing of the personal information is necessary for compliance with a legal obligation set by Office of Rail and Road Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR).
To share with emergency services, as required during emergency situations on board our services.	Legitimate interest and duty of care
Claims	To handle your claim in accordance with Claim Allocation and Handling Agreement (CAHA) for losses, property damage or personal injury.	Necessary for the performance of the contract. Licence obligations of the Office Rail and Road – Claim Allocation and Handling Agreement (CAHA).

Information provided by you as a Customer or Stakeholder

Area	Purpose of Processing	Legal Basis for Processing
Transactional data	Provided by you as part of a financial transaction, such as payment for tickets, refunds or compensation.	Performance of a contract and legal obligations.
Sending marketing information to customers	Collecting, updating and using contact details such as email address, SMS and postal address to inform you about promotions, news, ticket offers and destination ideas that may be of interest to you.	Consent provided by you
Pre and post travel information	Issuing pre and post travel information, including destination ideas and booking information	Consent provided by you
Tracking and improving the performance of website	Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access (this is used to help track and improve the performance of our website)	Legitimate interest
Performance tracking for targeted advertising	Information about your computer, including IP address, operating system and browser type for website performance and improvement. This allows us to track performance and serve relevant advertising likely to be of interest to you and does not identify you as an individual.	Legitimate interest
Information provided by customers to us	Information you provide to us by filling in forms on our site or that you email us, this includes when you subscribe or register for any service that we may provide via our site or when you complete transactions.	Performance of contract
Research and surveys	As part of customer research and surveys	Legitimate interest
Common law or statutory obligations	Complying with any common law or statutory obligations, such as in the prevention of fraud	Legal obligations
Service updates	Providing customers with updates to train services and/or strike information	Performance of contract
Social media	Handling customer social media enquiries	Legitimate interest
Marketing communications	Personal information such as your name and contact details when you register for an account or sign-up for marketing communications	Consent provided by you
Data analysis	Profiling and selecting customers in order to send relevant, targeted communications and information to improve our services	Consent provided by you
Interactions with our website and our app	Website visits and online behaviour, including app usage	Legitimate interest
On board Wi-Fi data connection	To provide you with a Wi-Fi service on board our services	Performance of a contract
Customer contact centre	To support in any queries with bookings, travel assistance or other issues	Performance of a contract
Email analysis	Email engagement statistics	Consent provided by you
Smart ticketing	Administration of your tickets and handling queries relating to your tickets	Performance of a contract and legitimate interests
Customer research panel	Joining our customer research panel	Consent provided by you
Social media	Your messages to us via social media channels	Legitimate interest
Prize draw/giveaways/competition forms	To publish the name, county and winner of a prize draw or competition and if relevant, the winning entry in accordance with the requirements of the CAP Code.	Legitimate interest to ensure compliance with the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code)
Catering purchases on board	To receive electronic receipts for Catering purchases made on board the train	Consent provided by you
Stakeholders – keeping you informed	To provide you with information about our goods and services that may interest you or them	Consent provided by you
Stakeholders – supporting Rail Partnerships	To support Community Rail Partnerships	Consent provided by you
Stakeholders – supporting community causes	To support causes within the community	Consent provided by you

Information provided by you in relation to the provision of Customer Services

Area	Purpose of Processing	Legal Basis for Processing
Travel assistance	To arrange and carry our extra assistance for your journey	Equality Act 2010, working with other Rail Industry partners to ensure compliance where complimentary services are supplied under contract. Please see our Disables People’s Protection Policy
Compliments, suggestions, complaints, reporting accidents and appeals	To respond, investigate and make the necessary enquiries regarding your initial correspondence.	Performance of a contract
To respond, investigate and make the necessary enquiries regarding the appeal.	Processing is necessary to protect the vital interests
To record and pass on details of accidents or injuries that have happened on our services to our Safety Team.	Legal obligation
Claims for Compensation and Refunds	To provide compensation in line with our Delay Repay Scheme. To handle the claims for compensation and refunds.	To provide compensation in line with our Passenger Charter and National Rail Conditions of Travel.
Revenue Protection & Prosecutions Policy	Preventing and reducing fare evasion and offenses of violence against its workforce, which may involve prosecution of perpetrators.	For fare evasion – National Conditions of Travel and National Railway Byelaws (2005) Regulations of Railways Act 1889. For serious and systematic fare evasion or revenue fraud – Fraud Act 2006. For Assault against our employees is an offence – Criminal Justice Act 1988, Offences against the Person Act 1861, Public Order Act 1986. Please see our Prosecutions Policy.

Information provided by you to our Human Resources Department

Area	Purpose of Processing	Legal Basis for Processing
Recruitment	For pre-appointment assessment for either job vacancies, apprenticeships, placements or our graduate training program.	Necessary for the performance of a contract with you or to take steps to enter into a contract.
To receive relevant notifications regarding job vacancies with Grand Central or other vacancies within the DB and Arriva organisations.	Consent provided by you

Information provided by you in relation to Subject Access Requests

Area	Purpose of Processing	Legal Basis for Processing
Subject Access Request	To process and investigate any complaint, subject access request and other general requests under the General Data Protection Regulation.	Consent provided by you. Legal obligation to process your personal information – General Data Protection Regulation (GDPR)

Information provided by you in relation to you visiting a Grand Central location

Area	Purpose of Processing	Legal Basis for Processing
Visitors	To enable visitors to gain entry/access into Grand Central location	Legitimate interest

Information we collect about you

We use your personal information as follows: Information we collect about you for Safety purposes

Area	Purpose of Processing	Legal Basis for Processing
Body worn cameras	Images are recorded for the purpose of Customer, Security, Staff Security, Crime Prevention and Public Safety on trains where body worn cameras are in use.	Necessary for the Legitimate interest, public interest task and/or legal obligation (prevention and detection of crime).

Information we collect about you as Customer or Stakeholder

Area	Purpose of Processing	Legal Basis for Processing
Purchase of tickets	Transactional information (such as your payment details when you buy tickets, the purchase and usage of Wi-Fi)	Performance of contract, legal requirement in relation to Limitation Act 1980
Marketing communications	Personal information such as your name and contact details when you register for an account or sign-up for marketing communications	Consent provided by you
Targeted communications	Profiling and selection customers in order to send relevant, targeted communication and information and improve services	Consent provided by you
Customer contact centre	To assist customers with any queries regarding their bookings, passenger assist requests and other issues	Performance of a contract
Smart ticketing	Administration of your tickets and handling queries relating to your tickets	Performance of a contract and legitimate interests
Behaviour	Website visits and online behaviour, including app usage	Legitimate interest
Engagement	Email engagement statistics	Consent provided by you
Customer research panel	Feedback via our Customer Research Panel (All submissions are made anonymous for analysis and reporting)	Legitimate interest
Prize draw/giveaways/competition forms	To publish the name, county and winner of a prize draw or competition and if relevant, the winning entry in accordance with the requirements of the CAP Code	Legitimate interest to ensure compliance with the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code)
Social media	Your messages to us via social media channels	Legitimate interest
Competitions	Competition entry winners	Consent provided by you
Customer experience	To gauge the experience and use feedback for service improvements such as surveys	Consent provided by you
Customer relations call recording	To record calls for monitoring and training purposes. Potentially used as evidence in fraudulent cases. (Note this does not include payment details)	Performance of a contract and legitimate interest

Information we collect about you as a potential employee

Area	Purpose of Processing	Legal Basis for Processing
Recruitment	To send you relevant job vacancy updates	Consent provided by you

Information we receive from other sources

We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under Section 11, “Questions about this Privacy Policy”

Information we receive from other sources for Safety purposes

Area	Purpose of Processing	Legal Basis for Processing
Accidents, Incidents, Assaults or Dangerous Occurrences	To meet our statutory obligations for the reporting of accidents, incidents, assaults or dangerous occurrences	The processing of the personal information is necessary for compliance with a legal obligation set by Office of Rail and Road Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR)
Body worn cameras	Images are required for evidential purposes in legal or disciplinary proceedings	Necessary for the Legitimate interest, public interest task and/or legal obligation (prevention and detection of crime).
Safety claims	To handle your claim in accordance with Claim Allocation and Handling Agreement (CAHA) for losses, property damage or personal injury	Necessary for the performance of the contract. Licence obligations of the Office Rail and Road – Claim Allocation and Handling Agreement (CAHA)

Information we receive from other sources as a Customer

Area	Purpose of Processing	Legal Basis for Processing
Smart ticketing	Administration of your tickets and handling queries relating to your tickets, which may contain other Train Operating Companies’ products	Performance of a contract and legitimate interests
Guest Checkout	You can use our booking service without registering as a new user on our mobile site, website or through our app. Transactions as a guest would however not be displayed in your account if you are a registered user, but subsequently choose to checkout as Guest. All personal data collected when booking as a Guest will be processed in accordance with this Privacy Policy.	Performance of a contract

Information we receive from other sources for the provision of Customer Services

Area	Purpose of Processing	Legal Basis for Processing
Travel Assistance	To carry out assistance for your journey	Performance of a contract
Compliments, suggestions, complaints and appeals	To respond, investigate and make the necessary enquiries regarding your initial correspondence	Performance of a contract
To respond, investigate and make the necessary enquiries regarding the appeal	Processing is necessary to protect the vital interests
Claims for compensation and refunds	To assist with the compensation claims by sharing the information with the appropriate other train operators	To provide compensation in line with our Passenger Charter and National Rail Conditions of Travel
Revenue, Protection & Prosecutions	To support revenue protection related investigations that may lead to prosecutions.	National Conditions of Travel and National Railway Byelaws

Information we receive from other sources in our Human Resources department

Area	Purpose of Processing	Legal Basis for Processing
Recruitment	We may receive references from previous employers. We may also receive reports from external suppliers for pre-employment testing or medical reports	Necessary for the performance of a contract with you or to take steps to enter into a contract

Information we receive from other sources in relation to Subject Access Requests

Area	Purpose of Processing	Legal Basis for Processing
Subject Access Request	Processing and investigating of Data Protection complaints received from the Information Commissioner’s Office	Consent provided by you. Legal obligation to process your personal information – General Data Protection Regulation (GDPR)

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5. Who do we share your information with?

We may disclose your personal data to the following categories of recipient for the purposes described in this Privacy Policy.

Sharing your information for Safety Purposes

• With Rail Safety and Standard Board, Rail Accident Investigation Branch, Office of Rail and Road, Government appointed enquires, legal representors and other Rail Industry Partners to meet our statutory obligations for the reporting of accidents, incidents, assaults or dangerous occurrences
• With British Transport Police, legal, other Rail Industry Partners, CCTV images required for evidential purposes in legal or disciplinary proceedingS
• With Solicitors, Transcare Law, Office of Road and Rail, consumer watchdogs, and other Rail Industry Partners in accordance with Claim Allocation and Handling Agreement (CAHA) for losses property damage or personal injury
• With Emergency Services as required during emergency situations on board our services, to provide you with medical assistance if required

Sharing your information as Passenger/Member of the Public or Stakeholder

Service Providers

• We use third party service providers to carry out many of the activities listed in Section 4, “How we use your personal data and the legal basis for such processing”. This includes our Customer Relationship Management (CRM) provider Acteol as well advertising and behaviour tracking from Google and Microsoft.
• Our service providers act on our instructions, and we ensure that they take measures to keep your personal data safe
• We don’t allow our service providers to use your personal data for any purpose other than carrying out the service in question, and we only provide them with those parts of your personal data that they actually need
• Other UK Rail Operators in order that they can provide support in respect of your Smartcard products, from any given location regardless of the retailer
• Fraudulent payment detection. We use a US based payment provider who is PCI DSS Level 1 accredited who may interrogate your payment data. Your payment data is used only for the transaction and your data is not retained any longer than is required for payment processing, fraud detection/prevention and auditing
• All payments for ticket purchase through Visa and Mastercard are processed by Silverrail
• Apptentive, Inc for the purpose of managing feedback in respect of the Grand Central app
• Chiltern Railways and group bookings/carnet ticket sales
• Whoosh Media and Wi-Fi portal provision
• Icomera and Wi-Fi provision

Other UK Rail Operators

• We share your personal data with some operators for ticket fulfilment purposes
• We may share your email address or phone number with some operators so that they can contact you with service messages, for example if a train is cancelled.
• We may also need to share some of your personal data with any other transport carriers or other service providers who provide you with any part of the services that you’ve booked through us.

The Authorities

• In some circumstances we have a legal obligation to share parts of your personal data with police or customs authorities, regulatory authorities, government & law enforcement agencies. This may include, but is not limited to, fraud prevention and detection.
• We may also disclose your personal data to any competent law enforcement body, regulator, government agency such as Department for Transport (DFT) or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation; (ii) to exercise, establish or defend or legal rights; or (iii) to protect your vital interests or those of any other person;

Sharing your information for the provision of Customer Services

• To carry out assistance for your journey we work closely with Office of Road and Rail, Rail Delivery Group, Rail Industry partners and Taxi companies in order to continually improve the levels of service we offer customers who require such assistance when making a journey
• To allow complaints and appeals to be processed by the appropriate company in accordance with the Railways Passenger Charter
• To provide compensation for delays in line with our Passenger Charter and National Rail Conditions of Travel
• Preventing and reducing the fare evasion and offences of violence against its workforce, which may involve prosecution of perpetrators in accordance with National Conditions of Travel and National Railway Byelaws.

Sharing your information – Human Resources department

• For external suppliers to support us in our pre-appointment assessment for either job vacancies, apprenticeships, placements or our graduate training program 

Sharing your information in relation to Individual Rights Requests

• Information Commissioner Office – for the purposes of reporting, processing and investigating of Data Protection complaints or incidents received from the Information Commissioner’s Office.

Other

• We may also transfer your personal data to a buyer or potential buyer (and its agents and advisers) of Grand Central in connection with any reorganisation, restructuring, merger or sale, or other transferring of assets provided that we inform any receiving party it must use your personal information only for the purposes disclosed in this Privacy Policy.
• We may disclose your data to any other person to whom you request us to make disclosure or if you consent to such disclosure.

6. Data Retention

We will not retain your personal data for longer than is necessary to fulfil the purposes for which we collected that personal information, unless the law permits or requires that we retain it for longer.

The table below explains in more detail how long Grand Central will store different types of customer information for:

Data Retention – Safety Purposes

Customer Information	Retention Period
Reporting of accidents, incidents, assaults or dangerous occurrences	As per the statutory provision (see Social Security (claims and payments) Regulations 1971; Regulation 25. Social Security Act 1992; OR Section 8. Limitation Act 1980)
Records relating to accident/injury	As per the statutory provision - generally from the date of the incident plus 12 years. A further retention period may need to be considered.
CCTV and Body worn cameras	Maximum 30 days dependant of system capabilities from record creation, unless there is a specific request relating to the CCTV/camera footage. Where there is a specific request which includes crime, terrorism and HM Coroner relating to the CCTV/camera footage, the footage will be kept for the duration of the claim matter, plus an additional six years after the claim is closed.
Safety claims	For the duration of the claim, plus an additional 6 years after the claim is closed
CCTV/body worn camera footage relating to a claim	For the duration of the claim matter, plus additional 6 years after the claim is closed.
Claimant bank details	Until Payment is made in full to the claimant.

Data retention relating to the provision of Customer or Stakeholder

Customer Information	Retention Period
For customers who have made an online transaction in the last 6 years	Transaction history – we will keep customer information associated with transactional data for 6 years from the date of the customers last transaction. After which point, all personal customer information will be deleted, but statistical information will be retained on a completely anonymised basis.
Anonymised website data	We will keep anonymised website data (including but not limited to traffic data, location data, operating systems and browsing information) for 38 months. This data helps us with the ongoing improvement and development of our website and does not identify users individually (for example through a MAC address, IP address or cookie data).
Stakeholder – General	For no longer than the necessary for the purposes for which the personal data was collected.
Stakeholder – Community Rail	For no longer than the necessary for the purposes for which the personal data was collected.
Stakeholder – Supporting causes in the community	For a period of 6 years after the support is provided.
Contact centre call recording	3 months

Data retention relating to the provision of Customer Services

Customer Information	Retention Period
Travel Assistance bookings	For a period of 2 years (as advised by Rail Delivery Group)
Compliments, suggestions, complaints and appeals	For no longer than the necessary purposes for which the personal data was collected (maximum period of 6 years)
Compensation and refunds	6 years from the date of the transaction or payment made
Revenue protection and prosecutions policy	For a period of 6 years following the end case completion

Data retention – Human Resources department

Customer Information	Retention Period
Job applications and interview records for unsuccessful candidates	6 months after notifying unsuccessful candidates. The applicant should be informed of GC’s retention period when they complete the application

Data retention – Individual Rights Access

Customer Information	Retention Period
Individual Rights Requests	We hold the data for 2 years

7. Information Security

We apply appropriate administrative, technical and organisational security measures to protect your personal data that is under our control from unauthorised access, collection, use, disclosure, copying, modification or disposal. All information you provide to us is stored on secure servers. Grand Central is part of the Arriva plc Group, which trains its employees regarding our data privacy policies and procedures and permit authorised employees to access personal data on a need to know basis, as required for their role. We also take steps to ensure that any service provider that we engage to process personal data on our behalf takes appropriate technical and organisational measures to safeguard such personal data.

8. Transferring Information Internationally

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Specifically, we may use third party service providers located in India, Ireland, Germany, Sweden, Tunisia, and the US. This means that, when we collect your personal information, it may be processed in these countries. However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Policy. These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information to our third party service providers and further details can be provided upon request.

9. Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

10. Your Data Protection Rights

You have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting Grand Central, via [email protected] or via our preference centre.
• Please note: We retain personal information from deactivated accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, assist with any investigations, enforce our terms and conditions, and take other actions otherwise permitted by law. We may also retain some pseudonymous data for analytics purposes so we can understand, for example, how many visitors we have had to the Website or Booking Service.
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us at [email protected] or the postal address below.
• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You can update your consent preferences at any time by logging into your account. Please note it can take up to 48 hours for this information to be updated.
  We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If you wish to withdraw consent from marketing communications, or close your online account with Grand Central, please contact us at any time at [email protected]. Please note that this may take up to 30 days.

11. Questions about this Privacy Policy

If you have any question, concerns or complaints about this Privacy Policy or our handling of your personal data, you can contact us by email using [email protected]  or by post to the following address:

GC Data Protection Champion
Grand Central Railway
3^rd Floor, Northern House
Rougier Street
York
YO1 6HZ

If you are unsatisfied with the response, you can contact Arriva plc's Data Protection Officer at [email protected].

You have the right to complain to a data protection authority about our collection and use of your personal information. If you are based in the European Economic Area, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries are available on the EU Commission's website via the following link): http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm).