Privacy Policy

1. GENERAL

Thank you for visiting our website and your interest in our initiative.

The RTR members, Construcciones y Auxiliar de Ferrocarriles SA, Deutsche Bahn AG, Faiveley Transport SA, Hitachi Rail SpA, Knorr-Bremse AG, Nederlandse Spoorwegen NV, Norske tog AS, Schweizerische Bundesbahnen AG, Siemens Mobility GmbH, Stadler Rail AG, and Trenitalia SPA, collectively referred to as “RTR Members”, “we“, or “us“, are committed to protecting the personal data collected from users of the website (https://www.rtr-initiative.com) (“Website“) (hereinafter referred to as “Users” or “you“). This privacy notice relates to the registration for and use of the Website (“Privacy Notice“). 

When using the Website, personal data may be processed by means of cookies and similar technologies. More information on the use of these technologies can be found in our Cookie Notice. Please read these documents together with this Privacy Notice.

We handle your personal data in a responsible manner and carefully process and secure personal data in accordance with the applicable regulations, including the General Data Protection Regulation of 27 April 2016 (“GDPR“).

Registration for and use of the Website are subject to our “Terms of Use“.

2. CONTROLLERS

The RTR Members act jointly as data controllers for the processing activities in connection with the Website.

The joint controllers are:           

The RTR Members have concluded an agreement to this effect, under which they are each responsible for complying with the obligations under the GDPR as follows:

3. PERSONAL DATA, PURPOSES AND LEGAL GROUNDS

3.1 Personal data

Below you can find out what personal data we process about you in connection with the Website. We may collect such personal data using cookies and similar technologies (about which you can find more information in our Cookie Notice). In addition to the cases mentioned below, personal data is also collected when you contact us by email, telephone or by using the contact form on the Website, in which case the data you provide to us are processed as well as information on any action we take following your interaction.

(a) In general when visiting the Website (with or without registration)  

When you use the Website, the browser on your end device (computer, laptop, table, smartphone, etc.) sends information to the server of the Website. This information is temporarily stored in a so-called log file (protocol file). The following data is collected without your intervention:

• (electronic) identification data, including (pseudonymized) IP address of the requesting computer, device ID or individual device identifier and device type;
• technical data, including name of the retrieved files and amount of data transferred, data and time of retrieval, notification of successful retrieval, requesting domain, browser type and, if applicable, the operating system of your end device and the name of your access provider.

(b) When registering via the Website

When you register via the Website and thus create an account, we collect personal data about you at the time of registration and throughout your participation, in particular:

• (electronic) identification and contact details, including your name, email address and password;
• company identification, including name of the company;
• last log-in date and time, browser type, access start (release), account-status, last accessed IP, initial registration (date);
• all other personal data that you choose to disclose.

3.2 Purposes and legal bases

Your personal data may be used for the purposes set out below. For each purpose, the legal basis on which the RTR Members process the personal data is stated.

In exceptional circumstances, your consent is required for the processing activities we may carry out (e.g., if you voluntarily provide us with more information than needed through a question or request). We will not carry out any processing activities regarding this data without your free, specific, informed and unambiguous consent.

4. DISCLOSURE OF PERSONAL DATA

We may share your personal data with following third parties if necessary for any of the purposes listed above:

• Competent authorities if required by law or upon their request. We may disclose personal data to the competent public authorities and the police when this is necessary, inter alia, to ensure the security and safety of you and third parties, or when we are obliged to do so in accordance with a legal provision or an administrative or judicial decision;
• External service providers, including but not limited to IT service providers, lawyers, consultants or other professional advisors and other service providers that help us in our business activities (e.g., asioso GmbH, Hetzner Online GmbH, Horváth & Partners GmbH);
• Future association (of the RTR Members and any potential new members), provided that such association would use your personal data only for the purposes disclosed in this Privacy Notice or as notified to you.

Other than this, we do not share your data with other parties. The disclosure of your data shall always be limited to the necessary minimum, and we will ensure that access to your data is properly secured by applying appropriate measures.

5. TRANSFERS TO COUNTRIES OUTSIDE THE EU/EEA

We do not nor do we intend to transfer any personal data to countries located outside the European Economic Area (EEA) or Switzerland.   

6. DATA SUBJECT RIGHTS

As a data subject, you have the following rights:

• Right of access: You have a right to access the personal data that we process about you, as well as the right to obtain a copy of that personal data (subject to certain exceptions).
• Right to data portability: Under certain conditions, you have the right to portability of the personal data you have provided us with.
• Right to correction and deletion: You have the possibility of having your data corrected or deleted by us free of charge at any time, provided that the legal conditions for this are fulfilled. Excluded from deletion are data which we are legally obliged to retain.
• Restriction of processing: You can require us to restrict the processing of your data if the applicable legal provisions are complied with.
• Objection: You may object to processing which has our legitimate interest as its legal basis.
• Withdrawal of consent: If we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time. However, this withdrawal will not affect the lawfulness of the processing of your personal data for the period prior to the time of this withdrawal and for processing activities based on another legal ground.
• Complaint to the competent authority: You have the right to file a complaint with the competent data protection authority of the place of your habitual residence or work or, if you believe that we did not act in accordance with the applicable data protection legislation, the place where the alleged infringement took place. The list of the data protection authorities in the European Economic Area is available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

To exercise the above rights, please send a request to (one of) the RTR members (see section 9 for the contact details). Such request should be accompanied by your full contact details and a means of verifying your identity (e.g., a copy of the front of your ID card or driving licence) or through contacting us via your account on the Website. However, we may reject requests that we deem manifestly unfounded or excessive.

When we obtain personal data directly from you, as a rule you are free to provide us with the personal data or not, except in case of a legal obligation. If you do not wish to provide your personal data, it is possible that you will not be able to use the services we offer, that your questions cannot be answered and/or that you will not be able to conclude an agreement with us.

7. RETENTION OF YOUR DATA

Your personal data will be kept for 18 months to fulfil the purpose for which they were collected, taking into account the duration of your contract with us (if applicable), the applicable statutory retention and/or limitation periods in accordance with applicable law.

The applicable storage period for personal data collected through cookies or similar technologies on this Website can be found in our Cookie Notice.

8. AMENDMENTS TO THIS PRIVACY NOTICE

We reserve the right to amend the Privacy Notice at any time in order, among other things, to further develop the Website and offers on it, to amend the Website to reflect changes to the legal structure according to which the RTR Members operate, or due to changed legal and/or regulatory requirements. Amendments to this Privacy Notice take effect at the time of publication. We advise you to always consult the most recent version. You can find the date of this version on the top of the page.

9. CONTACT DETAILS

If you have any questions regarding the processing of your personal data or exercising your rights as a data subject, you can contact (one of) the RTR Members using the following contact details: