At Wandrian Ventures Inc. (collectively, with its affiliates, “InterRail”), we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy. This Privacy Policy governs your use of the Services offered by InterRail, including but not limited to your use of www.italiadeals.com, www.italiapass.com, www.italiarail.com, www.italiarooms.com, www.italiatours.com, www.italymagazine.com, and www.railpass.com.
Remember that your use of InterRail’s Services is at all times subject to our Terms of Service, https://www.italiarail.com/terms-conditions, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.
As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the InterRail website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
Privacy Policy Table of Contents
- What this Privacy Policy Covers
- Personal Data
- How We Disclose Your Personal Data
- Tracking Tools, Advertising and Opt-Out
- Data Security
- Personal Data of Children
- U.S. State Consumer Privacy Rights
- Exercising Your Rights under the U.S. State Privacy Laws
- Other State Law Privacy Rights
- European Union, United Kingdom, and Swiss Data Subject Rights
- Contact Information
What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
Personal Data
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
| Category of Personal Data (and Examples) | Business or Commercial Purpose(s) for Collection | Categories of Third Parties With Whom We Disclose this Personal Data |
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| Contact Data such as first and last name and phone number |
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| Profile Data such as login name, email or other unique identifiers. |
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| Payment Data such as payment card type, last 4 digits of payment card, billing address, phone number, and email. |
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| Commercial Data such as purchase history. |
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| Device/IP Data such as IP address, IP address-based location, device ID, and type of device/operating system/browser used to access the Services. |
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| Consumer Demographic Data such as age and/or date of birth and zip code. |
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| Categories of Data Considered “Sensitive” Under U.S. State Privacy Laws (as defined below) such as passport number. |
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| Inferences Drawn From Other Personal Data Collected such as user behavior. |
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| Other Identifying Information that You Voluntarily Choose to Provide such as emails, letters, texts, or other communications you send us. |
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Our Commercial or Business Purposes for Collecting Personal Data
- Providing, Customizing and Improving the Services
- Creating and managing your account or other user profiles.
- Processing orders or other transactions; billing.
- Providing you with the products, services or information you request.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance for the Services.
- Improving the Services, including testing, research, internal analytics and product development.
- Personalizing the Services, website content and communications based on your preferences.
- Doing fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), the Colorado Privacy Act (the “CPA”), the Connecticut Data Privacy Act (the “CTDPA”), the Montana Consumer Data Privacy Act (“MCDPA”), the Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy and Security Act (“TDPSA”), Utah Consumer Privacy Act (the “UCPA”), or the Virginia Consumer Data Protection Act (the “VCDPA”) (collectively, the “U.S. State Privacy Laws”).
- Marketing the Services
- Marketing and selling the Services.
- Showing you advertisements, including interest-based, online behavioral or targeted advertising.
- Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about InterRail or the Services.
- Sending emails and other communications according to your preferences or that display content that we think will interest you.
Other Permitted Purposes for Processing Personal Data
In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, InterRail or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
- You
- When you provide such information directly to us.
- When you create an account or use our interactive tools and Services.
- When you use our interactive tools and Services.
- When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
- When you send us an email or otherwise contact us.
- When you use the Services and such information is collected automatically.
- Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
- If you use a location-enabled browser, we may receive information about your location.
- When you provide such information directly to us.
- Third Parties
- Vendors
- We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
- Advertising Partners
- We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.
- Vendors
How We Disclose Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
- Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
- Hosting, technology and communication providers.
- Analytics providers that help us analyze your use of our website and services.
- Security and fraud prevention consultants.
- Support and customer service vendors.
- Product fulfillment, suppliers and delivery providers.
- Payment processors.
- Our payment processing partners Stripe, Inc. (“Stripe”), Braintree (offered by PayPal, Inc.) (“Braintree”), and/or Authorize.net (offered by Visa Inc.) (“Authorize.net”) collect your voluntarily-provided payment card information necessary to process your payment.
- Please see Stripe’s, Braintree’s, or Authorize.net’s terms of service and privacy policy for information on its use and storage of your Personal Data.
- Advertising Partners. These parties help us market our services (including by way of Interest-Based Advertising) and provide you with other offers that may be of interest to you. They may include:
- Ad networks.
- Marketing provider.
- Advertising providers that provide services in relation to our marketing efforts.
- Business Partners. These parties provide relevant travel or Italian vacation and culture-related services or offerings.
- Parties You Authorize, Access or Authenticate
- Third parties you access through the services or otherwise authorize to receive your Personal Data. Other users.
Legal Obligations
We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.
Tracking Tools, Advertising, and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).
Additionally, the Services support “Do Not Track” requests sent from a browser.
We use the following types of Cookies:
- Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
- Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Service and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
- Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Session Replay Technology
We use session replay technology, such as Lucky Orange, in order to identify and resolve customer issues, to monitor and analyze how you use our Services, to better understand user behavior, and to improve our Services. By continuing to use the Services, you consent to the use of session replay technology.
Information about Interest-Based Advertisements
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
Data Security
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
Data Retention
We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
For example:
- We retain your payment data for as long as we need to process your purchase or subscription.
- We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
Personal Data of Children
The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13 years of age. We do not knowingly collect or solicit personally identifiable information from children under 16 years of age; if you are a child under 16 years of age, please do not attempt to register for or otherwise use the Services or send us any personal information. If we learn we have collected personal information from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided us personal information, please contact us at info@italiarail.com.
U.S. State Consumer Privacy Rights
If you reside in certain U.S. states, such as California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia, you may have certain rights afforded to you (as described below) depending on your state of residence. Please see the “Exercising Your Rights under the U.S. State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Please note that your rights may be subject to certain conditions or exceptions in accordance with applicable U.S. State Privacy Laws.
If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@italiarail.com.
- Access: You may have the right to request confirmation of or access to the Personal Information that we process about you. You can also request access to a portable copy of your Personal Information. If you are an Oregon resident, you also have the right to request a list of specific third parties, other than natural persons, to which we has disclosed your Personal Information.
- Deletion: You may have the right to request that we delete the Personal Information that we have collected about you.
- Correction: You may have the right to request that we correct any inaccurate Personal Information we have collected about you.
- Portability: You may have the right to request a copy of your Personal Information in a machine-readable format, to the extent technically feasible.
Targeted Advertising, “Sharing,” and “Selling”
Depending on your state of residence, you may have the right to opt out from the (1) selling, (2) sharing, or (3) processing for the purposes of targeted advertising of your Personal Data. These or similar terms may be defined differently depending on the applicable U.S. State Privacy Law. For example, in some states, “selling” is defined as the exchange of Personal Data for monetary or other valuable consideration, while in other states, “selling” only includes the exchange of Personal Data for monetary consideration. Additionally, in California, “sharing” is defined as the disclosure of Personal Data for cross-contextual behavioral advertising (or targeted advertising in other states).
You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the “Exercising Your Rights under U.S. State Privacy Laws” section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under certain U.S. State Privacy Laws, disclosing your data through third party Cookies for targeted advertising or cross-context behavioral advertising may be considered a “sale” and/or “share” of your Personal Data. For clarity, when we use the term “sell,” we mean for valuable consideration and not for any monetary value.
We sell or share your Personal Data with the following categories of third parties:
- Advertising Partners
Over the past 12 months, we have sold or shared the following categories of your Personal Data to categories of third parties listed above:
- Device/IP Data
- Web Analytics
We have sold or shared the foregoing categories of Personal Data for the following business or commercial purposes:
- Marketing and selling the Services.
- Showing you advertisements, including interest-based or online behavioral advertising.
You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the “Exercising Your Rights under the U.S. State Privacy Laws” section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.
Sensitive Personal Data
As needed, we may reach out to you to provide us with Personal Data that may be deemed “sensitive” under certain U.S. State Privacy Laws (“Sensitive Personal Data”). The categories of Sensitive Personal Data we collect and and our purposes for collecting such Sensitive Personal Data is described in the ‘Categories of Personal Data We Collect’ section above By providing us with the requested Sensitive Personal Data, you are consenting to our collection and processing of such information.
Depending on your state of residence, you may either have the right to opt-in, the right to opt-out, or if you are a California resident, the right to limit our use of your Sensitive Personal Data to permitted purposes, by following the instructions in the “Exercising Your Rights under U.S. State Privacy Laws” section. If you are a California resident, please note that our use and disclosure of Sensitive Personal Data are already only limited to the purposes set forth in section 7027(m) of the CCPA regulations, including: 1) performing the services or providing the goods reasonably expected, 2) preventing, detecting, and investigating security incidents, 3) resisting malicious, deceptive, fraudulent, or illegal actions, 4) ensuring physical safety of natural persons, 5) for short-term transient use, 6) performing services on behalf of the business, 7) verifying or maintaining quality or safety of a product or service, and 8) collecting or processing Sensitive Personal Data but not for the purpose of inferring characteristics. Therefore, we do not offer a way for you to submit such a request.
If you are a Colorado, Connecticut, Montana, Texas, or Virginia resident, you may withdraw your consent allowing us to process your Sensitive Data or, if you are a Utah resident, you may opt-out of the processing by following the instructions in the “Exercising Your Rights under the U.S. State Privacy Laws” section.
Automated Decision Making and Profiling
Depending on the state of your residence, you may have the right to opt-out the use of automated decision making technology or from the processing of your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable. However, we do not process your Personal Data in these manners.
Anti-Discrimination
We will not discriminate against you for exercising your rights under applicable privacy laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under applicable privacy laws. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Exercising Your Rights under the U.S. State Privacy Laws
To exercise the rights described in this Privacy Policy, you or, if you are a California, Colorado, Connecticut, Montana, Oregon, or Texas resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (such as your Contact or Profile Data), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
Request to Opt-Out of Sale, Share, and/or Targeted Advertising
As applicable, you may opt-out from any “sales,” “shares,” or targeted advertising through Cookies, by using the following methods:
- By implementing the Global Privacy Control or similar universal privacy control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this includes Do Not Track signals.
Request to Withdraw Consent to Certain Processing Activities
As applicable, you may withdraw your consent allowing us to process your Sensitive Data (including Sensitive Data Inferences), or 2) to sell, or process your Personal Data for Targeted Advertising or Profiling after you have exercised your right to opt-out by emailing us at info@italiarail.com.
Request to Access, Delete, or Correct
As applicable, you may submit a Valid Request for any other rights afforded to you in this Privacy Policy by emailing us at info@italiarail.com.
If you are a California, Colorado, Connecticut, Montana, Oregon, or Texas resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Appealing a Denial
If you are a Colorado, Connecticut, Montana, Oregon, Texas, or Virginia resident and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the U.S. State Privacy Laws (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by emailing us at info@italiarail.com (title must include your state of residence and “Appeal”).
If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: Colorado, Connecticut, Montana, Oregon, Texas, and Virginia.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at info@italiarail.com.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services support Do Not Track requests. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
Nevada Resident Rights
Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
European Union, United Kingdom, and Swiss Data Subject Rights
EU, UK, and Swiss Residents
If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. InterRail will be the controller of your Personal Data processed in connection with the Services.
If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at info@italiarail.com. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
- Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
- Profile or Contact data
- Payment Data
- Device/IP Data
- Categories of Data Considered "Sensitive" Under the State Privacy Laws
- Other Identifying Information that You Voluntarily Choose to Provide
- Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
- Profile or Contact data
- Identifiers
- Payment Data
- Commercial Data
- Device/IP Data
- Web Analytics
- Consumer Demographic Data
- Categories of Data Considered "Sensitive" Under the State Privacy Laws
- Inferences Drawn From Other Personal Data Collected
- Other Identifying Information that You Voluntarily Choose to Provide
- We may also de-identify or anonymize Personal Data to further our legitimate interests.
- Examples of these legitimate interests include (as described in more detail above):
- Providing, customizing and improving the Services.
- Marketing the Services.
- Corresponding with you.
- Meeting legal requirements and enforcing legal terms.
- Completing corporate transactions.
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Disclosing Personal Data
The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data with third parties.
EU, UK and Swiss Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at info@italiarail.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by emailing us at info@italiarail.com.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data by emailing us at info@italiarail.com.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about InterRail’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through InterRail and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to InterRail in the U.S. and will be hosted on U.S. servers, and you authorize InterRail to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses and/or the Data Privacy Framework(s), as discussed below.
Data Privacy Framework(s)
InterRail and our affiliates, ItaliaTours, LLC, and Italy Magazine, LLC, comply with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (“UK-U.S. DPF”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. InterRail has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of all personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF (the “EU-UK DPF Principles”). InterRail has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles, the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles shall govern. To learn more about the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-US DPF, and to view our certification, please visit https://www.dataprivacyframework.gov/.
The Federal Trade Commission has jurisdiction over InterRail’s compliance with the EU-U.S. DPF, the EU-UK DPF, and the Swiss-U.S. DPF. This Privacy Policy describes the types of Personal Data we collect, the purposes for which we collect and use your Personal Data, and the purposes for which we disclose your Personal Data to certain types of third parties in the sections above. Pursuant to the EU-U.S. DPF, the EU-UK DPF, and the Swiss-U.S. DPF, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain Personal Data relating to them in the U.S. Upon request, we will provide EU, UK, and Swiss individuals with access to the Personal Data that we hold about them. EU, UK, and Swiss individuals may also correct, amend, or delete the Personal Data we hold about them where it is inaccurate, or has been processed in violation of the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. An EU, UK, or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the U.S. under the EU-U.S. DPF, the EU-UK DPF, or the Swiss-U.S. DPF, should direct their query to info@italiarail.com. If requested to remove data, we will respond within a reasonable timeframe. For more information about rights afforded EU, UK, and Swiss individuals, please see the “European Union, United Kingdom, and Swiss Data Subject Rights” section of this Privacy Policy.
In addition, under the EU-U.S. DPF, the EU-UK DPF, and the Swiss-U.S. DPF, we will provide EU, UK, and Swiss individuals with the choice to opt-out from the sharing of their Personal Data with any third parties (other than our agents or those that act on our behalf or under our instruction), or before we use it for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized.
In addition to any other disclosures described in our Privacy Policy, in certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
InterRail’s accountability for Personal Data that it receives in the U.S. under the EU-U.S. DPF, the EU-UK DPF, and the Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on our behalf is described in the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles. In particular, InterRail remains liable under the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles if our agents process Personal Data in a manner inconsistent with the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles, unless InterRail proves that we are not responsible for the event giving rise to the damage.
In compliance with the EU-U.S. DPF, the EU-UK DPF, and the Swiss-U.S. DPF, InterRail commits to resolve EU-U.S. DPF Principles, EU-UK DPF Principles, and Swiss-U.S. DPF Principles-related complaints about our collection and use of your Personal Data. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the DPF should first contact InterRail at info@italiarail.com.
In compliance with the EU-U.S. DPF, the EU-UK DPF, and the Swiss-U.S. DPF, InterRail commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the EU-UK DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the U.S. If you are an EU, UK, and Swiss individual and you do not receive timely acknowledgment of your EU-U.S. DPF Principles, EU-UK DPF Principles, or Swiss-U.S. DPF Principles-related complaint from us, or if we have not addressed your EU-U.S. DPF Principles, EU-UK DPF Principles, or Swiss-U.S. DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Notwithstanding the foregoing, with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the EU-UK DPF, and the Swiss-U.S. DPF in the context of the employment relationship, InterRail commits to cooperate and comply with, respectively, the panel established by the EU data protection authorities, the UK Information Commissioner’s Office and the Gibraltar Regulatory Authority, and the Swiss Federal Data Protection and Information Commissioner.
If your EU-U.S. DPF, EU-UK DPF, or Swiss-U.S. DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Annex 1 of the Data Privacy Framework Principles, located at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
Contact Information:
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
- info@italiarail.com
- InterRail, LLC
- 68 Harrison Ave Ste 605 PMB 17937 Boston, Massachusetts 02111-1929 US
- UK: ItaliaRail Limited, Unit 2, Charnwood Edge Business Park, Syston Road, Cossington, Leicestershire, LE7 4 UZ, email into@italiarail.com.
- EU: Italia Ventures Srl, via Giolitti 34, binario 25, 00185 Roma, Italy, email: accounting@italiapass.com.
EFFECTIVE DATE: December 17, 2024