Wi-Fi Privacy Policy

ON THE MOVE: THIS IS WHAT YOU NEED TO KNOW ABOUT OUR WI-FI SERVICE DATA PROTECTION PRACTICES

As you're travelling with us, we've kept things simple with a summary of the key points regarding how we handle your data as part of our Wi-Fi service, provided by Icomera on TransPennine Express trains. For an in-depth look at our data protection approach for all services, you're welcome to click here.

Who We Are

We are Transpennine Trains Limited trading as TransPennine Express ("we" or "us"). We are registered in England and Wales under company number 12544930 and have our registered office at 7th Floor, Bridgewater House, 58-60 Whitworth Street, Manchester M1 6LT. Our VAT number is 324097412. In partnership with Icomera, we offer you Wi-Fi services aboard our trains.

Our Data Protection Officer

A Data Protection Officer has been appointed to oversee our approach to data protection. Should you have any queries, reach out via email at tpe.dataprotection@transpenninetrain.com or by mail at 7th Floor, Bridgewater House, 60 Whitworth Street, Manchester, M1 6LT.

Data Processing for Wi-Fi Service

To ensure a high-quality, reliable Wi-Fi service, we process certain data from your device, including the MAC address, IP address, session timestamp, and session ID, as well as the GPS position of the train. This information is crucial for maintaining service quality and addressing any support issues that may arise.

In addition to technical data, we collect personal information such as your name and email address through our Wi-Fi service. This data is integrated into our Customer Relationship Management (CRM) system to enhance your customer experience, allowing us to provide personalised support, service updates, and information relevant to our services.

Legal Grounds for Processing

In providing our Wi-Fi service aboard TransPennine Express trains, the collection and processing of your personal data are carried out in strict compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. The foundation of our data processing activities rests on our legitimate interests, which include:

• Facilitating Network Access: To provide you with seamless access to our Wi-Fi network, it is essential for us to process certain data such as your device's MAC address and IP address. This enables us to uniquely identify your device and maintain a stable connection throughout your journey.
• Enhancing Our Services: We continually strive to improve our Wi-Fi service, making it more reliable, efficient, and user-friendly. Processing data related to your Wi-Fi usage, such as session duration and bandwidth used, helps us to understand usage patterns and make necessary adjustments to our network infrastructure.
• Service Quality and Support: By processing data on the technical aspects of your Wi-Fi session, we can promptly address any connectivity issues, provide effective customer support, and ensure the overall quality of the Wi-Fi service.

Sharing Your Information

To deliver our Wi-Fi service effectively, we collaborate with Icomera, our primary Wi-Fi service provider, and engage with other essential third-party vendors. The sharing of your data with these parties is conducted with the utmost care and is limited to what is necessary to provide the Wi-Fi service. Specifically:

Icomera: As our primary partner in providing Wi-Fi services, Icomera requires access to certain technical data such as device identifiers and session information. This collaboration ensures the stability and reliability of the Wi-Fi connection aboard our trains.

Third-Party Vendors: Other vendors may be involved in supporting various aspects of the Wi-Fi service, such as network infrastructure maintenance, software provision, and customer support tools. These vendors are carefully selected and bound by strict data protection agreements to ensure they provide the same level of data protection and security as we do.

Communication and Information Updates

We understand the importance of keeping you informed about the Wi-Fi service and any developments that might affect your user experience. As such, we may contact you to share important updates or notices related to the Wi-Fi service. Communication may include, but is not limited to, service enhancements, maintenance schedules, or changes to this privacy notice. These communications are intended to keep you well-informed and to enhance your overall experience with our services.

Safeguarding Your Data

At TransPennine Express, we recognise the importance of your privacy and the need to protect your personal data. We are dedicated to safeguarding your information with a comprehensive suite of technical and organisational measures designed to ensure the highest levels of security and confidentiality.

Use of Cookies

To enhance your experience with our Wi-Fi service, we utilise cookies—small text files stored on your device. These cookies play a crucial role in facilitating a smoother connectivity experience by:

• Device Recognition: Cookies enable us to recognise your device, allowing for quicker connection times and reducing the need for you to repeatedly log in or authenticate your device.
• Service Improvement: By analysing how our Wi-Fi service is used, we can identify areas for improvement, making the service more efficient and user-friendly.
• User Preferences: Cookies help us remember your preferences and settings, personalising your Wi-Fi experience according to your usage patterns and choices.

Your Data Protection Rights

At TransPennine Express, we are committed to ensuring that your rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 are fully respected and facilitated. You have the following rights regarding your personal data:

• Right to Access: You have the right to request access to your personal data that we hold.
• Right to Rectification: If you believe that any personal data we hold about you is inaccurate or incomplete, you have the right to request its correction.
• Right to Erasure: In certain circumstances, you have the right to request the deletion of your personal data from our systems.
• Right to Restrict Processing: You have the right to request a restriction on the processing of your personal data under specific conditions.
• Right to Data Portability: You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit those data to another controller.

To exercise any of these rights, please contact our Data Protection Officer via email at tpe.dataprotection@transpenninetrain.com. We are here to assist you with any queries or requests related to your personal data.

Automated Decision Making and Profiling

We want to clarify that our Wi-Fi service does not involve any form of automated decision making or profiling using your personal data. Our processes are designed to ensure that all decisions affecting our users are made with human intervention and consideration.

Making a Data Protection Complaint

If you have any concerns or complaints about how we handle your personal data, please do not hesitate to reach out to our Data Protection Officer at tpe.dataprotection@transpenninetrain.com. While we are dedicated to resolving any issues related to your data protection rights, please note that we may not be able to assist with issues unrelated to data protection, such as Wi-Fi connectivity problems.

Policy Updates

This privacy policy was last updated in February 2024. We regularly review and, where necessary, update our privacy information. Should any significant changes be made to our data protection practices, we will communicate these changes through our usual channels.