Personal data protection policy

Capitalised terms used in this Policy are defined here.

The purpose of our data protection policy (hereinafter referred to as "Policy") is to provide you with information: it tells you how we collect and use your Data, the measures we put in place to protect it and the means available to you to control this use. It does not constitute a contract and does not entail any contractual obligation.

In the interests of transparency, this Policy explains to you, in a concise and understandable manner, the key concepts of data protection, the use we make of your Data and the commitments we make to protect it.

It is supplemented by Information Notices (also known as Notices of Information) which detail the information specific to each Processing operation we carry out, i.e. the purposes of the Processing operations, the type of Data concerned, the retention period, the Legal Basis, etc. The Notices are classified by category to help you more easily identify the one(s) you are looking for.

If you are specifically looking for information on the Cookies used on this website, you can find it here.

This Policy applies to all Data Processing implemented by SNCF Voyageurs as Data Controller, within the European Union, and relating to persons outside the company.

You are concerned by our Policy if you :

• Are a user of our digital spaces (e.g. the Website https://www.sncf-voyageurs.com/fr/ ),
• Are a customer or potential customer,
• Are a user of our Services,
• are a user of our stations or trains,
• Are a candidate for recruitment,
• Are a partner or service provider of SNCF Voyageurs.

You are not concerned by this Policy if the Processing of your Data is implemented by other companies in the SNCF group.

For example:

• If you use the SNCF Connect site, application or services, it is here.
• If you use the Eurostar site, application or services, it is here.
• If you are in contact with Gares & Connexions, please click here.
• If you are in contact with SNCF Groupe, please click here.

The Data we process comes from various sources:

4.1 Data collected directly from you

We may use Data that we have collected directly from you, for example when you create a customer account on an SNCF Voyageurs website or when you fill in a form to subscribe to one of our Services.

4.2 Data collected from public sources or third parties

We may also use Data that we have collected indirectly from third parties:

• Through Data from public or private bodies on the basis of our legitimate interest or legal obligations: data providers, fraud prevention bodies, bodies responsible for managing non-payments, etc,
• Through Data from commercial partners on the basis of your Consent,
• Through open access data sources.

4.3 Data collected automatically when using our digital areas

We may automatically collect your Data when you use our digital areas such as our Website. This automatic collection may in particular take place through the use of Cookies and other tracers.

For more information, please consult our Cookies Policy.

Our commitments

We undertake to inform you of the origin of the collection of your Data by means of information notices.

We only process Data that is relevant and necessary for the Purpose we are pursuing. We process this Data in the context of our relationship with you or your use of our Services.

Generally speaking, the Data we collect can be classified into Categories, which we present below in this Section, with examples of Data.

To find out what type of Data we collect for a particular Processing, please refer to the specific Information Notices for the Processing that concerns you.

• Identity Data: surname, first name, date of birth, nationality, photo, signature, etc.
• Identifiers: loyalty or subscription card number, identity card or passport number, social network identifiers, etc.
• Contact details: e-mail address, postal address, landline telephone, mobile telephone, etc.
• Personal details: family situation, number of children, contact person, etc.
• Connection and browsing data: connection identifiers, IP address, cookies, connection traces, browsing history, etc.
• Travel data: travel file number (reservation number), validation data (date, time, place of ticket validation), subscribed services (travel options), type of assistance required, etc.
• Banking data: means of payment (cheque, bank card, transfer), payment card number, payment card expiry date, bank details, etc.
• Customer profile, scores and segmentation: type of profile, score result, customer satisfaction indicator, etc.

In the course of certain Processing operations, we may also process documents which may contain Data in the Categories described above.

The length of time we retain your Data varies according to the Purpose of the Processing concerned and the applicable legislation. Your Data is kept until the Purpose for which it was collected or recorded has been fulfilled.

At the end of the Retention Period, your Data is permanently deleted or anonymised.

To find out how long we keep your Information for a particular Processing, please refer to the specific Information Notices for the Processing that concerns you.

Our commitments

SNCF Voyageurs undertakes not to keep your Data in a form that allows you to be identified for longer than is necessary to achieve the Purpose of the Processing.

SNCF Voyageurs undertakes to use only anonymous Data to carry out its statistical studies, such as measuring the number of train passengers or analysing the audience for its websites, whenever the Processing does not require the use of Data enabling you to be identified.

We process your Data mainly in order to carry out the operations necessary for the provision of the transport service, as well as to manage the various relationships we have with our customers and partners.

As required by law, we only process your Data where the Purpose of Processing can be based on one of the following Legal Bases:

• The performance of the contract between us, for example when the Purpose of Processing relates to the organisation of your trip or the management of your complaints;
• The Consent that you have given, after having been informed of the Processing that we will carry out, for example when the Purpose of the Processing is to carry out commercial prospecting operations (promotions, competitions, etc.);
• The legitimate interest that we may have in using your Data, insofar as this does not create an imbalance to your detriment, for example when the Purpose of Processing is to analyse the occupancy rate of our trains;
• The public interest missions entrusted to us, for example when the Purpose of the Processing is to detect breaches of the Transport Code;
• The legal obligation that may be imposed on us, for example when the Purpose of Processing is to assess the integrity of suppliers with whom we have a business relationship;
• Safeguarding your vital interests, in particular the transmission of Data concerning you to the emergency services in the event of an accident.

To find out the Purpose for which we use your Data and the Legal Basis on which we rely to implement a particular Processing, please refer to the specific Information Notices for the Processing that concerns you.

Our commitments

We undertake to always process the Information we collect or hold about you in accordance with the law, for specified, explicit and legitimate Purposes, and not to further process it in a way that is incompatible with those Purposes.

We are transparent about our Purposes and undertake to make them easily understandable.

We may transmit your Data to several types of Recipients.

8.1 To SNCF Voyageurs and SNCF Group employees

Your Data may be processed by employees of SNCF Voyageurs and the SNCF Group. The employees who process your Information are authorised to process this Information exclusively in order to achieve the Purpose of the Processing implemented by SNCF Voyageurs.

8.2 To our Subcontractors

We use the services provided by several specialised service providers (IT service providers, data hosts, etc.) who most often act as Subcontractors within the meaning of the RGPD. These Subcontractors have access to the Data that we collect solely in the context of and for the purposes of the Processing operations that we entrust to them. We ensure that each of these Subcontractors implements appropriate technical and organisational measures to guarantee the security and confidentiality of the Data processed.

We prefer to process and store your Data within the EEA - European Economic Area. However, we may transfer your Data to Subcontractors outside the EEA, for example for the purposes of backing up your Data or for remote maintenance. If the transfer takes place to a country outside the EEA in which the legislation has not been recognised as offering an adequate level of protection of the Data, we ensure that the necessary measures are put in place in accordance with the Data Protection Act and Articles 46, paragraphs 2 and 3 and 49 paragraph 1 of the GDPR, and in particular, where necessary, that standard contractual clauses in accordance with the model adopted by the European Commission or equivalent ad hoc clauses are incorporated into the contract concluded between SNCF Voyageurs and its service providers.

8.3 To other recipients

Your Data will only be transmitted to commercial partners with your Consent.

Under certain strict conditions, your Data may also be communicated to certain organisations that have the status of third parties authorised by law (government authorities, for example).

Our commitments

The SNCF Group applies strict authorisation policies to its staff, ensuring that your Data is only transmitted to employees authorised to access it in the context of their duties.

In the event of using the services of a Data Subcontractor, SNCF Voyageurs will only pass on your Data to the Data Subcontractor after requiring it to comply with its own security rules and having concluded a contract whereby the Data Subcontractor undertakes to take technical and organisational measures to guarantee the protection of your Data.

Where this service provider is located outside the EEA (i.e. where the Sub-Contractor's server is located outside the EEA), or where there is a risk of Data being transferred outside the EEA (i.e. where the server is located in the EEA but the service provider's country of origin is outside the EEA), we will put in place with the Subcontractor a transfer instrument that complies with the GDPR and, if necessary, additional measures to ensure a level of Data protection that is substantially equivalent to that of the GDPR.

We will not sell or rent your personal information to any outside organisation without your Consent.

Apart from these cases, we only pass on your Data to third parties after careful verification of the legal validity of the request to disclose your Data.

We implement appropriate technical and organisational measures to guarantee a level of security appropriate to the risks presented by the Processing of your Data.

When assessing the appropriate level of security, we take into account in particular the risks presented to you by the Processing, in the event of destruction, loss, alteration, unauthorised disclosure of the Data transmitted, stored or otherwise processed, or unauthorised access to such Data, whether accidental or unlawful, in accordance with the provisions of Article 32 of the RGPD.

By way of example, where possible and/or necessary, we may use Pseudonymisation or Data Encryption techniques.

When designing or selecting the Tools that enable your Data to be Processed, we ensure that they enable an optimum level of Data protection to be provided by the internal departments or publishers who design these tools.

We therefore implement measures that comply with the principles of protection by design and protection by default of your Data, in accordance with the provisions of Article 25 of the RGPD.

When we use the services of a service provider, we only disclose your Data to them once we have obtained their contractual commitment to comply with our own security rules.

We carry out regular audits of our own services and those of our service providers in order to verify that the Data security rules are being applied.

10.1 Your rights

The law gives you rights over how we process your Data. You have:

1. A right of access and information which allows you to obtain a copy and/or information about how we process your Data,
2. A right to rectification of your Data if the Data we use is inaccurate,
3. A right to erasure of your Data under certain conditions,
4. the right to object, on legitimate grounds, to the processing of your Data by us, or the right to withdraw your Consent in the case of processing carried out with your consent,
5. a right to the portability of your Data under certain conditions,
6. a right to limit the Processing that we carry out with your Data for a certain period of time,
7. The right to send us instructions concerning the storage, deletion and communication of your Data after your death,
8. the right to lodge a complaint with a supervisory authority, in particular the CNIL(https://www.cnil.fr/fr/plaintes).

Your rights may be subject to certain limits and conditions. You can find more information on the nature of these rights on the CNIL website.

10.2 How can you exercise your rights?

The channel through which you can exercise your rights is detailed in the Information Notice for each Processing. To find out how to exercise your rights, please refer to the specific Information Notices for the Processing that concerns you.

If you cannot find the Information Notice that corresponds to the Processing you are interested in, you can submit your request using one of the forms below, depending on the Service(s) you are using:

• TGV INOUI / INTERCITÉS
• OUIGO
• TER
• TRANSILIEN

Where necessary, or if there are reasonable doubts about your identity, we may ask you to identify yourself precisely by means of a copy of an identity document (identity card or passport) or any other element enabling us to prove your identity. The copy of your proof of identity will be deleted as soon as your request has been processed.

If you have any questions about this Policy or the protection of your Data, you can contact our Data Protection Officer by visiting this page.

Our commitments

SNCF Voyageurs has set up an organisation enabling it to satisfy any requests for rights that you may exercise throughout the Processing process, in compliance with the conditions and deadlines laid down by the applicable regulations.

In addition, SNCF Voyageurs undertakes to systematically inform any Data Subject who exercises his or her rights in the event of delay or impossibility of fulfilling his or her request.

Finally, SNCF Voyageurs has appointed a Data Protection Officer who can answer questions concerning the protection of your Data.

When you browse our digital spaces (websites, mobile applications, etc.), we deposit Cookies on your devices (computer, smartphone, tablet, etc.) with or without your Consent depending on the Purposes of the Cookies. Information on Cookies and how to refuse Cookies is set out in the Cookie Policy.

We reserve the right to modify this Policy at any time. All changes will be published on our Website. We advise you to consult it regularly, in particular when travelling with SNCF Voyageurs.

In addition, SNCF Voyageurs may modify, supplement or update the Information Notices for its Processing in order to take into account any legal, regulatory, case law and/or technical developments as well as any changes made to the Services.

We will inform you of any significant changes made to the Processing before they take effect. If you are in any doubt as to the current version of the Information Notice, we advise you to refer to the Information Notice published on our Website.