Website and Marketing Privacy Policy

This privacy notice explains how we collect, process and store your personal data:

  • Through your use of our website
  • When we market to you

Our website and marketing are not intended for children, and we do not knowingly collect personal data relating to children.

Please note that where we provide passenger WiFi, we do so a processor on behalf of the relevant controller. As a processor, we have a contractual relationship with the controller, which documents our respective responsibilities and liabilities in relation to data protection. For the avoidance of doubt, this privacy notice does not relate to your use of passenger WiFi. If you have any questions concerning how the controller uses your personal data, including in relation to passenger WiFi, please refer to the relevant controller’s privacy notice.

Further, we have a separate and internal privacy notice for current, former and prospective employees. If you have any questions in relation to the same, please do not hesitate to Contact Us.

Who we are

We are Nomad Holdings Limited, whose registered office is at The Place, 8th Floor, High Holborn, London, England WC1V 7AA with company number 05871463. Nomad Holdings Limited is registered with the Information Commissioner's Office (“ICO”) with registration number ZA437312.

Nomad Holdings Limited has the following subsidiaries:

  • Nomad Digital Limited
  • Nomad Digital GmbH
  • Nomad Digital Pty Limited
  • Nomad Digital BV
  • Nomad Digital Inc
  • Nomad Digital ApS

hereinafter referred to as the “Group”.

Please note that any marketing email that we send to you will come from Nomad Holdings Limited, however the content of such correspondence may refer to any member of the Group. This will be made clear to you when you opt-in to receive marketing from us.

Data Protection Officer

We have appointed a Data Protection Officer, who is responsible for overseeing Nomad’s ongoing commitment to data protection and privacy. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our Data Protection Officer using the details set out below.

How to contact us

Email address: dpo@nomadrail.com

Postal address: FAO Data Protection Officer, Nomad Digital, One Trinity, 5th Floor, Broad Chare, Newcastle upon Tyne, United Kingdom NE1 2HF

Telephone number: +44 (0) 3300889320

Your right to complain

You have the right to make a complaint at any time to the ICO or your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or your local supervisory authority, so please Contact Us in the first instance.

Personal data that we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.

We may collect, use, store and / or transfer different kinds of personal data about you, which we have grouped together as follows:

  • Identity Data – includes your first name, last name, title, the company that you work for and the geographic region in which you are located
  • Contact Data – includes your email address
  • Usage Data – includes information about how you use our website, products, services and solutions
  • Marketing and Communications Data – includes your preferences in receiving marketing from us

Please note that we do not collect any special categories of personal data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

How is your personal data collected?

You may give us your Identity, Contact, and Marketing and Communications Data by filling in forms, or by corresponding with us by email or otherwise. This includes personal data that you provide us with when you request marketing to be sent to you.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where you have provided your consent
  • Where it is necessary for our legitimate interests, e.g. where we have business or commercial reasons to use your personal data, however we will never put our legitimate interests about what is best for you

The below table demonstrates the purposes for which we may use your personal data, including the type of personal data and the lawful basis:

Personal corporate email addresses

We may collect your personal corporate email address when – for example – we exchange business cards with you at an event, or as part of our day-to-day business relationship with you. Whilst personal corporate email addresses – i.e. firstname.lastname@company.com – may constitute personal data and be subject to the relevant data protection legislation, they do not benefit from the rules on direct marketing and consent.  This means that organisations – including Nomad Digital – may market to you by email without receiving your opt-in consent. However, as you will appreciate, it serves little purpose for us to contact you if you do not want to hear from us, and you can unsubscribe at any time.

Third parties

We do not share your personal data with any third parties outside the Group, unless we are legally required to do so.

Cookies

You can set your browser to disable cookies. If you disable cookies, some parts of our website may become inaccessible or not function properly. For more information about how we use cookies, please refer to our Cookies Policy.

Change of purpose

We will only use your personal data for the purposes for which we originally collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis upon which we propose to do so.

International transfers

We may share your personal data within the Group. This may involve transferring your personal data outside the European Economic Area (“EEA”). Whenever we transfer your personal data out of the EEA, we will ensure that a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:

  • Transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
  • Put in place a contract with the recipient of the personal data, which means that the recipient must protect the personal data to the same standards as required within the EEA
  • Transfer your personal data under the Privacy Shield. The Privacy Shield is a framework, which sets out the standards for personal data to be sent between the United States and countries within the EEA. The Privacy Shields ensures that personal data is protected to the same standards as within the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data being accidentally lost, used or accessed in an unauthorised way, or altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach, and we will notify you and any applicable supervisory authority of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your legal rights

In certain circumstances, you have the following legal rights in relation to your personal data:

  • Access – This enables you to receive a copy of the personal data that we hold about you
  • Correction – This enables you to have any incomplete or inaccurate personal data that we hold about you to be corrected, however we may need to verify the accuracy of any new personal data that you provide to us
  • Erasure – This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note that at we may not always be able to comply with your request of erasure for specific legal reasons
  • Object to Processing – You have the right, for example, to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which may override your rights and freedoms
  • Restrict Processing – This enables you to ask us to suspend the processing of your personal data in the following scenarios: i) if you want us to establish the data's accuracy; (ii) where our use of your personal data is unlawful, but you do not want us to erase it; (iii) where you need us to hold your personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) if you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it
  • Transfer – We can provide your personal data, so that it can be transferred to you or a third party that you have chosen. Please note that this right only applies to automated information, which you initially provided consent for or where we have used the information to perform a contract with you
  • Withdraw Consent – You can withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain things to you

If you wish to exercise any of the above rights, please Contact Us.

You will not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in such circumstances.

We may need to request specific information from you in order to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request.

Please note that we try to respond to all legitimate requests within one (1) calendar month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

If you have any questions at all in relation to this privacy notice or any other matter relating to your personal data, please feel free to Contact Us.

This privacy notice was last updated on 4 September 2018. We may change this notice by updating this page to reflect changes in the law or our data protection practices.