Personal Data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

"Any information relating to an identified or identifiable natural person ('data subject'); An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".

We also make use of cookies, further information about cookies can be found here - http://www.aboutcookies.org/ or on our cookies page.

Cookies are used to understand user preferences such as stations entered during the Check My Route feature, as this allows us to prepopulate the stations later in the registration process. They are also used to understand where you came to the site from so Marketing can be informed as to the most efficient use of marketing budget.

By using our website and agreeing to this policy, you consent to our use of your data and cookies in accordance with the terms of this policy.

Who are we?

Delay Repay Sniper Ltd (DRS) is a wholly owned subsidiary of Tracsis plc. The application service ‘Delay Repay Genie’ was developed with the sole intention of making it easier for UK rail passengers to claim compensation for delays and cancellations encountered on their journey. The service is provision of information, what you do with that information is purely up to you. If you believe you are entitled to compensation because you intended to travel on a given train that was delayed or cancelled, then it is your responsibility to submit a claim with the relevant information (if you are subscribed to the 'DIY' service or within your Free Trial) or identify those trains to us by 'requesting auto claim' if you are a DRG subscriber.

How do we do this?

We do this by providing a daily email containing all the information needed to claim for compensation using data from a number of third-party open data sources, and other data under licence. In addition, we perform a series of validation checks prior to presenting the data to our customers to ensure that the data is accurate and increase the quality and integrity of the data.

After a Free Trial, Users of DRG can subscribe to a DIY or DRG service plan. There is no minimum subscription term, Users pay monthly for the service and can unsubscribe or lapse at any point. The DRG plan automates the submission of the compensation claims from the Users perspective. Once the User has identified the train they were on or impacted by and selected the button to submit that claim to DRG for onwards submission to the Train Operator. The DIY plan is an information only service whereby it is the Users responsibility to submit their compensation claims directly with the Operator for those instances where they were delayed.

Through the platform, DRG assists rail passengers with the submission of claims, providing a central repository for User claim history and journeys, presents all the required delay information to submit a claim and can be used to track the process of that claim if the User so wishes to use the functionality. Most importantly, the functionality and service, facilitates User submission of claims for compensation when they have been delayed or impacted, claims which may not be submitted via the Operator forms directly due to the effort required by the User.

Delay Repay Sniper is registered at the UK Information Commissioner’s office under registration number: ZA268634 and is registered in England and Wales under Company registration number 08653481 at Nexus, Discovery Way, Leeds, LS2 3AA.

How we use your information

This privacy notice tells you how the service, Delay Repay Genie, will collect and use your personal data for population of your DRG ‘My Account’ and for onwards transmission of the delay repay claims for compensation which you have submitted and authorised DRG for onwards transmission to the Train Operator at fault. In order to submit claims for compensation as authorised by the User, DRG has to collect the Users name and contact details, and preferred method of compensation as although DRG submits the claim to the Train Operator, all communication from the Operator and ultimate compensation goes directly to the User, DRG does not receive copies or remain involved post submission of the claim.

We also make use of cookies, further information about cookies can be found here - http://www.aboutcookies.org/

Cookies are used to understand user preferences such as stations entered during the Check My Route feature as this allows us to prepopulate the stations later on in the registration process. They are also used to understand where you came to the site from so we can be informed as to the most efficient use of the marketing budget.

By using our website and agreeing to this policy and our Terms and Conditions, you consent to the use of your data and cookies in accordance with the terms of this policy.

Why does DRG need to collect and store personal data?

In order for us to provide you with a service, we need to collect personal data for population of your DRG ‘My Account’ and onwards population of the Train Operators delay repay claim web form. In any event, we are committed to ensuring that the information we collect and use is appropriate and authorised for this purpose and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes, the service, Delay Repay Genie, provides the option to unsubscribe to all forms of communication via the unsubscribe process on each and every email. Users can also set preferences for the frequency of emails they wish to receive when visiting their DRG Account.

What personal data will DRG collect and how will DRG use the personal data it collects about me?

Delay Repay Genie will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR) as provided by our Users. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Delay Repay Genie is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

• Title, first name, surname, address, postcode, email and mobile number.
• Compensation preferences which may include bank account details or PayPal details.
• Ticket details, type, cost, duration, station from and to, references and photo card ID (if applicable).
• Route Information, start and end station and days/time of travel
• Operator password if you travel on one of the Operators which requires a login prior to submission of a claim
• Where did you hear about our service

The personal data we collect will be used for the following purposes:

• Population of your DRG 'My Account'.
• For DRG subscribers the data is used for your claim submission as identified by you to the train operator you wish to claim compensation for under the Delay Repay Scheme.

It is necessary for DRG to use your personal data to deliver the service you have subscribed to under the terms and conditions as set out here. We have a legitimate interest to submit our DRG subscriber’s claims for delay repay compensation to the train operator at fault via the train operators web form. This is the core service for our DRG subscribers and to fulfil our obligations DRG will submit your data to the train operator for the sole purpose of facilitating your claim for compensation under the Delay Repay Scheme.

We do not knowingly collect or store any personal information about children under the age of 16. If you are under 16 please get your parent’s or guardian’s permission before you provide any personal information.

Under what circumstances will Delay Repay Genie Limited contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Delay Repay Genie will use your email address as a core means of communication, to notify you of delays you may have been impacted by, reminders to update information as required, and to advise you of new features and or request input into our service improvement plan. Our legitimate interest in doing so is to fulfil the contractual obligations in the provision of data and to ensure that we obtain our customers feedback to continually improve our product.

Will DRG share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Delay Repay Genie in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Delay Repay Genie procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

We may disclose your personal data to the British Transport Police or any other law enforcement agency or court to the extent necessary for purposes including preventing, investigating, detecting, and prosecuting criminal offences; preventing threats to public security in accordance with applicable law; or validating a claim.

International data transfers

Information that we collect and store may be processed in countries which do not have data protection laws equivalent to those in force in the UK and European Economic Area and you agree to the transfer of personal information as described in this policy for the purpose of submission of delay repay claims to the Train Operators. Any data transferred outside of the European Economic Area is protected by Contract Arrangements and we do our upmost to ensure that our partners have the appropriate security measures in place.

How long will DRG keep my data?

Delay Repay Genie will process personal data while the User continues to pay for the monthly subscription and will store the personal data after the User ceases to be a subscriber of the Service to facilitate customer service issues and to accommodate a User wishing to stop using the service for a period of time i.e. no longer travelling due to holiday / sabbatical / secondment but will resume use of the account in the near future.

• We will delete your preferences data after 120 days; this includes compensation method and associated data.
• We will delete your account entirely after 180 days.

Your rights

At any point while we are in possession of, or processing your personal data, you, have the following rights:

Right of access - You have the right to request a copy of the information that we hold about you.

Right of rectification - You have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten - In certain circumstances, you can ask for the data we hold about you to be erased from our records.

Right to restriction of processing - Where certain conditions apply to have a right to restrict the processing.

Right of portability - You have the right to have the data we hold about you transferred to another organisation.

Right to object - You have the right to object to certain types of processing such as direct marketing.

Right to object to automated processing, including profiling - You also have the right not to be subject to the legal effects of automated processing or profiling.

Right to judicial review - In the event that Delay Repay Genie refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

Can I find out the personal data that the organisation holds about me?

Delay Repay Genie at your request, can confirm what information we hold about you and how it is processed. If Delay Repay Genie does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Delay Repay Genie or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Delay Repay Genie accepts the following forms of ID when information on your personal data is requested:

• Passport, driving licence, birth certificate, utility bill from last 3 months.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Delay Repay Genie Limited (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Delay Repay Genie Limited’s Data Protection Officer.

The details for each of these contacts are:

• UK Information Commissioner’s office (ICO) https://ico.org.uk/concerns/ or by calling 0303 123 1113
• Delay Repay Genie DPO, Kevin Smith, Kevin.Smith@tracsis.com or by calling 01937 833933

Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for Delay Repay Genie to process personal data, but it must be explicitly given. Where we are asking you for sensitive personal data, we will always tell you why and how the information will be used.

You may withdraw consent at any time by unsubscribing to the service by a) cancelling your subscription and method of payment and/or b) using our Contact Us form.

We use a select number of trusted Third-Party providers to help us provide Services to our Users. DRG only shares information with the Third Party that is required for the service they are offering and contractually bind these providers to keep any information shared with them as confidential and to be used only for particular purposes. For example, DRG has providers that process our Subscription transactions (PayPal), support the internal ticketing/support system, and manage the marketing communications. In addition, it is necessary to share personal information with Amazon Web Services which stores the information within their servers, solely related to the storage facilities. By using DRG Users explicitly consent to and authorise us to the sub-contract in this manner.

Amendments

Delay Repay Genie may update this policy from time to time by publishing a new version on our website..