1 - Preamble
The protection of your Personal Data is an important issue that RAIL LOGISTICS EUROPE takes seriously and on which the company wishes to establish the greatest transparency. This privacy policy (hereinafter the “Policy”) is therefore intended to keep individuals informed about the processing of data concerning them.
This Policy explains how your Personal Data is processed within the framework of the operation of the RAIL LOGISTICS EUROPE website (the “Site”), as well as the rights that users consulting the Site (the “User”) have with regard to their processed Personal Data.
We would also like to inform you that RAIL LOGISTICS EUROPE has appointed a Personal Data Protection Officer (DPO) whom you can contact to ask any questions you may have regarding the protection of your Personal Data at the following address: dpo-rle@sncf.fr
1 - Definitions
Here are the various terms relating to Data Protection that you will find in this Policy. You may also refer to Article 4 of the General Data Protection Regulation (GDPR) for more details.
“Personal Data”: refers to all information relating to a Data Subject, which makes it possible to identify him or her directly or indirectly by cross-referencing them. Surname, first name, identifier, telephone number, address, etc. may all constitute Personal Data.
“Data Subject”: refers to an individual who is the subject of Personal Data processing.
“Data Controller”: refers to the natural or legal person who determines the purposes and means of the Processing of Personal Data. The Data Controller concerned by this Policy is RAIL LOGISTICS EUROPE, a legal entity, a logistics and rail transport company.
“Subcontractor”: refers to the person who processes Personal Data under the authority, on the instructions and on behalf of the Data Controller. « Autorité de contrôle » : désigne l’autorité publique indépendante chargée de surveiller l’application du RGPD, en France l’Autorité de contrôle est la Commission Nationale Informatique et Libertés (CNIL).
“Processing”: refers to any operation or set of operations involving Personal Data carried out by the Data Controller. This may include, in particular, collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, as well as limitation, erasure or destruction.
“Consent”: means any free, specific, informed and unambiguous expression of will by which the Data Subject accepts, by a declaration or by a clear positive act, that Personal Data concerning him or her may be Processed. For example, the expression of choices by ticking boxes on a form or “on / off” buttons in a dialogue window displayed by the Site constitute Consent.
“Cookies”: refers to a text file or other trace deposited on a terminal when visiting the Site. A Cookie may be used to collect information relating to Data Subjects who consult the Site and to send them personalized services and content.
“Applicable Regulations”: with regard to the protection of Personal Data, it refers to European Regulation N°2016/679 of April 27, 2016 (the “RGPD”) and the French Data Protection Act N°78-17 of January 6, 1978 as amended.
Data processing and purposes of processing
A. Type of data collected
As Data Controller, RAIL LOGISTICS EUROPE is required to process Personal Data such as :
Name, first name, e-mail address and IP address of the user.
The data processed is adequate and relevant to the purposes pursued, and its collection is limited to what is strictly necessary.
B. Purposes of processing
RAIL LOGISTICS EUROPE processes Personal Data in order to manage applications and contact requests submitted on the site.
- Contact request
The User may contact RAIL LOGISTICS EUROPE directly from the Site to submit any request or commercial proposal. To do so, the User must fill in a form with his/her surname, first name, e-mail address and company. This data may be used to facilitate contact and for marketing analysis purposes.
Personal data may therefore be collected and processed as part of these operations.
2 - Legal basis for processing
The Data Processing carried out as part of the operation of the Site is based on the User's Consent, obtained directly when requesting contact via the dedicated form.
3 - Data recipients
Data collected on the Site is processed solely by our assigned and competent employees. It is not passed on to any third parties other than our subcontractors.
Furthermore, we only transmit to our Subcontractors the Data they need to perform the services for which they intervene, and we require that they do not use it for any other purpose.
4 - Shelf life
Data collected in connection with the management of contact requests is kept for a period of 2 years to give our teams time to process and study these requests in the best possible conditions.
5 - Hosting and transfers outside the european unionovh
2 Rue Kellermann, 59100 Roubaix
The data collected and processed by the RAIL LOGISTICS EUROPE Site is, as a matter of principle, exclusively hosted and processed in France, and is not transferred outside the European Union.
Otherwise, such transfers of Personal Data must be supported by an adequacy decision issued by the European Commission, Standard Contractual Clauses (SCC) or Binding Internal Company Rules validated by the competent supervisory authorities.
6 - Data security and user information
RAIL LOGISTICS EUROPE undertakes to protect the Personal Data collected. Furthermore, RAIL LOGISTICS EUROPE will notify the User in the event of rectification or deletion of data. In the event that the integrity, confidentiality or security of the User's Personal Data is compromised, RAIL LOGISTICS EUROPE undertakes to inform the User by any means.
RAIL LOGISTICS EUROPE keeps all data collected in the site's computer systems under reasonable security conditions.
7 - Users' rights to their personal data
In accordance with the applicable Regulations, the User has the rights listed below:
To request RAIL LOGISTICS EUROPE to access, rectify or delete Data, or to restrict the processing of Data relating to the Data Subject;
Object to the processing of his/her Personal Data;
He/she also has the right to the portability of his/her Data in a structured and usable format; To withdraw his/her consent at any time, without prejudice to the lawfulness of the processing based on the consent carried out prior to the withdrawal thereof, this right existing exclusively when the processing is based on Article 6 of the RGPD, i.e. on the consent of the Data Subject to the processing of his/her Personal Data for one or more specific purposes.
You can exercise your rights by email by sending a request to: dpo-rle@sncf.fr
If you become aware of a breach in the protection of Personal Data, you may also lodge a complaint with the competent supervisory authority, in France the CNIL.: www.cnil.fr
8 - Cookie-free tracking solution
For analytical tracking purposes and to ensure the proper functioning of the Site, RAIL LOGISTICS EUROPE uses Matomo Analytics on the Site. This is an alternative tracking solution without cookies that uses methods such as counting the number of unique IP addresses or browser fingerprinting to identify users instead of cookies. This solution uses config_id to group different actions into “visits” over a short period of up to 24 hours.
This solution is privacy-friendly, not relying on personal data collection, and enables the Site to comply with the RGPD without using a consent banner.
9 - Modification de la présente politique de confidentialité
Nous pouvons être amenés à modifier la présente Politique, afin notamment de nous conformer à toute évolution de la Réglementation Applicable, ou en cas de changement technique relatif au Site. Le cas échéant, nous changerons la date de dernière modification présente ci-dessous pour plus de lisibilité.
Date de dernière modification de la Politique : 15/03/24
Pour toute information complémentaire, n’hésitez pas à contacter le DPO de RAIL LOGISTICS EUROPE à l’adresse : dpo-rle@sncf.fr