1. When you use our Services

When you use our Services, you may be asked to provide us with certain personal data about yourself, such as your personal contact details (e.g., last name, first name, address, telephone number, email address, etc.) and data relating to your journeys and travel, particularly by train.

You are also free to provide us with additional data, particularly when you contact us or request a Service or make any kind of request.

We use your personal data to fulfill our contractual obligations to you, i.e., to provide and improve our Services, interact with you, and respond to your requests.

We may also use your personal data to pursue our legitimate interests, which include fraud detection, debt collection, and investigating any complaints we may receive from you or third parties. We use your personal data to comply with our legal obligations, such as retaining accounting records or responding to requests from authorities.

We may use your personal data to send you information about our Services, particularly if you subscribe to one of our marketing campaigns or newsletters. Your consent is requested if required by applicable law, and you may always opt out of marketing communications.

In this case, the legal basis for processing is our legitimate interest in informing you and developing our services, or, if required by applicable law, your consent.

We install video surveillance systems as part of our infrastructure management and passenger transport activities. Station platforms, train access points, and level crossings may therefore be subject to video surveillance.

Our video surveillance systems are designed to protect passengers, our employees, and the operation of our infrastructure. They are installed in particular to protect people from assault and incivility, to ensure the safety of property, and to prevent damage to property.

2. When you browse our website

When you browse and interact with our Sites, automated data collection technologies are used to collect certain personal data about you in order to understand your actions (e.g. which links were clicked, which pages were viewed), as well as other similar data and statistics (e.g., content response times, download errors, length of visits to certain pages, type of browser used, or location of connection). This information is captured using automated technologies such as cookies.

2.1. Cookies and web beacons

Cookies are text files that can identify visitors and save their personal preferences (e.g., language selection) as well as technical information (including click and navigation data).

Web beacons, or clear GIFs, are very small transparent images (1 pixel by 1 pixel) embedded in a website. They collect information about the activity of visitors to the site, such as the operating system used, the browser used, the IP address, and the time spent on the site.

The cookies we use can be classified into the following categories:

• Strictly necessary cookies: essential for the proper functioning of the site (e.g., WordPress).
• Analytical cookies: allow us to analyze user behavior and optimize the experience (e.g., Google Analytics, WooCommerce/Jetpack).
• Functional cookies: record your preferences for smoother navigation (e.g., language).
• Targeting and advertising cookies: used for personalized advertising and campaign tracking (e.g., Google Ads, Facebook Pixel).

We use cookies and web beacons to provide our Services, facilitate access to the Sites, understand how you navigate our sites, and identify Site malfunctions. This also allows us to improve your experience and the design and content of the Sites.

In this case, the legal basis for processing is the pursuit of our legitimate interest in improving your experience on our website and getting to know you better.

In order to operate our Sites, we may collaborate with third-party companies that place cookies or web beacons on the Sites. These companies help us manage the Sites and offer additional products and services. The use of these technologies by these third parties is subject to their own terms and conditions for the processing of personal data and is not covered by this Policy.

In particular, we use:
• Google Analytics: for audience analysis and user behavior.
• Google Ads and Facebook Pixel: for targeted advertising and remarketing.

The use of these technologies by these third parties is governed by their own privacy policies. The information collected by these partners is anonymized as far as possible. However, you can set your preferences via our Cookie Management Center.

The use of cookies can be disabled by selecting the appropriate settings in your browser. However, such deactivation may prevent the use of certain features of our Sites. For more information about cookies: allaboutcookies.org and youronlinechoices.com

Depending on the browser used, Google Analytics can also be disabled by installing an add-on or following these instructions. You can also view how your personal data is used when Google Analytics is used.

You can also change or withdraw your consent for non-essential cookies at any time by clicking on this link. (to be inserted once the policy has been validated)

When you authorize a third-party social network (such as Facebook, Instagram, LinkedIn, YouTube, etc.) to share with our accounts, we may receive any data that you share publicly on that social network and the data that is part of your profile. This may include basic data relating to your account (e.g., first name, last name, email address, gender, birthday, city of residence, profile photo, user ID, etc.) and any other data or activity that you authorize the third-party social network to share. These social networks are governed by their own terms of use and privacy policies, which we encourage you to read.

3. Disclosure of personal data

In order to provide our services, we may use external service providers
acting as subcontractors, in particular for the management of customer files,
external service providers for ticket and other transport reservations, as well as for
the operation of our vehicles. In this context, data may be communicated to them within the
limits of what is necessary.

In addition, we use service providers to manage and/or maintain the Site and analyze traffic
on our Sites. Personal data is only communicated to them to the extent necessary for the
performance of the tasks entrusted to them.

We may disclose your personal data to third parties (i) if this is necessary to achieve the purposes for which you have freely provided it to us, (ii) if you have given your prior consent, or (iii) if we are permitted or required to do so by law (e.g. at the request of a judicial authority, to assert our rights in court, or to collect a debt with the help of a collection agency). In addition, we use an external service provider for all matters relating to legal services, particularly when you file a complaint. Within the limits imposed by applicable law, your data may be disclosed to this service provider.

Personal data is processed in Switzerland and in the following countries: Ireland, Germany, and the United States.

If we were to use a foreign service provider located in a country that does not have an adequate level of data protection according to the competent data protection authorities, we would take the additional measures required by law before transferring your data abroad.

4. Safety and shelf life

Security measures (both technical and organizational) in line with best practices have been put in place, taking into account the risks involved, to protect your personal data against accidental or intentional manipulation, loss, destruction, disclosure, or unauthorized access.

Personal data is retained for as long as necessary for the purposes of processing and in accordance with the LPD.

Personal data may be stored for longer periods where there is a legal obligation to retain the data.

5. Rights

You have the right to obtain information free of charge about the personal data stored about you and, if this data appears to be inaccurate or incomplete, the right to have it corrected or deleted. You also have the right to object to the processing of your personal data, subject to grounds justifying the processing.

If you reside in an EEA country, you have the right, where the GDPR applies, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place where the alleged infringement occurred.

6. Update to our Policy

We may update this Policy from time to time.

We will seek to draw your attention to any significant changes. If you have provided us with your email address, you will be notified of the new Policy by email, where applicable. The new Policy will also be available on our Sites.

Use of our Services after a change to the Policy constitutes explicit acceptance of the changes, as does continued use of our Sites.

7. Contact

If you have any questions or requests regarding this Policy or our processing of personal data, you can contact us by writing to us at the following address:

Transports Martigny et Régions SA
Avenue de la Gare 66, 1920 Martigny
Email: info@tmrsa.ch
Phone: +41 (0)27 721 68 40