GOLDEN EAGLE PRIVACY POLICY

Purpose of this Privacy Notice

This privacy notice aims to give you information on how Golden Eagle Luxury Trains collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you purchase travel services, when you sign up to our newsletter, when you take part in a competition etc.

This website is not intended for children and the only circumstances in which we collect data relating to children, is where you make a booking of travel services and you have children in your party.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Golden Eagle Luxury Trains Direct

Golden Eagle Luxury Trains Direct (“GE Trains”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data. This privacy notice explains how we collect, use, store and share your personal data when you interact with us, including when you purchase travel services, use our website, or engage with our marketing.

This is a summary notice. You can request a full version of our Privacy Policy via Contact Us.

1. Controller and Contact Details

Golden Eagle Luxury Trains Ltd is the data controller responsible for your personal data.

Data Privacy Manager (DPM): Head of Marketing
Email: marketing@getrains.com
Address: Denzell House, Denzell Gardens, Dunham Road, Altrincham, WA14 4QF
Telephone: 0161 928 9410

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the opportunity to address your concerns first.

2. Changes to This Notice

 This notice was last updated in July 2026. We may update this notice from time to time. Historic versions are available upon request.

Please ensure that the personal data you provide remains accurate and up to date.

Third-party links

This website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The Data We Collect About You

 We may collect, use, store and transfer the following categories of personal data:

1. Identity Data

• First name, maiden name, last name
• Marital status
• Title, date of birth, gender

1. Contact Data

• Billing and delivery addresses
• Email address
• Telephone numbers
• Records of communications (emails, calls, live chat transcripts)

1. Financial Data

• Payment card details
• Bank account information (where applicable)

1. Transaction Data

• Details of bookings and travel services purchased
• Payment history

1. Technical Data

• IP address
• Browser type/version
• Time zone and general location data
• Device and system data

1. Usage Data

• Website interaction data
• Behavioural data via cookies and similar technologies

1. Marketing and Communications Data

• Your marketing preferences
• Responses to campaigns, forms, promotions

1. Profile & Engagement Data

• Information submitted through:
  • Website forms
  • Live chat
  • Pop-up forms
  • Blog subscriptions
  • Competitions or surveys
  • In person events

2. Special Categories of Personal Data

 Due to the nature of our travel services, we may process special category data, including:

• Medical conditions (where disclosed and relevant to travel arrangements)
• Dietary requirements (which may indicate religious or philosophical beliefs)
• We process this data only when:

• It is necessary to deliver your travel services, and
• You have provided explicit consent

You may withdraw your consent at any time. However, this may affect our ability to provide your booking and may result in cancellation under our Booking Conditions.

How We Collect Your Data

 We collect data through:

Direct Interactions

You provide data when you:

• Make a booking
• Contact us (phone, email, live chat)
• Subscribe to marketing or blogs
• Complete forms (including pop-ups or competitions)
• Provide feedback or images

Automated Technologies

We collect data automatically through:

• Cookies and tracking technologies
• Analytics tools
• Advertising platforms

This includes tools such as:

• Meta Ads (Facebook & Instagram)
• Website cookies (see Cookie Policy)

Third Parties

We may receive data from:

• Analytics providers (e.g. Google)
• Advertising platforms (e.g. Meta)
• Data providers or aggregators (where lawful)

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:

• Contractual necessity – to process and fulfil bookings
• Legitimate interests – to improve services, manage relationships, and grow our business
• Legal obligations – to comply with applicable laws
• Consent – for marketing communications and special category data

We do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or telephone. You have the right to withdraw consent to Marketing at any time via Contact Us.

Purposes for which we will use your personal data

Marketing

 We may use your data to send marketing via:

• Email
• Telephone
• Digital advertising (e.g. Meta platforms)

You can opt out at any time.

7. Cookies and Advertising

 We use cookies and similar technologies to:

• Improve website functionality
• Analyse performance and usage
• Personalise content and advertising

We also use Meta (Facebook & Instagram) advertising tools, which may track user interactions and enable targeted advertising.

You can manage your cookie preferences via our Cookie Policy and consent tools.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact Us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We may share your data with trusted third parties including:

• Travel providers and partners
• Payment processors
• IT and marketing service providers
• Analytics and advertising platforms

All third parties are required to:

• Process data lawfully
• Keep it secure
• Use it only for authorised purposes

Your personal data may be transferred outside the UK.

Where this occurs, we ensure appropriate safeguards, including:

• UK International Data Transfer Agreements (IDTAs)
• UK-approved Standard Contractual Clauses
• Transfers to countries deemed adequate by the UK Government

For travel bookings, transfers may be necessary to deliver services internationally.

We share your personal data within the Company. This will involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Where you have made a booking of travel services which are located or otherwise due to be fulfilled outside the EEA, we are required and are permitted to transfer your personal data to the supplier of the services that you have purchased, outside the EEA in order to:

• Make your booking and for those suppliers to be able to provide you with the travel arrangements that you have booked.

For all other transfers of data that are unrelated to the provision of travel services to you, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please Contact Us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We implement appropriate security measures to protect your personal data from:

• Unauthorised access
• Loss or misuse
• Alteration or disclosure

Access is limited to authorised personnel and partners.

We retain your personal data only as long as necessary, including:

• For legal, tax, and accounting purposes (typically 6–7 years)
• To fulfil contractual obligations

We may anonymise data for research or statistical purposes.

12. Your Legal Rights

 Under UK GDPR, you have the right to:

• Access your personal data
• Correct inaccurate data
• Request erasure
• Object to processing
• Restrict processing
• Request data portability
• Withdraw consent at any time

To exercise your rights, please contact us.

13. Fees and Response Time

 Requests are free of charge unless excessive or repetitive.
We aim to respond within one month.

LAWFUL BASIS

Legitimate Interest

means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us – Contact Us

Performance of Contract

means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation

means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Group acting as joint controllers or processors and who are based in the United Kingdom or Australia and provide IT and system administration services and undertake leadership reporting.

External Third Parties

i. Suppliers of travel services acting as processors based in Russia, Mongolia, China, Tibet, Norway, Kazakhstan, Uzbekistan, Turkmenistan, Armenia, Georgia, Azerbijan, India, Iran, Hungary, Austria, Switzerland, Germany, Italy, Slovenia, Czech Republic, Slovakia, Bosnia & Herzegovina, Serbia, Bulgaria, Romania, Greece and Turkey who provide the travel services that make up any booking of travel services that you make with us.

ii. Service providers acting as processors based in UK, Australia and United States of America who provide IT and system administration services.

iii. Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in UK who provide consultancy, banking, legal, insurance and accounting services.

iv. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

v. Other third parties including market research and development, fraud prevention agencies and price comparison sites.

YOUR LEGAL RIGHTS

You have the right to:

Request access

to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction

of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure

of your personal data. 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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing

of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right 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 override your rights and freedoms.

Request restriction of processing

of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data’s accuracy;

(b) where our use of the data is unlawful but you do not want us to erase it;

(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer

of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.