Privacy policy
https://BeyondTheTracks200.co.uk (our website) is provided by Railpen Limited, a company incorporated in England and Wales and registration number 02315380, whose registered address is at 7 Devonshire Square, London, United Kingdom, EC2M 4YH (‘we’, ‘our’ or ‘us’).
We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
Data Protection Legislation
We collect, use, and are responsible for certain personal data about you. The collection and use of your personal data is subject to various laws, including the Data Protection Act 2018, the retained EU version of the General Data Protection Regulation (UK GDPR) and the Data (Use and Access) Act 2025.
Children personal data
Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.
What this policy applies to
This privacy policy relates to your use of our website only.
Throughout our website we may link to other websites owned and operated by certain trusted third parties to provide more information about the railway and/or pensions industry. Those third party websites may also gather information about you in accordance with their own separate privacy policies.
For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We may collect and use the following personal data about you:
- your full name, and contact information, including email address, and company details (including company name and job title);
- details of any information, feedback or other matters you give to us when you contact us via the contact page on our website, or otherwise by phone, email, post or via social media;
- if applicable, your account details, such as username and login details; and
- if applicable, your activities on, and use of, our website.
How your personal data is collected
We collect personal data from you:
- directly, when you enter or send us information, such as when you complete our contact form available on our website or otherwise engage in our projects or services directly by contacting us or participate in surveys via our website; and
- indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies’ below.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
Providing information about our services, campaigns, and projects that you may be interested in. | For our legitimate interests in promoting our services, campaigns, and projects, and engaging with individuals who wish to discuss any of our services, campaigns, or projects, provided these interests are not overridden by your rights under data protection legislation. |
Enforcing legal rights or defend or undertake legal proceedings. | Depending on the circumstances:
|
Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website; and Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended | Depending on the circumstances:
If you have provided consent, you may withdraw it at any time by modifying your cookie settings through the ‘Consent Preferences’ link which can be found in our Cookies Policy: or by contacting us using the details provided within the ‘Contact us’ section below. Please note, this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn). |
Communications with you not related to marketing, including about changes to our terms or policies or changes to our website, campaigns, projects, or other important notices. | Depending on the circumstances:
|
Protecting the security of systems and data used to provide the services. | To comply with our legal and regulatory obligations. |
Updating and enhancing records. | Depending on the circumstances:
|
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business. | To comply with our legal and regulatory obligations. |
Marketing our services to existing and former customers | For our legitimate interests, i.e. to promote our campaigns, and projects, to our members or individuals and entities who wish to engage or contribute to such. See ‘Marketing’ below for further information |
To deal with any legal claims including litigation or investigating any complaint made about our use of personal data. | For our legitimate interests, i.e. to deal with complaints, legal claims, and litigation (and to comply with our legal and regulatory obligations). |
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction. In such cases information will be anonymised where possible and only shared where necessary. | Depending on the circumstances:
|
Special category personal data
We will not collect any personal that is treated as a special category to which additional protections apply under data protection law.
Marketing
We may use your personal data to send you updates (by email, telephone, or post) about our services, campaigns, and projects relating to the railway and/or pension industry or any of our investments.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by contacting us using the details contained within the ‘Contact us’ section below.
We may ask you to confirm or update your marketing preferences if you ask us to contribute or engage with you in further campaigns and projects in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell share it with other organisations outside of the Railpen group for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with third parties we use to help deliver our services, campaigns, and projects, e.g. information technology providers such as Microsoft, as well as website hosts and analytical providers who are strictly involved in enabling us to provide our website.
We do not share personal data with any third party other than those that are required to provide our website and we shall not share your personal data with any organisation unless such sharing is required for Railpen to comply with its legal and regulatory obligations.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Cookies
A cookie is a small text file which is placed onto your device (e.g., computer, smartphone, or other electronic device) when you use our website. We use cookies on our website, and they help us recognise you and your device and store some information about your preferences, past actions or choices.
For example, we may use cookies to make our website work as you’d expect. They also help us to:
- continually improve our website;
- improve speed and security of our website;
- analyse data about website traffic; and
- tailor our website to meet your needs.
We don’t use cookies to:
- collect any sensitive information; or
- send personally identifiable data to third parties.
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested. You can withdraw any consent to the use of cookies or manage any other cookie preferences at any time.
For further information on our use of cookies also see our Cookie Policy
Your rights
You generally have the following rights, which you can usually exercise free of charge:
- Access to a copy of your personal data: the right to be provided with a copy of your personal data.
- Correction (also known as rectification): the right to require us to correct any mistakes in your personal data
- Erasure (also known as the right to be forgotten): the right to require us to delete your personal data in certain situations
- Restriction of use: the right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
- Data portability: the right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations
- To object to use: the right to object at any time to your personal data being used for direct marketing (including profiling) and in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
- Not to be subject to decisions without human involvement: the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website
- The right to withdraw consents: if you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by emailing dataprotectionteam@railpen.com. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
If you would like to exercise any of those rights, please contact us (see below: ‘How to contact us’).
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner. They may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
We may change this privacy policy from time to time when we make significant changes we will take steps to inform you.
How to contact us
You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact email address is: dataprotectionteam@railpen.com.
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).
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