TMR Transports de Martigny et Régions SA, whose registered office is at Avenue de la Gare 66, 1920 Martigny (hereinafter: « TMR » or « we »), provides services (hereinafter: « Service(s) ») in the field of public transport, in particular by rail and by bus, as well as in the field of private transport (notably coach travel). TMR also operates a travel agency and offers the usual services, in particular by providing tailor-made travel offers to its customers.
Thus, in order to carry out the services described above, we provide various information on our websites: https://www.tmrsa.ch/ ; https://tmr-voyages.ch/, https://www.mont-blanc-express.ch/ (hereinafter: our « Site(s) »).
In order to be able to provide and develop our Services, as well as to provide content on our Sites, we collect, use and communicate a certain amount of personal data concerning you. When we refer to personal data, we mean personal data within the meaning of the Federal Act on Data Protection (FADP), as well as other data protection legislation where applicable, in particular the EU General Data Protection Regulation (GDPR). This is all the information that allows us to identify you immediately or in combination with other information. In this respect, we are the controller of the personal data processing mentioned in the context of this privacy policy.
This privacy policy (hereinafter: the « Policy ») sets out the conditions under which we process data concerning you, as well as the choices available to you regarding the collection, use and communication of this personal data.
By using our Services and/or accessing the Sites, you acknowledge that you have read, understood and accepted that you are subject to all the conditions set out in this Policy.
1. When you use our Services
1.1. Personal data that may be processed
When you use our Services, you may be asked to provide us with a certain amount of personal data concerning you, such as your personal contact details (for example surname, first name, address, telephone number, email address, etc.) and data relating to your journeys and travel, in particular by train.
You may also freely provide us with additional data, in particular when you contact us or request a Service or make any other request.
1.2. Purpose of using the personal data
We use your personal data in order to be able to fulfil our contractual obligations towards you, that is to say to provide and improve our Services, to interact with you and to respond to your requests.
We may also use your personal data to pursue our legitimate interests, which includes the detection of fraud, the recovery of debts, as well as the examination of any complaints we may receive, from you or from third parties. We use your personal data in order to fulfil our legal obligations, such as the retention of accounting documents or responding to requests from authorities.
1.3. Marketing / Newsletters
We may use your personal data to send you information about our Services, in particular if you subscribe to one of our marketing campaigns or to one of our newsletters. Your consent is requested if the applicable law provides for it, and you can always object to communications for marketing purposes.
In this case, the legal basis for the processing is the pursuit of our legitimate interest in informing you and developing our services, or, if the applicable law requires it, your consent.
1.4. Video surveillance
Video surveillance systems are installed by us in the context of our activities as an infrastructure manager and passenger transport operator. Station platforms, access to trains and level crossings may thus be subject to video surveillance.
The purpose of our video surveillance systems is to protect travellers, our employees and the operation of our infrastructure. Their installation is intended in particular to protect people from assaults and incivilities, to ensure the security of property and to prevent damage to property.
2. When you browse our site
When you browse our Sites and interact with them, automated data collection technologies are used in order to gather certain personal data concerning 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, the length of visits to certain pages, the type of browser used or the connection location). This information is captured by means of automated technologies such as cookies.
2.1. Cookies and web beacons
2.1.1. Personal data that may be processed
Cookies take the form of text files capable of identifying visitors and saving their personal preferences (e.g. their language choice) as well as technical information (including click-type and journey-type data).
Web beacons, or clear GIFs, are very small transparent images (1 pixel by 1 pixel) embedded in a website. They make it possible to collect information about the activity of the site’s visitors, for example the operating system used, the browser used, the IP address or the time spent on the site.
The cookies we use may be classified into the following categories:
- Strictly necessary cookies: essential for the proper functioning of the site (e.g. WordPress).
- Analytics cookies: allow user behaviour to be analysed and the experience to be optimised (e.g. Google Analytics, WooCommerce/Jetpack).
- Functional cookies: record your preferences for smoother browsing (e.g. language).
- Targeting and advertising cookies: used for personalised advertising and campaign tracking (e.g. Google Ads, Facebook Pixel).
2.1.2. Purpose of using the personal data
We use cookies and web beacons to provide our Services, facilitate access to the Sites, understand how you browse our sites and identify malfunctions of the Site. This also allows us to improve your experience as well as the design and content of the Sites.
In this case, the legal basis for the processing is the pursuit of our legitimate interest in improving your experience on our website and getting to know you better.
2.1.3. Collaboration with third-party companies
For the operation of 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 then subject to their own personal data processing conditions and is not covered by the Policy.
We use in particular:
- Google Analytics: for the analysis of the audience and user behaviour.
- 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 anonymised as far as possible. You can, however, set your preferences via our Cookie Management Centre.
2.1.4. Disabling cookies
The use of cookies can be disabled by selecting the appropriate settings within the browser used. However, such disabling could prevent the use of certain features of our Sites. For more information on cookies: allaboutcookies.org/fr and youronlinechoices.com/fr.
Depending on the browser used, disabling Google Analytics is also possible by installing an add-on or by consulting these instructions. You also have the option of viewing the use of your personal data when using Google Analytics.
You can also at any time change or withdraw your consent for non-essential cookies by clicking on this link. (to be inserted once the policy has been validated)
2.2. Third-party social networks
When you authorise 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 forming part of your profile. This may include the basic data relating to your account (e.g. first name, surname, email address, gender, birthday, city of residence, profile picture, user ID, etc.) and any other data or activity that you authorise the third-party social network to share. These social networks are governed by their own terms of use and privacy policies, which we invite you to read.
3. Communication of personal data
3.1. Sub-processing
For the performance of our services, we may use external service providers acting as sub-processors, in particular for the management of customer files, external service providers for the reservation of tickets and other transport documents, 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. Furthermore, we call on service providers to manage and/or maintain the Site and analyse traffic on our Sites. Personal data is only communicated to them within the limit necessary for the completion of the tasks entrusted to them.
3.2. Communication to third parties
We may transmit your personal data to third parties (i) if this is necessary for the pursuit of the purposes for which you freely transmitted them to us, (ii) if you have previously consented to it, or (iii) if the law permits or obliges us to do so (e.g. at the request of a judicial authority, to assert our rights in court or to proceed with the recovery of a debt with the help of a debt collection service). In addition, we call on an external service provider for everything relating to the tasks assigned to a legal department, in particular when you make a claim. Within the limits imposed by the applicable legislation, your data may be communicated to it.
3.3. Transfers abroad
The personal data is processed in Switzerland as well as in the following countries: Ireland, Germany, United States.
Should we need 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 adopt the additional measures required by law before any communication of your data abroad.
4. Security and retention periods
Security measures (of a technical and organisational nature) in accordance with the state of the art have been put in place, taking into account the risks incurred, to protect your personal data against any accidental or intentional manipulation, loss, destruction, communication or against any unauthorised access.
Personal data is retained for as long as necessary in view of the purposes of the processing and in accordance with the FADP.
Personal data may be retained longer where there is a legal obligation to retain the data.
a. Strictly necessary cookies
| Cookie | Purpose / Duration |
|---|---|
| PHPSESSID (web server) | Manages user sessions by storing a unique identifier. Duration: expires when the browser is closed. |
| wordpress_logged_in_ (WordPress) | Indicates whether a user is logged in in order to personalise the features. Duration: expires at the end of the session. |
| wordpress_test_cookie (WordPress) | Tests whether cookies are enabled in the user’s browser. Duration: expires at the end of the session. |
| wp_lang (WordPress) | Sets the language used for the pages displayed. Duration: expires when the browser is closed. |
b. Analytics cookies
| Cookie | Purpose / Duration |
|---|---|
| _ga (Google Analytics) | Identifies users anonymously in order to analyse their behaviour on the site. Duration: 2 years. |
| _ga (e.g. _ga_3X9ZB9H9ZR, _ga_NLC232H59F) | Variant of _ga, used to distinguish the sessions of different sites or users. Duration: 2 years. |
| _gid (Google Analytics) | Records a unique identifier in order to analyse users’ sessions and interactions. Duration: 24 hours. |
| _gat_gtag (e.g. _gat_gtag_UA_57284225_1, _gat_gtag_UA_2873245_65) | Limits the request rate in order to improve the site’s performance. Duration: 1 minute. |
| tk_ai (WooCommerce/Jetpack) | Internal tracking to analyse behaviours on WooCommerce (e-commerce). Duration: expires when the browser is closed. |
c. Functional cookies
| Cookie | Purpose / Duration |
|---|---|
| pll_language (WordPress plugin) | Remembers the language selected by the user for future visits. Duration: 1 year. |
d. Targeting and advertising cookies
| Cookie | Purpose / Duration |
|---|---|
| _gcl_au (Google Ads) | Measures the effectiveness of Google Ads advertising and understands how users interact with the site after a click. Duration: 90 days. |
| _fbp (Facebook Pixel) | Tracks users’ conversions after a click on a Facebook advertisement and enables retargeting. Duration: 90 days. |
5. Rights
You have the right to be informed free of charge about the personal data stored about you and, where this appears to be inaccurate or incomplete, the right to have it rectified or deleted. You also have a right to object to the processing of personal data concerning you, subject to grounds justifying the processing.
If you reside in an EEA State, you have the right, where the GDPR applies, to lodge a complaint with a supervisory authority, in particular in the Member State in which your habitual residence, your place of work or the place where the breach is alleged to have been committed is located.
6. Updating 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, where applicable, be informed by email of the new Policy. The new Policy will also be available on our Sites.
Using our Services after a change to the Policy constitutes explicit acceptance of the changes, as does the continued use of our Sites.
7. Contact
For any question or request relating to this Policy or to the processing of personal data that we carry out, you can contact us in writing by post at the following address:
Transports Martigny et Régions SA
Avenue de la Gare 66, 1920 Martigny
Email: info@tmrsa.ch
Telephone: +41 (0)27 721 68 40