---

Data Privacy Statement

Thank you for visiting our Website. Data protection is of particular importance for the us and we take the protection of your personal data very seriously. However, if a person wishes to use our company"s special services through our website, personal data processing may be required.

Through this Privacy Policy Alpha Trains seeks to inform you of the nature, scope and purpose of the personal information we collect, use and process. Furthermore we inform you as the data subject of your rights.

Alpha Trains, as controller, has implemented numerous technical and organizational measures to ensure sufficient protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can generally have security holes, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to submit personal data to us in alternative ways, for example by telephone.

1. Definition of Terms

This Privacy Statement is based on the terms used in the EU General Data Protection Regulation (GDPR) or other national Data Protection regulation. It should be easy to read and understand both for the public and for our customers and business partners. To ensure this, we would first like to explain the terms used.

We use the following terms, among others, in this Privacy Statement:

a) Personal Data

Personal Data is all information relating to an identified or identifiable natural person (hereinafter “Data Subject”). A natural person is deemed identifiable if he or she can be identified directly or indirectly, in particular by assignment to an identifier such as a name, an identification number, location data, an online identifier or one or more particular characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.

b) Data subject

The Data Subject is any identified or identifiable natural person whose personal data is processed by the Controller.

c) Processing

Processing means any operation or series of operations carried out with or without the aid of automated procedures in relation to personal data, such as the collection, recording, organisation, sorting, storage, adaptation or alteration, reading, retrieval, use, disclosure by transfer, dissemination or any other form of provision, comparison or linking, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of restricting their future processing.

e) Profiling

Profiling is any form of automated processing of personal data involving the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, behaviour, location or relocation of that natural person.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not assigned to an identified or identifiable natural person.

g) Controller

The Controller is the natural or legal person, public authority, institution or other body which alone or jointly with others decides on the purposes and means of the processing of personal data. Where the purposes and means of such processing are laid down by Union or Member State law, the Controller or certain criteria of his appointment may be designated according to Union or Member State law.

h) Processor

A Processor is a natural or legal person, authority, institution or other body that processes personal data on behalf of the Controller.

i) Recipient

A Recipient is a natural or legal person, authority, institution or other body to which personal data are disclosed, regardless of whether the recipient is a third party or not. However, authorities that receive personal data under Union or Member State law within the framework of a particular investigation are not regarded as recipients.

j) Third party

A Third Party is a natural or legal person, authority, institution or other body other than the Data Subject, the Controller, the processor and the persons authorised to process personal data under the direct responsibility of the Controller or the processor.

k) Consent

Consent means any informed and unambiguous expression of will voluntarily given by the data subject in the particular case in the form of a declaration or other clear, affirmative act by which the data subject indicates that he agrees to the processing of his personal data.

2. Controller

The Controller as defined by the General Data Protection Regulation, other data protection laws in force in the Member States of the European Union and other provisions of a data protection nature is:

Alpha Trains Group S.à r.l.
48, rue de Bragance, 1255 Luxembourg
Luxembourg
E-Mail: info@alphatrains.eu
Website: www.alphatrains.eu

3. Contact for data protection issues

You can contact us at any time with any questions or suggestions regarding data protection under datenschutz@alphatrains.eu

4. Log files

The Alpha Trains website collects a set of general data and information each time the website is accessed by a Data Subject or an automated system. This general data and information is stored in the log files of the server and comprises:

• browser types and versions used,
• the operating system used by the accessing system,
• the internet page from which an accessing system accesses our website (so-called referrers),
• the sub-web pages which can be accessed via
• the date and time of access to the website,
• an Internet Protocol address (IP address),
• the Internet service provider of the accessing system and
• other similar data and information used in the event of attacks on our information technology systems can be recorded.

When using this general data and information, Alpha Trains does not draw any conclusions about the Data Subject. Rather, this information is required to

• correctly deliver the contents of our website,
• optimize the content of our website and to advertise it,
• ensure the continued functioning of our information technology systems and the technology of our website, and
• provide law enforcement authorities with the information necessary for law enforcement in the event of a cyberattack.

Alpha Trains evaluates this anonymously gathered data and information on the one hand statistically and further with the aim to increase the data protection and data security within our company, in order to ensure an optimal protection level for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by an data subject.

You can find information about your data subject rights in section 14.

5. Contact

Due to legal regulations, our website contains information that allows you to contact our company quickly and electronically through sending an email to one of our e-mail addresses. Where a data subject contacts the controller via e-mail, the personal data transferred by the data subject will be stored automatically. Such personal data provided voluntarily by a data subject to the controller will be stored for the purpose of processing the data subject’s request and contacting the data subject. These personal data are not passed on to third parties. For general inquiries the legal basis for processing data is art. 6 sec. 1 f) GDPR, for inquiries concerning contracts or job-applications the processing is based on art. 6 sec. 1 b) GDPR. The controller will only process and store the personal data of the data subject for the time necessary to achieve the purpose of the data storage or to extent required by the European body issuing directives or regulations or other legislator to which the controller is subject.

You can find information about your data subject rights in section 14.

6. Registration (Investors Portal)

You can register for the investors portal on our website by filling in our registration mask with the following data:

• Name of the company
• Salutation
• Name
• Email-Address

After completion of the registration you transmit these data to us. The registration confirmation is sent to you by e-mail and contains a link for verification. When clicking on the link you will be finally registered on our investors portal.

The legal basis of the processing is Art. 6 para. 1 lit. b) DSGVO, since registration data must be processed in order to give you access to the investors portal. It is also based on Art. 6 sec. 1 f) GDPR as we have a legitimate interest in processing your data for register you for our investors portal.

The data will be stored for as long as necessary to achieve the purpose for which they were collected. This is usually the case as long as you are registered in our investors portal. We would like to point out that we may be legally obliged to comply with longer retention obligations.

You can find information about your data subject rights in section 14.

7. Login (Investors Portal)

You can log in to our website with your email address and password if you have previously registered. We need the data to authenticate you successfully.

The legal ground for processing your data is Art. 6 Para. 1 b) GDPR, since the successful registration entitles you to log into the portal. It is also based on Art. 6 sec. 1 f) GDPR as we have a legitimate interest in processing your data for letting you log in to our website.

The data will be stored for as long as necessary to achieve the purpose for which it was collected. This is basically given for the duration for which you are registered with us. We would like to point out that we may be legally obliged to comply with longer retention obligations.

You can find information about your data subject rights in section 14.

8. Forgotten your password (Investors Portal)

If you have forgotten your portal password, you can request a new one by sending us an information through the certain mask. For authentication reasons, you must enter your e-mail address so that we can send the new password to you.

The processing of your data is based on Art. 6 sec. 1 b) GDPR, as you have a contractual right to access our portal. It is further based on Art. 6 sec. 1 f) GDPR as we have a legitimate interest in providing you with access to our investors portal

The data will be stored for as long as necessary to achieve the purpose for which they were collected. This is basically for the duration for which you are registered with us.

You can find information about your data subject rights in section 14.

9. Cookies

The website uses so-called cookies. Cookies do not cause any damage to your computer and do not contain any viruses. Cookies serve to make our website more user-friendly, effective and secure. Cookies are small text files which are placed on a computer system via an Internet browser and stored by the browser. 

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which websites and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the visited websites and servers to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A particular Internet browser can be recognised and identified by its unique cookie ID.

For further information what Cookies we use, please see the sections below.

The Controller has integrated on its website the component Google Analytics (with anonymization function). Google Analytics is a web analytics service. Web analysis is the raising, collection and analysis of data about the behavior of visitors to websites. Among other things, a web analysis service collects data on which website an affected person has come to a website (so-called referrers), which subpages of the website were accessed or how often and for which length of stay a subpage was viewed. A web analysis is mainly used to optimize a website and cost-benefit analysis of Internet advertising.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, USA.

The Controller uses the addition "_gat._anonymizeIp" for web analytics via Google Analytics. By means of this addendum, the IP address of the Internet access of the data subject will be shortened and anonymised by Google if the access to our website is from a Member State of the European Union or from another state party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze visitor flows on our website. Among other things, Google uses the data and information obtained to evaluate the use of our website, to compile for us online reports showing the activities on our websites, and to provide other services related to the use of our website.

Google Analytics uses a cookie on the information technology system of the data subject. What cookies are, has already been explained above. By using this cookie Google is enabled to analyze the usage of our website. Each time one of the pages of this website is accessed by the Controller and a Google Analytics component has been integrated, the Internet browser on the information technology system of the data subject is automatically initiated by the respective Google Analytics component to submit data to Google for online analysis purposes. As part of this technical process, Google will be aware of personal data, such as the IP address of the data subject, which serve, among other things, Google to track the origin of the visitors and clicks, and subsequently make commission settlements possible.

The cookie stores personally identifiable information, such as access time, the location from which access was made, and the frequency of site visits by the data subject. Each time you visit our website, your personal information, including the IP address of the Internet connection used by the data subject, is transferred to Google in the United States of America. This personal information is stored by Google in the United States of America. Google may transfer such personal data collected through the technical process to third parties:

• Information on location (country, city, language, etc.)
• IP-address of used terminal device (anonymised)
• Information on terminal device and output resolution of computers (PC, tablet, smartphone, etc.)
• Information on browser and used Add-ons (Chrome, Edge, Safari, etc.)
• Information on operating system (Windows, MAC OS, Android, etc.)
• Source of visitors (search engines, Social Media or referring website)
• URLs of visited websites
• URLs of previously accessed pages (Referrer URL)
• Name of accessed data (downloads, videos, etc.)
• Data volume transferred of all accessed pages and data
• Status of site call (successful / not successful)
• Length of stay of visited websites and of total visit
• Date and time of visit and of accessed site pages

The data subject can prevent the setting of cookies through our website, as shown above, at any time by means of a corresponding setting of the Internet browser used and thus permanently contradict the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the option of objecting to and preventing the collection of the data generated by Google Analytics for the use of this website and the processing of this data by Google. To do this, the person must download and install a browser add-on at https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as a contradiction. If the data subject´s information technology system is later deleted, formatted or reinstalled, the data subject must re-install the browser add-on to disable Google Analytics. If the browser add-on is uninstalled or disabled by the data subject or any other person within their sphere of control, it is possible to reinstall or reactivate the browser add-on.

Additional information and Google´s privacy policy can be found at
https://www.google.com/intl/en/policies/privacy/ and https://www.google.com/analytics/terms/gb.html

Google Analytics is explained in more detail at
https://www.google.com/intl/de_de/analytics/

10. Hosting Service

Our websites are hosted on servers in Germany and France. For this purpose, we have entered into a data processing agreement with this hosting service provider to comply with the protection standards of the GDPR.

11. Our Links to other websites

Our website may contain links to different websites of others. If you click on such a link, you will be forwarded to that website. Please notice, that our Data Privacy Statement is not valid for the linked websites as we are not the responsible for these websites. Please refer to the certain Data Privacy Statement of that website in this regard.

12. Update

Because it is necessary from time to time to update these data protection notices, we reserve the right to change these instructions at any time. We will also publish the amended version of the privacy policy here.

13. Automated decision-making

As a responsible company we do not use any automatic decision-making or profiling.

14. Data subject rights

a) Right to confirmation

Every Data Subject has the right granted by the European body issuing directives or regulations to request a confirmation from the Controller of whether personal data concerning him are processed. If a data subject wishes to exercise this right to confirmation, he may contact our Data Protection Officer or another employee of the Controller at any time.

b) Right to information

Every data subject whose personal data are processed has the right granted by the European body issuing directives and regulations to obtain, at any time and free of charge, information from the controller about his processed personal data and a copy of such information. Furthermore, the European body issuing directives and regulations has granted the data subject the right to the following information:

• the processing purposes
• the categories of personal data processed
• the recipients or categories of recipients to whom the personal data have been or are still being disclosed, in particular recipients in third countries or international organisations
• if possible, the planned duration of the personal data storage or, if this is not possible, the criteria for determining this duration
• the existence of a right to rectification or erasure of the data subject’s personal data, a right to restriction of processing by the controller or a right to object to such processing
• the existence of a right to lodge a complaint with a supervisory authority
• where the personal data are not collected from the data subject: all available information about the origin of the data
• the existence of automated decision-making, including profiling, pursuant to Art. 22 (1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject has a right to information as to whether personal data have been transferred to a third country or to an international organisation. Where this is the case, the data subject also has the right to obtain information about the appropriate guarantees in connection with the transfer.

If a data subject wishes to exercise this right to information, he may contact us at any time.

c) Right to rectification

Every data subject whose personal data are processed has the right granted by the European body issuing directives and regulations to request the immediate rectification of incorrect personal data concerning him. Furthermore, taking into account the purposes of the processing, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration.

If a data subject wishes to exercise this right to rectification, he may contact us at any time.

d) Right to erasure (right to be forgotten)

Every data subject whose personal data are processed has the right granted by the European body issuing directives and regulations to request that the controller erase his personal data immediately, provided that one of the following reasons applies and to the extent that the processing is not necessary:

• The personal data have been collected or otherwise processed for purposes for which they are no longer necessary.
• The data subject withdraws his consent on which the processing pursuant to Art. 6 (1) a) GDPR or Art. 9 (2) a) GDPR was based and there is no other legal basis for processing.
• The data subject lodges an objection to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate reasons for the processing, or the data subject lodges an objection to the processing pursuant to Art. 21 (2) GDPR.
• The personal data have been processed unlawfully.
• The erasure of personal data is necessary to fulfil a legal obligation under Union or Member State law to which the controller is subject.
• The personal data have been collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

Where one of the above-mentioned reasons applies and a data subject wishes to have personal data stored by us erased, he may contact us at any time. We will arrange for the erasure request to be complied with immediately.

Where the personal data have been made public by our company and our company as the controller is obliged to erase the personal data pursuant to Art. 17 (1) GDPR, we will take reasonable steps, including technical measures, taking into account the available technology and the implementation costs, to inform other controllers who process the published personal data that the data subject has requested the erasure of all links to these personal data or of copies or replications of these personal data by these other controllers, provided that processing is not necessary. We will take the necessary steps on a case-by-case basis.

e) Right to restriction of processing

Every data subject whose personal data are processed has the right granted by the European body issuing directives and regulations to ask the controller to restrict the processing if one of the following conditions is met:

• The accuracy of the personal data is disputed by the data subject for a period of time that enables the controller to verify the accuracy of the personal data.
• The processing is unlawful, the data subject rejects the erasure of the personal data and instead requests that the use of the personal data be restricted.
• The controller no longer needs the personal data for the processing purposes, but the data subject needs them to establish, exercise or defend legal claims.
• The data subject has lodged an objection to the processing pursuant to Art. 21 (1) GDPR and it has not yet been determined whether the controller’s legitimate reasons outweigh those of the data subject.

If one of the above-mentioned conditions applies and a data subject wishes to have personal data stored by us restricted, he may contact us at any time. We will initiate the restriction of processing.

f) Right to data portability

Every data subject whose personal data are processed has the right granted by the European body issuing directives and regulations to receive the personal data relating to him that he provided to a controller in a structured, common and machine-readable format. In addition, the data subject has the right to pass these data on to another controller without obstruction by the controller to whom the personal data were provided, provided that the processing is based on the consent pursuant to Art. 6 (1) a) GDPR or Art. 9 (2) a) GDPR or on a contract pursuant to Art. 6 (1) b) GDPR and that the processing is carried out using automated methods, provided that the processing is not necessary for the performance of a task in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his right to data portability pursuant to Art. 20 (1) GDPR, the data subject has the right to request that the personal data be transferred directly from one controller to another controller, to the extent that this is technically feasible and provided that this does not affect the rights and freedoms of other persons.

To exercise the right to data portability, the data subject may contact us at any time.

g) Right to object

Every data subject whose personal data are processed has the right granted by the European body issuing directives and regulations, for reasons arising from his particular situation, to object at any time to the processing of his personal data, which are processed pursuant to Art. 6 (1) e) or f) GDPR. This also applies to profiling based on these provisions.

In the event of an objection, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves to establish, exercise or defend legal claims.

Where we process personal data in order to carry out direct marketing, the data subject has the right to object at any time to the processing of personal data for the purpose of such marketing. This also applies to profiling to the extent that it is connected with such direct marketing. If the data subject objects to processing by us for direct marketing purposes, we will no longer process the personal data for these purposes.

In addition, the data subject has the right, for reasons arising from his particular situation, to object to the processing of his personal data which we carry out for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR, unless such processing is necessary to fulfil a task in the public interest.

To exercise the right to object, the data subject may contact us. Furthermore, the data subject may exercise his right to object in connection with the use of information society services, Directive 2002/58/EC notwithstanding, by means of automated procedures using technical specifications.

h) Automated decisions in individual cases including profiling

Every data subject whose personal data are processed has the right granted by the European body issuing directives and regulations not to be subject to a decision based exclusively on automated processing – including profiling – which has legal effect against him or significantly affects him in a similar manner, provided that the decision is not necessary for the conclusion or fulfilment of a contract between the data subject and the controller, or is admissible under Union or Member State law to which the controller is subject, and that such law contains appropriate measures to safeguard the rights, freedoms and legitimate interests of the data subject or is made with the data subject’s express consent.

Where a decision is necessary for the conclusion or fulfilment of a contract between the data subject and the controller or is made with the express consent of the data subject, we will take appropriate measures to safeguard the rights, freedoms and legitimate interests of the data subject, including at least the right to obtain human intervention on the part of the controller, to express his point of view and to contest the decision.

If the data subject wants more information on this point, he may contact us at any time.

i) Right to withdraw the data protection consent

Every data subject whose personal data are processed has the right granted by the European body issuing directives and regulations to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise his right to withdraw consent, he may contact us at any time.

j) Right of data subject to lodge a complaint with a Supervisory Authority

Pursuant to Art. 77 GDPR  every data subject whose personal data are processed also has the right to lodge a complaint with a competent supervisory authority.

You can find a list of relevant contact addresses at:

Members | European Data Protection Board (europa.eu)
https://edpb.europa.eu/about-edpb/board/members_en

Source: German Society for Data Protection  (https://dg-datenschutz.de)
Privacy Statement Status: 01.2021

---

Legal Notice and Disclaimer

Delimitation

The https://www.alphatrains.eu domain is part of the world wide web and is therefore linked to external websites that may change at any time and are not subject to this sphere of responsibility and for which the following information does not apply. It was closely verified exactly once that the links do not violate any conventions or laws before they were included here. You can recognise links that lead to external web projects because they open in a new window of the browser.

Copyright protection and use

The author specifically grants you the right to make a private copy for your own personal use. However, you are not entitled to change and/or transmit the materials or publish them yourself. Unless explicitly stated otherwise, Alpha Trains holds the copyright for texts. Most illustrations are subject to copyright by Alpha Trains.

No liability

The contents of this web project have been carefully verified and created to the best of our knowledge. However, no claim is made for the completeness, currency, quality, and correctness of the information presented here. No responsibility is assumed for prejudice resulting from relying on the contents of this website or their use.

Property right infringement

If you suspect that one of your property rights is violated by this website, please inform us immediately by email, so that remedial action can be taken quickly. Please note: the lengthy involvement of a lawyer to issue a warning at the service provider"s expense does not correspond to the latter"s real or presumed intention. Alpha Trains assumes no responsibility for the currency, correctness, completeness, or quality of the information provided. Liability claims against Alpha Trains relating to material or immaterial damage caused by the use or non-use of the information provided or by the use of incorrect or incomplete information are generally excluded, unless it is proven that Alpha Trains has acted with intent or gross negligence. All offers are subject to change and non-binding. Alpha Trains expressly reserves the right to change, supplement, or delete parts of the web pages or the entire offer without a specific announcement or to cease publication temporarily or permanently.

References and links

In the case of direct or indirect references to external websites (“links”), which are beyond the sphere of responsibility of Alpha Trains, any liability would be assumed only in the event that Alpha Trains is aware of the content and if it is technically possible and reasonable for the company to prevent their use in the case of illegal content. Alpha Trains therefore explicitly declares the linked pages to be free of illegal content at the time the links were added. Alpha Trains has no influence upon the current and future design or the content of the linked pages. Therefore, the company hereby explicitly distances itself from all content of all linked pages that were changed after the link was added. This statement applies to all links and references within Alpha Trains’ own internet offering as well as to external entries in guest books, discussion forums, and mailing lists set up by Alpha Trains. Only the provider of the page to which reference was made is liable for illegal, incorrect, or incomplete contents and, in particular, for damages arising from the use or non-use of information presented in this way, and not the person who merely refers to the respective publication by means of links.

Copyright and trademark law

Alpha Trains strives to comply with the copyrights of the graphics, audio documents, video sequences, and texts utilised in all publications, and use graphics, audio documents, video sequences, and texts created independently by Alpha Trains, or otherwise adopt licence-free graphics, audio documents, video sequences, and texts. All brands and trademarks mentioned within the internet offering and, where applicable, protected by third parties, are subject without restriction to the provisions of the respectively valid trademark law and the ownership rights of the respective registered proprietor. The mere mention of trademarks does not imply that they are not protected by the rights of third parties!

Copyright

All concepts, texts, images, and other information published on the website are – unless otherwise stated – subject to the copyright of Alpha Trains. This is considered intellectual property. Any duplication, distribution, storage, dispatch, reproduction, or transmission of the contents for commercial or private purposes is explicitly prohibited without the written consent of Alpha Trains. The copyrights (intellectual property) of the Alpha Trains logo and the website www.alphatrains.eu are exclusively owned by Alpha Trains.

Cooperation partners

The respective cooperation partner is solely responsible for content relating to the cooperation partner. If your rights are or may potentially be infringed by the textual description of the cooperation partner, please contact the liable cooperation partner directly. Alpha Trains dissociates itself from the accuracy of these text contents.

Legal validity of this disclaimer

This disclaimer is to be considered as part of the internet offering which you were referred to from this website. If sections or individual formulations of this statement do not or no longer comply with the current legal situation or are no longer or not correct, the content and validity of the other sections of the document remain unaffected by this.