Vie privée

Privacy Notice

Last updated: May 2026

Introduction

Welcome to the JRPass Ltd's ("JRPass") privacy notice. Your privacy is important to us, and we are committed to protecting your personal data.

Important information and who we are

Purpose of this privacy notice

JRPass is a leading online retailer of travel products specifically aimed at tourists using the Japanese rail travel network. We primarily provide an easy and convenient way for tourists to use our online platform to purchase orders for Japan Rail Passes and associated products that can be easily exchanged for physical travel passes upon arrival in Japan.

References in this privacy notice to JRPass' services includes users of our social media and website at https://jrpass .com. This privacy notice describe and explain the personal data that JRPass collects and processes through your use of this website, including any data you may provide through this website when you purchase a product or service, how we process it and for what purpose, how we protect your personal data when you visit our website (regardless of where you visit it from) and to tell you about your privacy rights.

JRPass is committed to ensuring that your personal data is protected and secured in accordance with applicable legislation including the principles related to the processing of personal data as set out in Article 5 of the UK GDPR.

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 personal data. This privacy notice supplements the other notices and is not intended to override them.

Controller

JRPass Ltd is the controller and responsible for your personal data (collectively referred to as JRPass Ltd, "we", "us" or "our" in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

Full name of legal entity: JRPass Limited

Email address: [email protected]

Postal address: JRPass Ltd, 320 City Road, London EC1V 2NZ

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include 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.

What Personal Data do we collect about you?

When we use the term 'personal data' in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, to an individual. It does not include data where the identity has been removed (anonymous data).

In order to use our product and services and book tickets, or when you interact with us through social media and our website, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect, nor do we require to provide, any special category data about you. This includes personal data revealing racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, data concerning a person's health, sex life and sexual orientation, genetic data and biometric data (where used for identification purposes). Nor do we collect any information about criminal allegations, proceedings or convictions.

Personal Data you give us about others: this website is not intended for use by children, and our products are not designed to be purchased by children. Some of our travel products include the ability for you to purchase tickets that can be used by children and whose details we may also need from you in order for them to use those travel tickets. By entering someone else's personal data (including children) for this purpose you confirm you've either got their permission to give it, or permission from their parent or guardian (if the passenger is under 16).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • place an order for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • give us some feedback.
• Automatically Collected Personal Data. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Cookies are small text files that are placed on your device which web servers utilise and that can be retrieved later in the domain that placed the cookie. We use cookies to provide an enhanced user experience and assist you in navigating our website. For more information about our use of Cookies, please contact us.
• Personal Data from Third parties or publicly available sources. We may obtain personal data about you from other sources as set out below, which we may combine with personal data we collect automatically or directly from you:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU;
    • advertising networks; and
    • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

How we use your personal data

We may only use your personal data when we have a legal basis to do so. We use different legal bases depending on the purpose of our processing activity. These legal bases are contractual necessity, legitimate interests (ours, yours, or those of another party), consent, compliance with a legal obligation, performing a task in the public interest, and protection of vital interests. Further details of what these mean can be found in the Glossary below. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

You can find more detail in "Purpose for which we will use your personal data".

Most commonly, we may use your personal data in the following circumstances:

• To operate, provide, develop, and improve our website and products.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

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.

Please note that in the table below we may rely on more than one legal basis to process your personal data, depending on the specific purpose for which we are using your data. Please contact us if you need details about this.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the JRPass Ltd group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the Third Parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

Restructure. We may seek to acquire other businesses, merge with them or there may be a restructure of JRPass. If a change like this happens to our business, then we would need to transfer your personal data, but your personal data would still be treated in the same way as set out in this privacy notice.

Third Parties. We only give third parties the parts of your personal data that they need, including travel operators/partners that we work with who also need your data to create tickets and provide services to you. For some of our travel operators/partners based in Japan we do not share any personal data and only give them anonymised aggregate data (such as the number and type of tickets sold). We require all third parties to keep your personal data safe, to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in, to locations where we and our third-party service providers have operations.

In the event of a transfer, including to countries outside the UK or the European Economic Area (EEA), we will ensure that i) the personal data is transferred to countries that are recognised as offering an adequate level of protection (which may include but not be limited to the EEA and Japan) , or ii) the transfer is made pursuant to appropriate safeguards such as the International Data Transfer Addendum to the European Commission's standard contractual clauses for international data transfers. If you have any questions about these safeguards, then please contact us.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to erase your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your rights and choices

You have rights and can also make choices about the collection and use of your personal data by JRPass. You can control your personal data that JRPass has obtained and exercise your data protection rights as highlighted in this section. Please note that some of these rights apply generally, while others will only apply in certain circumstances, and in some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law.

• Right to access: You have the right to obtain information about the personal data stored about you, including information about the processing.
• Right to rectification: You have the right to require us to rectify any incorrect or inaccurate personal information about you that we hold.
• Right to erasure: You have the right to require us to erase some or all of your personal data.
• Right to object to the processing of your personal data: In certain circumstances you have the right to object to the processing of your personal data.
• Right to restriction of processing: In certain circumstances, you have the right to require us to restrict the use of your data.
• Right to data portability: In certain circumstances you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to share it with a third party.
• Right to withdraw consent: Where you have previously provided your consent to the processing of personal data you are entitled to withdraw that declaration(s) of consent with future effect. However, this right to withdraw consent does not affect the legitimacy of any processing operations previously executed.

If you wish to exercise any of the rights set out above, please contact us. Please note that we reserve the right to not fulfil a request to exercise any of the above rights and choices if we are unable to ascertain your identity. If you are not satisfied with how we have responded to a request, you also have the right to lodge a complaint with the Information Commissioner.

Glossary

LEGAL BASES FOR PROCESSING

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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

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

External Third Parties

• Service providers acting as processors based in United Kingdom, EU, United States, Japan who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based the United Kingdom and Japan provide consultancy, banking, legal, insurance and accounting services.
• 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.