1. introduction

Bene Rail International NV (“benerail”, “we”, “us”, “our”) is committed to protecting and respecting your privacy. In this privacy notice we explain how benerail collects and uses your personal data. This privacy notice applies to personal data that benerail processes when users visit our website (https://benerail.com) or contact us via the contact form or interact with us in other ways.

We process your personal data primarily to answer your questions. If you provide us with the personal data of other individuals, you guarantee that this individual was informed of this privacy notice, and that insofar as a certain processing requires the consent of this individual, you have obtained his or her consent for the processing of his or her personal data by us.

In this privacy notice, we provide more information about the personal data we collect and use and what your rights are. Please click on the relevant paragraph below for more information.

This website may use cookies and/or other similar technologies. More information on this processing can be found in our cookie notice. Please consider this document together with this privacy notice.

By using our website, you acknowledge having read this privacy notice.

2. who we are

We are Bene Rail International NV, a Belgian company with head office at Hallepoortlaan 40, 1060 Brussels, Belgium and responsible for the personal data we process.

benerail acts as controller for the processing of your personal data as described in this privacy notice.

3. personal data we process

3.1. general

The term “personal data” used in this privacy notice describes information that can be used to identify or reasonably link to an individual, such as full name, mailing address, email address, business contact information and IP address, or other identifying computer/browser information. Personal data that has been anonymized, and therefore can no longer be used to identify an individual, is not considered personal data by us.

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

a. contact data

• first name
• last name
• email address

b. communication data

• The content of your message and our correspondence in order to respond to your enquiry
• Information you provide when communicating with us.

c. technical data

• your IP address
• browser type and version
• operating system
• other technical details about your visit to our website

We collect this information via cookies and similar technologies. Collection of this data is disabled by default when you first enter our website and is only collected when you give us permission to do so. For more information, please consult our cookie notice.

d. usage data

• browsing behavior
• clickstream to, through, and from our website (including date and time)
• page response times
• download errors
• length of visits to certain pages
• page interaction information (such as scrolling, clicks, and mouse-overs)

3.2. children younger than 16 years

Our website and contact form are not intended for children younger than 16 years. We do not knowingly collect personal data relating to children. If you believe that we have collected personal data from a child, please contact us so we can delete it.

4. how we collect your data

We collect personal data in the following ways:

a. personal data provided by you

When you fill in the contact form on our website or otherwise contact us.

Unless otherwise indicated, the provision of personal data to us is not a statutory or contractual requirement and you are not obliged to provide your personal data to us. If you decide not to provide your personal data, we might, in some instances, not be able to provide you with all features of the website or a product or service. Completion of any forms or surveys is entirely voluntary, although you may be required to submit certain personal data to us to allow us to adequately handle your inquiries or requests.

b. when you use our website

As you interact with our website, we may automatically collect and use personal data  through cookies and similar technologies. For more information, please refer to our cookie notice.

We use services from Google, including Google Analytics on our website. The data collected via Google Analytics is processed in a pseudonymized manner.

5. purposes for which we use your personal data

The categories of personal data and legal basis for each purpose of the processing are set out in the table below:

Purposes	Categories of personal data	Legal bases
To provide and maintain our website and any products or services related thereto.	Contact Data Communication Data ⁠Technical Data Usage Data ⁠ Company Data	The processing is necessary for our legitimate interest in processing your personal data to provide you with our website and any products or services related thereto.
To provide optimal customer experience, for example by ensuring that we present our website content in the most effective manner for you and for your device.	Technical Data Usage Data	Where legally required, we will request your prior consent (e.g. non-essential cookies and tracking technologies, where relevant, in accordance with our cookie notice). In other cases, the processing is necessary for our legitimate interest in knowing our customer and maintaining our relationship with you or your organisations, with a view to providing an excellent customer experience.
To provide you with technical support, requested information, a response to your inquiries, and to communicate with you.	Contact Data Communication Data⁠ Technical Data ⁠Company Data	Where legally required, we will request your prior consent (e.g. non-essential cookies and tracking technologies, where relevant, in accordance with our cookie notice).   In other cases, the processing is necessary for our legitimate interest to provide you with support, to answer questions or requests and to improve and promote our products and services in this way.
We use integrations with LinkedIn on our website for marketing purposes. The data collected in this manner is subject to LinkedIn’s privacy policy.	Contact Data Technical Data Usage Data	We will request your prior consent in accordance with our cookie notice.
To improve and maintain the quality of our website, services and products by performing support activities for products and/or services, identifying and resolving bugs and service errors, adding new features and optimizing your user experience.	Technical Data Usage Data	Where legally required, we will request your prior consent (e.g. non-essential cookies and tracking technologies, where relevant, in accordance with our cookie notice).   In other cases, this processing is necessary for our legitimate interest to analyze, report on, manage and improve our services and/or our website.
To analyze and report on the use of our website, our services and the website traffic, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.	Technical Data Usage Data	Where legally required, we will request your prior consent (e.g. non-essential cookies and tracking technologies, where relevant, in accordance with our cookie notice).   In other cases, this processing is necessary for our legitimate interest to analyse, report on, manage and improve our services and/or our website.
To comply with legal and regulatory obligations, such as court orders, law enforcement requests, regulator inquiries, or other.	Contact Data Communication Data Technical Data Usage Data Company Data	Where a legal obligation applies to us, the processing is necessary to comply with legal obligations applicable to us.   In the absence of a relevant legal obligation, the processing is necessary for our legitimate interest in conducting our business in a responsible manner and in accordance with best practices.
To enforce our terms of use or this privacy notice, and establish, exercise and protect our rights, including in legal proceedings or in complaint and dispute management procedures.	Contact Data Communication Data Technical Data Usage Data Company Data	This processing is necessary for our legitimate interest to collect personal data for use in resolving any disputes and/or to defend ourselves in and out of court.
To respond to your data subject request under the GDPR	All relevant personal data relating to the request: Contact Data Communication Data Technical Data Usage Data Company Data	This processing is necessary for our legal obligation under Chapter III of the GDPR.
To prevent or detect fraud and illegal uses, abuse, spam, fraud, security incidents and other harmful activity regarding our website or services.	Contact Data Communication Data Technical Data Usage Data Company Data	Where a legal obligation applies to us, the processing is necessary to comply with legal obligations applicable to us.   In the absence of a relevant legal obligation, the processing is necessary for our legitimate interest to deal with misuse, fraud and crime.
To prepare for and effect a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.	Contact Data Communication Data Technical Data Usage Data Company Data	This processing is necessary for our legitimate interest in carrying out the said business transactions to implement our business strategies or grow our business.

6. granting access to or sharing data with third parties

6.1. general

We may share your personal data for the fulfilment of one or more of the purposes set out above. In that context, we may share your personal data with:

• internal recipients, including our employees and internal staff if this is necessary to perform their role.

• third party service providers, including IT service providers, sub-contractors and suppliers, used to provide or support the website, products and/or services. If necessary to carry out their task, your personal data may also be transferred to these third-party service providers. In that case, they process your personal data solely in accordance with our instructions and in line with the applicable data protection laws.
• social media companies in the event we use their tools on our website; in which case we may share aspects of your website behaviour with social media in order to show personalised advertising or to prevent less relevant advertising from being shown on their platforms or third-party websites. 
• marketing, advertising and analytics providers including when we or third-party marketing, advertising, and analytics providers collect personal information to implement and evaluate our website and services and for advertising, analytics, measurement and marketing purposes. This personal data is generally collected through cookies and other tracking technologies via our website. We will not share your personal data with third parties for their marketing purposes without your consent.
• members of the benerail group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
• a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.
• regulatory authorities, government authorities, law enforcement, or courts in order to comply with any court order, law, or legal process, including responding to any government or regulatory request, or to establish, exercise or defend our rights.
• professional advisors, such as lawyers, auditors, bankers and insurers where necessary in the course of the professional services that they render to us.

All such recipients are required to protect your personal data and only process it in accordance with applicable data protection laws.

6.2. third party websites

Our website may contain links to third-party websites, plug-ins, services, social networks or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. This privacy notice does not apply to those websites. For more information on how they process personal data, please consult their own privacy notices.

7. security and retention

7.1. security

benerail takes appropriate technical and organizational measures to protect your personal data against loss, unauthorized access, or unlawful use. However, no method of transmission over the internet is entirely secure, and we cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure, please immediately notify our Privacy Office using the contact details set out below.

7.2. retention

Your personal data will be retained only as long as necessary to fulfil the purpose for which it was collected.

The storage period for personal data will depend on: (i) the period of time required for the purposes for which it was collected; (ii) any compatible and lawful purposes subsequently established; (iii) any new purposes to which you subsequently consent; and/or (iv) compliance with legal and regulatory requirements, including statutory retention terms and prescription periods under applicable data protection laws.

After this storage period, your data will be securely deleted or anonymized.

8. your rights

You may contact our Privacy Office to exercise your rights under applicable data protection laws, including:

• right of access
• right to rectification
• right to erasure
• right to restriction of processing
• right to data portability
• right to object

8.1. withdrawal of consent

You may withdraw your consent at any time by contacting our Privacy Office (insofar the processing is based on your consent). This withdrawal will however not affect the lawfulness of the processing of your personal data for the period prior to the time of this withdrawal and processing activities based on another legal basis.

8.2. denial or restriction of rights

In certain cases, we may be legally entitled to deny or restrict the exercise of your rights. If this applies, we will inform you accordingly.

8.3. privacy Office

benerail Privacy Office

Hallepoortlaan 40

1060 Brussels

Belgium

Email: privacyoffice@benerail.com

8.4. questions, comments or complaints

If you have any questions or complaints about this privacy notice or the processing of your personal data, please contact our Privacy Office.

Furthermore, if you believe that we did not act in accordance with the legislation concerning the processing of personal data, you have the right to file a complaint with the competent supervisory authority of your place of habitual residence or work or where an alleged infringement took place. For Belgium, this is the Data Protection Authority (www.dataprotectionauthority.be). The list of the data protection authorities in the European Economic Area is available here.

9. how this notice is updated

This privacy notice took effect on July 2026 and replaces the previous version. It may be updated from time to time. We recommend that you always consult the most recent version. Changes will be communicated via the website before taking effect.