THE POLAR EXPRESS™ Train Ride – Edinburgh Waverley 2026

1. INTRODUCTION

Holdham Events Limited (“the Company”, “we”, “us”, “our”) is committed to protecting and respective your privacy.

This Privacy Policy explains how we collect, use, store, and protect your personal data when you:

• Purchase tickets
• Attend our events
• Use our website
• Interact with us

We process personal data in accordance with the UK General Data Protection Regulation and the Data Protection Act 2018.

2. DATA CONTROLLER

Holdham Events Limited is the data controller responsible for your personal data.

3. PERSONAL DATA WE COLLECT

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

• Full name
• Email address
• Telephone number
• Billing address
• Ticket type and quantity
• Event date and time
• Purchase history
• Payment details (processed via third-party providers)
• Names of attendees
• Age category (e.g. adult/child)
• Mobility needs
• Accessibility requirements
• IP address
• Device information
• Website usage data (via cookies and analytics)
• Preferences for receiving communications
• Engagement with marketing consent

4. HOW WE USE YOUR DATA

We use your personal data for the following purposes:

4.1 Contractual Purposes

• Processing ticket purchases
• Delivering the event
• Communicating important event information

4.2 Operational and Safety Purposes

• Managing accessibility requirements
• Ensuring safe delivery of the Event
• Responding to incidents or emergencies

4.3 Customer Support

• Responding to enquiries
• Managing complaints

4.4 Marketing

• Sending promotional communications (where consent is given)
• Providing updates on future events

4.5 Legal and Compliance

• Fraud prevention
• Compliance with legal obligations
• Defending or enforcing legal claims

5. LEGAL BASIS FOR PROCESSING

We rely on the following lawful bases:

• Contractual necessity – to fultil your booking
• Legal obligation – to comply with applicable laws
• Legitimate interests – to operate and improve our business
• Consent – for marketing communications

6. SHARING YOUR DATA

We may share your data with:

6.1 Service Providers

• Ticketing platforms
• Payment processors
• IT and hosting providers

6.2 Operational Partners

• Railway operators
• Event partners and suppliers

6.3 Insurance / Protection Providers

• Refund Protection Cover providers (e.g. XCover), where applicable

6.4 Authorities

• Law enforcement or regulatory bodies where required

We ensure all third parties process data securely and lawfully.

7. INTERNATIONAL TRANSFERS

Where data is transferred outside the UK, we ensure appropriate safeguards are in place in accordance with applicable law.

8. DATA RETENTION

We retain personal data only as long as necessary, including:

• For fulfilment of the Event
• For legal, accounting, and reporting purposes

Typical retention periods may be up to 6 years for financial records.

We implement appropriate technical and organisational measures to protect your data, including:

9. DATA SECURITY

• Secure payment processing
• Access controls
• Data encryption where appropriate

10. YOUR RIGHTS

Under UK data protection law, you have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request erasure (in certain circumstances)
• Restrict processing
• Object to processing
• Request data portability

To exercise your rights, please email customers@holdham.com.

11. COOKIES AND TRACKING

We use cookies and similar technologies to:

• Improve website performance
• Analyse usage
• Support marketing and advertising

You can manage cookie preferences via your browser settings.

12. PHOTOGRAPHY AND VIDEO

The Event may be photographed or recorded.

By attending, you acknowledge that:

• You may appear in event photography or video
• Such content may be used for promotional purposes

13. CHILDREN’S DATA

We collect limited data relating to children (e.g. names or age category) solely for operational purposes.

Parents or guardians are responsible for providing consent.

14. THIRD-PARTY LINKS

Our website may contain links to third-party websites. We are not responsible for their privacy practices.

15. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Updates will be published on our website.

16. CONTACT

For any privacy-related enquriies, please contact:

Data Protection Officer: dataprotection@edinburghthepolarexpressride.com

17. COMPLAINTS

If you are not satisfied with how we handle your data, you may lodge a complaint with the Information Commissioner’s Office.