Privacy Policy

Railway Transport of Montenegro JSC Podgorica

Railway Transport of Montenegro JSC Podgorica respects the privacy of its passengers, service users and visitors to its official website, www.zpcg.me, and is committed to protecting their personal data.

This Privacy Policy explains what personal data we may collect, why and how we process it, how we protect it, and what rights you have regarding your personal information.

Personal data is processed in accordance with the applicable Law on Personal Data Protection of Montenegro and other relevant legislation.

1. Data Controller

The data controller responsible for processing personal data is:

Željeznički prevoz Crne Gore AD Podgorica (Railway Transport of Montenegro JSC)

  • Registered address: Trg Golootočkih žrtava 13, 81000 Podgorica, Montenegro
  • Tax Identification Number (TIN): 02723620
  • Website: www.zpcg.me
  • Email: [email protected]
  • Telephone: +382 20 441 197

For any questions concerning the processing or protection of your personal data, please contact us using the details provided above.

2. Personal Data We Collect

When you use our website or electronic services, we may collect and process the following categories of personal data:

  • First and last name, when voluntarily provided.
  • Email address and telephone number when submitting inquiries, requests or complaints.
  • The content of messages and any documents you submit to us.
  • Technical information, including IP address, browser type, operating system and website access data.
  • Information required for booking or purchasing train tickets through our associated electronic services.

We collect only the personal data necessary for a specific and legitimate purpose.

We ask users not to submit sensitive personal information through contact forms unless it is necessary to exercise a specific right or obtain a requested service.

3. Purposes of Personal Data Processing

We process personal data for the following purposes:

  • Responding to inquiries and providing information about railway transport services.
  • Handling passenger requests, complaints and claims.
  • Providing train ticket booking and purchasing services.
  • Improving the functionality, accessibility and security of our website.
  • Preventing misuse and unauthorized access to our information systems.
  • Complying with applicable legal and regulatory obligations.

We do not use personal data for purposes incompatible with those for which it was originally collected unless an appropriate legal basis exists.

4. Legal Basis for Processing

Depending on the specific purpose, personal data is processed on one or more legal grounds permitted under applicable legislation, including:

  • The data subject's consent, where required.
  • Performance of a contract or taking steps at the data subject's request prior to entering into a contract.
  • Compliance with legal obligations.
  • Performance of tasks carried out in the public interest, where supported by an appropriate legal basis.
  • Legitimate interests, where permitted by applicable law and subject to the protection of individuals' rights and freedoms.

Where processing is based on consent, you may withdraw your consent in accordance with applicable law.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

5. Contact Forms and Electronic Communication

When you contact us through our website or by email, we use the information you provide to process your request and communicate with you.

Access to this information is restricted to authorized personnel who require it to perform their professional duties.

Personal data is retained only for as long as necessary to respond to your request, unless a longer retention period is required by law or justified by the protection of legal interests.

6. Online Train Ticket Purchases

Our website, www.zpcg.me, may contain links to the online train ticket purchasing platform available at tickets-zpcg.me.

When purchasing electronic train tickets, personal data necessary for processing the purchase, issuing tickets, verifying travel eligibility and handling potential complaints may be collected and processed.

Payment card details are entered into the secure environment of the payment processing service provider and are not stored within the information systems of Railway Transport of Montenegro.

Further information about personal data processing related to online ticket purchases is available in the Privacy Policy of the online ticketing platform.

7. Cookies

Our website may use cookies, which are small text files stored on your device when you visit a website.

Cookies may be used for the following purposes:

  • Ensuring the essential functionality of the website.
  • Remembering user preferences and settings.
  • Analyzing website traffic and improving user experience.
  • Maintaining website security and stability.

Cookies that are not strictly necessary for the operation of the website are used only where an appropriate legal basis exists, including user consent where required.

Users can manage cookies through their browser settings and, where available, through the website's cookie consent management interface.

8. Sharing Personal Data

Railway Transport of Montenegro does not sell users' personal data.

Personal data may be disclosed or made accessible to:

  • Authorized employees, within the scope of their professional responsibilities.
  • IT service providers, hosting companies and other technical service providers processing data on our behalf.
  • Electronic payment service providers, where necessary to complete transactions.
  • Competent public authorities, where disclosure is required by applicable law.

When personal data processing is entrusted to third parties, appropriate measures are taken to protect the confidentiality and security of the information.

9. Personal Data Retention

We retain personal data only for the period necessary to fulfill the purposes for which it was collected or for the period required by applicable law.

Retention periods depend on the type of data, the purpose of processing and the legal obligations applicable to each category of records.

Once the applicable retention period expires, personal data is deleted, securely destroyed or anonymized, unless another lawful basis for continued retention exists.

10. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, disclosure or unlawful processing.

These measures include access controls, user authorization management and other security procedures appropriate to the nature and risks of the processing activities.

Access to personal data is restricted to authorized personnel.

11. Your Rights

In accordance with the applicable Law on Personal Data Protection of Montenegro, you have the right to:

  • Receive information about the processing of your personal data.
  • Request access to personal data relating to you.
  • Request the correction of inaccurate or incomplete personal data.
  • Request the deletion of personal data where the applicable legal conditions are met.
  • Submit an objection or a request for the protection of your rights in accordance with the law.
  • Withdraw previously given consent where processing is based on consent.

Certain rights may be restricted where the retention or processing of personal data is necessary to comply with legal obligations.

To exercise your rights, you may contact us at [email protected] or submit a written request to our registered address.

12. Complaints to the Supervisory Authority

If you believe that your personal data has been processed in violation of applicable legislation, you may contact Railway Transport of Montenegro to seek clarification or exercise your rights.

You also have the right to submit a request for the protection of your rights to the competent supervisory authority:

Agency for Personal Data Protection and Free Access to Information of Montenegro

(Agencija za zaštitu ličnih podataka i slobodan pristup informacijama)

Such requests may be submitted in accordance with the procedures established by applicable law.

13. Links to Third-Party Websites

Our website may contain links to external websites and digital services operated by third parties.

When visiting external websites, we recommend reviewing their privacy policies, as their personal data processing practices may differ from those described in this document.

14. Changes to This Privacy Policy

Railway Transport of Montenegro reserves the right to update or amend this Privacy Policy to reflect changes in applicable legislation, personal data processing practices or website functionality.