Privacy Policy

Effective Date: January 1, 2025

Last Updated: June 10, 2026

Introduction

Passenger.ie ("we," "our," or "the App") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile app (available for iPhone and Android) and our website. The service helps anyone book train tickets in Ireland, and is designed especially with Free Travel Pass holders in mind.

By using Passenger.ie, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this privacy policy, please do not use the App.

Information We Collect

Information You Provide to Us

When you use Passenger.ie to book train tickets, we collect the following information that you directly provide:

• Personal Details: Full name (as it appears on your Free Travel Pass, if you are travelling with one)
• Contact Information: Email address (for ticket delivery) and phone number
• Travel Information: Origin and destination stations, travel dates, and journey preferences
• Free Travel Pass Status: Whether you are booking as a Free Travel Pass holder

Information Automatically Collected

We may automatically collect certain information when you use the App:

• Device Information: Device type, operating system version, unique device identifiers
• Usage Data: App features used, booking frequency, and interaction patterns
• Error Reports: Crash logs and error diagnostics to improve app stability

Information from Third-Party Services

When processing your booking, the App interacts with the train operator's publicly accessible booking system. We do not store or have access to:

• Any account credentials you may hold with the train operator
• Payment card information
• Your complete booking history with the train operator

Cookies and Local Storage

No Advertising or Cross-Site Tracking

Passenger.ie does not use advertising, marketing, or targeting cookies. We do not:

• Track you across other websites
• Share data with third-party advertisers
• Sell your personal data
• Use advertising networks of any kind

Website Analytics

Our website uses PostHog, a privacy-focused analytics service hosted on EU servers, to understand how the site is used (for example, pages viewed and buttons clicked). PostHog stores a small first-party identifier in your browser so repeat visits can be counted. This data is used solely to improve the service:

• Session recording is disabled
• Data is never used for advertising and never sold
• No tracking across other websites takes place

Browser Local Storage (Essential Functionality)

We also use browser local storage for essential accessibility features:

• Font Size Preference: We store your selected font size to maintain accessibility settings across sessions. This preference remains on your device and is never transmitted to our servers.

Legal Basis: This storage is used under GDPR Article 6(1)(f) (legitimate interests) to keep the service accessible and to understand, in aggregate, how it is used — without profiling you or tracking you across other sites.

How We Use Your Information

We use the collected information for the following purposes:

• Service Provision: To facilitate train ticket bookings through the train operator's booking system
• Understanding Your Request: The journey request you type (e.g. "Galway to Dublin tomorrow") is processed by AI language-model providers (OpenAI, with Google Gemini as a backup) solely to extract the origin, destination, and date of your journey
• Communication: To send booking confirmations and tickets to your email address
• Support: To respond to your inquiries and provide customer support
• Improvement: To enhance app functionality and user experience
• Legal Compliance: To comply with applicable laws and regulations

Data Sharing and Disclosure

We share your information only in the following circumstances:

With the Train Operator

Booking information is transmitted to the train operator's booking system solely for the purpose of completing your ticket reservation. This includes:

• Passenger name
• Contact details
• Journey information
• Free Travel Pass status

Service Providers

We share limited information with third-party service providers that assist us in operating the service:

• AI Language-Model Providers (OpenAI, Google): The text of your journey request, to understand where and when you want to travel
• Analytics (PostHog, EU-hosted): Anonymous usage data to improve the service
• Payment Processors (Apple, Google, Stripe): Purchases are processed by the Apple App Store, Google Play, or Stripe — we never see your card details
• Cloud Services: For secure hosting, data storage, and processing

Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities.

Data Security

We implement appropriate technical and organizational security measures to protect your personal information, including:

• Encryption: All data transmissions are encrypted using industry-standard protocols
• Access Controls: Limited access to personal information on a need-to-know basis
• Regular Updates: Security patches and updates to maintain protection standards
• No Payment Data: We never collect or store payment card information — purchases are handled by the Apple App Store, Google Play, or Stripe

Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

• Booking Information: Retained for 90 days after travel date for support purposes
• Contact Information: Retained until you request deletion or uninstall the App
• Usage Analytics: Aggregated and anonymized data may be retained indefinitely

Your Rights Under GDPR

As a user in Ireland/EU, you have the following rights under the General Data Protection Regulation (GDPR):

• Right to Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate personal data
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Request limitation of processing your personal data
• Right to Data Portability: Request transfer of your data to another service
• Right to Object: Object to processing of your personal data
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise any of these rights, please contact us at privacy@passenger.ie

Children's Privacy

Passenger.ie is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete such information.

International Data Transfers

Your information may be transferred to and processed in countries other than Ireland. We ensure that such transfers comply with GDPR requirements and that your data receives adequate protection.

Third-Party Services

The App interacts with the train operator's website and services. Your train travel is governed by the train operator's own privacy policy and terms of service, and we encourage you to review them.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by:

• Posting the new Privacy Policy in the App
• Updating the "Last Updated" date at the top of this policy
• Sending an email notification for significant changes

Contact Information

If you have questions or concerns about this Privacy Policy, please contact us at:

Data Protection Officer

For GDPR-related inquiries, you may contact our Data Protection Officer at:

Email: privacy@passenger.ie

Supervisory Authority

You have the right to lodge a complaint with the Irish Data Protection Commission:

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland
Website: www.dataprotection.ie