Privacy Policy

Effective Date: January 1, 2025

Last Updated: January 1, 2025

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 iOS application designed for Irish Rail Free Travel Pass holders.

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
• 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: Confirmation that you are 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, we interact with Irish Rail's booking system through their public APIs and website. We do not store or have access to:

• Your Irish Rail account credentials
• Payment card information
• Complete booking history from Irish Rail

Cookies and Local Storage

We Do NOT Use Cookies

Passenger.ie does not use cookies of any kind. We do not:

• Track your browsing activity
• Use analytics or advertising cookies
• Share data with third-party advertisers
• Use marketing or targeting cookies

Browser Local Storage (Essential Functionality)

We use browser local storage only for essential accessibility features:

• Font Size Preference: We store your selected font size to maintain accessibility settings across sessions

Legal Basis: This localStorage usage is considered essential functionality under GDPR Article 6(1)(f) (legitimate interests) as it:

• Enhances accessibility for users with visual impairments
• Does not track or profile users
• Contains no personal or identifiable information
• Remains solely on your device and is never transmitted to our servers

No Cookie Banner Required: Because we only use essential local storage for accessibility and do not use tracking cookies, we are not required to display a cookie consent banner under GDPR or ePrivacy Directive.

How We Use Your Information

We use the collected information for the following purposes:

• Service Provision: To facilitate train ticket bookings through Irish Rail's system
• 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 Irish Rail

We transmit your booking information to Irish Rail's systems solely for the purpose of completing your ticket reservation. This includes:

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

Service Providers

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

• Email Services: To deliver booking confirmations and tickets
• Analytics Services: Anonymous usage data to improve the App
• Cloud Services: For secure 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

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 Irish Rail's website and services. Your use of Irish Rail's services is governed by their own privacy policy and terms of service. We encourage you to review Irish Rail's privacy practices.

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