Privacy Notice for Passengers

Last updated: 30 March 2026

1. Who We Are

CaminoCabs Limited is a private company limited by shares, incorporated in Ireland.

• Company Registration Number: 806705
• Registered Address: Finglas, Dublin, Ireland
• Contact Email: info@caminocabs.ie

CaminoCabs is the data controller responsible for your personal data under the General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018.

1.1 Key Definitions

• "Transportation Services" means all taxi transportation services and other transportation services that may be provided by an SPSV, as made available for procurement by Passengers or otherwise intermediated by CaminoCabs through the Platform.
• "Intermediation Services" means the services provided by CaminoCabs through the Platform to facilitate Transportation Services being procured by Passengers and provided by Drivers.
• "Driver" means a licensed SPSV driver who provides Transportation Services through the CaminoCabs Platform.
• "Passenger" or "you" means any person who uses the CaminoCabs App to request Transportation Services.

2. What Personal Data We Collect

We collect the following categories of personal data:

2.1 Account and Profile Data

• Full name
• Email address
• Phone number
• Profile photo (optional)
• Account creation date
• Last activity timestamp

2.2 Business Profile Data (Optional)

If you choose to set up a business profile:

• Company name
• VAT/CIF number
• Billing address
• Business payment method

2.3 Payment Data

• Payment card details (processed securely by Stripe)
• Last 4 digits of your card
• Card brand (Visa, Mastercard, etc.)
• Payment preference (cash or card)
• Transaction history
• CaminoCredits balance and history
• Outstanding debt (if applicable)

Note: We do not store your full card details. Payment processing is handled securely by Stripe, a PCI-DSS compliant payment processor. CaminoCabs invoices and collects payment of the fare in the name and on behalf of the Driver.

2.4 Location Data

• Real-time GPS location (when the app is in use and you have granted permission)
• Saved addresses (Home, Work, favourites)
• Pickup and drop-off locations from your trip history
• Saved routes

2.5 Trip Data

• Complete trip history
• Origin and destination addresses
• Date, time, and duration of trips
• Distance travelled
• Fare paid and payment method
• Tips given to drivers
• Vehicle type requested
• Number of passengers
• Cancellations (reason, timestamp, who cancelled)
• Destination changes during trips
• Prebook (scheduled ride) details

2.6 Rating and Reputation Data

• Your passenger rating (average score)
• Total ratings received
• Ratings you give to drivers
• Written reviews (when required for low ratings)

Important: Your passenger rating is not visible to you but is used internally to maintain service quality and driver safety. Drivers can see your rating and total trips completed before accepting a ride request.

2.7 CaminoPoints Data

• Current points balance
• Lifetime points earned and spent
• Membership tier (Bronze, Silver, Gold, Platinum)
• Tier progress
• Points transaction history
• Signal Score and Signal Reliability
• Signals created and successful pickups

2.8 Communications Data

• In-app chat messages with drivers during trips
• Support chat conversations (including AI-assisted support)
• Support tickets and their history
• VoIP call logs (duration and status only; calls are not recorded)

2.9 Device and Technical Data

• Device type and model
• Operating system version
• App version
• Push notification tokens
• Device identifiers
• Theme preferences
• Notification settings

2.10 Security and Anti-Fraud Data

• Device hash
• IP address hash (for signals)
• Fraud flags and review status
• Account suspension records

2.11 Analytics and Usage Data

We use Firebase Analytics, a service provided by Google, to help us understand how users interact with our app. This service collects anonymised usage data such as:

• Screen views and navigation patterns
• Feature interactions (e.g., which features are used most frequently)
• Session duration and frequency
• App performance metrics (e.g., load times, crashes)
• General device and operating system information

This data is aggregated and anonymised — it is not linked to your personal identity and is used solely to improve the app experience. No advertising identifiers are collected, and no analytics data is sold or shared with third parties for advertising purposes.

3. How We Use Your Personal Data

Purpose	Legal Basis (GDPR)
Creating and managing your account	Contract performance
Processing ride bookings and payments	Contract performance
Providing Intermediation Services to connect you with available Drivers	Contract performance
Showing Drivers your location for pickup	Contract performance
Calculating fares and collecting payments on behalf of the Driver	Contract performance
Sending trip receipts and notifications	Contract performance
Managing CaminoPoints rewards programme	Contract performance
Applying promotional credits	Contract performance
Providing customer support (including AI-assisted)	Contract performance / Legitimate interest
Maintaining passenger rating system for Driver safety	Legitimate interest
Preventing fraud and abuse	Legitimate interest
Collecting anonymised analytics to improve app performance and user experience	Legitimate interest
Improving our Intermediation Services and App functionality	Legitimate interest
Complying with legal and tax obligations	Legal obligation
Sending marketing communications (if opted in)	Consent

4. Who We Share Your Data With

4.1 Drivers

When you book a ride through our Intermediation Services, the Driver (who provides the Transportation Services directly to you) can see:

• Your first name
• Your profile photo (if provided)
• Your passenger rating
• Number of trips completed with CaminoCabs
• Pickup and drop-off locations
• Your phone number (for contact during the trip)

4.2 Third-Party Service Providers

Provider	Purpose	Data Shared	Location
Firebase (Google)	Authentication, database, storage, push notifications, analytics	Account data, trip data, device data, location data, anonymised usage analytics	EU (Belgium)
Stripe	Payment processing (collecting fares on behalf of Drivers)	Payment card details, transaction data, billing information	EU (Ireland)
Google Maps	Maps, navigation, address search	Location data, addresses searched	EU
Anthropic (Claude AI)	AI-powered customer support	Support chat messages, trip context for support queries	United States
Agora	In-app voice calls between Passengers and Drivers	Voice call audio (real-time only, not recorded)	Global (edge servers)
Brevo (Sendinblue SAS)	Transactional emails, website contact form processing, CRM storage of enquiries	Email address, name, phone number, message content, trip details for receipts	EU (France)

4.3 Administrators

CaminoCabs administrators may access your data for:

• Customer support and dispute resolution
• Reviewing low ratings (2 stars or below require admin approval)
• Fraud investigation
• Legal compliance

4.4 Legal and Regulatory Authorities

We may share your data with law enforcement, regulatory bodies, or courts when required by law or to protect our legal rights.

5. International Data Transfers

Most of your data is processed within the European Union. However, some data is transferred to the United States:

• Anthropic (Claude AI): Support chat messages are processed by AI servers in the United States.
• Agora: Voice call audio may be routed through global servers, including outside the EU.

Where data is transferred outside the EU/EEA, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions where applicable

6. How Long We Keep Your Data

Data Type	Retention Period
Active account data	As long as your account is active
Trip history (active users)	As long as your account is active
Payment transaction records	6 years (Irish tax law requirement)
Receipts	6 years (Irish tax law requirement)
Analytics data	26 months (Firebase Analytics default retention)
Support tickets	Deleted when account is deleted
Website contact form enquiries	Up to 24 months, or until you request deletion
Data after account deletion	See "Account Deletion" section below

7. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Right of Access: Request a copy of your personal data.
• Right to Rectification: Request correction of inaccurate data.
• Right to Erasure: Request deletion of your data (see Account Deletion below).
• Right to Restrict Processing: Request limitation of how we use your data.
• Right to Data Portability: Receive your data in a portable format.
• Right to Object: Object to processing based on legitimate interests.
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, contact us at info@caminocabs.ie.

8. Account Deletion

You can request deletion of your account directly from the app:

Settings → Personal Information → Delete Account

How it works:

• You must re-enter your password to confirm
• There is a 30-day grace period during which you can cancel the deletion
• You cannot delete your account if you have an outstanding debt
• After 30 days, deletion is processed automatically

What is deleted:

• Your profile and personal data
• Profile photo
• Saved addresses
• Payment methods
• Support tickets
• Prebooks (scheduled rides)
• CaminoPoints balance and history

What is anonymised (not deleted):

For legal and accounting purposes, trip records are anonymised rather than deleted. This means:

• Your name is replaced with "Deleted User"
• Your email, phone, and photo are removed
• Trip details (date, fare, route) are retained for Driver accounting and tax compliance

9. Children's Privacy

CaminoCabs is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from children under 18. If you believe a child has provided us with personal data, please contact us immediately at info@caminocabs.ie.

10. Security

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

• Encryption of data in transit (HTTPS/TLS)
• Encryption of data at rest
• Secure authentication via Firebase Authentication
• Access controls limiting who can view your data
• Regular security reviews
• Anti-fraud monitoring

11. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. We will notify you of significant changes by:

• Posting a notice in the app
• Sending you an email
• Updating the "Last updated" date at the top of this notice

12. Contact Us

13. Complaints

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the Irish Data Protection Commission: