This Privacy Notice is issued by the National Transport Authority of Dún Scéine, Harcourt Lane, Dublin (“NTA”, “we”, “us”, “our”).
We provide an integrated ticketing scheme called ‘TFI Leap Card’ as a convenient way to pay for public transport services (“ TFI Leap Card”). The purpose of this notice is to inform you of the data relating to you that we may collect and use in connection with TFI Leap Card, Free Travel Card, this website, Leap Top Up app and the uses (including disclosures to third parties) we may make of such data.
If you have any questions about our use of your personal data, please contact us at firstname.lastname@example.org
Personal Data that we Collect and Process
We will collect and process personal data relating to you in connection with your use of TFI Leap Card and our relationship with you. This personal data may include:
- your name and contact details, including your address, phone number, email address;
- your social media ID, if you chose to log in via social media;
- your date of birth;
- your chosen TFI Leap Card label name and your chosen TFI Leap Card account user name;
- your chosen responses to security questions;
- the unique identifier assigned to your TFI Leap Card (Card Serial Number) and the times when you use your TFI Leap Card to pay for public transport services;
- your Free Travel Card number;
- your credit/debit card or bank account details, where you make payments by credit/debit card or automatic direct debit and when you request a refund;
- if you apply for a personalised TFI Leap Card, the photograph that you provide to us;
- if you apply for a Student Leap Card, the school/college/institute that you attend;
- if you apply for a Child Leap Card (age 16-18) or Young Adult Card (age 19-23), an official document confirming your identity (passport, learner permit etc);
- information that you provide to us when contacting Customer Care;
- Your use of TFI Leap Card and/or Free Travel Card;
Purposes of Processing and Legal Basis
For all the below purposes of processing the legal basis is the performance of tasks that we carry out in the public interest and the exercise of official authority vested in us by law, including Section 44(1)(c) of the Dublin Transport Authority Act 2008, as amended.
- processing your application for a TFI Leap Card;
- providing you with a TFI Leap Card and facilitating your use of TFI Leap Card in accordance with our terms and conditions with;
- enabling you to pay for public transport services with TFI Leap Card, providing you with receipts when you purchase credit or tickets with the Leap Top-Up App, logging your transactions, calculating and deducting travel credits, facilitating pre-paid tickets to be loaded onto your TFI Leap Card and processing top-ups
- registering you to TFI services;
- managing your TFI Leap Card account;
- authenticating you to TFI Leap Card website;
- providing you with customer support;
- providing you with refunds of the tickets and cards
- contacting you in order to provide you with updates in relation to TFI Leap Card;
- carrying out research and customer satisfaction surveys;
- generating and analysing statistics regarding usage of TFI Leap Card, Free Travel Card, and public transport services. Personal data will be pseudo-anonymised and where possible anonymised before being used for this purpose;
- fraud prevention, investigation and detection;
- establishing, exercising or defending legal claims;
- performing our functions as a public authority and complying with our legal obligations;
- Improving and developing our websites and apps.
For the automatic ID verification for the Child Leap Card (age 16-18) or Young Adult Card (age 19-23) the legal basis is reasons of substantial public interest with a basis in law, which includes the Data Protection Act 2018 in conjunction with the Dublin Transport Authority Act 2008.
For sending you promotional and marketing materials, subject to any preferences that you express when we collect your contact details or subsequently the legal basis is the consent you have given to the processing.
You can opt out of receiving promotional and marketing materials from us at any time by using the ‘unsubscribe’ facility or contacting Customer service.
Recipients of Data
We may disclose your personal data to other organisations in connection with the above purposes, including:
- to public and private service transport operators when you are using their services;
- to third parties who we engage to provide services to us in connection with TFI Leap Card integrated ticketing Scheme, such as outsourced service providers, IT services providers, professional advisers and auditors;
- to other public authorities and bodies where required or permitted by law, such as An Garda Síochána, or other law enforcement authorities for the purposes of the prevention, investigation or detection of crime.
We will not hold your personal data for longer than is necessary. We retain your personal data for as long as we need it for the purposes described in this Notice, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.
- TFI Leap Card Transaction data (for registered and personalised customers only) is retained for 13 months.
- For data analytics purposes and to provide analytics on transport use, TFI Leap Card and Free Travel Card transaction data will be pseudonymised after 13 months and anonymised after 3 years;
- Customer service data is retained for 12 months;
- Personal data you provide in relation to your application for a TFI Leap Card, or in order to register a TFI Leap Card is retained for:
- As long as you choose to remain as Registered, (i.e. until you unregister) or;
- Until you return or refund all your TFI Leap Card(s) (i.e. close your account); or
- Until the expiry of all your TFI Leap Card(s) (assuming that you do not opt to request a replacement
- Personal data that you provide to receive Student Card, Child Card (age 16-18), Young Adult Card (age 19-23), personal data are retained for:
- For approved applications 60 days after expiry of the card (assuming that you do not opt to request a renewal or replacement) for application personal data;
- For associated to the application documentation – up to 60 days following completion of the review.
- For abandoned or rejected card applications 60 days following rejection or application abandonment;
- For uncollected cards 60 days after the application completion.
- The email address that you provide when you opt in to receive marketing communications is retained until you unsubscribe to these communications.
- The email address that you provide when opt in to receive e-Receipts via Leap To-Up App until you unsubscribe from receiving the e-Receipts.
The information you provide to the Authority may occasionally be passed to third parties located outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. This is solely for the purposes of the operation of the integrated ticketing scheme (and not for direct marketing purposes).
If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission. If you would like to receive further details of the measures that we have taken in this regard, please contact us at email@example.com.
You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:
- Right to access the data – You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
- Right to rectification – You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
- Right to erasure – You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
- Right to restriction of processing or to object to processing – You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
- Right to data portability – You have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine-readable format.
Where you have given your consent to receive marketing communications, the right to withdraw your consent to the processing at any time.
Please note that these rights are not absolute, and are subject to certain restrictions and exemptions. For example, the right to erasure of personal data will not apply where we have a legitimate interest to hold such data and we may continue to process your personal data, despite an objection by you, where we have compelling legitimate grounds for the processing which override your interests, rights and freedoms. If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org or you can contact our Data Protection Officer at email@example.com.
We may occasionally update this policy. We encourage you to periodically review this policy for the latest information on our privacy practices.
If you are not happy with the way we are using your personal data or how we facilitate your rights or comply with our obligations under applicable data protection law, you have a right to make complaint to the Data Protection Commission via https://www.dataprotection.ie/ website.
Updated January 2023