Privacy Policy

Effective Date: January 2026 — Pneuma Holdings Ltd

Wayfare is committed to protecting your personal data in accordance with the UK GDPR and Data Protection Act 2018. This policy outlines how we collect, use, and safeguard your data.

Data Controller: Pneuma Holdings Ltd

Contact: privacy@wayfareapp.co.uk

What We Collect

Identity data: name, date of birth
Contact data: email, phone number, address
Travel data: journey details, ticket purchases
Payment data: card details, billing address
Technical data: device type, IP address, cookies

How We Use Your Data

To process ticket purchases and refunds
To manage Delay Repay claims with train operators
To send service updates and disruption alerts
To improve app functionality and user experience

Legal Basis

Contractual necessity: ticketing and claims processing
Legitimate interest: fraud prevention, analytics
Consent: marketing communications, cookies

Sharing and Transfers

Shared with train operators for ticketing and claims
Payment processors for secure transactions
No sale of personal data to third parties
Data may be stored or processed outside the UK with appropriate safeguards

Your Rights

Access, correction, deletion, portability
Object to processing and withdraw consent

Contact: privacy@wayfareapp.co.uk

Comparative Alignment

Wayfare's privacy practices align with best practices from leading rail services including Trainline (clear data usage, AI assistant transparency), LNER (controller responsibility, lawful basis clarity), Omio (international data transfers, consent-based marketing), and National Rail (supplier transparency, anonymised analytics).