eFlow Data Protection Notice

a) About TII  

Transport Infrastructure Ireland (“TII”) is the operational name of the National Roads Authority (“NRA”) following the dissolution of the Railway Procurement Agency and the transfer of its functions to the NRA in accordance with the Roads Act 2015. TII’s main address is Parkgate Business Centre, Parkgate Street, Dublin 8, D08 DK10, Ireland. 

b) About eFlow  

eFlow is a registered business name of TII (references to “eFlow” in this notice are references to Transport Infrastructure Ireland).  eFlow (TII) operates the barrier-free tolling system on Dublin’s M50 motorway and it is also a provider of electronic tags for use in connection with the payment of tolls on all toll roads in the Republic of Ireland.   

TII has appointed Turas Mobility Services Ltd (“Turas”) to provide tolling and other related services in relation to the operation of the eFlow barrier-free tolling system.    

eFlow (TII) is the controller of personal data that is collected and processed in accordance with this notice.  As Turas operates the eFlow tolling service on behalf of TII, it generally acts as a processor of any personal data collected and processed in connection with such services. 

The purpose of this notice is to inform you of the personal data relating to you that eFlow may collect and process in order to provide toll road services and the uses (including disclosures to third parties) that eFlow may make of such personal data.  

eFlow fully respects your right to privacy and is committed to protecting your personal data. Any personal data that is processed in relation to the eFlow business is processed in accordance with applicable data protection law.  

Information in relation to the processing of your personal data when you access the website eflow.ie is available on the eFlow website privacy notice.

The processing of personal data is required in order to provide toll road services to registered and unregistered eFlow customers (which includes customers who use the eFlow Website and the eFlow: My Tolls App and who contact eFlow by telephone or post). eFlow may collect and process some or all of the following personal data in relation to you:  

The personal data relating to you that eFlow holds is generally collected directly from you (e.g. when you use eFlow services, including when you drive on the M50 Toll Road or engage with us by post or via the eFlow website, the eFlow: My Tolls App or by telephone).    

As well as collecting information from you directly, eFlow may receive or collect information about you and your vehicle from the following sources:  

• the National Vehicle and Driver File, in accordance with specific legislative authority;  
• foreign vehicle licensing authorities, in the countries in which the vehicle is registered;  
• vehicle rental companies, to enable eFlow to contact you and request the payment for your passage;  
• compatible operators in connection with the processing of interoperable toll transactions (compatible operators include (i) other toll road operators, when you use the eFlow electronic tag on such toll roads and (ii) other tag providers, if you use an electronic tag issued by such tag provider to pay for toll journeys on the M50); 
• toll passage photographic and video recordings for all vehicles that use the M50 toll road; and  
• cameras/CCTV on the M50.  

The personal data described above is used by us and by third party service providers acting on our behalf. The legal bases on which we collect, process and transfer your personal data for these purposes are: 

• where such processing is necessary to comply with TII’s legal and regulatory obligations (“Legal Obligation”);  
• where such processing is necessary to carry out its tasks in the public interest and/or in the exercise of official authority vested in TII (“Public Interest/Official Authority”);  
• where such processing is necessary for the performance of a contract with you or where it is necessary to take steps at your request prior to entering into a contract with you (“Contract”); and 
• your consent (“Consent”), where this is the case you will be asked to give a positive indication of that consent.  

Purposes of processing activities and associated legal bases  

eFlow processes personal data in order to:  

The legal basis on which we collect, process and transfer special categories of data relating to you (e.g. data relating to health) in the manner described above are that of Public Interest and Consent (specifically, your explicit consent to such processing).  

The legal basis for processing your personal data for the purposes of criminal proceedings is TII’s performance of its statutory functions with regard to the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties in connection with unpaid tolls. 

In connection with the above, eFlow may transfer your personal data outside the European Economic Area to service providers in India, New Zealand, Argentina, the United Kingdom and the United States of America In such circumstances, eFlow ensures that appropriate measures are in place to comply with its obligations under applicable law governing such transfers.   

The European Commission has the power to determine, on the basis of Article 45 of Regulation (EU) 2016/679 (the GDPR) whether a country outside the EU offers an adequate level of data protection. In this regard, eFlow relies on the adequacy decisions in respect of transfers to InnoCraft Ltd. in New Zealand, W5 Marketing Intelligence Ltd. and Euro Parking Collection plc (EPC) in the UK and to Kapsch Trafficom Argentina S.A. in Argentina (see further details below).  

Transfers to MOJO Web Solutions LLC in the United States of America and VPTI Solutions Private Limited in India are made on the basis of contracts governing such transfers that contain ‘standard contractual clauses’ approved by the European Commission. 

Further details of the measures that eFlow has taken in this regard are available from the eFlow Data Protection Officer, using the contact details indicated below.   

In connection with eFlow, the following are the key recipients of personal data processed by TII: 

We may also disclose any of your personal data detailed in the “Personal Data Processed by eFlow” section above to other organisations in connection with the above purposes, in the following circumstances:  

• We may share personal data with our agents, contractors and service providers (as well as sub-contractors of such parties) who assist us with the operation of aspects of our services and functions, such as our banking and printing/postal correspondence contractors, foreign vehicle licensing authorities and law enforcement agencies.  
• Where we appoint a new operator of eFlow, we may share personal data with this new operator in order to facilitate the successful transition to the new operator and to ensure continuity of service for eFlow customers during any transition period.  
• Where we are under a duty to disclose or share personal data in order to comply with any legal obligation, or to protect the rights, property or safety of eFlow, our customers, or others.  
• Where required or permitted by law, we may share your personal data with other public authorities and bodies, such as the Gardaí or other law enforcement authorities for the purposes of the prevention, investigation, detection, or prosecution of criminal offences or the execution of criminal penalties.  
• In connection with the processing of interoperable toll transactions in Ireland, we may disclose your personal data to a relevant compatible operator.  
• We may share toll passage data with key stakeholders, e.g. the Department of Transport, for the purposes of research and statistical analysis. 
• For the purpose of operating competitions on behalf of TII we may disclose, subject to your consent, your name, email address and marketing preferences provided to us by you.  
• Where we are otherwise permitted by law.  

Generally, we will only retain your personal data for as long as necessary for the purpose or purposes for which it was obtained, including for the purposes of satisfying any legal, accounting, or reporting requirements. The retention periods differ depending on the type of categories of personal data held.  

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Further specific information on our retention practices in relation to the processing activities discussed above is available from the eFlow Data Protection Officer, using the contact details indicated above.   

You are not under a statutory obligation to provide eFlow with any personal data. However, there  

are certain pieces of information that you must provide to us in order to open an eFlow account or to pay a toll or a penalty (e.g.  your name, your contact details and payment details). If we do not receive this information, this will impact our ability to (i) process your application; and/or (ii) process your payment (which may result in enforcement proceedings). 

The personal data which we process is held on secure servers hosted by Turas Mobility Services Ltd. eFlow has adopted appropriate technical and organisational security measures to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction or damage. We will also ensure that our agents or third-party service providers who process your data are required to keep your data safe and secure. 

You have the following rights, in certain circumstances, 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 – You have the right to request that we no longer process your personal data for particular purposes. 
• Right to object to the processing of your personal data – You have the right to object to our processing of your personal data for particular purposes. 
• Right to data portability – You have the right to receive your personal data, which you provided to us, in a structured, commonly used machine readable format or to require us to transmit that data to another controller. 
• Right to withdraw your consent – where our processing of your personal data is based on you having provided consent, you have 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 reason to continue 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. 

In order to exercise any of the rights set out above, please contact the eFlow Data Protection Officer, using the contact details below.  

If you have any questions or complaints about our use of your personal data, please contact the eFlow Data Protection Officer using the contact details below. Alternatively, TII’s Data Protection Officer may be contacted as follows:  

• by post: Data Protection Officer, Transport Infrastructure Ireland, Parkgate Business Centre, Parkgate Street, Dublin 8, D08 DK10  
• by phone: +353 1 646 3600
• by email: dataprotection@tii.ie 

Further information about data protection can be found on the Data Protection Commission’s website: www.dataprotection.ie  

You also have the right to lodge a complaint with the Data Protection Commission if you are not happy with the way we have used your information or addressed your rights. Details of how to lodge a complaint can be found on the Data Protection Commission’s website.  

You can contact eFlow in the following ways:  

• by post: Data Protection Officer, Turas Mobility Services Limited, Block 8, Harcourt Centre, Charlotte Way, Dublin, D02 K580 
• by email: dataprotection@eflow.ie 
• by phone: 0818 50 10 50 (International: +353 1 4610122) 
• by using the Webchat with the eFlow team or the General Query Form on the eFlow website. 

We may amend this Data Protection Notice from time to time. Any material changes we make to this Data Protection Notice in the future will be posted to our website (www.eflow.ie). This Data Protection Notice was last updated on 20 June 2025.