Privacy policy
1. What Trilho is
Trilho is a mobile app (Android and iOS) for planning public-transport journeys in Portugal. It works without sign-up: there is no user account, e-mail, password or profile.
2. Data we process
2.1 Requests to our server
To compute routes, departures and nearby stops, the app sends our server the parameters of the request (for example origin and destination stops, or approximate coordinates when you ask for “stops near you”). These requests are processed on the spot and are not linked to any identity. Coordinates are redacted from the server's technical logs. Technical logs (IP address, time, request path) are kept for 7 days for operational purposes and then deleted.
2.2 Location
The app asks for precise location permission only when you tap features that need it (nearby stops, automatic origin). Location is used on the device and in the ephemeral requests described above. We do not store your location history, and location never enters the anonymous statistics.
2.3 Anonymous usage statistics (optional)
To understand which features are used, the app may send anonymous events: a random identifier generated on the device (not linked to your identity or to OS identifiers), the SIM country (2-letter code), the day and the event type (for example “search” or “route chosen”) with coarse properties (operator, fare option). We never send text you type, specific stops, location or trip history. It is off by default: it only runs if you turn it on during the initial setup screen or later in Settings → Anonymous · share usage; switching it off deletes the local queue immediately. Data is aggregated and raw records are deleted after 90 days.
2.4 Transport card (NFC)
When you hold a Navegante or Andante card to your phone, it is read locally. The card contents are not sent to our server.
2.5 Crash reports
If the app crashes, a technical report (app version, device model, stack trace) may be sent for diagnosis. It contains no personal identifiers or location.
3. Legal basis
Requests to the server are necessary to provide the service you ask for (GDPR Art. 6(1)(b)). Anonymous statistics rest on your consent (Art. 6(1)(a)), which you can withdraw at any time.
4. Processors and where data lives
| Service | Purpose | Where |
|---|---|---|
| Hetzner Online GmbH | Hosting of the Trilho server | Nuremberg, Germany (EU) |
| Cloudflare, Inc. | DNS, hosting of this website and e-mail forwarding | EU / global (website and e-mail) |
| Sentry (Functional Software, Inc.) | Crash reports, when enabled | Frankfurt, Germany (EU region) |
| PostHog Inc. | Aggregated analysis of anonymous events, when enabled | Frankfurt, Germany (PostHog EU Cloud) |
Timetable and alert data come from the transport operators and Portugal's National Access Point (NAP) under their open licences. We do not share or sell individual data to third parties.
5. Your rights
By design we hold no personal data linked to you that we could look up — so the rights of access, rectification and portability have no object. Objection and erasure are exercised on the device: switch statistics off in Settings and delete the app. For any question write to feedback@trilhoapp.com; we reply within 30 days at most. You also have the right to lodge a complaint with the Portuguese supervisory authority, CNPD (cnpd.pt).
6. Children
The app is not specifically aimed at children under 16 and collects no data that could identify age.
7. Changes
Any change to this policy is published here with a new date. The Portuguese version is at /privacy.