This Privacy Policy explains how PERIER sp. z o.o. processes personal data in connection with the BetterBahn service.
1. Data Controller
PERIER sp. z o.o., ul. 1 Maja 39, 71-627 Szczecin, Poland KRS 0001203585, NIP 8513340283, REGON 543161719 Email: [email protected]
No Data Protection Officer has been appointed. For all data-protection matters, please contact us at the email address above.
2. Overview of Processing
- Split-ticketing search: for anonymous users we do not process personal data; search queries are forwarded anonymously to external APIs.
- User account: when registering, we store email address, name and, optionally, travel preferences and search history.
- Subscriptions and billing: for Pro subscriptions and the Trip Pass we process billing data via our payment provider Stripe (existing subscriptions: Mollie). We keep withdrawal and cancellation declarations as proof.
- Analytics: a cookieless measurement of how the Service is used (no consent required), and additional analytics cookies only with your explicit consent.
3. Automatic Data Collection
3.1 Server log files
Each time you access the Service, we automatically store the following data in log files: IP address, date and time of access, name and URL of the requested file, amount of data transferred, message about successful retrieval, browser type and version, operating system, and the name of your internet service provider.
Legal basis: Article 6(1)(f) GDPR (legitimate interest in operating and securing the Service). Retention: we delete log files automatically after 7 days.
3.2 Privacy-friendly website analytics
We measure page views and navigation without cookies, on our own EU infrastructure. We do not store IP addresses for this. Data processed: page views and navigation, anonymised referrer data, anonymised browser information, aggregated usage statistics. Legal basis: Article 6(1)(f) GDPR.
3.3 Analytics with consent
If you accept analytics cookies, we also process the following data: page views and navigation, referrer data, browser information, error and performance data, anonymised user interactions. Retention: 12 months. Legal basis: Article 6(1)(a) GDPR (consent).
4. Cookies
4.1 Strictly necessary cookies
- Session cookie: authentication token for logged-in users (valid for 7 days)
- cc_cookie: stores your cookie preferences
4.2 Analytics cookies
Analytics cookies are only set with your explicit consent. They store an anonymised IP address, page views and navigation, browser information (User Agent), referrer data, error and performance data and anonymised user interactions. Retention: 12 months. Processing takes place on EU servers.
You can manage or revoke your consent at any time via the cookie banner or the cookie settings on our website. Revocation does not affect the strictly necessary functions of the Service.
5. Split-Ticketing Functionality
For anonymous users, our split-ticketing functionality does not process personal data. Search queries are forwarded anonymously to external APIs.
We process: travel connections (origin and destination stations, date, time), travel class and BahnCard status, Deutschlandticket status.
We do not process: your IP address, personal identification data, booking data or payment information.
6. User Account and Registration
Registration is voluntary and unlocks features such as saved travel preferences and search history.
6.1 Registration data
Email address, name, password (stored as a secure hash). Legal basis: Article 6(1)(b) GDPR (contract performance). Retention: until you delete your account.
6.2 Travel preferences
BahnCard type, preferred travel class, Deutschlandticket status, passenger age. Legal basis: Article 6(1)(a) GDPR (consent).
6.3 Journey history
Origin and destination stations, travel date and time, travel class, original price and split-ticket price, savings. Legal basis: Article 6(1)(b) GDPR. You may delete individual entries or your entire account at any time.
6.4 Search logs
When you search while signed in, we keep a technical log of each search linked to your account: origin and destination stations, travel date and time, search options (travel class, BahnCard, traveller age, Deutschlandticket, bike), number of results, cheapest price and, where applicable, an error code. Purpose: finding faults in the service and answering your support requests. Only our administrators have access. Legal basis: Article 6(1)(f) GDPR (legitimate interest in running the service without faults). Retention: after 30 days we remove the link to your account and the search options; what remains is an anonymous entry for statistics. When your account is deleted, the link is removed, even before the 30 days are up.
7. Subscriptions, Trip Pass and Billing Data
7.1 Payment and invoice data
When you subscribe to BetterBahn Pro or buy a Trip Pass, we process the following data: name, email address, billing country, payment status, payment method reference (e.g. tokenised card identifier provided by Stripe, or by Mollie for existing subscriptions; never the full card number), invoice number, amount, currency, and any VAT identification number you provide for B2B invoicing. For a Trip Pass we also store the route (origin and destination station) and the last day it covers.
Legal basis:
- Article 6(1)(b) GDPR: performance of the subscription or Trip Pass contract
- Article 6(1)(c) GDPR: compliance with legal obligations relating to invoicing and accounting (Polish VAT Act, Tax Ordinance)
- Article 6(1)(f) GDPR: fraud prevention
Retention: we keep invoices and accompanying accounting records for 5 years from the end of the calendar year in which the tax obligation arose, as required by Polish tax law.
7.2 Proof of your request for an immediate start
With your order you expressly ask us to start the service even if the withdrawal period is still running, and you confirm that you know your right of withdrawal ends once we have fully performed the contract (§ 356(5) BGB). As proof we store the time of the order, the version of the notice text you saw and the language it was shown in. For Pro we store these details in our database with your subscription. For orders placed through Stripe Checkout we also store them as metadata at Stripe (checkout session and subscription or payment).
Purpose: proof of your express request, for example if you withdraw later and we calculate the value of the service provided up to then (§ 357a(2) BGB). Legal basis: Article 6(1)(c) GDPR (legal obligations relating to the right of withdrawal) and Article 6(1)(f) GDPR (legitimate interest in proving our claims). Retention: in our database until you delete your account; at Stripe together with the records of the payment concerned.
7.3 Confirmation emails
When your Pro subscription or Trip Pass starts, we send you a confirmation by email. In it we confirm your request for an immediate start (§ 312f BGB). For a Trip Pass it also shows the route, the last day it covers and the amount paid. We answer withdrawal and cancellation declarations with an acknowledgement of receipt (section 8). These emails are part of the contract, so you cannot unsubscribe from them. Legal basis: Article 6(1)(b) and (c) GDPR.
8. Withdrawal and Cancellation
8.1 Withdrawal declarations
You can withdraw from a contract online using the withdrawal function on our website (§ 356a BGB, Article 11a Directive 2011/83/EU). We store: your name, the email address for the acknowledgement of receipt, the contract you withdraw from (type, identifier and description as shown to you), the email address used for the purchase if you are not signed in, your details of the order if you describe the contract yourself, the text of the declaration, the language, the time it reached us, when we sent the acknowledgement and handled the withdrawal, and your user ID if you are signed in. We do not store an IP address with the declaration.
Purpose: handling your withdrawal and proof that and when it reached us. We send the acknowledgement of receipt right away to the email address you gave, with the content of the declaration and the date and time it reached us (§ 356a(4) BGB). Our support inbox receives a copy. Legal basis: Article 6(1)(c) GDPR.
Retention: as long as claims under the contract can be raised or we have to keep the declaration for our accounting (section 7.1). If you delete your account, we keep the declaration as proof, but it is no longer linked to your account. Declarations you submit while signed in are included in your account's data export.
8.2 Cancellations
You can cancel your subscription using the cancellation function on our website (§ 312k BGB). We store: your name, the email address for the confirmation, the type of cancellation (ordinary or extraordinary) and, for an extraordinary cancellation, the reason you give, the contract you cancel, the email address used for the purchase if you are not signed in, your details of the contract if you describe it yourself, the requested end date and the end of the paid period, the text of the declaration, the language, the time it reached us, whether and when we carried out the cancellation, sent the confirmation and handled it, and your user ID if you are signed in. We do not store an IP address with the declaration.
Purpose: carrying out your cancellation and proof that and when it reached us. If you are signed in and cancel your current Pro subscription ordinarily at the end of the paid period, we carry out the cancellation at Stripe right away. We handle all other cancellations ourselves; for these our support inbox receives a copy. We send the confirmation right away to the email address you gave, with the content of the declaration and the time it reached us. Legal basis: Article 6(1)(b) GDPR (contract performance) and Article 6(1)(c) GDPR (§ 312k BGB).
Retention, account deletion and data export: as for withdrawal declarations (section 8.1).
8.3 Abuse prevention
To stop anyone misusing the withdrawal or cancellation function, for example to send a stranger email after email, we limit the number of requests. For this we keep counters in our cache (Redis) for your IP address (not hashed, up to 1 hour after the last request) and for the email address you gave, in lower case (up to 24 hours after the last submission). The entries are then deleted automatically. Legal basis: Article 6(1)(f) GDPR (legitimate interest in preventing abuse).
9. Feedback System
Using the feedback system is voluntary. We use it to improve the Service. Data processed: satisfaction rating, selected improvement suggestions, free-text feedback (optional), page context, User Agent, user ID (only if logged in), IP address (hashed, for abuse prevention). Legal basis: Article 6(1)(f) GDPR.
10. Recipients and Third-Party Processors
We store user accounts, preferences, journey history, feedback and withdrawal and cancellation declarations on our own infrastructure in the EU and do not share them with third parties. The following external services process data on behalf of BetterBahn:
10.1 Stripe (payment service provider)
- Provider
Stripe Payments Europe, Limited, The One Building, 1 Grand Canal Street Lower, Dublin 2, Ireland
- Role
processor under Article 28 GDPR with respect to payment processing on behalf of PERIER sp. z o.o.; in some respects (fraud prevention, AML compliance) Stripe acts as an independent controller.
- Data
name, email, billing address and country, VAT identification number where provided, tokenised payment instrument, amount, currency, transaction status and, for orders through Stripe Checkout, the time, text version and language of your request for an immediate start (section 7.2).
- Purpose
processing card payments (including Apple Pay and Google Pay) for BetterBahn Pro subscriptions and the Trip Pass, and recurring billing via Stripe's subscription API.
- Legal basis
- Article 6(1)(b), (c) and (f) GDPR.
- Privacy policy
- stripe.com/privacy
10.2 Mollie (payment service provider, existing subscriptions)
- Provider
- Mollie B.V., Keizersgracht 126, 1015 CW Amsterdam, Netherlands
- Role
processor under Article 28 GDPR with respect to payment processing on behalf of PERIER sp. z o.o.; in some respects (fraud prevention, AML compliance) Mollie acts as an independent controller.
- Data
name, email, billing country, tokenised payment instrument, amount, currency, transaction status.
- Purpose
processing card and SEPA payments for BetterBahn Pro subscriptions and recurring billing via Mollie's subscription API. Applies only to subscriptions taken out before 13 August 2026; new subscriptions are processed through Stripe.
- Legal basis
- Article 6(1)(b), (c) and (f) GDPR.
- Privacy policy
- mollie.com/privacy
10.3 Analytics provider (with consent)
A processor under Article 28 GDPR, on EU servers. Purpose: website analytics, performance monitoring and error tracking, only if you have accepted analytics cookies. Legal basis: Article 6(1)(a) GDPR.
11. Your Rights
Under the GDPR you have the following rights:
- Right of access (Article 15)
- Right to rectification (Article 16)
- Right to erasure (Article 17)
- Right to restriction of processing (Article 18)
- Right to data portability (Article 20)
- Right to object (Article 21)
- Right to withdraw consent at any time (Article 7(3)), without affecting the lawfulness of processing carried out before withdrawal
To exercise your rights, please contact us at [email protected].
You also have the right to lodge a complaint with a data-protection supervisory authority. The competent authority for PERIER sp. z o.o. is:
Prezes Urzędu Ochrony Danych Osobowych (UODO) ul. Stawki 2, 00-193 Warszawa, Poland uodo.gov.pl
12. Data Security
We use appropriate technical and organisational measures to protect your data from unauthorised access, loss, misuse and alteration. The website uses SSL/TLS encryption for all data transmission. We store passwords as secure hashes, never in plain text. All data (user accounts, analytics, feedback, billing) is processed on EU infrastructure under GDPR.
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in the Service or legal requirements. The current version is always available on this page.