There are ten trams on the LUAS Red and Green lines currently testing a system for analysing passenger numbers and direction of travel in order to make improvements to the LUAS service.

This trial is organised by a partner of the LUAS Network, the company FLOWLY SAS (838 864 908 RCS Saint-Denis), responsible for processing and recipient of the data.

Wi-Fi sensors installed on trams detect passive signals (probe requests) from electronic devices such as smartphones, tablets, etc., without identifying people.

The raw data of probe request includes:

  • Mobile Access Control (MAC) address – an identifying number specific to that device
  • Routes and travel time
  • Log data (date, time, RSSI – signal strength indicator, device type, Wi-Fi sensor identification)

Collected data is not used to identify specific individuals. We are not collecting data such as your name, browsing history or phone numbers.

Wi-Fi sensor filters out devices other than mobile phones and pseudonymises data in near real-time. As result we will not be able to identify any individuals from the data collected. The data is further filtered to remove non-tram users and [then] anonymised.

Pseudonymisation is the process of distinguishing individuals in a dataset by using a unique identifier that does not reveal their 'real world' identity. The goal of anonymisation is to remove any link with the user. This is a way of protecting people's privacy in accordance with the Data Protection Commission’s: Guidance on Anonymisation and Pseudonymisation (June 2019).

For more information on this trial please see
For data protection statement and more information about us please see our notice.

In order to actively participate in and contribute to the success of this trial, we invite you to leave the Wi-Fi function of your device(s) enabled.

Opposition to data collection.

You can object to the collection of your MAC address under the conditions above. Your MAC address will then be kept for the implementation of your opposition for the duration of the trial.

To get your MAC address :

To exercise your right to object, complete the form below :

After submitting the form, your MAC address will no longer be collected. Any data that has not yet been anonymized will also be deleted.

Rights relating to the data collected.

You can also request further information or exercise your right of access, rectification, erasure or limitation of the processing of your data by email at, within 3 hours from the time of collection of your MAC address. Beyond that, post data anonymisation, the data and associated GDPR rights are no longer available.