Privacy Policy
Last updated: 5 November 2026
Pamio is a booking and lesson-management platform for driving schools and driving instructors. A school’s owner, administrators and instructors (“staff”) use the Pamio app — on the web and in the Android and iOS apps — to run their diary, keep their students’ records and log Essential Driver Training (EDT) lessons with the Road Safety Authority (RSA). Students reach their school by WhatsApp, Telegram, phone or email, where Pam, the school’s AI assistant, answers, and through private pages of their own. This policy explains what personal data we process, why, who helps us, how long we keep it, and your rights.
It covers pamio.io and its free tools, the Pamio app (web, Android — including Android Auto — and iOS), the students’ pages, the channels students use to reach a school, and the ways people get in touch with Pamio itself.
1. Who is responsible for your data
Pamio Limited (“Pamio”), an Irish company (CRO no. 822663), provides the platform.
- A school’s records — its students and their lessons, messages, calls, notes, mock tests, payments and RSA details: the school is the data controller and Pamio is its data processor. We process them only to provide the service, on the school’s instructions. A data processing agreement is available on request.
- Pamio is the controller for staff sign-in accounts, a school’s subscription and billing with us, our public website and its analytics, people who contact us or ask to hear from us, support conversations, security logs, and running and improving the service.
Questions either way: info@pamio.io.
2. The Free plan, the Pam trial and the Pam plan
Pamio has two plans. Moving from one to the other never deletes anything.
- The Free plan (Ireland only) is RSA lesson logging, mock tests, a student list, account activity and in-app support. For each student it keeps their name and what the RSA asks for (driver number, date of birth and logbook number), the EDT lessons logged and the RSA’s replies, and any mock tests the instructor marks. Outside the Pam trial below, it doesn’t ask for a student’s mobile number or email address, a Free school’s students hear nothing from Pamio — no messages, no reminders, no Pam — and their lessons page stays closed; a mock test reaches a student only if the instructor shares it from their own phone.
- The Pam trial. Every Free school starts with three months of the Pam plan, free. During them the school can connect WhatsApp, Telegram, email and a phone line and Pam answers its students, so everything this policy says about the Pam plan applies. When the three months end, Pam and those channels switch off and the diary becomes read-only; the records stay in the school’s account on the Free plan.
- The Pam plan is the whole product: the diary, Pam on the school’s WhatsApp, Telegram, email and phone line, reminders and confirmations, the students’ own pages and, where a school offers it, card payment for lessons. A school pays for it through Stripe (section 7).
Free means free, not paid for with data. On no plan do we sell personal data, show advertising, or use a school’s student records to market anything.
3. Who uses Pamio
- Staff — a school’s owner, administrators and instructors, all adults — sign in to the app as themselves, with an email address and password, a code we email them, or a Google or Apple account.
- Students never sign in. They message or ring their school as they always have. The school can give a student private links: a setup form for their details, a lessons page to book, move or cancel, a page with their instructor’s lesson notes, a page to take up a lesson the school offers, and a payment page. Each link is personal and works like a key, so it shouldn’t be shared.
- Anyone can use pamio.io and its free tools, such as the mock test marker, without an account.
4. What we collect
| Whose data | What | Why |
|---|---|---|
| School staff (owners, administrators, instructors) | Name, email address and mobile number; a password (stored only as a secure hash) or the Google or Apple account you sign in with; the school’s details (name, country, areas, working hours, cars, prices); when you last signed in, and the platform (iPhone, Android or web), its system version and the app version you last used; a push token for each device where you allow notifications, and your notification settings; the access needed for the channels you connect (a Telegram bot, your own WhatsApp Business number), stored encrypted; usage analytics (pages viewed, buttons tapped, errors) and recordings of the app’s screens, with students’ details and everything typed masked. | To create and secure your account, sign you in, run the app, send the notifications you ask for, and find what needs fixing. |
| A school’s billing | The plan, the number of instructors, the price and any trial dates; the school’s name, its billing email and Stripe’s customer and subscription references; invoices and payment status. For a school in Great Britain, the business evidence UK tax rules ask us to keep (a DVSA ADI or PDI number, or a company or VAT number). Card details go to Stripe, never to us. | To bill the subscription, keep tax records and show the school what it pays. |
| A school moving its phone number to Pamio | The account holder’s name and address, the account number and billing phone number with the current provider, a signed porting form and a recent bill. The two documents go straight to Telnyx and are not kept by us. | To move the number. |
| Students (entered by the school, or by the student on the setup form) | Name, mobile number and email address (and any extra address for lesson updates); licence category, gearbox, area and usual meeting point; the student’s own car (make, model, colour, registration) if lessons are in it; a driving test date the student gives; the phone number, Telegram account or email address they message from; lessons booked, moved, cancelled, confirmed or missed, and the reminders sent; messages with the school on WhatsApp, Telegram and email, including Pam’s replies and — where a school runs its own WhatsApp Business number through Pamio — the school’s own replies from the WhatsApp Business app; for phone calls, the caller’s number and a text transcript; lesson notes and mock tests the instructor writes (faults, notes, result); payments for lessons; acceptance of the school’s terms, or a request not to be contacted; and how the student first reached the school — for example an ad, the school’s website, its Pamio page or ChatGPT — kept as a source, a campaign name and, from ChatGPT, the place and gearbox they asked about; never a browsing history. | To book and run lessons, send reminders and confirmations, let Pam answer the student’s questions about their own lessons, give staff the student’s history and conversation, take payments where offered, and show the school which of its ads bring students. |
| Learner drivers — RSA logging (Ireland) | The student’s date of birth and driver number (both from the learner permit), the logbook number the instructor issued, the EDT programme and which modules are complete, and — for each lesson logged — the RSA’s reply (accepted, already recorded or refused, and why). The student may enter their permit details on the setup form; the instructor may enter or correct them. When an instructor’s phone checks the RSA portal, Pamio also receives what the portal lists under that instructor’s login for the last two months (driver number, date of birth, logbook number, name, module and dates), matches it to the school’s students by driver number and fills in permit details that are missing. A row for anyone who isn’t one of the school’s students is used only to suggest a match, and is not stored. | Only to log the student’s EDT lessons with the RSA on the instructor’s behalf, keep a true record of what the RSA holds, and show the instructor what is left. Not used for anything else. |
| People who message a school before they are set up | A new number that messages a school is sent the school’s setup form. Until the form is done we keep the number, the messages and how the person found the school as a pending record that the school’s staff can’t see. Someone who finds a school through ChatGPT or the school’s Pamio page and opens its sign-up link becomes a pending record too, with the area and gearbox they asked about (and, from ChatGPT, an anonymous reference to their ChatGPT connection). | To join the person to the school once they finish the form, and to count what each of the school’s ads brought. |
| People who try Pam on our demo number | Your phone number, your messages or call, and any test lessons. | To let you try Pam. Deleted automatically about a day later. |
| People who ask us to get in touch (the demo form, a “Call me” field, or a WhatsApp message to our own number) | Name, mobile number, school name if given, what you wrote, and a label saying where you came from (for example “google / organic”). The demo form and “Call me” go to our team’s private Telegram group; a WhatsApp message to our number is kept in our support records. | To call or message you back about Pamio. Deleted on request. |
| Driving instructors who ask about the Free plan | The email address you leave on pamio.io (on the Free plan page, or the bar and menu on other pages), where you left it, the page or campaign that brought you, and whether you confirmed, unsubscribed or heard back from us. We keep it only once you tap the confirmation email; an unconfirmed address is deleted after 30 days. When the Free plan opens to you, our team switches on sign-in for your address, and signing in with the code we email you creates your free account. | Only to tell you about the Free plan and help you start on it. Every email carries an unsubscribe link; once you unsubscribe we keep the entry only marked as unsubscribed, so you are never emailed again. |
| Driving instructors who use the mock test marker on pamio.io | While you mark, the sheet stays in your browser on your phone. When you email it: your email address, the sheet itself (the faults, your notes, the student’s first name if you typed it), a student’s email address if you ask us to send them a copy, and the page and campaign that brought you. Your address joins our list for the marker, and our team is told it was used. | Only to send you the sheets you ask for; we send you nothing else. A student’s copy carries nothing from us but the sheet, and we don’t store the student’s address. |
| Visitors to pamio.io and to schools’ Pamio pages | Pages viewed, buttons clicked, where you came from (such as a search engine, an ad’s tags or the page that linked to us), your device and browser type, and your approximate location (town or country, worked out from your IP address); Google Analytics cookies unless you turn them off (section 8). On a school’s Pamio page and its WhatsApp button page we count visits and taps by source and campaign, and may match a first message to the ad that brought it. | To understand how people find and use the site and which of a school’s ads work. Never used to identify you or for advertising. |
| Everyone | The technical data any web service needs: request and security logs, including IP addresses; a bot check on the sign-up form (Cloudflare Turnstile); and, from the students’ setup form, error reports (the browser type and what went wrong). | Security, reliability and abuse prevention. |
On your phone
Permissions. The mobile apps ask for the microphone only while you record a voice message for support, for your photo library (on iPhone) only so you can pick a photo or video to send to support, and for notifications if you want them. Nothing is read or sent until you pick or record it, and the rest of the app works without them. The apps don’t use your location.
“Import from phone” opens your phone’s own contact picker and reads only the one contact you pick — their name and phone number — to fill in the form. Nothing else is read from your contacts, no contact list is uploaded, and those details are saved only if you then add that student.
Android Auto. In the car the Android app shows the day’s lessons. It keeps the last list it fetched (names, mobile numbers and meeting points) in the app’s private storage so it still works without signal, and deletes it once you are signed out. Lesson notes are fetched when you tap them and are never stored on the phone.
The RSA portal
When an instructor logs an EDT lesson, Pamio sends the learner’s driver number, date of birth, logbook number, the module and the lesson date to the RSA’s ADI portal — exactly what the instructor would type into it by hand — and reads back the portal’s records as described above. The RSA is not a Pamio service provider: it is a separate public body running its own portal under the instructor’s own account, and it holds that record under its own rules. Pamio cannot alter or remove a lesson once the RSA has recorded it.
The instructor’s RSA portal login is never stored by Pamio. It lives only on the instructor’s own phone, in the phone’s secure store, and is used on that phone to sign in to the portal. Pamio’s servers hold the instructor’s ADI number and name as the portal shows them, which phone is connected and when the login was last checked — never the password.
Payments
Paying for a lesson. Where a driving school offers to take payment for a lesson through Pamio, the payment page and your card details are handled by Stripe, our payment processor, under Stripe’s own privacy policy, and the money goes to your instructor’s own Stripe account. Pamio never sees or stores your card number; we keep a record of the payment (amount, date, the card brand, country and type Stripe reports, the lesson it paid for, and the instructor it was paid to) so your instructor, the school and you can see what was paid and so refunds can be made. The Booking Terms explain who you are paying. An instructor who takes payments gives Stripe the identity and bank details Stripe asks for, directly on Stripe’s pages.
Paying for Pamio. A school’s subscription is billed through Stripe too, and Pamio never sees the card.
We do not collect payment-card details ourselves, your precise location, health data or other special-category data. We do not record calls: a call’s audio streams to the voice provider while it happens (section 7) and we keep only a text transcript. The only recorded audio we handle is a voice message you choose to send to support.
5. How we use personal data
- Run the service: the diary and bookings, Pam on the school’s channels, reminders and notifications, RSA logging, mock tests and notes, payments, and accounts.
- Keep accounts secure and prevent abuse.
- Bill a school’s subscription, and send staff the emails that come with it (trial, billing and account emails).
- Answer support requests.
- Show a school where its students come from and which of its ads work.
- Understand how pamio.io and the app are used, find faults, and improve reliability and quality.
AI. Pam is an AI assistant. It reads a student’s messages to answer questions about the student’s own lessons and the school, and hands anything else to the school’s staff; the student books, moves and cancels on their own lessons page. Pam makes no decisions about anyone that have legal or similarly significant effects. We also use AI to sort emails a school receives from addresses it doesn’t know yet, to summarise email threads for staff, and to give a first answer to in-app support requests (anything it can’t answer goes to our team). None of our AI providers uses this data to train its models.
Who at Pamio sees data. Pamio’s founders can see a school’s records, to support the school and run the service, and may read a conversation or call transcript to fix a problem or improve Pam’s answers. Every change they make to a school’s account is recorded.
We do not sell personal data, and we do not use it for third-party advertising.
6. Legal bases (GDPR)
- Contract — to provide the service to a school and its staff, and to bill for it.
- Legitimate interests — to secure, maintain and improve the service (including analysing how staff use the app and checking the quality of Pam’s answers), to reply to people who contact us, to measure how our public website is used, and to show a school which of its ads work — balanced against your rights; you can object (section 11).
- Consent — where you opt in to something specific, such as the Free plan emails (confirmed by your tap), notifications, or the phone permissions above; you can withdraw it at any time.
- Legal obligation — tax and accounting records, and requests we are legally bound to answer.
For a school’s records, the school decides the legal basis for its own use of them; we process them on its instructions.
7. Service providers we rely on
We use a small set of providers (sub-processors) to run Pamio. They process data only on our instructions and under contract.
| Provider | What it does for us | Where |
|---|---|---|
| Amazon Web Services (AWS) | Hosting, the database and file storage, sending and receiving email, maps, and alerts. Everything we hold is stored here. | EU (Ireland) |
| Anthropic | The AI behind Pam’s messages, the sorting and summaries of emails, and first answers to support requests. It receives the messages and the context needed to answer them (such as the student’s lessons and the school’s details). | United States |
| OpenAI | Pam’s voice on phone calls, where a school takes calls; it hears the call as it happens and receives the call’s context. | United States |
| Deepgram | Pam’s voice on phone calls for a school that uses it instead of OpenAI; it hears the call as it happens and receives the call’s context. | United States |
| Telnyx | WhatsApp messaging, phone numbers and calls, and moving a school’s existing number to Pamio. | United States |
| Meta (WhatsApp) | Every WhatsApp message passes through WhatsApp. A school that connects its own WhatsApp Business number uses Meta’s platform directly, and connecting it in the app opens Facebook’s sign-in. | EU and United States |
| Telegram | The Telegram channel, where a school uses it, and our team’s internal messaging. A screenshot, video or voice message you attach to a support request is delivered there and lives there, not on Pamio’s servers. | Outside the EU/EEA |
| Stripe | A school’s Pam plan subscription, and card payments for lessons. | EU and United States |
| Sign in with Google; Firebase, for sign-in and notifications in the mobile apps (it carries the notification’s text); Google Analytics on our public pages (section 8); and Google Fonts, which sees your IP address when a page loads its fonts. | United States and EU | |
| Apple | Sign in with Apple, and delivering notifications to iPhones. | United States |
| Browser push services | Delivering notifications to a web browser (Google, Mozilla, Apple or Microsoft, depending on the browser); the notification itself is encrypted. | Depends on the browser |
| PostHog | Analytics, error reports and masked screen recordings in the app, keyed by internal IDs rather than names or numbers; anonymous visit counts on our public pages. | EU (Frankfurt) |
| Cloudflare | The bot check on the sign-up form (Turnstile), which sees your IP address and browser details. | Worldwide |
| Fontshare | A font on our pages; it sees your IP address when the font loads. | Worldwide |
Where a provider processes data outside the EU/EEA, the transfer is covered by appropriate safeguards, such as the European Commission’s Standard Contractual Clauses or the EU–US Data Privacy Framework.
Not our providers, but they receive data: the RSA (section 4); ChatGPT, when a student uses it to find a driving school — it sends us the place and gearbox they asked about and we send back schools and a sign-up link; the networks that carry a message or call to the school; a school’s own WhatsApp Business account and Telegram bot; an instructor’s own Stripe account, for a lesson payment; and a school’s previous phone provider, when its number moves to Pamio.
8. Cookies and similar technologies
pamio.io uses a few cookies and some browser storage. You can change your choice at any time from the Cookie settings link at the bottom of every page, or here: .
| Name | What it does | Kept for |
|---|---|---|
| Strictly necessary — always on | ||
| pamio_admin | Keeps you signed in to the app | 90 days, or until you sign out |
| pamio_pending | Holds a sign-up between the form and the email confirmation | 24 hours |
| pkce_verifier, signup_intent, signup_src, signup_country, invite_token, app_flow | Carry a Google sign-in, a sign-up or an invite through to the end (signup_src: where you came from; signup_country: the country you picked) | 10 minutes |
| pamio_cookie_consent (browser storage) | Remembers your cookie choice | Until you change it |
| Preferences (browser storage) | Small things on that device: a banner you closed, the app’s settings, recent searches, a form or mock test you haven’t finished, and the email address you last signed in with | Until you clear your browser’s data |
| Analytics | ||
| _ga, _ga_2T5ZD7PF8N | Google Analytics: counts visits to our public pages — a school’s Pamio page and its WhatsApp button page included — and where visitors came from. On unless you press Reject all or turn Analytics off in Cookie settings; then they are deleted and none are set again. | Up to 2 years |
| ph_phc_…_posthog | PostHog: counts page views and clicks on our public pages without identifying you, and runs the app’s analytics once you sign in. It is not covered by the Cookie settings switch. | Up to 1 year |
| On a school’s own website | ||
| pamio_attr | Set by Pamio’s link script if the school adds it to its own website: keeps an ad’s campaign tags so a tap through to Pamio is credited to the right campaign. It sends nothing to us by itself. | 30 days |
We never use cookies for advertising. Google Analytics isn’t used in the Pamio app, and the students’ own pages (the setup form, lessons page, notes page, offer page and payment page) load no analytics or third-party scripts; the payment itself happens on Stripe’s page, under Stripe’s own cookies.
9. Where data is stored, and for how long
Pamio’s data is stored in the European Union (AWS, Ireland); the providers in section 7 process some of it elsewhere while they do their part.
- A school’s records — students, lessons, notes, mock tests, the RSA record, payments, call transcripts, the messages Pamio sends and the account’s activity — are kept while the school keeps its account.
- Chat messages from students (and a school’s own replies from the WhatsApp Business app) are kept for 7 days after the conversation goes quiet. An incoming email is kept for 7 days, and what’s needed to keep an email conversation together for up to 30 days.
- A pending record (someone who messaged a school but hasn’t finished its setup form) stays until they finish it or the school’s account is deleted; ask us and we will delete it sooner.
- Demo testers are deleted automatically about a day after they try Pam.
- Our email lists (the Free plan and the mock test marker): an unconfirmed Free plan address is deleted after 30 days; any other entry stays until you ask us to delete it.
- Support conversations are kept as our record of what was asked and answered, also after a school deletes its account, and are deleted on request.
- Logs: security and service logs are kept for up to 90 days.
- Backups: the database is backed up every day, and backups are kept for a short period before they are deleted.
- Billing: Stripe keeps invoices and payment records for as long as tax and accounting law requires.
When a school deletes its account (Settings → Account → Delete account — see Delete your account), its staff, students, lessons, conversations, notes, mock tests, RSA records, payment records, devices and activity are deleted at once. We keep only a short record that the account existed (the school’s name, the first administrator’s name and email, the plan, how many students and lessons it had, and when and why it was deleted), support conversations, the log of changes our team made, and — if the address came from our Free plan list — that entry, marked as deleted. Backups, logs and the 7-day chat window age out as above.
Removing a student or a staff member. A school can delete a student who has no lessons on record; a record with lessons stays part of the school’s history, and a student can ask their school, or us, to erase it completely. The school’s activity history keeps a line saying the student was removed. A removed staff member loses access at once on every device; an instructor whose name is on past lessons stays as a removed record so the school’s history stays whole.
10. Security
Everything between your device and Pamio travels over HTTPS/TLS. The database, its backups and our stored files are encrypted at rest, and the access tokens for a school’s connected channels are sealed with keys held in AWS’s key service. Passwords are stored only as secure hashes. The database and services run inside a private network, and what each person can see is decided on our servers by their role. No system is perfectly secure, but we take reasonable measures to protect personal data; our security page says more.
11. Your rights
Subject to applicable law, you can ask to access, correct, delete, export or restrict your personal data, and you can object to processing based on legitimate interests. To exercise any right, email info@pamio.io. For a school’s records about you — as one of its students or instructors — the school is the controller: ask the school, or ask us and we will pass the request on and help it act. A school’s administrator can delete the whole account from Settings → Account.
You can also complain to a data protection authority: in Ireland, the Data Protection Commission (dataprotection.ie); in the UK, the Information Commissioner’s Office (ico.org.uk); elsewhere in the EU/EEA, your local authority.
12. Children
Pamio is not directed at children, and only adults use the app. Learner drivers can be as young as 16: their records are created and managed by their school, their own pages open only through the school’s personal links, and we collect a student’s date of birth only because the RSA needs it to log EDT lessons.
13. Changes to this policy
We may update this policy from time to time. We’ll change the “Last updated” date above and, for material changes, take reasonable steps to let account holders know.
14. Contact
Pamio Limited (CRO no. 822663) · info@pamio.io