Privacy & Cookies

Introduction to this Policy.

Passport365 (hereinafter, “Passport365.com”) is committed to protecting the privacy of its users.  This Privacy & Cookie Policy ( the “Policy”) is designed to help you understand what information we gather, how we use it, what we do to protect it, and to assist you in making informed decisions when using our services.  Unless otherwise indicated below, this Policy applies to any website that references this Policy, any of Passport365.com’s websites, as well as any data Passport365.com may collect across partnered and unaffiliated sites.

For purposes of this Policy, “Services” refers to the Passport365.com’s service which can be accessed via our website located at Passport365.com  The terms ‘us’, ‘its’, ‘ours’ and/or ‘we’, as used herein, shall refer to us, Passport365.com and/or our affiliates, assignees, successors and/or brands.  As used herein, the terms ‘you’, ‘your’, and/or ‘yourself’ refer to you, a user/visitor/browser of our websites, whether registered under an account or not.

As used herein and elsewhere, the words “collect”, “use”, “process”, “treat”, “disclose” and analogous shall be related to personally identifiable information (the “PI”) and other data that we may collect from our users and/or visitors, including cookies inside a computer and mobile device IDs.

This Policy shall be supplemented by our Terms and Conditions of Use (the “Terms”), and any other guidelines, terms and policies made available by us from time to time, incorporated herein by reference.

Consent & Scope of this Policy.

By accessing our Services, you accept our Policy and Terms, and you consent to our collection, storage, use and disclosure of your PI information as described in this Privacy Policy.  In addition, by using our Service (on our websites or across partnered and unaffiliated sites) you are accepting the practices described in this Policy.  We will also ask for your specific consent to certain parts of the Service (i.e. newsletter subscription) via clickable boxes with legends similar or analogous to “I Accept”.

Information Gathering and Usage.

We may collect both “Non-Personal Information” and “Personal Information” about you. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. “Personal Information” includes information that can be used to personally identify you, such as your name, address and email address.

When you register for any Passport365.com product, we will ask for information such as your name, company name, email address, billing address, credit card information.  Members who sign up for the free account are not required to enter a credit card.

Passport365.com uses collected information for the following general purposes: Services provision, billing, identification and authentication, Service improvement, contact, and research.  Passport365.com does not share your personal information with third parties, unless explicitly approved by you.

The information we collect is used to improve the content of our websites and the quality of our Service, and is not shared with or sold to other organizations for commercial purposes, except to provide Services you’ve requested, when we have your permission, or under the following circumstances:

• When it is necessary to share your PI in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of the specific application, or as otherwise required by law.
• When we transfer your PI if Passport365.com is acquired by or merged with another company. In this event, Passport365.com will notify you before PI about you is transferred and becomes subject to a different privacy policy.

In addition, we may also track information provided to us by your browser and mobile device IDs when you view or use the Service, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Service, the time and date of access, and other information that does not personally identify you.

If you do not wish to disclose any or part of your PI to us, you may still be able to use some of the functionalities of our Services, though we will not be able to guarantee that you will be able to enjoy them at their fullest if you elect not to disclose it to us.  Overall, your final remedies will be to close this web tab, delete your account with us and/or exit our Service.

Your Rights as Data Subject.

The General Data Protection Regulation (GDPR) allows individuals in the EU greater control over their personal data and grants them a number of rights with regard to how that data is processed, stored, and accessed.

For the purposes of the GDPR, in the European Union Passport365.com is both a “data controller” and a “data processor” of PI you provide to us for the primary purposes of providing you with our Services.

The section below covers the certain situations that you, as data subject, and we as a data controller, are most likely to see, but you should also carefully review the full list of data subject rights here: https://gdpr-info.eu/chapter-3/.  You retain the right to access, amend, correct or delete your PI where it is inaccurate at any time.  To do so, please contact support@passport365.com.

• The right to be forgotten:  You can request us to be “forgotten”; that is, to have all of your PI removed from our Service.  If we are asked to do this, we will remove any PI you we collected from you as requester.  We will also need to contact any third parties, such as our cloud service providers, that process your PI on our behalf.  To ensure that any personal data in Passport365.com’s possession can be removed in a timely manner, you can relay any request to be “forgotten” to us by submitting a request-
• Data portability:  Under the GDPR, our users located in the EU may request Passport365.com to send them any PI in our possession.  In this case, we will provide you with any PI that you have in a commonly used, machine-readable format.
• Access:  As a data subject, you can ask Passport365.com to confirm how and where your PI is being stored and processed.  You also have the right to know how such that data is shared with third parties by us.
• Rectification:  As data subject, you have the right to obtain from Passport365.com, without undue delay, the rectification of inaccurate PI concerning you.

Your privacy request must include, at the least, the following information: (i) your complete name, address and/or e-mail address in order for us to notify you the response to your request; (ii) attached documents establishing your identity; and (iii) a clear and concise description of the PI with regard to which you seek to enforce any of your privacy rights.  If you request rectification, please indicate amendments to be made and attach documentation to back up your request.

Upon receipt of your privacy request, and after due review, we may then edit, deactivate and/or delete your PI from our Services within thirty (30) days.  In case of secure databases under our control where deletion is impossible, we will make such information permanently inaccessible.

Email Communications & Opting Out.

We collect the e-mail addresses of those who communicate with us via e-mail, aggregate information on what pages users access or visit, and information volunteered by the consumer (such as survey information and/or website registrations).

We will send you Service-related announcements on occasions when it is necessary to do so.  For instance, if our Service is temporarily suspended for maintenance, or a new enhancement is released, which will affect the way you use our Service, we might send you an email.

Generally, you may not opt-out of these communications, which are not promotional in nature.  Based upon the PI that you provide us, we may communicate with you in response to your inquiries to provide the services you request and to manage your account.  We will communicate with you by email or telephone, in accordance with your wishes.  We may also use your Personal Information to send you updates and other promotional communications.

If you no longer wish to receive those email updates, you may opt-out of receiving by following the instructions included in each update or communication.

Information Collected from Payment Processors.

We use third party payment partners in order to bill and process any payments and subscriptions made via our Services.  These platforms will request you to disclose them sensitive information in order to complete purchases and operations related to our Services.  Such third-party payment processing platforms are governed by their own safety standards, policies and terms of use.

We take great care in selecting our third party payment processing platforms, and stride to be aware of their operations and functionalities.  We strongly advise our users to engage in online safety measures and practices in order to protect their financial information.

Information Collected from Mobile Devices.

When you access our Service via a mobile device, we may use your mobile device ID (i.e. the unique identifier assigned to a mobile device by the manufacturer) and/or Advertising ID (for Apple iOS 6 and later) instead of cookies in order to recognize you, track the relevant ads displayed, and their performance and display.

Links to other websites.

As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain.  This Policy applies solely to information collected by us through the Service.

Therefore, this Policy does not apply to your use of a third-party website accessed by selecting a link via our Service.  To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that website or application.  We encourage our users to read the privacy statements of other websites before proceeding to use them.

Cookies & Web Beacons.

A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a web website’s computers and stored on your computer’s hard drive.  Cookies are required to use the Services.  We use cookies to record current session information, but do not require permanent cookies.

We also use the so-called ‘beacons’, which are small files, sometimes only a pixel in size, embedded onto the pages of our websites.  Beacons are used to identify each of our pages in order to be analyzed by our system tools.

We may also collect and use the data contained in log files, which may include your IP (internet protocol) address, your ISP (internet service provider), the browser you used to visit our platform, the time you visited our platform and which sections you visited.

You can always configure your browser to refuse cookies and beacons.  For more information, please visit www.allaboutcookies.com.  Unlike cookies, device IDs cannot be deleted, but you can select to reset your Advertising IDs in the “Settings” section of your mobile device, among other settings.

We do not currently offer “do-not-track” or similar mechanisms.

Data and Information Storage.

Passport365.com uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run our Services. Although Passport365.com owns the code, databases, and all rights to the Passport365.com applications, you retain all rights to your PI.  Your PI is only accessible by a limited number of our employees who have special access rights.

We will retain your PI only for as long as it is reasonably necessary for our business purposes (e.g. as long as your account is active).  We will also retain and use your PI for our compliance obligations, to resolve disputes among our users, and enforce our contracts with authorized third parties.

Please take into account that the Internet and related transmissions are not secure or error free communication means.  Additionally, if you post information on a public forum, message board, blog or bulletin board, any PI you elect to disclose therein there may or will be read, collected and/or used by other users of such forums and could be used by third parties to send you unsolicited messages.

Disclosure of Personally Identifiable Information.

Passport365.com may disclose personally identifiable information under special circumstances, such as to comply with subpoenas or when your actions violate the Terms of any of our applications.  Accordingly, we must reserve our right to disclose your PI when we or our affiliates, clients, contractors, licensors, officers, agents and/or representatives reasonably believe it necessary to protect our interests, or where you result to be in breach of our Terms and/or this Policy.

Henceforth, we will have the right to disclose any and all collected PI and/or data, under the following circumstances:

• If required under applicable law, rules or regulations.
• In response to a valid request or subpoena from a government or law enforcement agency.
• To defend ourselves and our affiliates, licensors, officers, agents and representatives from legal claims and processes brought to us by third parties (including takedown notices).
• To defend the property, rights and integrity of any of our users, advertisers or licensors.
• To stop or cause to cease any actions that we may consider to cause –whether allegedly or factually– a contingency or liability.

Changes to this Policy.

Passport365.com may periodically update this Policy.  We will notify you about significant changes in the way we treat PI by sending a notice to the primary email address specified in your Passport365.com Service primary account holder account or by placing a prominent notice on our websites.  Your continued use thereof after the last effective date of modifications thereof indicates your acceptance of such modifications.

Service Eligibility & Age of Consent.

Through the simple use of our platform and our products and services, you hereby represent and warrant that you are at least eighteen (18) years of age –or older– as of the date of first access thereof.  If you are still a minor (which may depend on the jurisdiction where you reside), you may only access our Services under the direct supervision of your parent or legal guardian.

Passport365.com does not knowingly collect any kind of information from persons under the age of thirteen (13).  If we learn or have reason to suspect that any user is under the age of thirteen (13), we will delete any PI under that user’s account.

International Transfer Notice.

We have our headquarters in the United Kingdom.  Henceforth, your PI may be accessed by us or our affiliates, agents, partners, advertisers or third-party service providers in the United Kingdom and our locations which may or may not be located in your country of residence, and you hereby consent to such access and transfer by simple disclosure.  All Passport365.com related entities are subject to the privacy practices set out in this Policy and any applicable jurisdictional legislation.

How to Contact Us.

If you have any questions regarding this Policy or the practices of our websites, or wish to withdraw your consent for the continued collection, use or disclosure of your PI, please contact via our contact us from https://www.passport365.com/contact-us/ or in writing to: PASSPORT365 GLB, Data & Privacy,  Suite C, 107-109 The Grove London, England, E15 1HP.

Date of last effective update is 20th May, 2018.