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PassApp Privacy Policy

This PassApp Privacy Policy (the "Privacy Policy") describes the information that PassApp collects and processes about you and what it can do with that information.

At PassApp, we prioritize the protection of personal data and see it as an opportunity to create value for our users. By responsibly using personal information, we not only protect the privacy of those who have entrusted us with their data, but also enable them to operate securely and confidently within our system and app.

Therefore, your privacy is very important to us and we strive to protect it and work hard to make sure that is the case.

PassApp, in order to provide its services, processes, collects and in some cases discloses information about people who, like you, are users and visitors of the website and/or the app.

This Privacy Statement is an integral part of the PassApp Terms and Conditions click Here

Providing your voluntary, express and informed consent to this Privacy Policy is an essential requirement in order to have any kind of relationship with PassApp.

To make it easier for you to read, we will present several questions and their answers. In case your question is not included, you can send it to info@passapp.net and we will respond within 48 hours.

To begin,

YOU MUST PROVIDE YOUR EXPRESS AND INFORMED CONSENT

for PassApp to transfer or disclose your Personal Information to the recipients detailed in this Privacy Statement.

Now we will show you how we work with your personal data at PassApp:

The objective of PassApp is to streamline and simplify processes that are repeatedly performed in different types of establishments, such as access and exit registrations, pre-authorization of third parties, or space management. To this end, we have created a system that gathers personal information from those who belong to the establishments, as well as their visitors.
For this reason, it is important to note that when you register with PassApp you are generating a user along with a personal password that will allow you to operate within the system. In some circumstances, PassApp must share your data with associated establishments in order to comply with the mentioned purpose.
In Section "How do we share Personal Information?", you can find more information regarding this. This Privacy Statement applies to all PassApp, data processing services and operations, whether it is PASSAPP LLC or its subsidiaries or affiliates.
It is important to mention that PassApp's services are intended for users located in different countries where PassApp has a presence or operation.
PassApp is responsible for the processing of user data through its subsidiaries or affiliates. To find out which company or companies are responsible for processing in your country of residence, please refer to the corresponding Exhibit.
Furthermore, the data controller is the one who decides on the processing of personal data. To do so, they determine the purposes or uses for which personal information will be used, as well as the means that will be used for such processing.
PassApp collects your personal information so that you can access associated establishments in a simpler way, authorize visits, be authorized as a visitor, and/or perform any other available actions for the establishments with which you interact, enjoy our services, and continuously improve them. In some cases, you provide personal data yourself when registering. In others, we process them automatically because a third party shared them with us to facilitate your entry into associated establishments.
The inaccuracy or falsehood of the personal data you provide could result in the suspension and/or cancellation of services. Similarly, Passapp may suspend or permanently disable users who violate this Privacy Policy.

These are some of the personal data that we collect and process with your consent:
1) Information that you provide directly when creating a user:
a) Email address
b) Cell phone number
c) Personal image, such as a selfie
2) Information when completing your user profile:
a) First and last name
b) Country and document number
c) Front and back photos of your documents
d) Date of birth
3) Optional complementary information to complete your profile:
a) Data about your vehicle/s: Make, model, color, license plate number, insurance expiration, and photo of the insurance credential
b) Data about your driver's license: Front and back photos of your license and license expiration date
c) Data as a service provider/supplier: Type of service provider/supplier, materials used, data on workers' compensation insurance or other certificates
d) Access to your contact list, if you give permission, solely to show you which of your contacts also use PassApp

Why do we require your contact information?
Our application may request access to your contact list if you give permission. This access request is made in order to provide you with a more interactive and personalized experience. By accessing your contacts, we only collect basic data such as Last Name, First Name, and Phone Number. This data is securely and confidentially stored in our database.
We use this contact information exclusively for the purpose of allowing you to identify which of your contacts already have our application installed. This functionality makes it easier for you to integrate and connect with your acquaintances within our platform.
We want to assure you that we handle your contact data with the utmost care and responsibility. We have implemented advanced security measures to protect the privacy of your data, such as encryption and restricted access to authorized personnel only.
Please note that we will never share your contact data with third parties without your explicit consent. The collected information will only be used within the context of our application and for the purpose of improving your user experience.

4) Data collected automatically when using the platform:
a) Information about the devices or computers from which you access the PassApp platform and other data captured automatically (such as browser or operating system type or version, settings, and parameters)
b) Internet IP address used when connecting to our services or browsing our websites.
c) Certain information about user and visitor activity within our website and apps. This information may include the URL they come from (whether or not on our website), which URL they subsequently access (whether or not on our website), pages visited, interactions with those pages, searches performed, among other information stored, retained, and processed.
d) If you have the PassApp application installed, the version of the application that you have installed.
The collection and processing of your personal data allows us to provide you with excellent service so that you can access our platform quickly and securely, and offer you functionalities that best suit your needs. Unless specifically prohibited by applicable regulations, PassApp will use your personal data for the following purposes:

-Register you in our systems.
-Identify and contact you.
-Provide you with the services and/or benefits that you use, request or hire with us.
-Create and maintain a record of access and exits to different establishments.
-Address your comments, complaints, and suggestions, as well as provide you with support.
-Address the exercise of your rights in accordance with existing regulations.
-Improve our services, develop new ones, and offer you a better experience with PassApp platforms.
-Comply with legal obligations and requirements from competent authorities.
-Comply with the regulations applicable to PassApp in general.
-Compliance with general information regimes, as applicable in each country.
-Compliance with informative requirements from competent administrative or judicial authorities.
-Provide user information to government entities with collaboration agreements to fulfill their competences.
-Detect and prevent fraud, abuse, and related crimes to protect the security of our users and the sustainability of the platforms.
-Protect the rights of users, third parties, or PassApp's own rights.
-Defend the tangible and intangible assets of PassApp.
-Enforce PassApp's rights against breaches of its Terms and Conditions and this Privacy Policy.
-Allow other users or third parties to enforce their rights.
-Contact you through different channels (email, text messages (SMS), push notifications, phone calls, or any other means) for advertising and/or promotional purposes of PassApp's and/or third-party products and services.
-Carry out all types of marketing activities, advertising, commercial prospecting, and/or market research.

Some of these purposes may not be applicable if: a) you do not use the service associated with those purposes, or b) the services linked to those purposes are not offered in your country of residence.
The use of your data for any other purpose that is not compatible with the details listed above will be communicated to you before we proceed with its processing so that you can freely express your consent.
Lastly, it is important to know that PassApp will maintain your personal data for as long as it is necessary to fulfill the purposes for which they were collected.
Protecting your privacy is very important to PassApp. Therefore, it is important for you to know that we do not sell or commercialize information that identifies our users.
We also do not share or otherwise transfer your Personal Information to third parties, except as indicated below:

PassApp may assign, transmit, and/or transfer your Personal Information to:

"Service Providers": Service providers or outsourcing companies are third parties we hire to act on behalf of PassApp to provide a service following our instructions and in accordance with this Privacy Policy to help improve or facilitate operations through our platform such as (a) computer system providers, cloud service providers, database providers, and technology service providers in general, (b) advertising or marketing agencies, (c) data analysis. These Service Providers only access the information strictly necessary to provide the agreed services and cannot use it for purposes other than those entrusted to them by PassApp.

"Business Allies": Companies with which Passapp has a collaboration or alliance relationship, in order to offer new services. In these cases, PassApp always ensures that confidentiality and security standards are met, through the signing of agreements or conventions whose object is the privacy of the personal data of our users and compliance with applicable legislation.

"PassApp Group": Companies that belong to our corporate group, which operate under our same internal processes and policies, whether controlled, controlling, or affiliated with PassApp, to comply with our internal regulations, and facilitate the management of PassApp's services.

"Public Authorities": Administrative and judicial authorities that require information in the exercise of their competence, for the purpose of: (a) collaborating in the investigation and reporting of fraud, as well as any activity or circumstance that could generate legal liability to PassApp and/or its users; (b) safeguarding a public interest, the procurement or administration of justice, the recognition, exercise or defense of a right in a judicial or administrative process, and/or the resolution of disputes; and (c) complying with applicable laws, regulations, or legal provisions, or a duly founded and motivated mandate from a competent authority.

Likewise, PassApp may disclose your Personal Information to public entities and/or authorities discretely when there are sufficient reasons to consider that your activity is suspicious of attempting or committing a crime or attempting to harm others.
If PassApp decides to share your Personal Information with third parties other than those mentioned, we will request your prior and express consent, provided that there is no legal authorization or obligation that allows it to be done without that consent.
Finally, PassApp will not be responsible for the misuse of your Personal Information by any third party when such third parties directly collect and/or process your Personal Information.
The services provided by PassApp require the support of a technological infrastructure, such as servers and cloud services, which may be owned or provided by third parties.
Part of this infrastructure may be established in a country different from yours.
It may also happen that the recipients of the data indicated above in the section “How do we share Personal Information?” are located in a different country.
The countries receiving the transferred data may not offer adequate levels of personal data protection in accordance with applicable regulations.
In these cases, PassApp takes measures to safeguard your data, through contractual clauses or binding corporate rules that impose the same protection measures as those described in this Privacy Statement.
We will only store personal information for the time necessary to fulfill the purpose for which it was collected, to comply with regulatory or legal requirements, or during the legal prescription period of possible legal or contractual liabilities.
Once that period has ended, the data will be deleted or anonymized in such a way that no person can be individually identified, as established by the legal regulations.
At PassApp we are committed to providing you with more and better services that simplify the various access and actions you have to perform in your life in relation to different establishments.
To achieve this, we may use tools that help us be more efficient through techniques known as "artificial intelligence," "machine learning," or "Big Data." Automated decisions are those that are made based on the use of algorithms and computer programs, without any human intervention in the decision-making process.
In accordance with current regulations, you have the right to request a review of a decision based on automated data processing with a negative impact. For these purposes, you can request it at: info@passapp.net
At PassApp we do everything in our power to protect the privacy of your Personal Information. But it is very important for you to know that the user will be responsible for all acts that take place through the use of their personal information and password.
If you have any questions, you can contact: info@passapp.net
PassApp services are only available for those individuals who have legal capacity to contract in accordance with applicable regulations. Therefore, if you do not meet this condition, you should not provide your personal information.
  
PassApp allows users limited access to certain data, only in cases where it is strictly necessary based on the function they perform, such as a security agent in a establishment, limited exclusively to the data necessary for the performance of the specific task at that particular time.
Under no circumstances may other users communicate your personal information to third parties without your consent and/or the consent of PassApp , as appropriate. And in the event that this occurs, PassApp will not be responsible for the actions of this third party.
PassApp is not responsible for the use that any user or other person may make of the information published on the Website and/or App.
PassApp may include links to third-party websites, which does not indicate that they are owned or operated by PassApp.
Therefore, the processing of Personal Information by the third-party responsible for those aforementioned websites is not covered by this Privacy Policy.
Likewise, you acknowledge and accept that PassApp has no control over such websites and is not and will not be responsible for the content or services provided by such sites, nor for the way in which they process your Personal Information, so if you enter such websites, you do so at your own risk and responsibility.
Applicable regulations grant you certain rights regarding your Personal Information, such as: (i) access; (ii) update; (iii) rectification; (iv) cessation of the sending of advertisements, offers, and promotions; (v) deletion; (vi) revocation of consent; (vii) confidentiality, (viii) portability.
You may make any inquiry, claim, and/or request regarding your Personal Information by contacting PassApp through sending an email to info@passapp.net or through the contact information provided in the exhibit of each country included below.
In certain cases, we will keep in our files your Personal Information that you have asked us to delete in order to comply with the purposes described in this Privacy Policy or when there is a contractual or legal obligation to keep your Personal Information. Once such purpose has been fulfilled or the contractual or legal obligation has been eliminated, we will proceed to delete your Personal Information.
The user expressly acknowledges and agrees that PassApp may use a behavior tracking system through the use of "cookies" and/or other similar tracking technologies.
These technologies are used in order to know the interests and behavior of those who visit or are users of our website and, in that way, provide them with better service or provide related information.
We also use the information obtained through cookies to analyze the pages browsed by the visitor or user, the searches performed, improve our commercial and promotional initiatives, display advertising or promotions, interest banners, news about PassApp, improve our content and articles, personalize such content, presentation, and services, as well as promote and enforce the rules and security of the site; we also use them so that the user does not have to enter their password as frequently during a browsing session, always having as the objective of the installation of cookies, the benefit of the user who receives it, and which will not be used for purposes outside of PassApp.
Likewise, we store cookies to offer a more interactive experience on the site, based on user actions.
Your personal data obtained through these technologies will not be transferred to third parties in a manner different from that indicated in this Privacy Policy.
You should know that the installation, permanence, and existence of cookies on your computer or device depends solely on your will and can be deleted whenever you wish. To learn how to delete cookies from your system, you need to review the Help section of your browser.
In this regard, you can delete stored cookies at any time, configure the browser to request approval before storing cookies, or directly prevent cookies from being stored. This procedure is performed differently in different browsers and must be performed in each browser you use on your devices.
Below we provide the different procedures for managing this setting in the most commonly used browsers:

-From Internet Explorer (on Windows)

http://windows.microsoft.com/es-es/windows-vista/block-or-allow-cookies

-From Firefox

https://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-que-los-sitios-we

-From Google Chrome

http://support.google.com/chrome/bin/answer.py?hl=es&answer=95647

-From Safari (on Mac)

http://www.apple.com/legal/privacy/es/cookies/

If you disable cookies, please note that you may not be able to use and enjoy all the functionalities offered by PassApp.
As required by the principle of proactive responsibility, PassApp complies with the regulations and industry standards regarding security measures applicable to your Personal Information.
However, PassApp is not responsible for illegal interceptions or violations of its systems or databases, or for their use by unauthorized persons. PassApp is also not responsible for the improper use of the information obtained through those means.
In compliance with the applicable regulations, PassApp will make the necessary notifications in case of security incidents or violations of privacy.
If PassApp makes changes in the way Personal Information is managed, we will notify you through our usual channels, such as email or messages through the applications, so that you can give us your consent.
To the extent permitted by the regulations of each country, in the case of users who do not accept those new terms, the contractual link with PassApp will be dissolved and the Personal Information of said user will not be used in any other way than that which was informed at the time of collection.
The Privacy Policy will be governed by the applicable laws detailed in the exhibit of each country included below. In case of any controversy or divergence related to the interpretation, validity, celebration, or compliance with this Privacy Policy, it will be resolved by the competent courts indicated in those exhibit of each country.
Version: The general Terms and Conditions included herein correspond to version V.X-2-08-04-2021.
The provisions of this exhibit are exclusively applicable to users and visitors domiciled in the Republic of Argentina. In case of contradiction between the provisions of the main text of the Privacy Policy and this exhibit, the provisions of this exhibit shall govern for users and visitors domiciled in the Republic of Argentina.

Who is responsible for processing Personal Information?

In Argentina, PassApp Services are provided by PASSAPP S.A.S., CUIT 30715732064, with registered address at Uruguay 1127, 7th floor, Ciudad Autónoma de Buenos Aires, CP 1016, Republic of Argentina.
These PassApp Services are offered through the website: www.passapp.net
The data controller for the data collected in the Republic of Argentina is PASSAPP S.A.S.

How can you exercise your rights to control your Personal Information?

In compliance with the provisions of Law No. 25,326, Regulatory Decree No. 1558/2001, and the binding provisions and/or resolutions issued by the Agency of Access to Public Information, it is communicated that "the owner of personal data has the faculty to exercise the right of access to them free of charge at intervals not less than six months, unless a legitimate interest is proved for that purpose in accordance with Article 14, paragraph 3 of Law No. 25,326. THE AGENCY OF ACCESS TO PUBLIC INFORMATION, as the Control Body of Law No. 25,326, has the attribution to attend to the complaints and claims filed by those affected in their rights due to non-compliance with the current regulations on personal data protection. The owner may at any time request the removal or blocking of his or her name from the databases referred to in this article. In all advertising communications made by mail, telephone, email, internet, or other remote means, it must be expressly and prominently indicated that the data subject has the possibility to request the total or partial removal or blocking of his or her name from the database. Upon request of the interested party, the name of the responsible or user of the database that provided the information shall be informed."

Without prejudice to the provisions of the Privacy Policy, you may also make inquiries and/or exercise the rights of access, rectification, and deletion of your Personal Information by postal mail to Uruguay 1127, 7th floor, Ciudad Autónoma de Buenos Aires, CP 1016.

Applicable Law and Jurisdiction
The Privacy Policy shall be governed by the laws of the Republic of Argentina.
In the event of any controversy or divergence related to the interpretation, validity, celebration or compliance thereof, you and PassApp declare that you submit to the exclusive jurisdiction of the National Ordinary Courts with jurisdiction in Ciudad Autónoma de Buenos Aires, expressly waiving any other jurisdiction that may correspond to you.
The provisions in this exhibit apply exclusively to users and visitors residing in the Federative Republic of Brazil or any other situation in which Brazilian laws apply. In case of contradiction between the provisions in the main text of the Privacy Policy and this exhibit, the provisions in this exhibit shall govern for users and visitors domiciled in the Federative Republic of Brazil.

The collection of your Personal Information is based not only on your express consent but also on: (i) compliance with PassApp's legal or regulatory obligations; (ii) the regular exercise of rights in judicial, administrative or arbitral proceedings; (iii) the execution of the commercial and contractual relationship between PassApp and the users; (iv) the legitimate interest of PassApp or a third party.

By visiting the website: www.passapp.net, you, as an adult person, agree to the collection, use, transmission, production, reception, classification, access, reproduction, distribution, handling, filing, storage, deletion, evaluation, and/or control of information, modification, communication, transfer, dissemination, extraction, or any processing activity ("Processing") of your personal data and information as described in this Privacy Policy.

Who is responsible for processing Personal Information?

In the Federative Republic of Brazil, PassApp Services are provided by PASSAPP BRASIL LTDA, CNPJ sob o nº 43.010.588/0001-77, with headquarters at Avenida Paulista, nº 1765, 7º andar, conjunto 72 – Bela Vista, em São Paulo/SP, CEP 01311-200, Brasil. This company is responsible for processing the personal data we collect from you.

How can you exercise your rights to control your Personal Information?

The applicable regulations grant you the following rights over your Personal Information: (i) access; (ii) correction of incomplete, inaccurate or outdated Personal Information; (iii) anonymization, blocking or deletion of unnecessary, excessive or illegally processed Personal Information; (iv) portability of Personal Information; (v) deletion of Personal Information when it is no longer necessary for the purposes for which it was collected, except in cases of necessary retention for: (a) compliance with a legal or regulatory obligation; (b) transfer to a third party for another reason authorized by laws or any other rule that regulates the protection of personal data in Brazil, including the Brazilian Personal Data Protection Law – LGPD 13,853/2019; or (c) exclusive use by the controller in an anonymous form; (vii) information on the public and private entities with whom PassApp has shared your Personal Information; (viii) information about the possibility of not giving consent and about the consequences of your refusal; (ix) revocation of consent; (x) filing a complaint with the National Authority for the Protection of Personal Data related to the processing of your Personal Information; and (xi) objecting to the processing of your Personal Information due to non-compliance with applicable law.

Without prejudice to the provisions in the Privacy Policy, you may also make inquiries and/or exercise the rights of access, rectification and deletion of your Personal Information by postal mail at Avenida Paulista, nº 1765, 7º andar, conjunto 72 – Bela Vista, em São Paulo/SP, CEP 01311-200.

Applicable Law and Jurisdiction

The Privacy Policy shall be governed by the laws of the Federative Republic of Brazil. In the event of any controversy or divergence related to the interpretation, validity, celebration or compliance thereof, you and PassApp declare that you submit to the exclusive jurisdiction of the competent Courts of the City of Sao Paulo, expressly waiving any other jurisdiction that may correspond to them, except if you are within the legal concept of consumer, in which case you may file claims before the competent Courts of your domicile.
The provisions in this exhibit are exclusively applicable to users and visitors domiciled in the Oriental Republic of Uruguay. In case of any contradiction between the provisions in the main text of the Privacy Policy and this exhibit, the provisions in this exhibit shall apply for users and visitors domiciled in the Oriental Republic of Uruguay.

Who is responsible for the processing of Personal Information?

In the Oriental Republic of Uruguay, PassApp services are provided by PASSAPP URUGUAY S.A.S., RUT: 218839920011, with its address at Blanes Juan Manuel 1121, 003, Montevideo, Ciudad de Montevideo, Oriental Republic of Uruguay.

These PassApp services are offered through the website: www.passapp.net

The database responsible for collecting data in the Oriental Republic of Uruguay is PASSAPP URUGUAY S.A.S.

How can you exercise your rights to control your Personal Information?

In compliance with the provisions of Law No. 18.331 and its amendments, as well as the binding provisions and/or resolutions issued by the Control Authority, and without prejudice to the provisions of the Privacy Policy, you may also make inquiries and/or exercise your right to access, rectify and delete your Personal Information by postal mail at Blanes Juan Manuel 1121, 003, Montevideo, Ciudad de Montevideo, Oriental Republic of Uruguay.

Applicable Law and Jurisdiction

The Privacy Policy shall be governed by the laws of the Oriental Republic of Uruguay.
In case of any controversy or disagreement related to the interpretation, validity, celebration or compliance of the Privacy Policy, you and PassApp declare that you submit to the exclusive jurisdiction of the courts located in the City of Montevideo, expressly waiving any other jurisdiction that may correspond to them.
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