The following text is a full statement of the privacy policy of Passle Limited (we, us, our) a company registered in England under company number 08044570 and with registered address at 1a Walton Crescent, OX1 2JG Oxford, UK.

We respect your privacy rights. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

We receive a number of different types of information about you, including the information that we require when you register and the information you submit to our website, the app or any other related software and services provided by us (the Service).

Registration information

When you sign up for the Service, you are required to provide your name, email address and password and you may submit an image, which may identify you.

Information you choose to share

Your information also includes the information you choose to share on the Service.  This includes a record of each time you visit the Service as well as when you post information on it, upload a file such as an image, document or video, or comment on something that another user has uploaded. It also includes the information you choose to share when you take an action on the platform.

Information others share about you

We receive information about you from other users of the Service, such as when they post information on the Service, invite you to join a Passle, upload your contact information, post a photo or video of you.

When people use the Service, they may store and share information about you that they have, such as when they upload and manage their invites and contacts.

We stipulate in our Terms of Use that other users must not upload any personal data about you without your permission.

Other information we receive about you

We also receive other types of information about you:

  • When you post things like photos or videos on the Service, we may receive additional related data (or metadata), such as the time, date, and place the photo or video was created.
  • We receive data from the computer, mobile phone or other device you use to access the Service, including when multiple users log in from the same device. This may include your IP address and other information about things like your internet service, location, the type (including identifiers) of browser you use, or the pages you visit.  It will also include the date and time you visit the Service.

Who can see information about you?

The information that you choose to share and the information that others share about you is available to other users of Passle. In this statement this information is referred to as Your Information.  Once made ‘Live’ Your Information is made available to other users of the Service. It is also possible for other users to copy Your Information (for example by taking screen shots, or printing).  We have no control over the use or distribution of these kinds of copies.

If you are uncomfortable that any information that you choose to share appears on a Passle you can delete it, or we can delete it for you on request. Be aware that prior to deletion other users may have already made copies of the information beyond our control.

In addition, we may disclose any information we receive about you in the following circumstances:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements or to protect the operation of the Service, or the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

How we use the information we receive

We use Your Information in connection with the services and features we provide to you and other users like your colleagues and our partners including for the following purposes:

  • as part of our efforts to keep our products and services (including those which our suppliers provide to you through the Service) safe and secure;
  • to protect our or others’ rights or property;
  • to make suggestions to you and other users of the Service; and
  • for internal operations, including troubleshooting, data analysis, testing, research and service improvement.

Where we store information about you

The data that we collect from you may be transferred to, and stored at, a destination outside the EEA, including any member of our group (meaning any parent undertaking or subsidiary undertaking of us, as those terms are defined at section 1162 of the United Kingdom’s Companies Act 2006). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Service; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.

How long we store the information we receive

We store data for as long as it is necessary to provide products and services to you and others, including those described above. Typically, information associated with your account will be kept until your account is deleted. However, you understand that information will still be contained in archive or backups for a reasonable period of time or retained if required by law. Account and personal data can be deleted by you or on request.

For certain categories of data, we may also tell you about specific data retention practices.

Cookies

We may obtain information about your general internet usage by using a cookie file, which contains information that is transferred to your computer’s hard drive. They help us to improve the Service and to deliver a better and more personalised experience.

How we use the data we collect

We may use data collected about your use of different functions of the Website and Service in connection with the features we provide to you, and share this data with other users like your colleagues, other customers and our partners, including for the following purposes:

  • To provide you with a customised experience when you visit our Website and Service
  • To provide you with technical and customer support
  • To communicate statistics around posts created, viewed, shared etc
  • To share data regarding the performance of ISTATOY emails with other customers for sales conversions and lead generation
  • To share data regarding digest subscriptions and the performance of Channel digest newsletters with customers

We will only process any personal data relating to you for the specific purposes outlined above if you have given us your explicit consent to process that data.

You can find out more about our use of cookies, how our third-party services use cookies, and how to control your cookies on our separate Cookie Policy page, which forms part of this Privacy Policy of Passle Limited.

Your Rights

You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

You have the right to access information which we held about you.  Further information is available on this page – which sets out how you can make a data subject access request.

You also have the right to ensure that we hold correct and up to date information. If you believe that any information we hold about you is incorrect or out of date, please contact us at our registered address. We may need to ask you for further information and identification to help us to comply with this request.

Finally, we may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

Children

Our Service is not directed at persons under 16. If you are a parent and become aware that your child has been using our Service you can contact us at support@passle.net and we will take steps to remove any personal information, content and/or delete the account.

Changes to Our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to support@passle.net.

Last updated 20 November 2019