Legal Policies

Effective Date: 06.03.2025

This Privacy Policy (“Policy”) is an integral part of our End User License Agreement (“EULA”) and Terms of Service (“TOS”). It explains how OVO Dijital Servisler Anonim Şirketi (“Company,” “we,” “us,” or “our”) handles data when you use the PassMate - Passbook Wallet mobile application (“App”) and related services (“Services”).

This Policy outlines the types of data we collect, how we use and protect it, and your rights regarding your personal data, in compliance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

For any privacy-related inquiries, contact us at: support@getpassmate.com

1. Data Collection & Usage We do not collect or store personal data via the App. However, we collect limited user-provided data when you contact us for support.

Data Collected Only When Users Contact Us: If you reach out to us via email for support or inquiries, we may collect:

• Name & Surname (if provided) • Email Address (for responding to your inquiry) • Address (to understand location-specific issues) • Device Model & Operating System (for troubleshooting technical issues) • Pass Type (to identify the type of digital pass used in the app)

Purpose: This information is used only to provide customer support and resolve technical issues. We do not sell, rent, or share this data with third parties.

Data NOT Collected by Us: • We do not collect personal data through the app. • We do not track, sell, or share personal information.

2. Third-Party Services & Data Processing While we do not collect personal data, the App integrates third-party services that may process non-personal data for analytics, push notifications, and crash reporting. These services include:

• Firebase Services (Google LLC) : Used for crash reporting (Firebase Crashlytics), analytics (Firebase Analytics), and push notifications (Firebase Cloud Messaging - FCM). • Huawei Cloud Services: Used for push notifications (Huawei Cloud Messaging - HCM) and device analytics on Huawei devices. • Amazon Web Services (AWS): Used for secure backend hosting and API infrastructure.

Third-Party Data Processing: These services may collect non-personal device information, such as: • Device model, OS version, time zone, country, and crash logs (for debugging & app performance) • Push notification tokens (for sending notifications) • Approximate location (via IP address) (for analytics purposes, but not stored)

Opt-Out: Users can disable tracking, analytics, and push notifications via device settings

For more details, review the privacy policies of these third-party services: • Google Firebase:
https://firebase.google.com/support/privacy • Huawei Cloud Services:[https://developer.huawei.com/consumer/en/doc/app/10134

3. Data Sharing with Third Parties We do not share, sell, or rent any personal data with third parties. However, we may disclose limited information under specific circumstances as outlined below:

Subject to Your Consent We may share personal data only if you explicitly provide consent. Once shared, the data will be subject to the third party’s privacy policy and practices.

– Legal Compliance & Policy Enforcement We may disclose personal data if required to: • Enforce our policies and agreements. • Investigate potential violations of our Terms of Service. • Prevent fraudulent activities, security threats, or technical issues. • Protect the rights, property, or safety of our users, partners, or third parties.

– Compliance with Law Enforcement & Regulations We may disclose personal data if legally required to comply with: • Applicable laws, legal processes, or regulatory requirements. • Government requests or court orders. Any disclosure will be limited to the minimum necessary for compliance.

– Affiliate Partners & Corporate Transactions If PassMate becomes part of a corporate transaction (e.g., merger, acquisition, asset sale, or restructuring), personal data may be transferred to the acquiring entity, which will assume the rights and obligations outlined in this Privacy Policy.

Additionally, we may share non-personal data with our affiliate partners for business operations, promotional activities, or collaborations. However, any such sharing will not include personal data.

– Service Providers We work with third-party service providers that perform essential functions on our behalf, including:

• Cloud storage & infrastructure – Amazon Web Services (AWS) • Push notifications – Firebase Cloud Messaging (FCM), Huawei Cloud Messaging (HCM) • Analytics & crash reporting – Firebase Analytics, Firebase Crashlytics

Important: These service providers only process data on our behalf and cannot use it for any other purpose. We ensure all service providers comply with GDPR, CCPA, and relevant data protection laws.

– User Rights & Data Control

Users can opt out of tracking, analytics, and notifications via device settings.
Users can request data deletion by contacting support@getpassmate.com.

4. User Rights & Data Protection Under GDPR, CCPA, and other privacy laws, you have the right to:

Access & Review: Request a copy of any personal data we store.
Correction: Request updates to incorrect information.
Deletion: Request deletion of your data unless required by law.
Opt-Out: Disable analytics and push notifications in device settings.
Withdraw Consent: Revoke consent where applicable.
File a Complaint: Contact your local data protection authority if you believe your rights have been violated.

To exercise these rights, contact: 📧 support@getpassmate.com

5. Data Retention We retain user support data only as long as necessary to resolve issues or as required by law. Once resolved, we may delete or anonymize this data.

Retention Period: Support-related data is retained for up to 12 months unless required for legal or security reasons.

6. Security Measures We implement industry-standard security measures to protect user interactions. However, no method of transmission over the internet is 100% secure.

If you suspect a security breach, please contact us immediately.

7. International Data Transfers We store and process data on cloud servers located in the EU, US, and Asia. If data is transferred outside of your jurisdiction, we ensure it remains protected under applicable legal frameworks, including Standard Contractual Clauses (SCCs) for EU users.

8. Children’s Privacy Our App is not intended for children under 13 years old. We do not knowingly collect data from minors.

If a parent or guardian believes their child has provided personal data, please contact us for deletion.

9. Changes to This Policy We may update this Privacy Policy from time to time. Any significant changes will be notified via our App or other means as required by law.

Continued use of our App after changes take effect constitutes acceptance of the updated Policy.

10. Contact Us For any privacy concerns, please contact us: 📧 Email: support@getpassmate.com 🌐 Website: https://www.getpassmate.com

End User License Agreement (EULA) Effective Date: 06.03.2025

This End User License Agreement (“Agreement” or “EULA”) is a legally binding contract between you (“User” or “you”) and OVO Dijital Servisler Anonim Şirketi (“Company,” “we,” “us,” or “our”) governing your use of our mobile application (“App”) and associated services (“Services”). By downloading, installing, or using the App, you agree to be bound by the terms of this Agreement. If you do not agree to these terms, do not use the App.

License Grant We grant you a limited, non-exclusive, non-transferable, and revocable license to use the App for personal, non-commercial purposes in accordance with this Agreement and applicable laws.
Restrictions You may not:

Copy, modify, distribute, sell, or lease any part of the App.
Reverse-engineer, decompile, or attempt to extract the source code.
Use the App for unlawful purposes.
Interfere with or disrupt the integrity or performance of the App.

Ownership OVO Dijital Servisler Anonim Şirketi retains all ownership, intellectual property, and proprietary rights in the App and its content. This Agreement does not transfer any ownership rights to you.
Privacy and Data Collection Your use of the App is also governed by our Privacy Policy, which details how we collect, store, and use your data. By using the App, you acknowledge and consent to data processing as described in our Privacy Policy: https://www.getpassmate.com/legal/privacy
Third-Party Services The App may integrate with third-party services, including but not limited to Firebase Cloud Messaging (FCM), Huawei Cloud Messaging (HCM), and AWS services. We are not responsible for third-party services’ terms or privacy policies.
Updates and Modifications We may update, modify, or discontinue any aspect of the App at any time. Your continued use of the App after updates constitutes acceptance of the modified terms.
Termination This Agreement remains in effect until terminated. We may suspend or terminate your access to the App at any time if you violate this Agreement or engage in activities harmful to us or other users.
Disclaimer of Warranties The App is provided “as is” and “as available” without warranties of any kind, express or implied. We do not guarantee that the App will be error-free, secure, or uninterrupted.
Limitation of Liability To the maximum extent permitted by law, OVO Dijital Servisler Anonim Şirketi shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages arising from your use of the App.
Governing Law and Dispute Resolution This Agreement shall be governed by and construed in accordance with the laws of the State of Delaware, United States, without regard to its conflict of laws principles. Any disputes arising from or relating to this Agreement shall be resolved exclusively in the state or federal courts located in Delaware, United States. You agree to submit to the personal jurisdiction of such courts and waive any objections based on venue or forum non conveniens.
Changes to This Agreement We may update this Agreement at any time. Continued use of the App after changes take effect constitutes acceptance of the revised terms.
Contact Information If you have any questions about this Agreement, contact us at: Email: support@getpassmate.com Website: https://www.getpassmate.com

Terms of Service Effective Date: 06.03.2025

These Terms of Service (“Terms”) govern your access to and use of our mobile application (“App”) and services (“Services”). By using the App, you agree to comply with these Terms. If you do not agree, you must not use the App.

Acceptance of Terms By accessing or using the App, you acknowledge that you have read, understood, and agreed to be bound by these Terms, EULA and our Privacy Policy.
Eligibility You must be at least 13 years old to use the App. By using the App, you represent that you meet this age requirement. If you are using the App on behalf of an organization, you confirm that you have the authority to bind that organization to these Terms.
User Conduct and Acceptable Use You agree to use the App and Services only for lawful purposes. You shall not:

Violate any applicable laws or regulations.
Use the App for fraudulent, misleading, or harmful activities.
Interfere with or disrupt the functionality, security, or integrity of the App.
Attempt to gain unauthorized access to any part of the App or another user’s data.
Transmit viruses, malware, or other harmful code.
Use the App to engage in harassment, hate speech, or abusive conduct.

Permissions and Notifications The App does not require user registration. However, to access full features such as time and location-based notifications and alerts from pass providers, you must grant the necessary device permissions. These include:

Location Permissions: To receive relevant location-based notifications and alerts from pass providers.
Notification Permissions: To allow the App to send time-based and location-based reminders. You may adjust your permission settings at any time through your device settings, but disabling these permissions may limit the App’s functionality.

Service Availability and Modifications We reserve the right to modify, update, or discontinue any part of the App or Services at any time without liability. We do not guarantee that the App will always be available, error-free, or secure.
Intellectual Property Rights All content, trademarks, and intellectual property in the App are owned by PassMate Alliance. You are granted a limited, non-exclusive, non-transferable right to access and use the App for personal, non-commercial purposes. You may not copy, modify, distribute, or reverse-engineer any part of the App.
Third-Party Services The App may integrate with third-party services, including but not limited to Firebase, Huawei Cloud Messaging, and AWS. We are not responsible for their content, policies, or practices. Your interactions with third-party services are at your own risk.
Termination We may suspend or terminate your access to the App and Services at our sole discretion if you:

Violate these Terms.
Engage in prohibited activities.
Pose a risk to other users or the integrity of the App. Upon termination, your right to use the App ceases immediately.

Disclaimer of Warranties The App and Services are provided “as is” and “as available” without warranties of any kind. We do not guarantee uninterrupted or error-free operation, nor do we warrant that the App is free of viruses or harmful components.
Limitation of Liability To the extent permitted by law, OVO Dijital Servisler Anonim Şirketi shall not be liable for any direct, indirect, incidental, special, or consequential damages arising from your use of the App, even if advised of the possibility of such damages.
Indemnification You agree to defend, indemnify, and hold harmless OVO Dijital Servisler Anonim Şirketi from any claims, damages, losses, liabilities, or expenses arising from your violation of these Terms or misuse of the App.
Governing Law and Dispute Resolution These Terms shall be governed by the laws of the State of Delaware, United States. Any disputes shall be resolved exclusively in the state or federal courts of Delaware. You agree to waive any objections based on jurisdiction or venue.
Changes to These Terms We may update these Terms from time to time. If we make significant changes, we will notify users through the App or other communication methods. Continued use of the App after changes take effect constitutes acceptance of the revised Terms.
Contact Us If you have any questions regarding these Terms, please contact us at: Email: support@getpassmate.com Website: https://www.getpassmate.com