Privacy Policy

Mar 6, 2024
                        

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/privacyHuawei 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

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