This Privacy Policy applies to Passvers desktop applications (collectively, the "Products"), Passvers.com (collectively, the "Sites") and other interactions (e.g., customer service inquiries) you may have with Passvers. If you do not agree to the terms, do not access or use the Products, Sites or any other aspect of Passvers's business. This policy applies to the company's employees, contractors, and officers. The company has a contract with all data processors that it uses in compliance with the GDPR and ensures that all data processors are compliant with Data Protection Legislation. The policy does not apply to third-party services. Information collected by third parties is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

When you interact with our Sites and Products, we collect three types of user information.

1. Personal data related to your visit to our website and the purchase and use of our products

When you visit to our Site, or purchase Products through the Sites or the Products, or use our products, Passvers collects the following personal data through the collection forms in the ordering process or other processes.

• Personal information: Name, gender, age, email address, address, country, postal code, phone number, company name and industry you work for;
• Order information, such as the products you purchase, date and amount of the order;
• Payment information such as Credit card information (type, number, expiration date, CVV security code)/debit card information or other payment/billing information. Payments information provided by you via the Sites will be stored and processed by mycommerce.com and any other third party service providers as designated by us from time to time. We will collect certain information on the Sites required for mycommerce.com and such third-party services providers to process payments, including credit/debit card numbers, security numbers and other related payment information. All such information is subject to the privacy policy of mycommerce.com (available here https://www.mycommerce.com/corporate-policy/ ) or any other third party service provider as applicable.
• Information we get from your visit to our websites. We collect information about how you visit our websites (including the webpage that led you to our Sites, the search terms entered into a search engine which led you to our Sites);
• Information we get from your use of our products. We collect information about the products that you use and how you use them and your local device information, including but not limited to your device information, operating system, username, location, IP address, operating log information, crash reports and the information and format of the files you are working with (with your additional consent);
• Your product serial number;
• Content of customer support communications.

As using cookies, Passvers can provide you with simple and personalized experience of the internet. Cookies are small data files that Passvers can recognize you when you come back to Passvers and offer valuable and customized service for you. We gather the technologies and information without any personal details then automatically save them in log files, which include Internet Service Provider (ISP), Internet Protocol (IP) addresses, browser type and so forth. Customers are allowed to delete related cookies optionally. However, before that, you should finish the order information when you back to Passvers website again. Passvers will not disclose your individual information to any website or make any profit.

Passvers's website or services are not directed to children. If you believe that we have mistakenly or unintentionally collected information of a minor through our services without appropriate consent, please notify us through email support@passvers.com so that we may immediately delete the information from our servers and make any other necessary corrections.

If you are under the age of 13, please do not submit any personal information through the Sites and/or Products. We encourage parents and legal guardians to monitor their children's internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Sites and/or Products without their permission.

We use, process, and store your information as necessary to perform our contract with you and for our legitimate business interests, in operating our Sites, Products, Services.

1. Use of collected information related to your visit to our website and the purchase and use of our products

Passvers uses the information we collect in your visit to our Sites and purchase and use of our Products for the following purposes:

• In order for Passvers to provide you with the ordered product(s);
• For the performance of a contract to which you are party, and the collected data are necessary in order for Passvers to identify and bill you and to charge its bank card number;
• For verifying your identity and providing customer service or support;
• Analyze your use of our Site and Products to better understand how they are being used so we can improve our services and the user experience and engage and retain users.

2. Use of information related to comments areas

Passvers collects information in comments areas in order to improve its products and provide the consumers and potential consumers with a better and transparent information about the Passvers products. Said comments and the related personal data are provided by you on a voluntary basis so that the processing of the collected personal data relies on your consent.

Passvers may use the comments (with your relevant information) you post for marketing purpose in order for others to better understand and use our products.

3. Use of information related to newsletters and advertising emails

Passvers collects the information in order to provide consumers and potential consumers with information and news regarding Passvers products. The subscription to Passvers's newsletter and the related provision of personal data is made on a voluntary basis so that the processing of the collected information relies on your consent.

We only disclose information to third parties when:

• e use service providers who assist us in meeting business operations needs, including hosting, delivering, and improving our Products. We also use service providers for specific services and functions, including email communication, customer support services, and analytics. These service providers may only access, process, or store personal data pursuant to our instructions and to perform their duties to us.
• We have your explicit consent to share your personal data (if required).
• We believe it is necessary to investigate potential violations of the Terms of Products, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or potential threats against persons, property, or the systems on which we operate our Site and/or Products.
• We determine that the access, preservation, or disclosure of your information is required by law to protect the rights, property, or personal safety of Passvers and users of our Site and/or Products, or to respond to lawful requests by public authorities, including national security or law enforcement requests.
• We need to do so in connection with a merger, acquisition, bankruptcy, reorganization, sale of some or all of our assets or stock, public offering of securities, or steps in consideration of such activities (e.g., due diligence). In these cases, some or all of your information may be shared with or transferred to another entity, subject to this Privacy Policy.
• We may disclose non-personal data, such as information we get from your visit to our websites, publicly and to third parties – for example, in public reports about word usage, to partners under the agreement with us, or as part of progress reports we may provide to users.

Passvers does not share your information with third parties for the purpose of enabling them to deliver their advertisements to you. Passvers does not sell or rent your personal data.

Third parties' applications and products

Some third-party applications and services that work with us may ask for permission to access your information. Those applications will provide you with notice and request your consent in order to obtain such access or information. Please consider your selection of such applications and services, and your permissions, carefully.

Some third parties' embedded content or plugins on our Sites and/or Products, such as Facebook "Like" buttons, may allow their operators to learn that you have visited the Sites, and they may combine this knowledge with other data they have collected about your visits to other websites or online services that can identify you.

Data collected by third parties through these apps and plugins are subject to each parties' own policies. We encourage you to read those policies and understand how other companies use your data.

Data storage and transfer

When you use the Products on your computing device, user content you save will be stored locally on that device and synced with our servers. If you post or transfer any information to or through our Site and/or Products, you are agreeing to such information being hosted and accessed on our servers.

The collected personal data may be transferred by Passvers to recipients which are located outside the European Union and such destinations may not have laws which protect a user's personal data to the same extent as in the European Union.

Passvers ensures that your personal data processed by Passvers or by its suppliers and partners operating outside the European Union are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this Privacy Policy.

Data deletion and retention

You can remove your information from Passvers at any time by emailing us with the respective request: support@passvers.com. However, we may keep some of your information for as long as reasonably necessary for our legitimate business interests, including fraud detection and prevention and to comply with our legal obligations including tax, legal reporting, and auditing obligations.

Data breaches

All breaches will be reported to the relevant supervisory authority within 72 hours, unless the data was anonymized or encrypted or if it has a particularly high risk. Breaches of this policy by staff, contractors, officers of Passvers will be dealt with under the company's grievance and disciplinary policy and may lead to a disciplinary sanction.

If Passvers learns of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on the Site. Depending on where you live, you may have a legal right to receive such notices in writing.

Passvers uses, processes, and stores information, as necessary to perform our contract with you, and based on our legitimate interests in order to provide the Products and Services. We rely on your consent to process information to send promotional emails and to place cookies on your devices. In some cases, Passvers may process Personal Data pursuant to the legal obligation or to protect your vital interests or those of another person.

Individuals located in the European Economic Area (EEA) have certain rights in respect to their personal information, including the right to access, correct, or delete information we process through your use of the Sites, and/or Products. If you're a user based in the EEA, you can:

• Have your information corrected or deleted. You may ask us to correct information you think is inaccurate or completely delete all information that we hold about you by emailing: support@passvers.com.
• Access your personal data report by submitting a request at support@passvers.com. This report will include the information we have about you, provided to you in a structured, commonly used, and portable format.
• Object to us processing your personal data. It is your right to lodge an objection to the processing of your personal data by emailing: support@passvers.com if you feel the "ground relating to your particular situation" apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights, and freedoms, or the processing is for the establishment, exercise or defence of a legal claim.
• You can ask us to stop using your information, including when we use your personal data to send you marketing emails. We only send marketing communications to users located in the EEA with your prior consent, and you may withdraw your consent at any time by clicking the "unsubscribe" link found within Passvers emails and changing your contact preferences. Please note you will continue to receive transactional messages related to our Products, even if you unsubscribe from marketing emails.
• Complain to a regulator. If you're based in the EEA and think that we haven't complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.

This privacy policy was last updated on 25 May 2018 and this version is in line with the new GDPR guidelines.

We may need to update this Policy to keep pace with changes in our Sites, Products, and services, our business, and laws applicable to us and you. We will, however, always maintain our commitment to respect your privacy. We will notify you of any material changes that impact your rights under this Policy by email (to your most recently provided email address) or post any other revisions to this Policy, along with their effective date, in an easy-to-find area of the Sites, so we recommend that you periodically check back here to stay informed of any changes.

You may contact us with any questions relating to this Privacy Policy by e-mailing: support@passvers.com.