PRIVACY POLICY

Revised 1 September, 2017 PASSAPP is firmly committed to the security and protection of personal information of our Users and their contacts. This Privacy Policy describes how PASSAPP will collect, use, share and process personal information. By accepting the PASSAPP Privacy Policy and/or using the Services You consent to the collection, use, sharing and processing of personal information as described herein. If You provide us with personal information about someone else, You confirm that they are aware that You have provided their information and that they consent to our use of their information according to our Privacy Policy. You may opt-out at any time to prevent further use of the information shared via the Services. Please note that provision of information from the PASSAPP database is constitutionally protected under applicable laws on Freedom of Expression, see the Terms of Service.

1 Personal Information Collected

1.1 User Profile

When You create a user profile and confirm being the holder of a certain number, PASSAPP will collect the information provided by You. In order to create a user profile, You must register Full name and phone number. Additional information that may be provided at Your option include, but is not limited to, photo

1.2 Installation and Use

When You install and use the Services, PASSAPP will collect personal information from You and any devices You may use in Your interaction with our Services. This information may include e.g.: geo-location; Your IP address; device ID or unique identifier; device manufacturer and type; device and hardware settings; SIM card usage; applications installed on your device; ID for advertising; ad data, operating system; web browser; operator; IMSI; connection information; screen resolution; usage statistics; default communication applications; access to contacts, version of the Services You use and other information based on Your interaction with our Services such as how the Services are being accessed (via another service, web site or a search engine), order information and other usage activity and data logged by PASSAPP’s servers from time to time.

1.3 Third Party Services

You may provide us with Your user identifier information regarding, or to enable Your usage of, certain third party services (together with a mapped photo where applicable) e.g. social networking services and payment services, in order for the Services to interoperate with such third party services. You may use such third party services to create Your user profile or log in to our Services, share information with such third party services, or to connect Your user profile with the respective third party services. Such third party services may automatically provide us with access to certain personal information retained by them about You (e.g.,your payment handle, unique identification information, content viewed by You, content liked by You and information about the advertisements You have been shown or may have clicked on) and You agree that we may collect, use and retain the information provided by these third party services in accordance with this Privacy Policy. You may be able to control the personal information You allow us to have access to through the privacy settings on the respective third party service. We will never store any passwords created for any third party services.

1.4 Contact Information

Where PASSAPP mobile applications (“PASSAPP Apps”) are obtained from other sources than Apple App Store, You may share the names, numbers, and email addresses contained in Your address book (“Contact Information”) with PASSAPP by enabling the PASSAPP Enhanced Search Functionality. Where the PASSAPP Apps are obtained from Apple App Store, we will only use permitted Contact Information to make our Services more relevant to You and Your engagement with the PASSAPP community. In addition to Contact Information, if You choose to activate use of a third party service, such as social networks services, within the Services, PASSAPP may collect, store and use the list of identifiers associated with said services linked to the Contact Information in order to enhance the results shared with other Users. You acknowledge and agree that any Contact Information that You share with PASSAPP is submitted for publication in the PASSAPP database, for which a Publishing Certificate has been issued. Such Publishing Certificate provides for constitutional protection under the US Law on Freedom of Expression. Please note that no other contact information other than the phone numbers and thereto attached names, and email addresses will be collected and used from Your address book. Other numbers or information that may be contained in Your address book will be filtered away by our safety algorithms and will therefore not be collected by PASSAPP. Please also note that You can always choose not to share Contact Information with PASSAPP and if You have shared such information and changed Your mind, You can delist Your number or opt-out to render Your entire Contact Information unavailable for search in the PASSAPP database.

2 Use of Personal Information

2.1 Provide, improve and personalize our Services

PASSAPP may use the personal information collected to provide, maintain, improve, analyze and personalize the Services to its Users, partners and third party providers. More specifically, PASSAPP may use such information to: a display the number associated with a certain name following a manual name search against the PASSAPP database, subject to that name searches will only produce a number linked to the name if the number is available for search in a public database or relates to a User who has made his or her name available for search, provide Your information to the person You reach out to when requesting a contact via the PASSAPP name search service, in which case Your request will be forwarded to that person via a Pass. b display information based on connections a User may have in common, directly or indirectly, with other Users via a “social graph” algorithm. c send in application push notifications and reminders and deliver messages via the Services, in which case Your messages will be kept for a limited period of time in order to deliver the messages but PASSAPP will not, unless specifically stated, monitor the content of Your messages. d enable You to use and share Your information in connection with Your registration, login or other use of third party services e.g. payment service providers, online services, social networking sites and other third party API’s.

2.2 Statistical data from the Services

We use aggregated or anonymized personal information for statistical and analytical purposes. We may come to share such data with third parties. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.

2.3 Personalize our advertising and communications

We may use any of the information collected, as set out above, to provide You with location and interest based advertising, marketing messaging, information and services. We may also use the collected information to measure the performance of our advertising and marketing services. We may contact You for verification purposes or with information pertaining to the Services or special offers, e.g. newsletter e-mails, SMS and similar notifications about PASSAPP’s and our business partners’ products and services. We also use the collected information to respond to you when you contact us.

2.4 Compliance with laws and prevention of fraudulent or illegal activities

We may use the collected information to comply with applicable laws and to enforce our agreements and protect and defend the rights or safety of PASSAPP, its Users or any other person and verify provided User profile information with third party providers and ensure technical service functionality and data accuracy, perform trouble-shooting and prevent or detect fraud, security breaches or illegal activities.

3 Sharing and Disclosure of Personal Information

In addition to the sharing and disclosure of personal information that is included as part of the functionality of the Services as described in section 2 above, PASSAPP may disclose personal information if we believe such action is necessary to: a comply with the law, or legal process served on us; b protect and defend our rights and the enforcement of our agreements; or c protect the security and safety of Users or members of the public or other aspects of public importance, provided, of course, that such disclosure is lawful. We transfer information to trusted vendors, service providers, and other partners who support our business and Services, such as providing technical infrastructure services, bug testing, analyzing how our Services are used, measuring the effectiveness of ads and services and facilitating payments as well as potential partners who may wish to work with us to provide other services. PASSAPP will always require these third parties to take appropriate organizational and technical measures to protect personal information and to observe applicable legislation. PASSAPP may also share personal information with third party advertisers, agencies and networks. Such third parties may use this information for analytical and marketing purposes e.g. to provide measurement services and targeted ads and for improvement of products and services. The information may be collected by such third parties by use of cookies, or similar technologies. We may disclose and transfer Your Information to our associated or affiliated organisations or related entities and to any third party who acquires, our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets.

4 Information Security and Transfer of Personal Information to Other Countries

In order to provide the Services, PASSAPP will transfer, process and store personal information in a number of countries, including but not limited to USA, and may also use cloud based services for this purpose. PASSAPP may also subcontract storage or processing of Your information to third parties located in countries other than Your home country. Information collected within the European Economic Area (“EEA”) may, for example, be transferred to and processed in a country outside of the EEA, which may not provide the same level of protection for personal data as within the EEA. You acknowledge and agree that PASSAPP may transfer Your personal information as described above for purposes consistent with this Privacy Policy. We take all reasonable precautions to protect personal information from misuse, loss and unauthorized access. PASSAPP has implemented physical, electronic, and procedural safeguards in order to protect the information, including that the information will be stored on secured servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet or method of electronic storage is 100% secure.

5 Accessing and Updating Personal Information

PASSAPP may on its own initiative, or at Your request, replenish, rectify or erase any incomplete, inaccurate or outdated personal information retained by PASSAPP in connection with the operation of the Services. When required by applicable law, You have the right to know what personal information is stored about You and to have any such information corrected or deleted on Your request. See contact details below.

6 Minors

Services are not intended for or designed to attract anyone under the relevant age of consent to enter into binding legal contracts under the laws of their respective jurisdictions. PASSAPP does not intentionally or knowingly collect personal information through the Services from anyone under that age. We encourage parents and guardians to be involved in the online activities of their children to ensure that no personal information is collected from a child without their consent.

7 Changes to this Privacy Policy

PASSAPP may at any time with or without a separate notice change this Privacy Policy, and You are encouraged to review this Policy from time to time. In case of substantial changes, PASSAPP will notify the Users by push notice or via notice in the Services. Your continued use of the Services after a notice of changes has been communicated to You or published on our Services shall constitute consent to the changed policy.

8 Contact

If You have any additional questions about PASSAPP’s Privacy Policy or want to make a request regarding certain personal information, You are encouraged to contact PASSAPP. The contact information is: 2035 Sunset Lake RoadSuite B-2, Newark, Delaware 19702, United States of America You can also send Your enquiries via email to info@passapp.com For Users that may have grievances pertaining to the Services, PASSAPP has appointed a Grievance Officer to deal with Your issues. You may reach him/her on info@passapp.com