Privacy Policy

Last updated: 01 January 2025

This Privacy Policy describes how Smart Pass (“we”, “us”, “our”) collects, uses and protects personal information when you use our website and services.

1. Data Controller

The data controller is Smart Pass. If you have any questions about this Privacy Policy or your personal data, please contact us at privacy@smartpass.example.

2. Personal Data We Collect

We may collect the following categories of personal data:

• Usage data (e.g. pages visited, access logs, technical information about your device and browser).

Only if you fill the contact forms, we may collect the following categories of personal data:

• Identification data (e.g. name, surname).
• Contact information (e.g. email address, phone number).
• Any other information that you voluntarily provide through our contact forms or other interactions.

3. Purposes and Legal Bases of Processing

We process your personal data for the following purposes:

• To respond to your enquiries and provide customer support.
• To operate, maintain and improve our website and services.
• To send you information about our products and services, where permitted by applicable law.
• To comply with legal obligations and to establish, exercise or defend legal claims.

4. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by law.

5. Data Sharing

We may share personal data with trusted service providers who assist us in operating our website and delivering our services, subject to appropriate contractual safeguards. We do not sell your personal data.

6. International Transfers

Where personal data is transferred outside your country or region, we take appropriate measures to ensure that the data is protected in accordance with applicable data protection laws.

7. Your Rights

Subject to applicable law, you may have the right to:

• Access your personal data.
• Request rectification or erasure of your personal data.
• Restrict or object to the processing of your personal data.
• Receive your data in a structured, commonly used and machine-readable format.
• Withdraw consent at any time, where processing is based on your consent.

To exercise your rights, please contact us at privacy@smartpass.example.

8. Security

We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

9. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated “Last updated” date.