Privacy Policy

Welcome to Passle’s Privacy Policy.

Passle respects your privacy and is committed to protecting your personal data.

This Privacy Policy will inform you as to how we look after your personal data that we collect from you, or are provided with through your use of our website or our services; whether accessed via our website or via our app – downloadable via Apple Store and Google Play – (regardless of where you visit or use them from) and tell you about your privacy rights and how the law protects you. Our services can only be accessed if you have an account with us.

Where we process data on behalf of our customers we are acting as a processor rather than a controller. Please refer to their privacy policies for details on how they use your data.

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights and obligations
10. Changes to the privacy policy

1. Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process your personal data, through your use of our website and/or our services, for example, when you create an account with us, sign up to our newsletter or upload any content to our services.

Our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Who can see information about you

You may choose to share certain information with other users of our services. You should consider carefully what information you wish to share with other users of our services. It is possible for other users of our services to copy information you have shared with them, for example, by taking screen shots. We have no control over the use or distribution of any copies made.

If you wish to delete any information that you have shared on our services, you can either do so yourself or contact us at support@passle.net. However, prior to deletion other users may see such information and/or make copies, which is beyond our control.

Controller

Passle Limited (referred to as Passle, we, us or our in this Privacy Policy) is the controller and responsible for your personal data set out below.

Contact details

If you have any questions about this Privacy Policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Passle Limited
Email address: support@passle.net
Head Office postal address: 1a Walton Crescent, Oxford, OX1 2JG, UK

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, email address, title and the organisation you represent.
• Contact Data includes address (including the address of the organisation that you represent), email address, social media links and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website or use our service (for example, a record of each time you access our service, post information on it, upload a file or comment on another user’s post), as well as metadata with regard to the time, date, and place the photo or video was created, when you post things like photos or videos.
• Profile Data includes your username, email address and password, your interests, preferences and feedback, including the data provided when your account is set up. You may submit an image, which may identify you.
• Usage Data includes information about how you use our website, and our services, such as a record of each time you visit the service as well as when you post information on it, upload a file such as an image, document or video, or comment on something that another user has uploaded. It also includes the information you choose to share when you take an action on the platform.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions.You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • create an account with to use our service
  • subscribe to our services
  • share any information on our service (for example, when you comment on something another user has uploaded)
  • request marketing to be sent to you
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We may also collect other cookies if you consent to these cookies. Please see our Cookie Policy for further details.
• Other users. Other users of our service may share information about you that they have. For example, when they post information on our service, invite you to join Passle, when they upload and manage their invites and contacts, or post a photo or video of you. We stipulate in our Terms of Website Use that other users must not upload any personal data about you without your permission.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• To establish, exercise or defend legal claims.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or placing non-essential cookies. You have the right to withdraw consent to marketing at any time by contacting us, or using the unsubscribe link in the marketing emails we send you.

How and why we use your personal data

We describe below all the ways we plan to use your personal data and the lawful basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data, where more than one ground has been set out in the table below.

Marketing

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing. We will send you marketing communications if we believe that you or the organisation that you represent may be interested in receiving marketing communications from us (and you have not previously opted out from receiving such marketing), in which case the lawful basis for contacting you will be our legitimate interest.

Targeted content

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which content may be relevant for you (we call this marketing).

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your use of our services.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@passle.net.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below (for the purposes set out in the table above):

• Our customers (to provide them and any authors of information about who has read their articles).
• Service providers (for example, payment, IT support and system administration services, hosting services – including cloud storage and data management services – who may access your personal data.
• Professional advisers including lawyers, bankers, auditors, business advisors and insurers.
• Third parties who we have a duty to disclose or share your personal data with in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements or to protect the operation of the service, or the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• Government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information).
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or who may choose (or contemplate) to invest in us. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

The personal data we collect from or about you may be transferred to, processed and stored, at destinations outside the UK (for example, we share your data with our group company in the US).

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

Within our Information Security Policy, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. By default, we retain soft deleted data for 18 months. This is for reporting purposes, and it allows us to reinstate client data upon request.

Clients who cancel their contract with Passle can make a request for their data to be hard deleted – this can be completed from our main database within 48 hours, and then from our backups within 21 days (i.e.: the period of time it takes for our backups to expire). In other circumstances you can ask us to delete your data: see your legal rights and obligations below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights and obligations

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data (commonly known as a subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) and you want to object to the processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may have compelling legitimate grounds to process your data which override your rights and freedoms.
• Request restriction of processing your personal data. You also have the right to restrict us from processing your personal data if the data is inaccurate, the processing is unlawful (but you do not want us to erase it), we no longer need your personal data for the purposes for which we hold it (but you need it to establish, exercise or defend legal claims) or you have objected to our use of your data but we need to verify whether we have an overriding legitimate ground to use it.
• Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at support@passle.net.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Making a complaint

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

10. Changes to the Privacy Policy

We keep this Privacy Policy under regular review. This version was last updated on 20 April 2023.