(Last updated on December 12, 2015)
This Policy details how we receive, collect and use information in connection with our website located at mypassi.com (the "Site"), the MyPassi smartphone solution ("MyPassi App"), and other products and services provided on mypassi.com website or the backend of the MyPassi App („Service“)
By visiting this site or using the Service, you are accepting the policies and practices described in this Policy, as such Policy may be amended from time to time. Each time you visit the Site or use the Service, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy.
To be clear about the terminology we are using, when we use the phrase "Personal Information" in this Policy, we mean information about you that is personally identifiable, like your name, address, e-mail address, billing information, or phone number, as well as other non-public information that is associated with this personal information. When we use the phrase "Anonymous Information" in this Policy, we mean information that is not personally identifiable, or linked to your Personal Information such as aggregated information, general demographic information and IP addresses. Anonymous Information does not necessarily enable identification of individual persons.
1. Collection and use of Information
When you install the MyPassi App or register on the Site, you will be asked to provide us with your phone number to allow us access to your mobile device's address book.
A copy of the phone numbers in your address book (but not emails, notes and names - or any other personal information in your address book) will be stored on our servers and will only be used to:
(a) notify you when your contacts become active on MyPassi,
(b) indicate which of your contacts is already a MyPassi user,
(c) correctly display the name of each contact as it appears in your address book when a call, a SMS or a location request is received.
(d) sync your contacts with the MyPassi Backend to ensure the MyPassi service.
The copy of your address book (just phone numbers, no names) is stored on a live database. This database have a historical backup. If you delete the address book from our servers (more about this below), it will not be deleted instantly and permanently. If you wish to permanently delete please contact us via e-mail firstname.lastname@example.org including your name, phone number.
Your phone number will be used for identification purposes as your MyPassi user ID.
Since MyPassi users may add your phone number to their address book and see that you registered to MyPassi, we do not consider the fact that your phone number exists on MyPassi as private information.
Online Status (free, busy, not available)
Other users will see your availability status set on your behaviours You may configure this via the settings within the MyPassi App.
Location Information (location request)
MyPassi allows you to attach your location information to location request you send to other users on their requests. If you choose to share your location with a specific user or group of users your location will be retrieved from your device and sent to MyPassi. We use Google location services for all location requests and therefore we use Google´s APIs. For detailed information please visit https://developers.google.com/maps/documentation/business/geolocation/
Automatically collected data
We always use Google Analytics within the MyPassi App and on the mypassi.com websites.
Our servers may automatically collect data about your Internet address when you visit the site. This information, known as an Internet Protocol address, or IP Address, is a number that is automatically assigned to your computer by your Internet service provider whenever you are on the Internet. When you request pages from our Site, our servers may log your IP Address and, if applicable, your domain name. Your IP Address is used to help identify you and to gather demographic information about our members and users as a whole, but does not include personally identifiable information. Our server – in link to Google Analytics - may also record the referring page that linked you to us (e.g., another web site or a search engine); the pages you visit on this Site; the web site you visit after this Site; the ads you see and/or click on; other information about the type of Web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Site or a referral site; and other Web usage activity and data logged by our servers. We use this information for internal system administration, to help diagnose problems with our servers, and to administer our Service. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider.
Third-Party Sites and Privacy Practices
We will never use the statistical analytics tool to track or to collect any Personal Information of visitors or users. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a device user. We will not associate any data gathered from this site with any Personally Identifiable Information from any source, unless you explicitly submit that information via a fill-in form on our website.
2. Sharing and Disclosure of Information
We do not rent, sell, or share any information about our users with any third-parties, except as specifically described herein. We may disclose your 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 or property (including the enforcement of our agreements); or
(c) act in urgent circumstances to protect the personal safety of users of our service or members of the public.
In order to provide you with MyPassi products you have requested, MyPassi may sometimes, if necessary, share your Personal Information (excluding your address book and related information) and traffic data with trusted partner service providers and/or agents, for example: technical providers of phone authentications services and analytical services, customer support, or hosting services. MyPassi will always require these third parties to take appropriate organizational and technical measures to protect your personal data and traffic data and to observe the relevant legislation. MyPassi will never share your address book information with any third party, except as may be required by law (see below).
The following is a description of how we may share your Personal Information with trusted third party partners. Should we add additional partners, we will immediately update this description:
1. We use third party companies in order to send you an authentication SMS when you register with MyPassi. In order to send you the SMS, we send one of these third party companies your phone number and the authentication message. These third parties are contractually obligated to only use your phone number for the transmission of the authentication SMS.
2. If we fail to send you an SMS (this happens in certain cases) you may ask us to call you and read you the authentication code on the phone. This is done using a third party automated phone system. In order to call you, we provide this third party partner with your phone number and send the "audio content" of the call to them. The third party partner in turn will typically use another phone provider who may use another phone provider and so on until the call reaches you. This is an industry standard mechanism for the transmission of phone calls. The third party partner is contractually obligated to only use your phone number for the completion of the authentication phone call.
3. We may use Push Notification Services to notify you about various events related to the app. If we do, the phone number or the name of the person calling you or sending you a message may be part of the notification. This message is sent to the push notification service provider, for delivery to your device.
4. We use third parties to process the payment and/or billing information that you submit on our site or through the MyPassi App to facilitate payment transactions. We require that these third parties take the appropriate organizational and technical measures to protect your personal data and traffic data and to comply with relevant laws, but we are not liable or responsible for these third party transactions. Therefore, you should review such third party terms and conditions before providing your payment or billing information.
Notwithstanding any of the foregoing, the MyPassi servers that are used to store your Personal Information are owned and hosted Hetzner https://www.hetzner.de/hosting/unternehmen/ueber-uns
We may disclose information about you if we determine that for national security, law enforcement, or other issues of public importance that disclosure of information is necessary.
We may from time to time ask you to provide information about your experiences, which will be used to measure and improve quality. You are at no time under any obligation to provide any of such data. Any and all information which is voluntarily submitted in feedback forms on the site or any survey that you accept to take part in is used for the purposes of reviewing this feedback and improving the MyPassi software, products and websites.
We may contact you to send you messages about faults and service issues. Furthermore, we reserve the right to use email, the MyPassi software or SMS to notify you of any eventual claims related to your use of our software, websites and/or products, including without limitation claims of violation of third party rights.
We may send you alerts via the MyPassi software to notify you when someone has tried to contact you. We may also use the MyPassi software to keep you up to date with news about our software and products that you have purchased and/or to inform you about other MyPassi products and related information.
3. Children's Privacy
MyPassi websites and software clients are not intended for or designed to attract anyone under the age of 13 and we do not intentionally or knowingly collect personal information on our sites from anyone under the age of 13 (or older in some jurisdictions). We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission.
We take reasonable precaution to protect Personal Information from misuse, loss and unauthorized access. Although we cannot guarantee that Personal Information will not be subject to unauthorized access, we have, electronic, and procedural safeguards in place to protect Personal Information. All data connections through the MyPassi App are transfered over standard industrial secured connections, the so called SSL connections via https certificates. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.
5. Business Transitions
We will post a notice on this Site of any such change in ownership or control of the Personal Information we may have prior to such transfer.
6. Changes to Policy
From time to time, we may revise this Policy. We reserve the right to update or modify this Policy, or any other of our policies or practices, at any time with or without notice. However, we will not use your Personal Information in a way that is materially different than the uses described in this Policy without giving you an opportunity to opt-out of such differing uses. We will post the revised Policy on the Site, so that users can always be aware of what information we collect, how the information is used and under what circumstances such information may be disclosed. You agree to review the Policy periodically so that you are aware of any modifications. Your continued use of the Site indicates your assent to any changes and signifies your agreement to the terms of our Policy. If you do not agree with these terms, you should not use the Site, the MyPassi App, or any other service.
7. Change or Removal of Information
If you provided your e-mail address to us and wish to update it, you may do so by sending an e-mail to email@example.com.
If you no longer wish to receive e-mail communication from us, such as offers, updates and newsletters, you may opt-out of receiving such communications by following the instructions included in each newsletter or communication. In addition, you can remove your e-mail address at any time by sending an e-mail with the subject line of UNSUBSCRIBE to firstname.lastname@example.org .
Due to technological reasons, we do not know when and if you delete the application. Therefore, if we detect no activity from your device for 180 days, we will assume that you deleted the application and we will remove your address book from our servers. However, since we are not certain that you deleted the application (you may just be on vacation, etc.) we will not deactivate your MyPassi account (which is your phone number and device ID).
If you wish to delete your account completely, you can go to the "Settings" tab in the MyPassi App, and tap the "Reset Account" option. Please note that this will remove your data from MyPassi, and deactivate MyPassi on your device. If you have additional concerns and/or requests, you can contact MyPassi at email@example.com.
8. Contact Information
Please direct all questions in connection with this Policy via e-mail to firstname.lastname@example.org or by writing to
ecqui GmbH, Währinger Straße 12/9, 1090 Wien