Privacy Policy

Last updated: 13th December 2023

Data privacy is central to the way Passby Technologies Limited operates. This Privacy Policy describes how, when and why we collect personal data across our geolocation services. It will outline our data collection and use practices for the data (‘Information’) that we collect and the data we receive from our data partners as well as Information we collect through our website.

  1. Information we collect and how we collect it

We obtain a variety of data (‘Information’) from trusted third-party data partners. Our data partners collect this data primarily through software development kits (SDKs)that have integrated mobile apps or application programme interfaces (APIs). These interfaces provide app developers Information about their users. The following Information is collected from these sources:

  • IDFA, Android Advertiser ID or other type of advertising identifier (“Advertising ID”);
  • Precise geographic location of the mobile device at a certain time, expressed as the latitude, altitude, longitude and timestamp of the mobile device and the derived identity of the location, such as a fast food restaurant.
  • Mobile device operating system, Mobile Device Make and Model;

Our Partners do not provide us with any data, device or otherwise, that can be directly used to identify an individual, such as name, mobile phone number or email address.

  1. Information we collect through our website

We may collect Information from you when you visit our website. We only collect personal Information that you provide to us if you register on Any Information that you give us from then on is added to your record and may be used to market to you.

We may process Information about your computer, including available IP addresses, operating system and browser type, for system administration and to report aggregate Information. This is statistical data about browser usage and patterns, and does not identify any individual.

Where there are links to other websites, this data protection policy does not apply to those websites. You should refer to the privacy statement of the owner of the relevant website.

  1. Cookies

For the same reason, we may obtain Information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain Information that is transferred to a computer’s hard drive. They help us to improve our site and to deliver a better and more personalized service.

You may refuse to accept cookies by activating the relevant setting on your browser. However, if you select this setting you may be unable to access certain parts of our site.

  1. What do we do with the Information we collect and how we share it
  • We analyze and contextualize the data provided by our Partners to make inferences about human location and footfall patterns. We utilise raw geolocation data to develop an accurate derivative geospatial model that enables organizations to utilize foot traffic and visitation as a tool.
  •  We also aggregate the Information collected from our data partners before processing and sharing to our customers. We share the Information in an anonymized way. For example, pseudonymous identifiers such as MAID have a one-way hash applied. We never share Information that can directly identify an individual such as name, mobile phone number and email address.

Our customers are a wide range of companies and organizations that use location data to draw insights and better understand the consumer and market trends related to human movement patterns for the purposes of their business. We work with industries such as advertising, retail, real estate, construction and finance.

The above is not an exhaustive description of all possible ways Information may be used but is an overview of how we collect the Information and what we do with it. We may from time to time use the Information internally to make service improvements, disclose Information to our service providers and public authorities such as law enforcement, if we are legally required to do so. Similarly, in the event of any potential merger or acquisition, any Information we have will likely be transferred to the leading organisation and shared in a similar way with their partners.

  1. How to opt out of services

To avoid the use of your device’s mobile advertising identifiers (and the location Information associated with it) from our services, you can manually opt-out. Should you wish to request to view or delete personal Information held by pass_by, please submit your request in writing to or use this form.

You can also control and limit what location Information is collected through your device settings. Be aware, that if you do stop location services, some apps that depend on this may be affected.

  1. Children’s Privacy

Our products and website are not designed to gather Information from children under 16. If you suspect we’ve collected data from someone under these ages, please contact us using the details provided below.

  1. Storage of Information

All pass_by’s Information is stored and encrypted using AES-256 and processed in a cloud infrastructure based in North America.

  1. Data Retention

Information pass_by collect is retained indefinitely. Pass_by will delete all data within opt-out requests.

  1. Security of Information

Pass_by is committed to meticulously securing the Information in our possession, guarding against unauthorized access, destruction, and potential data breaches. We consistently assess and enhance our security processes and physical safety measures to comply with industry standards. However, it’s important to acknowledge that even with these efforts, no measures are completely immune to vulnerabilities. Hence, we cannot offer an unconditional assurance regarding the security of individual data components under our care.

  1. Variation of this statement

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. We recommend you review this page regularly if of interest.

  1. Privacy notice regarding GDPR

The EU General Data Protection Regulation (GDPR) came into effect in May 2018 and applies to all 27 member countries of the European Union (EU) and countries in the European Economic Area (EEA). Pass_by does not currently intend to collect or process any Information from the affected countries above and in addition we request that our data partners do not share any Information from these countries. We will update this policy should our approach to the geographic area change.

In the event that pass_by does receive data within the EU or EEA, we delete this data and ensure that it does not form part of any further processing.

If you are based in the EU or EEA and believe your data has been collected by pass_by, you have the right to stop any processing of your personal data and can do so any time by following the instructions in the opt-out section of this policy.

  1. Privacy notice for applicable US states

As of 2023, new consumer privacy laws are or will be effective in California, Colorado, Connecticut, Utah and Virginia. If you are a resident of California or a state mentioned above, by law you may obtain additional rights regarding the use of your personal Information. California and other states have the statutory right to opt-out of the ‘sale’ of their personal Information. Pass_by permits this right to all US residents. Within California law and other state regulations, a ‘sale’ is defined broadly as ‘any kind of disclosure to another business or third party for monetary or other valuable consideration’.

To request an opt-out, please email or complete the following form.

For more information on the California Consumer Privacy Act, or state laws of Colorado, Connecticut, Utah and Virginia – please visit the State Law Privacy Notice of the relevant state law.


If you have any further questions or comments about this privacy statement, please contact us at We will aim to respond to your enquiry as quickly as possible.

Passby Technologies Limited Ltd. (“pass_by.”) incorporated company based in the United Kingdom.

Passby Technologies Limited

64 Knightsbridge
London, SW1X 7JF

Tel: (917) 810-7675