End user privacy
Passby Technologies Limited’s privacy policies and procedures cover the use of geospatial data from the point of processing to our products and customers.
pass_by takes data privacy very seriously. It forms the backbone of the geospatial industry and as a result we must ensure we are always compliant with the data we receive from our partners and process across all applicable privacy laws and industry privacy regulations.
This includes:
- Transparent and clear disclosures on the processing of geospatial data;
- User opt-in consent, where applicable, for the processing of location data from mobile devices
- Respecting and implementing users’ choices and their device settings.
In addition, we legally require that our clients treat and process any data products received from us in compliance with all applicable privacy laws, regulations and their own policies.
Privacy Statement
Last updated: 3rd July 2023.
We are concerned about privacy issues and want you to be familiar with how we process, use and share information we receive and the options available to you. If you have any questions you may contact us (see the “Contact Us” section of our website).
Passby Technologies Limited (“we,” “our,” “Passby Technologies Limited”, “pass_by”), and its subsidiaries provide an range of geospatial data products (“the Products”) , which rely on anonymized mobile location data from third-party mobile devices (“Device Data”)
What Device Data do we collect
Some of the Device Data we receive from Partners may constitute Personal Data under applicable laws.
Passby Technologies Limited may process the following types of Device Data:
- IDFA, Android Advertiser ID or other type of advertising identifier (“Advertising ID”);
- Location of the mobile device expressed as the latitude, altitude, and longitude 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 you, such as your name, mobile phone number or email address.
Legal basis for processing data
Our legal basis for processing and using the Device Data described in this Privacy Policy will depend on the personal data concerned and the context in which we process it. We process personal data from you:
- where we need it to perform a contract with you (e.g., to fulfill an order);
- where the processing is in our legitimate interests (which include the purposes listed, above); or
- if we otherwise have your consent.
What do we do with the data we process?
We analyze and contextualize the data provided by the Partners for purposes of providing accurate geospatial products to our clients. These products can be used for advertising, audience segmentation, people-based movement analytics, improving business decision making by better understanding of customer movement patterns, assisting municipalities in urban planning by enhanced understanding of movement patterns, and similar purposes that utilize location as a tool.
In what ways can I control the Data processed?
a) Privacy Policies: Check the privacy policy of any app you download and make sure you understand what it is asking for and why it is asking for it. In particular, check the types of data the application processes from or about your device(s). Do not download, or continue the use of, a mobile application if you do not feel comfortable with the data process practices described in their privacy policy.
b) Device Settings: All major mobile device operating systems enable users of mobile devices to control the types of data process in and through mobile applications.
a. iOS (Apple)
Instructions on how to control location settings can be found here:
Instructions on how to limit add tracking can be found here:
For other privacy-related settings on iOS please go to Settings from your mobile device’s home screen and select “Privacy”.
b. Android (Google)
Instructions on how to control device location settings can be found here:
79522
Instructions on how to limit ad tracking on Android devices can be found here:
How does Passby Technologies Limited disclose the data to third parties?
We may disclose Device Data with third parties such as retailers, financial institutions, real estate companies, researchers, data analytic platforms and advertising in accordance with the terms of the
agreements, and only for the purposes of performing such agreements, that we have in place with such third parties. Such disclosures do not include any Device Data that can directly
identify a user such as a name, mobile phone number or an email address.
We may also disclose data provided by our partners to:
– Our service providers (e.g. Our server and data storage providers);
– Public authorities such as law enforcement, if we are legally required to do so or if we need to protect our rights and those of third parties and;
– Our subsidiaries or affiliates; or a subsequent owner, co-owner or operator of our services and their advisors in connects with a merger, consolidation, restructuring, sale or in connection with bankruptcy proceedings or other type of professional reorganization.
Variation of this statement
From time to time we may change or vary this statement. You can tell when changes have been made to the statement by referring to the “Last Updated” line at the very top of the
statement. Please check this statement regularly to ensure you are aware of any changes.
Contact
If you have any further queries, questions or comments about this privacy statement, please contact us at hello@passby.com. We will aim to respond to your enquiry as quickly as possible.
Passby Technologies Limited Website – Users and Clients
The Passby Technologies Limited. Data Protection and Privacy Statement (2023).
Passby Technologies Limited Ltd. (“pass_by.”) incorporated company based in the United Kingdom.
Our principal activity is the creation and provision of Geospatial Data Products. The legal entity that operates passby.com is Passby Technologies Limited
Our contact details are as follows:
pass_by
64 Knightsbridge
London, SW1X 7JF
Tel: (917) 810-7675
Data Protection and Privacy Policy
This policy sets out the basis on which any personal data we process from you or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1. Your Personal Information
1.1 We only create a record in your name if you register on www.passby.com. Any information that you give us from then on is added to your record.
1.2 pass_by is committed to the protection of your personal information in accordance with the principles of the United Kingdom of Great Britain and Northern Ireland’s Data Protection Act 1998 (“the Act”). These provide that personal data must be:
- Processed fairly and lawfully
- Processed for limited purposes and in an appropriate way
- Adequate, relevant and not excessive for the purpose
- Accurate
- Not kept longer than necessary for the purpose
- Processed in line with data subjects’ rights
- Secure.
2. Use of your Personal Information
pass_by may use information about you for the following purposes:
2.1 Administration
Contact information will be used for general administration purposes. Such purposes include the physical mailing of pass_by deliverables and ad hoc communications; sending emails about pass_by events and other initiatives; and distribution of the pass_by newsletter and other electronic publications by e-mail.
2.2 Service monitoring and professional education
pass_by will retain information about how individuals and organizations make use of the pass_by service – both for service monitoring and improvement purposes. The main example of this type of information is a record of the purchases individuals or organizations have made, however other examples include the retention of information gathered from individuals and organizations about the level of satisfaction they have with pass_by. and its services, along with suggestions for how pass_by. should develop in the future.
2.3 Research and Development
From time to time pass_by will ask individuals for input into the organization’s ongoing services. This input may take the form of a questionnaire response, e-mail or a written record of opinions, suggestions and ideas or conversation with pass_by staff. pass_by may also record information about individuals’ areas of expertise, enabling pass_by to seek input from these individuals as appropriate or in order to facilitate service improvements.
2.4 Networking
To facilitate networking between pass_by forum members the restricted access Members- only web site may display a restricted set of information (Name, Company, Email address and Telephone Number) related to individuals. Access to this information will only be granted to authorised users of the Members-only web site. To allow Members to network with other Members, the names of participants may be recorded and displayed on both the Members-only web site and in documentation related to the forum.
3. Information processed automatically and Cookies
3.1 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.
3.2 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 personalised service.
3.3 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.
Manage Cookie Preferences
4. Links
The pass_by website contains links to other websites and this data protection policy does not apply to those websites. If you transfer to another website you should read their data protection statement for their policy on the use of personal information. For the purpose of the Data Protection Act 1998 (the Act), the data controller is Passby Technologies Limited, 4 Bloomsbury Place, WC1A 2QA, United Kingdom.
5. Disclosure of Information
We may disclose personal information about you to third parties if we are under a duty to disclose or share personal data 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 rights, property, or safety of pass_by employees, pass_by or its customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
6. Your Rights
You have the right to ask us not to process personal data for marketing purposes. We will usually inform you (before processing the data) if we intend to use that data for such purposes or if we intend to disclose their information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to process your data. You can also exercise the right at any time by contacting us at hello@passby.com
In the event of violations of the GDPR, data subjects are entitled to lodge a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal resources.
7. Access to Information, Subject Access and Right to Erasure requests and do not sell:
GDPR
Should you wish to request to view or delete personal information held by pass_by, under the General Data Protection Regulation, please submit your request in writing to optoutrequest@passby.com or use this form.
California Consumer Privacy Act
As of January 1st 2023, a new data privacy regulation, the California Consumer Privacy Act, came into effect. This policy provides residents of California the right to know what personal information is processed about them, if that information is being sold and to which companies. Furthermore, it permits consumers to opt-out of the sale of their personal information. To make a Do Not Sell My Personal Information request please click here or e-mail optoutrequest@passby.com. Should you wish to opt-out, the service you receive will not be impacted.
Colorado Privacy Act:
Effective from July 1st, 2023, the Colorado Privacy Act provides Colorado residents with the right to access, correct, delete, or obtain a copy of their personal information. It also allows individuals to opt-out of the processing of their personal data for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects. To exercise these rights, please send your request to optoutrequest@passby.com. Your service will not be impacted by the decision to exercise these rights.
Connecticut Personal Data Privacy and Online Monitoring Act:
Effective from July 1st, 2023, the Connecticut Personal Data Privacy and Online Monitoring Act allows Connecticut residents to request the disclosure of any personal information that is being processed, shared, or sold. It also gives them the right to request the deletion of their personal information. To exercise these rights, please send your request to optoutrequest@passby.com. Opting out will not affect the services provided to you.
8. Changes to our Privacy Policy
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.
9. Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to hello@passby.com.