End user privacy
Passby Technologies Limited’s privacy policies and procedures cover the use of proximity and location data from the point of collection to ours and our customers’ platforms. Learn more here.
pass_by takes data privacy very seriously. It forms the backbone of the proximity and location based digital industry and as a result we must ensure we are always compliant with the data we manage and handle across all applicable privacy laws and industry privacy regulations.
- Transparent and clear disclosures on the collection of proximity and location data;
- User opt-in consent for the collection of location data from mobile devices
- Respecting and implementing users’ choices and their device settings.
In addition, we insist that our clients and customers treat and process location and proximity data received from us in compliance with all applicable privacy laws, regulations and their own polices.
Last updated: 3rd July 2023.
We are concerned about privacy issues and want you to be familiar with how we collect, use and share information we receive about our clients and users and the options available to you. If you have any questions you may contact us (see the “Contact Us” section of our
Passby Technologies Limited (“we,” “our,” “Passby Technologies Limited”), and its subsidiaries offer an aggregation platform service, where we collect Proximity and Location data (“the Data”) which we receive and store when a third party utilises the pass_by SDK or Platform (“the Service”).
With your consent, we may collect two kinds of location information through your use of the Service on your mobile phone or device. To identify locations near you and to appropriately enable the services, we may gather location information through your mobile phone or device’s geolocation, GPS or similar capabilities. Furthermore as part of the Service, we may collect information about your location within participating locations through your mobile phone or device’s Bluetooth, Wi-Fi or similar capabilities in combination with technology implemented by and with our partners. We refer to the location information collected through your mobile device’s applicable geolocation, GPS, Bluetooth or similar capabilities simply as “Location Information”.
We will only gather these kinds of Location Information if you agree to share them with us by opting-in to the Services from one or more of our partners (either during your initial app download, login or later.) to receive the Services and by enabling these capabilities on your mobile device. Once you have opted-in to receive the Services and consented to our gathering of Location information, the Passby Technologies Limited Software and Services will continue to collect Location Information about you until you log off (they will continue to gather information if they are running in the background) or use your phone’s or other device’s setting to disable your mobile device’s applicable geolocation, GPS, Bluetooth, Wi-Fi or similar capabilities for the Passby Technologies Limited Software or Services.
Information we collect automatically: When you utilise the Service or they are enabled, we may automatically collect certain information about your use of the Services such as the page you requested, where you click on the page and other information (“Information Collected Automatically”).
Aggregation of Personal Information: In an ongoing effort to better understand users, we may aggregate and compile Personal Information and other information our partners collect from users in a way that does not personally identify any one user (“Aggregated Personal Information”).
What kind of data does Passby Technologies Limited collect, and how does it collect it?
Passby Technologies Limited may collect the following types of data:
– IDFA, Android Advertiser ID or other type of advertising identifier (“Advertising ID”);
– Date and Time stamp information on engagement with the Service;
– Latitude and longitude of the mobile device when the interaction with the Service occurred;
– The ID of the sensor belonging to the Service that the mobile device interacted with and the corresponding information associated with that ID;
– Mobile device operating system,Mobile Device Make and Model;
– The name and version of the mobile application through which the interaction with the Service occurred;
– The duration of an interaction with the Service and;
– Device state and locale.
Our Partners do not provide us with data that can be directly used to identify you, such as your name, mobile phone number or email address.
Legal basis for processing data
- 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 collect?
We analyze and contextualize the data provided by the Partners for purposes of providing accurate location intelligence to our clients. This location intelligence 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. The data may also be used for the purpose of improving and analyzing the various services provided by us.
Third-party vendor list
A list of our trusted partners can be found here.
In what ways can I control the Data collected?
b) Device Settings: All major mobile device operating systems enable users of mobile
devices to control the types of data collected in and through mobile applications.
a. iOS (Apple)
Instructions on how to control location settings can be found here:
b. iOS (Apple)
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”.
c. Android (Google)
Instructions on how to control device location settings can be found here:
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 the data provided by our clients and partners with third parties such as
advertising networks, publishers and advertisers 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 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.
Passby Technologies Limited retains data for a limited period as follows;
1. Data segments. Data received by the Service may be categorised into non-personal,non-sensitive demographic segments such as “movie goers” or “fashion shoppers”.
We retain such segmented data sets for a period of 24 months from the date they were created.
2. Location data. We retain a device (or Advertising ID’s) association with a certain location or “venue” such as a sports stadium, for a period of 24 months from the date we receive such data from our partners.
3. Proximity interactions. We retain an individual mobile device’s interaction with a specific proximity sensor such as a Wi-Fi router or Bluetooth Beacon located in a certain area of a “venue” such as an an airport, for a period of 24 months.
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.
If you have any further queries, questions or comments about this privacy statement, please contact us at email@example.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 supply, creation and provision of Proximity Marketing products, software and services. The legal entity that operates passby.com is passby technologies limited.
Our contact details are as follows:
London, SW1X 7JF
Tel: (917) 810-7675
This policy sets out the basis on which any personal data we collect 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.tamo.co. 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
- Not kept longer than necessary for the purpose
- Processed in line with data subjects’ rights
2. Use of your Personal Information
pass_by may use information about you for the following purposes:
Contact information will be used for general administration purposes. Such purposes include the physical mailing of pass_by deliverables and ad hoc communications; sending e-mails 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 organisations 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 organisations have made, however other examples include the retention of information gathered from individuals and organisations 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 organisation’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.
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 collected automatically and Cookies
3.1 We may collect 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
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 pass_by. Ltd. of pass_by, 4 Bloomsbury Place, WC1A 2QA, United Kingdom.
5. Disclosure of Information
6. Your Rights
You have the right to ask us not to process personal data for marketing purposes. We will usually inform you (before collecting 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 collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org
In the event of violations of the GDPR, data subjects are entitled to log 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 recourses.
7. Access to Information, Subject Access and Right to Erasure requests and do not sell:
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@pass_by.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 collected 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@pass_by.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 email@example.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 collected, 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 firstname.lastname@example.org. Opting out will not affect the services provided to you.