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Privacy Policy
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1. Introduction

Welcome to SendbyPass. We are committed to safeguarding your privacy and ensuring that your Personal Data is protected and secure. This Privacy Policy outlines how we collect, use, disclose, and protect your Personal Data in compliance with the General Data Protection Regulation (GDPR). It applies to all the platforms that are operated or managed by Sendbypass (collectively, “SendbyPass”, “we” and “us”), including our website, mobile application and any related services (collectively referred to as the “Services”).
This Privacy Policy is an integral part of our Terms & Conditions (“T&C”) and by interacting with any of our Services, you also agree to the terms described in this Privacy Policy and any subsequent amendments and modifications thereto.

2. Definitions

For the purposes of this Privacy Policy:
Personal Data means any information relating to an identified or identifiable natural person (“Data Subject”). Process means any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, or otherwise making available, alignment, combination, restriction, erasure, or destruction. Controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
Processor means a natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller.
User, you means any individual who interacts with our Services, including passengers, shoppers, travelers, and senders. Terms & Conditions or T&C refers to the agreement between you and SendbyPass that governs your use of our Services. The T&C work in conjunction with this Privacy Policy.
Terms capitalised in this Privacy Policy, but not otherwise defined herein, shall have the meanings ascribed to them in the T&C.

3. Data Collection

At SendbyPass, we respect your privacy and strive to collect and Process only the Personal Data we need to provide and improve our Services, which their types and methods of collecting them are as follows:

  • 1. Personal Data you directly provide to us

    We collect the following Personal Data when you create an account or directly communicate or provide information with us:

    • Account Information

      SendbyPass collects identifiers, such as your name, email address, username, profile picture, phone number, and postal address when you sign up for a SendbyPass account, or to receive information on our Services. We may also collect or generate indirect identifiers (eg, “USER12345”).

    • Payment Information

      We collect your payment information such as bank details, credit, debit, or other payment card information, if you choose to purchase access to SendbyPass products or Services. This information is processed in compliance with PCI-DSS standards to ensure its security.

    • User Content and Feedback

      When you use our Services, we collect Personal Data that is included in file uploads, messages, reviews, details about the items you request for delivery, including product links, descriptions, prices, or feedback that you provide to our Services (“Content”). This may include personal identifiers, transaction details, and any other information you choose to provide. Any information posted or otherwise disclosed publicly to all the Users with consent (ie, posting in forums, our social media services), will be considered as public information and would be available to all Users who have access to our Services.

    • Communication Data

      If you communicate with us, including via our social media accounts, we collect your name, contact information, and the contents of any messages you send.

  • 2. Personal Data We Receive Automatically from Your Use of the Services

    When you visit, use, or interact with the Services, we receive the following information automatically (“Technical Information”):

    • Log Data

      Based on your device or browser permissions, your device or browser automatically sends us information about when and how you install, access, or use our Services. This includes information such as your device type, operating system information, browser information, mobile network, connection information, mobile operator or internet service provider (ISP), time zone setting, IP address (including information about the location of the device derived from your IP address).

    • Troubleshooting Information

      We collect information about how our Services are performing when you use them. If you or your device experiences an error, we may collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.

    • Usage Data

      We may also automatically collect some information in relation to your interaction with our Services, such as device identifiers (including device or advertising identifiers, probabilistic identifiers, and other unique personal or online identifiers), the dates and times of access, browsing history, search, information about the links you click, pages you view, and other information about how you use the Services, the features you use and the actions you take.

    • Cookies and Similar Technologies

      We use cookies, web beacons, pixel tags, and similar technologies to operate and administer our Services, and improve your experience. These technologies help us to recognise you, customise or personalise your experience, market additional products or Services to you, and analyse the use of our Services to make them safer and more useful to you.
      For more detailed information about the types of cookies we use, their purposes, and how you can manage your cookie preferences, please see our Cookie Policy accessible here.

    • Location Data

      You hereby explicitly consent that we may collect precise geographic location data using the GPS functionality of your device your and IP address to enhance our Services, provide relevant recommendations, and ensure efficient and accurate transport Services. You can withdraw your consent for the collection of precise location data at any time through your device settings or by contacting us at the email address mentioned below (in “Contact Us” section).

    • Data in Relation to the Third Parties

      We may include third-party advertisements and other content from third parties on our Services. Information gathered through these integrated technologies is directly collected by these third parties for their own use, as well as for use by other authorised entities. The handling of such data is governed by the privacy policies of those third parties.

4. Data Usage

We Process the collected data for various commercial and technical purposes. The following table explains these purposes, indicating the types of Personal Data that would be Processed in relation to them, and the legal basis for them according to the GDPR.

Purpose

To provide and maintain our products and Services

Types of Data Processed
  • Account Information
  • Payment Information
  • User Content and Feedback
Legal Basis
  • Contract
  • Legitimate interest
Purpose

To improve and develop our Services and conduct research on them

Types of Data Processed
  • Account Information
  • Payment Information
  • User Content and Feedback
  • Usage Data
  • Log Data
  • Troubleshooting Information
  • Location Data
Legal Basis
  • Contract
  • Legitimate interest
  • Consent
Purpose

To provide and promote (and enable the promotion of) third-party products and services to you which we think would be helpful to you

Types of Data Processed
  • Account Information
  • Usage Data
  • Log Data
  • Cookies and Similar Technologies
  • User Content and Feedback
Legal Basis
  • Consent
Purpose

To create and administer your account

Types of Data Processed
  • Account Information
  • Payment Information
Legal Basis
  • Contract
Purpose

To communicate with you for non-marketing purposes including by sending you Services-related emails, push notifications, and other messages

Types of Data Processed
  • Account Information
  • Communication Data
Legal Basis
  • Contract
  • Legitimate interest
Purpose

To send you marketing communications, where you have signed up to receive them

Types of Data Processed
  • Account Information
  • Communication Data
Legal Basis
  • Consent
Purpose

To conduct other marketing activities, analysis and research

Types of Data Processed
  • Usage Data
  • Log Data
  • User Content and Feedback
Legal Basis
  • Legitimate interests
Purpose

To prevent and investigate fraud, unlawful or criminal activity, unauthorised access to or use of Personal Data, misuses of our Services, and to protect the security of our systems and Services

Types of Data Processed
  • Account Information
  • Payment Information
  • User Content and Feedback
  • Log Data
Legal Basis
  • Legitimate interests
  • Public Tasks
  • Legal obligation
Purpose

To comply applicable laws and regulations, such as satisfying tax or reporting obligations, or to comply with a lawful governmental request of information

Types of Data Processed
  • Account Information
  • Payment Information
  • Log Data
Legal Basis
  • Legal obligation
Purpose

To comply applicable laws and regulations, such as satisfying tax or reporting obligations, or to comply with a lawful governmental request of information

Types of Data Processed
  • Account Information
  • Payment Information
  • Log Data
Legal Basis
  • Legal obligation

You also hereby consent that we may also use Personal Data for other purposes communicated to you.
SendbyPass will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our T&C. When assessing retention periods, we first carefully examine whether it is necessary to retain the Personal Data collected and, if retention is required, work to retain the Personal Data for the shortest possible period permissible under law, or either notify you and strive to obtain your specified consent.

5. Data Sharing and Disclose

We disclose and share your Personal Data to the following categories of third parties under following circumstances:

  • 1. Personal Data you directly provide to us

    We will discloses Personal Data described above between and among our affiliates (meaning an entity that controls, is controlled by, or is under common control with SendbyPass), subsidiaries, and related entities, which may use the Personal Data we shared only in a full compliance with this Privacy Policy.

  • 2. Service providers and business partners

    To conduct and facilitate our business operations and to perform certain Services and functions such as website and data hosting, ensuring compliance with industry standards, research, auditing and data processing, we may disclose Personal Data to vendors and service providers, including providers of hosting Services, customer service vendors, cloud Services, content delivery Services, data warehouse Services, support and safety monitoring Services, email communication software, web analytics Services, payment and transaction providers, and other information technology service providers. These parties will access, process, or store Personal Data only in relation to performing their duties to us.

  • 3. Business or Corporate Transfers

    In the event of SendbyPass being involved in a merger, acquisition, corporate transaction, bankruptcy, reorganisation, receivership, transition of service to another provider, or other situation involving the transfer of business assets (collectively, a “Transaction”), SendbyPass will disclose your Personal Data with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

  • 4. Governmental Authorities and Entities

    We may disclose Personal Data to governmental and judicial authorities,

    • if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, including for legal, tax or accounting purposes, in response to their requests for such information or to assist in investigations,
    • to protect, enforce and defend our rights or property,
    • if we determine, in our sole discretion, that there is a violation of our terms or policies;
    • to detect or prevent fraud or other illegal activity; and
    • to protect the safety, security, and integrity of our products, employees, or users, or the public.
  • 5. Third-parties

    Personal Data collected by third-party ads, content or technologies integrated with any of our Services will be disclosed to such third parties.

6. Data Protection and Retention

We will retain your Personal Data for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, complying with our legal obligations, or otherwise explained in this Privacy Policy.
When the Personal Data collected is no longer required by us, we and our service providers will perform the necessary procedures for destroying, deleting, erasing, or converting it into an anonymous form as permitted or required under applicable laws and regulations.

  • 1. EU Standard Contractual Clauses

    We rely on the standard contractual clauses approved by the European Commission for transfers of Personal Data to countries outside the EEA.

  • 2. Privacy Shield Framework

    For transfers to the United States, we may rely on the EU-US Privacy Shield Framework.

7. Unidentified Data

At SendbyPass, we believe that great privacy rests on great security. We use commercially reasonable administrative, technical, and physical safeguards to protect your Personal Data, taking into account the nature of the Personal Data and the processing, and the threats posed. We constantly work to improve on these safeguards to help keep your Personal Data secure, and to detect and automatically block security threats from ever reaching it. If we do detect something risky that we think you should know about, we’ll notify you and help guide you through steps to stay better protected.
Please be advised that, despite our efforts and the security measures outlined in this Privacy Policy, no method of data transmission over the Internet, via Wi-Fi, or through encryption can be guaranteed to be entirely secure. Unauthorised third parties may intercept or access Personal Data transmitted through our platform or via email. While we employ commercially reasonable measures to protect the information you provide, we cannot guarantee its absolute security. Therefore, any transmission of Personal Data to SendbyPass is at your own risk.

8. User Rights

At SendbyPass, we value your privacy and strive to provide you with control over your Personal Data. In accordance with the General Data Protection Regulation (GDPR) and other applicable laws, you have the following rights regarding your Personal Data:

  • 1. Right to be Informed

    You have the right to be informed about types of Personal Data SendbyPass processes about you, the business or commercial purposes for collection, how to contact SendbyPass, how long are we storing your Personal Data, the categories of third parties to whom we may disclose it.

  • 2. Right to Access

    You have the right to request (via email or a designated link) a copy of the Personal Data we hold and have processed about you, among with information about how we use and share it. This request would be fulfilled at no cost.

  • 3. Right to Rectification

    If you believe that your Personal Data that we retain is inaccurate or incomplete, you have the right to request its correction or completion.

  • 4. Right to Erasure

    You have the right to request the deletion of some of your Personal Data or all of it under certain conditions, such as when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent. However, in some circumstances, we may lawfully refuse your request of deletion, which are as following:

    • processing data is necessary for exercising the right of freedom of expression and information;
    • you have an ongoing service request, order or issue for which your Personal Data is necessary (such as your luggage not being reached to your destination);
    • you have misused or are suspected to have misused our Services;
    • your Personal Data is necessary to us in order to exercise, defend, or establish our rights and claims;
    • for compliance with a legal obligation which requires processing your Personal Data (such as your payments, in relation to tax obligations); and
    • processing data is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with applicable laws.
  • 5. Right to Restrict Processing

    You can request the restriction of processing your Personal Data by SendbyPass in certain circumstances, such as when you contest its accuracy or object to its processing. In such cases, you will be informed of the restriction before it is lifted.

  • 6. Right to Data Portability

    You have the right to obtain your Personal Data from us and reuse it for your own purposes across different Services. We will provide your data in a structured, commonly used, and machine-readable format.

  • 7. Right to Object

    You have the right to object to the processing of your Personal Data in certain situations, including for direct marketing purposes (such as our newsletter).

  • 8. Withdrawal of Consent

    Where SendbyPass’ processing of your Personal Data is based on consent, you have the right to withdraw your consent. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

  • 9. Automated Decision-Making (when applicable)

    To exercise your rights, you or your authorised agent may submit a request by emailing us at the email address mentioned below (in “Contact Us” section). After we receive your request, we may verify it by requesting information sufficient to confirm your identity. We will respond to your request within a reasonable timeframe and in accordance with applicable laws.
    Your rights as described in this section are in addition to, and not in derogation of, any rights you may have under our T&C; Therefore, you must consider compliance with any relevant provisions in the T&C, when exercising these rights.

9. International Data Transfers

We store and process your Personal Data primarily within the European Economic Area (EEA). However, due to the international nature of our business, we may transfer your Personal Data outside the EEA to our affiliates and service providers located in other countries. When we transfer your Personal Data to countries outside the EEA, we take appropriate safeguards to ensure that your rights continue to be protected. These safeguards may include:

10. Children

Our Services are not directed towards, and we do not knowingly collect, use, disclose, sell, or share any information about, children under the age of 18. If you become aware that a child under the age of 18 has provided any Personal Data to us while using our Services, please email us at the email address mentioned below (in “Contact Us” section) and we will investigate the matter within a reasonable timeframe and, if appropriate, delete the Personal Data. Users under 18 must have permission from their parent or guardian to use our Services.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page, unless another type of notice is required by applicable law.
We encourage you to review this policy periodically for any updates.

12. Contact Us

If you have any questions about this Privacy Policy, or have any questions, complaints or requests regarding your Personal Data, you can contact us as described below:

Data Protection Officer (DPO):Email: [email protected]Phone: +370 625 49672

Please note that under the laws of several countries, you have the right to lodge a complaint with the supervisory authority in the place in which you live or work. A full list of EU supervisory authorities’ contact details is available here.
If you live or work in the UK, you have the right to lodge a complaint with the UK Information Commissioner’s Office.

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