SAFEPASSAGE PRIVACY POLICY

3.1 Information You Provide Directly

3.2 Information Collected Automatically

3.3 Information from Third Parties

We may receive information about you from:

• Payment processors regarding transaction status
• Business partners who refer you to our Services
• Third-party services used for fraud prevention and security

4.1 Contract Performance

Processing necessary for the performance of our contract with you, including:

• Providing age verification and document verification services
• Managing your account and subscription
• Processing payments and billing

4.2 Legitimate Interests

Processing necessary for our legitimate interests or those of third parties, including:

• Improving and developing our Services
• Ensuring security and preventing fraud
• Providing customer support
• Sending service-related communications

4.3 Legal Obligations

Processing necessary to comply with legal obligations, including:

• Responding to legal requests and court orders
• Complying with data protection regulations
• Maintaining records for tax and accounting purposes

4.4 Consent

Where required by law, we process certain data based on your consent, which you may withdraw at any time.

5.1 Provide and Maintain Services

• Perform age verification and document verification
• Process transactions and manage subscriptions
• Provide customer support and respond to inquiries
• Send service updates and technical notifications

5.2 Improve and Develop Services

• Analyze usage patterns and service performance
• Develop new features and improvements
• Conduct research and development
• Fix bugs and technical issues

5.3 Ensure Security and Compliance

• Detect and prevent fraud, abuse, and security incidents
• Enforce our Terms of Service
• Comply with legal obligations
• Protect the rights and safety of SafePassage and our users

5.4 Communications

• Send transactional emails about your account
• Provide technical support and service announcements
• With your consent, send marketing communications

6.1 Service Providers

We share data with third-party service providers who perform services on our behalf:

• Emblem: Provides privacy infrastructure for verification processing
• Payment Processors: Currently PayPal for payment processing
• Cloud Infrastructure: For hosting and data storage
• Analytics Providers: For service improvement and usage analysis

All service providers are bound by contractual obligations to protect your data and use it only for the purposes we specify.

6.2 Business Transfers

If SafePassage is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

6.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including:

• Court orders and legal process
• Government requests
• Law enforcement investigations

6.4 Protection of Rights

We may disclose information where we believe it is necessary to:

• Protect the safety of any person
• Address fraud, security, or technical issues
• Protect SafePassage's rights or property

6.5 Aggregated Information

We may share aggregated, anonymized information that cannot identify you personally for research, marketing, or other purposes.

7.1 Verification Data

• Facial images and document images: Processed in real-time and not stored
• Verification results: Retained for the period required by applicable regulations
• Transaction logs: Retained for audit and compliance purposes

7.2 Account Data

• Active accounts: Retained for the duration of your subscription
• Closed accounts: Basic information retained as required for legal and tax purposes
• Payment records: Retained as required by financial regulations

7.3 Legal Requirements

We may retain certain information for longer periods when required by law or to protect our legal interests.

8.1 Security Measures

• Encryption of data in transit using TLS/SSL
• Encryption of sensitive data at rest
• Access controls and authentication mechanisms
• Regular security assessments and audits
• Employee training on data security

8.2 Privacy by Design

• Minimization of data collection
• Privacy-first architecture through our partnership with Emblem
• Double anonymity ensuring separation between verification and content services
• Regular privacy impact assessments

8.3 Incident Response

In the event of a data breach, we will:

• Notify affected users within 72 hours as required by law
• Notify relevant supervisory authorities
• Take immediate steps to mitigate harm
• Document the incident and our response

9.1 Safeguards

For transfers outside the EEA, we ensure appropriate safeguards through:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions where applicable
• Other legally recognized transfer mechanisms

9.2 Your Rights

You have the right to information about the safeguards we use for international transfers of your data.

10.1 Access and Portability

You have the right to:

• Access your personal data
• Receive your data in a structured, machine-readable format
• Transfer your data to another service provider

10.2 Correction and Deletion

You have the right to:

• Correct inaccurate or incomplete data
• Request deletion of your data (subject to legal requirements)
• Restrict processing in certain circumstances

10.3 Objection and Withdrawal

You have the right to:

• Object to processing based on legitimate interests
• Withdraw consent where processing is based on consent
• Opt-out of marketing communications

10.4 Automated Decision-Making

When our Services use automated processing for age verification:

• You have the right to request human review
• You may express your point of view and contest decisions
• Alternative verification methods are available upon request

10.5 How to Exercise Your Rights

To exercise any of these rights, please contact us at privacy@safepassageapp.com. We will respond to your request within 30 days.

11.1 Types of Cookies We Use

• Essential Cookies: Required for the Services to function properly
• Performance Cookies: Help us understand how users interact with our Services
• Functional Cookies: Remember your preferences and settings
• Analytics Cookies: Collect aggregated data about Service usage

11.2 Managing Cookies

You can control cookies through your browser settings. Note that disabling certain cookies may limit your ability to use some features of our Services.

13.1 European Economic Area (EEA) Rights

EEA residents have additional rights under GDPR, including:

• Right to lodge a complaint with your local supervisory authority
• Right to withdraw consent at any time
• Right to object to processing for direct marketing
• Rights related to automated decision-making and profiling

13.2 California Privacy Rights

California residents have rights under CCPA, including:

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising privacy rights

13.3 Other Jurisdictions

We respect privacy rights under all applicable laws. If you have questions about your rights in your jurisdiction, please contact us.

14.1 Emblem Integration

Our Services integrate with Emblem's privacy infrastructure. Emblem's processing of data is subject to:

• Our data processing agreement with Emblem
• Emblem's Terms of Service: https://www.emblemapp.com/terms
• Emblem's Privacy Policy: https://www.emblemapp.com/privacy

14.2 Payment Processors

Payment processing is handled by third-party processors (currently PayPal) subject to their own privacy policies. We do not store complete payment card information.

14.3 Links to Other Sites

Our Services may contain links to third-party sites. We are not responsible for the privacy practices of these sites.

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact us:

16.1 Supervisory Authority

EEA residents may also contact their local data protection authority with questions or complaints.