Your data is

As of 19 March 2021

We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the Passendo ApS. (“Passendo”, “controller”, “we”, “us”, “our”). The use of www.passendo.com (“Internet pages of Passendo”, “website”) is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject. According to our Privacy Statement we believe that the only personal data that we process are your e-mail addresses and only before we use SHA256 to get the hash string. In any additional instance of data processing (what may happen during provision of our services, e.g. marketing profiling, newsletter subscription etc.) we shall use our best to process your data in accordance with the best practices and applicable law. The processing of personal data of a data subject shall always be in line with the laws of Denmark (primarily) – “applicable law” – including the General Data Protection Regulation (“GDPR”), and in accordance with the country-specific data protection regulations applicable to Passendo. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we may collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled. As the controller, Passendo has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

This GDPR Privacy Statement along with our Privacy Statement and Website Privacy Policy form the sole legal document and are inherent parts of it.

1. Definitions

The data protection declaration of Passendo is based on the terms used by the European legislator for the adoption of the GDPR. Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, inter alia, the following terms:

a. Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”, “user”, “you”, “your”, “yours”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person such as your education, work experience, skills, photo, city or area and endorsements.

b. Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c. Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d. Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e. Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

f. Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g. Controller or controller responsible for the processing

Controller or controller responsible for the processing is 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.

h. Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i. Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third-party or not.

j. Third-party

Third-party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k. Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which you, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the Controller

The controller for the purposes of the GDPR, the applicable law and other applicable data protection laws and other provisions related to data protection is: Passendo ApS Tagensvej 85F, DK-2400 Copenhagen N Denmark Phone: +45 29 68 08 33 Email: aj@passendo.com Website: www.passendo.com

3. Name and Address of the Data Protection Officer

The Data Protection Officer of the controller is: Mykola Vdovychenko, Passendo ApS Tagensvej 85F, DK-2400 Copenhagen N Denmark Phone: +45 29 68 08 33 Email: aj@passendo.com Website: www.passendo.com Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.

4. Cookies

The Internet pages of Passendo use cookies. Cookies are text files that are stored in a computer system via an Internet browser. Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID. Through the use of cookies, Passendo can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie. The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

5. Collection of General Data and Information and Its Use by Passendo

The website of Passendo collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected information may include (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems. When using these general data and information, Passendo does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Passendo analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

6. Additional Provisions on Use of Personal Data and Website Functional

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the written request or indication of the data subject, insofar as there are no statutory storage obligations. The Data Protection Officer particularly designated in this data protection declaration, as well as the entirety of the controller’s employees are available to the data subject in this respect as contact persons. We may contact you by any electronic means such as email and other ways through Internet pages of Passendo, including text messages and push notifications. We may send you messages about the availability of Internet pages of Passendo, security, or other service-related issues as well as changes of this Privacy Statement. We may use user’s personal data (which can include your communications) needed to investigate, respond to and resolve complaints and issues with our services provided via Internet pages of Passendo (e.g., bugs, failures etc.). We use your data (which may include your communications) if we think it is necessary for security purposes or to investigate possible fraud or other violations of other legal documents published on Internet pages of Passendo. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our website (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of data controller, Passendo, personnel, or others. We attempt to notify Passendo about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand. We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Statement.

7. Security of Personal Data

Passendo does implement security safeguards designed to protect your personal data, such as HTTPS and other measures. We regularly monitor our systems for possible vulnerabilities and attacks. Although, we cannot warrant the security of any information that you provide us. There is no guarantee that such data will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We currently do not share personal data with third-parties for their direct marketing purposes. Learn more about this and about our response to “do not track” signals. If you have questions or complaints regarding this Privacy Statement, please first contact Passendo.

8. Subscription to Our Newsletters