Privacy and Cookies

PASSENGER2 PRIVACY & COOKIE POLICY

Passenger2 (“we”, “us”, “our”) is committed to protecting your privacy. This Policy explains how we collect, use, and share your personal information when you visit our website https://www.passenger2.com or use our services.

WHO WE ARE
Passenger2 is a UK-based developer.

Address: 272 Bath Street, Glasgow, Scotland, G2 4JR
Phone Number: +44 (0)131 618 0960
Email: contact@passenger2.com

LAWFUL BASES FOR PROCESSING
Under the UK GDPR and EU GDPR, we rely on the following lawful bases:

• Consent – You may withdraw consent at any time via our cookie settings or by contacting us.
• Contractual obligation – When processing is necessary to provide our services.
• Legal obligation – When required by law.
• Legitimate interests – For site security, fraud prevention, and service improvement.

INFORMATION WE COLLECT
We will collect and process the following information:

• Name and contact details (address, email, phone)
• Username and account details
• Payment information (processed securely via PayPal, Square, and WooPayments/Stripe; we do not store card details)
• Automatically collected data: IP address, browser type, operating system, referring/exit pages, device ID, clickstream data
• Tracking technologies: cookies, beacons, tags, item tracking codes
• Marketing preferences (via Brevo email marketing)
• Optional identifiers: Pilot ID (if entered by users within the application)

We do not process sensitive personal data.

HOW WE USE YOUR INFORMATION

• Account creation and management
• Processing payments and orders
• Customer support and dispute resolution
• Marketing and promotional communications (with consent)
• Testimonials and feedback collection
• Targeted advertising (with consent)
• Site security and fraud prevention
• Compliance with legal obligations
• Analytics and performance monitoring (via Overtracking)

SHARING YOUR INFORMATION
We will not transfer your personal information to third parties without your consent, except:

• Payment processors: PayPal, Square, WooPayments/Stripe
• Email marketing: Brevo
• Analytics: Overtracking, Google Analytics
• Social media/advertising: Facebook, Instagram, TikTok, YouTube, Discord, X (Twitter)
• Legal requirements: To comply with law, court orders, or public authority requests
• Business transfers: In case of merger, acquisition, or restructuring

Where data is transferred outside the UK/EEA, we ensure safeguards such as adequacy decisions or Standard Contractual Clauses approved by the ICO/EU.

COOKIES
Cookies are small text files stored on your device. We use them to improve site functionality and user experience.

Cookie Categories

• Strictly necessary cookies – Required for secure login, payments, and essential site functions.
• Analytical/performance cookies – Help us understand site usage. Disabled unless you opt in.
• Functionality cookies – Remember preferences (language, region). Disabled unless you opt in.
• Targeting/advertising cookies – Track visits and interests to tailor ads. Disabled unless you opt in.

Consent
When you first visit our Site, you will see a banner allowing you to accept, reject, or manage categories of cookies. Only strictly necessary cookies are set by default. You can change your preferences at any time via the “Cookie Settings” link in our footer.

More information on cookies: www.allaboutcookies.org.

YOUR DATA PROTECTION RIGHTS
You have the right to:

• Access your personal information
• Rectify inaccurate or incomplete informatio
• Request erasure of your data
• Restrict processing in certain circumstances
• Object to processing in certain circumstances
• Request data portability

We will respond within one month. Contact: contact@passenger2.com.

SECURITY
We implement appropriate technical and organisational measures, including encryption, secure servers, access controls, and regular audits, to protect your personal data.

CHILDREN’S DATA
Our services are not directed to individuals under 18. We do not knowingly collect data from minors. If we discover such data, we will delete it immediately.

PILOT ID VISABILITY
Within our application, users may choose to enter their Pilot ID to link their online account. Please note that if you choose to make your Pilot ID public, it may appear in search engine results (e.g., Google). This is optional and at your discretion. We recommend caution when sharing identifiers that could be searchable online.

RETENTION
We retain personal information for 90 days to 2 years after account termination, or longer if required for legal, fraud prevention, or enforcement purposes. Anonymous or aggregated data may be stored indefinitely.

INTERNATIONAL CUSTOMERS
Passenger2 sells worldwide. Depending on your country of residence, you may have additional privacy rights under local laws (e.g., EU GDPR, CCPA/CPRA in California). We will comply with applicable requirements in your jurisdiction.

COMPLAINTS
If you have concerns, contact us at contact@passenger2.com.
You may also complain to the ICO:
Information Commissioner’s Office
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF

Helpline: 0303 123 1113
Website: www.ico.org.uk