Privacy Policy

01Our two roles

For the businesses that use PasslyWallet (our customers) we are the data controller of their account data.

For the members (end customers) of those businesses, the business is the controller and PasslyWallet acts as a processor: we process member data solely on the business’s instructions. A data processing agreement is available on request via privacy@passlywallet.com.

02What data we process

Business account data: business name, admin names and email addresses, and settings.

Member data: name, email, phone number, optional birthday, loyalty points and transactions, wallet pass identifiers and (where applicable) device push tokens.

Technical data: IP address and limited logs for security and abuse prevention.

03Purposes and legal basis

We process this data to provide the loyalty service: generating wallet passes, tracking points, and sending transactional emails.

Legal bases: performance of the contract (with the business), legitimate interest (security and service), and the member’s consent at signup.

04Processors and service providers

We use carefully selected subprocessors: Vercel (hosting), Neon (database, EU region), Resend (email) and Apple/Google (wallet passes). They process data only for us and under a data processing agreement.

We never sell your data.

05Retention and deletion

We keep data as long as the account or membership is active. A business can export or erase a member’s data on request; on erasure we irreversibly anonymise the personal data.

When an account ends, we delete or anonymise the associated data within a reasonable period.

06Your rights

You have the right to access, rectification, erasure, portability and objection. If you are a member of a connected business, address your request to that business; we support them with export and erasure tools. For account data you can contact us directly.

You may also lodge a complaint with the Dutch Data Protection Authority (autoriteitpersoonsgegevens.nl).

07Security

We protect data with encryption in transit, hashed passwords and API keys, and strict separation between different businesses’ data (tenant isolation).

08Cookies

We use only functional cookies (login session and language preference). No tracking or advertising cookies.

09Contact

Questions about privacy? Email privacy@passlywallet.com or info@passlywallet.com.