AssetPass Ltd (“us”, “we”, or “our”) operates the AssetPass mobile application (hereinafter referred to as the “Service”).

AssetPass respects your privacy and is committed to protecting the personal information that you share with us. In this Privacy Policy, we describe how we collect, use, and disclose information that we obtain about you to provide our AssetPass service.

We only ask for personal information when we truly need it to provide a service to you. We collect it by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used.

If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.

AssetPass goes to tremendous effort to ensure that any information you share with us is protected by the very best technical and procedural safeguards possible today.

AssetPass will not share your personal information for commercial gain but we may contact you from time to time to inform you, our customer, about promotions or services that AssetPass feel may be of interest to you.

AssetPass will also communicate to you regarding the AssetPass App to ensure that we are operating in accordance with your wishes.

Information Collection and Use

Personal Data

To operate our Service, we require you to provide us with certain personally identifiable information, such as your email address, first and last name and your mobile phone number. Video and images are also considered as personal information and we also collect these to fulfil your wishes, these are encrypted on your device prior to being stored on our service.

We may use your Personal Data to contact you with AssetPass newsletters, AssetPass marketing or AssetPass promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these marketing communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Usage Data

To improve and protect our service when you access the Service from your mobile device, we may collect certain information automatically (“Usage Data”), including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data

Cookies are files with small amounts of data that are commonly used to store and receive identifiers and other information on computers, phones and other devices. We use cookies to personalise your experience with AssetPass and we may use third party code and libraries that may use cookies to collect information to improve our service to you.

Use of Data

AssetPass uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

AssetPass will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Legal Requirements

AssetPass may disclose your Personal Data Metadata (email address, first and last name) in that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of AssetPass
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

AssetPass cannot disclose the contents of your albums as they are encrypted from your device.

Album release

AssetPass cannot disclose the contents of your albums as they are encrypted. Only you, a recipient you have specified or in some instances recipients your trustee nominates (if you have asked them to do so) can access the content.

If your trustees request to release your album your permission will be sought prior to release. Should you not respond to their request (after a predefined period, normally a month) your trustees will be allowed to release the album to a recipient.

Once an album has been released to recipients AssetPass is no longer responsible for the privacy of your album contents.

Your right to be forgotten

We only retain collected information for as long as necessary to provide you with your requested service. What data we store, we’ll protect to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.

We will retain your Personal Information as necessary in connection with the purposes described in this Privacy Statement, for as long as your account is active, and in accordance with AssetPass retention policies.

Security of Data

The content (videos and images) you entrust with AssetPass is secured to some of the highest technical capabilities possible, it is encrypted on the mobile device before being transmitted over a secure connection to the AssetPass storage facilities where it is also stored using very strong encryption.

This provides you the assurance that your personal moments will never fall into the wrong hands.

Service Providers

We may employ third party companies and individuals to facilitate our Service, provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are contractually obligated not to disclose or use it for any other purpose.

Children’s Privacy

We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By email: info@AssetPass.com
• By visiting this page on our website: https://www.AssetPass.com