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Privacy Policy – Processing of Personal Data

Last updated: May 6, 2026

Data Controller Passy S.r.l. 

Via Livornese 1027 - 56122 - Pisa (PI), Italy 

VAT No: 02334100506 - Tax Code: 02334100506 - REA: 199305 

Certified Email (PEC): passy@pec.it - Website: www.passy.it  


Types of Data Collected 

Passy S.r.l. collects the following categories of personal data:

  • Contact data: first name, last name, email address, phone number, postal address.
  • Browsing data: IP address, browser type, operating system, pages visited, cookie-related data.
  • Data voluntarily provided: information submitted via contact forms, registration, or direct communications.
  • Transaction-related data: data necessary for the execution of contracts and provision of services/products. 


Purpose of Processing 

Personal data are processed for the following purposes:

  • Provision of requested services and products
  • Management of information requests and customer support
  • Sending of commercial and promotional communications (subject to consent)
  • Compliance with legal and tax obligations
  • Improvement of website browsing experience
  • Statistical and market analysis


Legal Basis for Processing 

Data processing is based on:

  • Consent of the data subject
  • Performance of a contract
  • Compliance with legal obligations
  • Legitimate interest of the Data Controller


Processing Methods 

Data processing is carried out using electronic and/or paper-based means, adopting appropriate security measures to ensure confidentiality and integrity of the data. 


Data Sharing 

Personal data may be shared with:

  • Third-party service providers (e.g. hosting, IT services, consultants)
  • Competent authorities when required by law
  • Authorized personnel and collaborators involved in processing activities 


Data Transfers Outside the EU

In the event of transfers of personal data outside the European Union, Passy S.r.l. ensures the adoption of appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission. 


Data Retention 

Personal data are retained for the time necessary to achieve the purposes for which they were collected, in compliance with applicable legal requirements. 


Data Subject Rights 

Data subjects have the right to:

  • Access their personal data
  • Request rectification or deletion
  • Restrict processing
  • Object to processing Receive data in a structured format (data portability)
  • Withdraw consent (where applicable)
  • Lodge a complaint with the competent
  • Data Protection Authority


Cookie policy 

The website www.passy.it uses cookies to improve the browsing experience. Detailed information on the cookies used and how to manage them is available in the Cookie Policy on the website.


Changes to this Privacy Policy

Passy S.r.l. reserves the right to modify this Privacy Policy at any time. Updates will be published on the website. 


Contact Information

For any questions or requests regarding this Privacy Policy, please contact Passy S.r.l.:

Address: Via Livornese 1027 - 56122 - Pisa (PI), Italy

Certified Email (PEC): passy@pec.it

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Privacy Policy – Passy Mobile Application


This section supplements the general Privacy Policy and describes the processing of personal data carried out through the Passy mobile application.


Types of Data Collected

The app may collect and process the following categories of data:

  • User identification data (where required by the service)
  • Device technical data
  • App usage data
  • Location data (precise and approximate)


Location Data

The application uses the following permissions:

  • Precise location (ACCESS_FINE_LOCATION)
  • Approximate location (ACCESS_COARSE_LOCATION)
  • Background location (ACCESS_BACKGROUND_LOCATION)
  • Foreground service location access (FOREGROUND_SERVICE_LOCATION)

Location data may be collected:

  • While the app is in use
  • Even when the app is running in the background
  • During the execution of active foreground services


Purpose of Processing

Location data are used exclusively for:

  • Enabling access to physical spaces through proximity technologies (e.g. Bluetooth, NFC)
  • Allowing automatic proximity detection
  • Ensuring the proper functioning of access control and security services
  • Improving the overall user experience of the platform


How Location Data Are Used

Location data may also be collected when the app is not actively in use, in order to:

  • Enable automatic interaction with devices and access points
  • Ensure continuity of the service


Data Sharing

Location data:

  • Are not sold to third parties
  • Are not used for advertising purposes
  • Are processed exclusively for operational and service-related purposes


User Control

Users can at any time:

  • Revoke location permissions through device settings
  • Limit access to location to “while in use only”
  • Disable location services

Please note that disabling location access may affect the proper functioning of certain app features.


Legal Basis for Processing

Processing of personal data is based on:

  • Performance of the service requested by the user
  • Legitimate interest of the Data Controller to ensure system security and functionality


Contact Information

For any questions or requests regarding this Privacy Policy, please contact Passy S.r.l.:

Address: Via Livornese 1027 - 56122 - Pisa (PI), Italy

Certified Email (PEC): passy@pec.it