This Privacy Notice for Passave LLC ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at http://www.passave.org or any website of ours that links to this Privacy Notice.
• Download and use our mobile application (Passave: Password Manager), or any other application of ours that links to this Privacy Notice.
• Use Passave. Passave is a secure digital vault application designed for zero-knowledge data management, enabling users to store and protect sensitive information with enterprise-grade encryption across mobile, web, and extension platforms.
• Engage with us in other related ways, including any marketing or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@passave.org.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• usernames
• passwords
• contact or authentication data

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by RevenueCat and Stripe. You may find their privacy notice link(s) here: https://www.revenuecat.com/privacy and https://stripe.com/en-it/privacy.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Data: We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, IP address (or proxy server), and information about the features of our application(s) you accessed.
• Push Notifications: We may request to send you push notifications regarding your account or certain features of the application(s). You may opt out in your device's settings.

Google API

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes only with your prior explicit consent.

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law.

If you are located in the EU or UK: We may rely on the following legal bases to process your personal information: Consent, Legal Obligations, and Vital Interests.

If you are located in Canada: We may process your information if you have given us specific permission (express consent) or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations and/or with specific third parties.

We may need to share your personal information in the following situations:

• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition.
• Offer Wall: Our application(s) may display a third-party hosted "offer wall."

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you provided by your social media provider.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state or country of residence, you have rights that allow you greater access to and control over your personal information.

You may review, change, or terminate your account at any time. If you have questions or comments about your privacy rights, you may email us at info@passave.org.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

We do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online, as no uniform technology standard has been finalized.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of applicable US states, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information.

Categories of Personal Information We Collect:

• Identifiers: YES
• Personal information categories listed in the California Customer Records statute: YES
• Geolocation data: YES (We have not collected other categories like biometric data or commercial transaction data in the past 12 months).

We will use and retain the collected personal information as needed to provide the Services for as long as the user has an account with us.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at info@passave.org or contact us by post at:

Passave LLC
Via Teodosio 20
Milan, Milano 20131
Italy

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please visit: https://passave.org/danger-zone.