PASSO Privacy Policy
Version 1. Last updated: 2026-11-11.
Quick summary
- PASSO needs no account. We never ask for your name, e-mail, phone number or contacts.
- Your recorded rides stay on your phone. They are never uploaded.
- To plan a route, search for a place or show a map, PASSO sends the request (for example where you are starting and where you are going, or what you typed in search) to our servers.
- If you import a track from a file and no downloaded region covers it, PASSO sends that imported track to our server so it can be matched to roads.
- PASSO shows no ads and does not read your advertising identifier. It shares an install identifier and subscription events with our measurement provider unless you turn that off in Settings > Ad measurement.
1. Who we are
The controller for the personal data in this policy is Fren Safety Inc., a New Jersey corporation, United States. The person responsible for privacy is Sami Demiroluk. Contact: [email protected].
2. What we process
2.1 Requests to our servers
- Routing and map requests. Your start point (often your GPS position), destination, waypoints and travel mode, and the map tiles for the area around your route.
- Search and reverse geocoding. The text you type, with a location hint (the position of the map or of you), and the position of a point you tap to name it.
- Connection data. Every request to our servers carries your IP address, the PASSO user agent, and the country the app believes you are in.
- Imported tracks. A route file you imported is sent only when no downloaded region pack covers it, and only that imported track: never a ride you recorded. Our gateway does not log the points of the track, and our server does not keep them after matching the track to roads.
2.2 Ad measurement (AppsFlyer)
PASSO shows no ads and does not read your advertising identifier (we switch it off in the SDK and remove the Android advertising-ID permission; PASSO never shows Apple's tracking prompt). To learn which of our own ads bring riders to the app, PASSO shares with AppsFlyer an install identifier, the install source (Google Play install referrer on Android; Apple's privacy-preserving attribution on iOS) and an event when a free trial starts. We share no name, e-mail, location or ride data for this. This is on by default, in every country, and you can turn it off at any time in Settings > Ad measurement; while it is off the AppsFlyer SDK does not start.
2.3 Purchases (RevenueCat, Apple, Google)
Subscriptions are sold by Apple (App Store) or Google (Google Play); they handle your payment and tell us whether you are subscribed. RevenueCat, our purchase-management provider, receives an anonymous app user id, your purchase history and the store receipt, and forwards subscription events to AppsFlyer when ad measurement is on.
2.4 The free trial without a card
If you start the free trial without a card, PASSO stores a marker with the start time in the iOS Keychain or the Android Block Store, so that deleting and reinstalling the app does not give a second trial. On Android the Block Store may be backed up to your Google account by Google.
2.5 On your phone only
Recorded rides, exports, saved routes, settings and downloaded region packs stay on your phone. When you save a video or card, PASSO adds it to your photo library; it never reads your library. PASSO has a developer diagnostic file that is off unless a developer switches it on by hand.
2.6 Permissions
PASSO asks for your location while you use it to guide you, including with the screen off during a ride. On Android it runs a foreground service with a notification, and it does not use Android's background-location permission. On iOS, location can continue in the background during ride guidance. It may ask to show notifications , and on Android 10 and older to save exports to the gallery. The iOS microphone permission is required by the audio library that speaks guidance; PASSO does not record audio.
3. What we do not collect
No account, name, e-mail address, phone number, contacts, advertising identifier, recorded ride upload, photo-library read access, audio, or crash report sent to a server. PASSO uses no crash-reporting service.
4. Why we process it, and the legal basis
| Purpose | Data | Legal basis (GDPR / UK GDPR) |
|---|---|---|
| Give you the route, search and map you ask for | Route, search and imported-track requests | Performance of a contract (Art. 6(1)(b)) |
| Keep the service secure and working | Connection data | Legitimate interests (Art. 6(1)(f)) |
| Measure which ads bring riders | Install identifier, install source, trial-start event | Consent (Art. 6(1)(a)); on by default, and you can withdraw it at any time in Settings > Ad measurement |
| Manage your subscription | Anonymous purchase id, purchase history, receipt | Performance of a contract |
| Prevent repeat free trials | The trial marker | Legitimate interests |
5. How long we keep it
Server logs, which can include the request address, your IP address and the country, are kept for as long as necessary for security and operation, and for no longer than 2 years. Our gateway does not log request bodies. AppsFlyer and RevenueCat keep data under their own terms (see section 7). Data on your phone stays until you delete it or uninstall; the trial marker survives uninstall by design.
6. Who receives data
- RevenueCat (United States): purchases.
- AppsFlyer (United States): ad measurement, only with the switch on.
- Apple and Google, as the stores and as their own controllers.
- Cloudflare, which carries our requests and serves map tiles, and the servers that answer them, which are in Germany and Finland (European Union).
We do not sell your personal data.
7. International transfers
Our providers RevenueCat and AppsFlyer are in the United States and Cloudflare operates globally. For how each of them handles transfers and the safeguards it relies on, see their own published terms: RevenueCat (data processing terms), AppsFlyer (data processing terms) and Cloudflare (data processing terms).
8. Your rights
Depending on where you live you can ask to access, correct, delete, restrict or port your data, and object to processing. PASSO holds no account, so most of what we can find is the anonymous purchase id and the AppsFlyer id: use Settings to turn off ad measurement, and write to [email protected]. You can withdraw consent at any time. You can complain to your data protection authority.
9. Children
PASSO is not directed to children under 13 (16 where the local age of digital consent is 16), and we do not knowingly process their data.
10. Region notes
- EEA / UK / Switzerland. GDPR / UK GDPR as in sections 4 to 8.
- Türkiye. The KVKK notice (aydınlatma metni) is in Turkish at /passo/tr/privacy/.
- United States: your privacy choices. We do not sell your personal information. If you are in a US state whose law gives you a right to opt out of "sharing" personal information, to opt out turn off Settings > Ad measurement in PASSO: this stops the install identifier and subscription events going to AppsFlyer. You can also write to [email protected].
- Japan (APPI and the Telecommunications Business Act). See section 11.
- South Korea (PIPA, Location Information Act). Korean pages: privacy notice, location-based service terms and personal location information policy.
- Australia / New Zealand. We handle personal information under the Australian Privacy Principles and the NZ Privacy Act 2020. Personal information is disclosed overseas to the recipients in section 6, and we remain accountable for it.
11. Japan: APPI and Telecommunications Business Act notice
- Purposes of use. Giving you routes, search and maps; keeping the service secure; managing subscriptions; preventing repeat free trials; measuring which of our ads bring riders (sections 2 and 4).
- Security measures. TLS in transit; no account database; recorded rides stay on the phone.
- External environment (countries where personal data is handled). United States (RevenueCat, AppsFlyer); Germany and Finland (our origin servers); Cloudflare's global edge. For the safeguards each provider relies on, see section 7.
- Provision to third parties abroad. RevenueCat and AppsFlyer, as listed in section 6. We provide data to them for the purposes above; their own published terms describe how they protect it.
- What the app sends to other companies. To AppsFlyer, only while ad measurement is on: an install identifier, the install source and a trial-start event, plus subscription events forwarded by RevenueCat. To RevenueCat: an anonymous app user id, purchase history and the store receipt. Apple and Google receive what the stores collect under their own terms.
- Requests to access, correct, stop using or delete: write to [email protected]. The person responsible is Sami Demiroluk.
12. Changes
We will post changes here and change the version above. Material changes will be shown in the app.
13. Contact
Fren Safety Inc., attention Sami Demiroluk. [email protected].