Privacy Policy

  1. Scope of this Policy.

1.1 This is the Privacy Policy (the “Policy”) the web site located at (including its sub-domains and its mobile optimized versions), along with any and products and services owned, offered and/or provided by Yellow Submarine Ltd. (collectively referred to hereinafter as “Passerport”, and also referred as us’, ‘its’, ‘ours’ and/or ‘we’).

1.2 This Policy shall be supplemented by our Terms and Conditions of Use, and any other guidelines, terms and policies made available by us from time to time, all incorporated herein by reference.

1.3 As used herein and elsewhere, the words “collect”, “use”, “process”, “treat”, “disclose” and analogous shall be related to personally identifiable information (the “PI”) and other data that we may collect from our users and/or visitors, including cookies inside a computer and mobile device IDs.

  1. Consent for Collection, Use and Disclosure.

2.1 By the simple use of our products, services or websites, through registration, or through a clickable action such as the “I Agree” button or otherwise, you hereby agree, acknowledge and unambiguously consent to the collection, use, processing, treatment and limited disclosure of your PI in Belize, the Netherlands and other countries and territories, for the purposes set forth in this Policy.

2.2 Accordingly, you hereby agree, acknowledge and unambiguously consent that we may disclose your PI to our affiliates, clients, agents, officers, licensors and/or distributors, in accordance with this Policy.

2.3 Any PI that you provide to us must be true, accurate, current, non-misleading, and relevant for the purposes for which you are providing it.

  1. Information You Disclose to Us.

3.1 We collect PI, content, communications, and other information you provide when you use our products, including when you sign up for an account, create or share content, and message or communicate with others. This can include information about the content you provide, such as the location of a photo or the date a file was created. It can also include what you see through the features we provide, such as the use of a camera.

3.2 Our platform automatically process PI, content and communications you and others provide to analyze context for the purposes described below.  You can choose to provide information in your profile about your religious views, political views, what you do for work, or your health.  This and other information, such as racial/ethnic origin or philosophical beliefs, could be subject to special protections under the laws of your country

3.3 In a general scope, you will provide us your name, surname, age, email address, physical address, personal photography, national identification and phone number, among other PI.  This list is only for reference and not exhaustive, and we may collect further information.

3.4 We collect information about the people, pages, accounts, tags, and groups you are connected to and how you interact with them across our products, such as people you communicate with the most or the groups which you take part.  We may also collect contact PI if you choose to upload, sync, or import from a device which we use for things like helping you and others find people you may know.

3.5 We collect information about how you use our products, such as the types of content you view or engage with, the features you use, the actions you take, the people or accounts you interact with, as well as the time, frequency, and duration of your activities.  For example, we analyze when you’re using and have last used our products, and what posts, videos and other content you view on our products.  We also collect information about how you use features like our camera.

3.6 We also receive and analyze content, communications, and information that other people provide when they use our products. This can include information about you, such as when others share or comment on a photo of you, send a message to you, or upload, sync, or import your information.

  1. Purposes of Information Collected.

4.1 We use your PI to execute, manage, provide and improve our services and products.  Accordingly, we will generally collect, use and disclose your PI to:

  1. Provide, operate, maintain, improve, and promote our platform and our products and services.
  2. Verify your e-mail address; send password retrieval links and other account notices.
  3. Improve your user experience and provide you with personalized support
  4. Develop, research, process, safeguard and improve our services.
  5. Answer to comments, questions, and requests you submit to us.
  6. Offer promotions, newsletters, send service related announcements and contact you about inquiries for our products and services.
  7. Investigate and prevent fraudulent transactions, unauthorized access to our services, and other suspicious activities.
  8. Monitor and analyze trends, usage, and activities in connection with our products and services and for marketing or advertising purposes.

4.2 If you do not wish to disclose any or part of your PI to us, you may still be able to use some of our products and services, though we will not be able to guarantee that you will be able to enjoy them at their fullest if you elect not to disclose it to us.  Overall, your final remedies will be to close this web tab, delete your account with us and/or exit our app.

  1. Other Collected Information.

5.1 We may also collect information from advertisement, developers, and publishers who send us things such as social plug-ins for Login.  These partners provide information about your activities on Passerport, including information about your device, websites you visit, the ads you see, and how you use the services, whether or not you have used a social media account to log into Passerport. For example, a developer could use API to tell us what’s wrong with sign in functionality.

5.2 We may receive information about your online and offline actions and purchases from a third-party data provider who have the rights to provide information about your usage on our site.

5.3 Google receives your data when you visit or use their services or through third parties they work with. They are required to have lawful rights to collect, use, and share your data before providing any data to us.

5.4 We use payment partners in order to bill and process any payments and subscriptions made via our platform and our services.

5.5 These platforms will request you to disclose them sensitive information in order to complete purchases and operations related to our services, and such third-party payment processing platforms are governed by their own safety standards, policies and terms of use.

5.6 We take great care in selecting our third party payment processing platforms, and strive to be aware of their operations and functionalities; thus we strongly advise our users to engage in online safety measures and practices in order to protect their financial information.

  1. Information Collected from Mobile Devices.

6.1 When you access our platform via a mobile device, we may use your mobile device ID (i.e. the unique identifier assigned to a mobile device by the manufacturer) and/or Advertising ID (for Apple iOS 6 and later) instead of cookies in order to recognize you, track the number of relevant ads displayed, their performance and display.

  1. Other Information Collected.
  • 1 We may also collect anonymized, non-personally identifiable information and share it with third-parties such as our affiliates, clients, agents, officers, licensors and/or distributors, including but not limited to aggregate user statistics, analytics, demographic information, and web site usage information.
  • 2 We will not share identifiable PI with third-parties for marketing purposes without your permission. With your consent, these third-parties may offer promotions (including email promotions) or sell items or services to you through our services.
  1. Storage of Information.

8.1 As our user, you will generally be able to control and select the amount and type of PI you may disclose to us.  We continuously try to improve our user experience, and strive to provide you the best choices for the disclosure, edition or removal of the PI being processed by us.

8.2 We will retain you PI only as long as necessary for the fulfillment of the purposes herein set forth.

8.3 Accordingly, we will undertake the open and transparent management of your PI and will: (i) inform you about how your personal information may be used and disclosed (including overseas); (ii) maintain the safety and integrity of your personal information; (iii) develop guidelines and procedures regarding retention, including minimum and maximum retention periods; (v) destroy or erase any PI when no longer required in order to fulfill the purposes set forth herein and/or (v) enforce your individual right to access and correct your PI.

8.4 We will retain your PI only for as long as it is reasonably necessary for our business purposes (e.g. as long as your account is active); and we will also retain and use your PI for our compliance obligations, to resolve disputes among our users, and enforce our contracts with authorized third-parties.

  1. Safety of Collected Information.

9.1 We use industry standard protocols and technology to protect your registered user information and PI, such as Secure Socket Layer (SSL) technology and secure databases, and your PI is only accessible by a limited number of our employees who have special access rights.

9.2 Overall, we implement and maintain reasonable security measures to protect our databases and records from unauthorized access, acquisition, destruction, use, modification or disclosure.

9.3 Notwithstanding the foregoing, please take into account that the Internet and related transmissions are not secure or error free communication means.

  1. Access to Personally Identifiable Information.

10.1 In order to enforce your privacy rights, please contact us as indicated in the contact section of our Site. Upon your due request, we inform you of the existence, use, and disclosure of you PI, allow you reasonable access to such PI, and we will enable you to challenge its accuracy and completeness and, if required, have it amended.

10.2 Your privacy request must include, at the least, the following information: (i) your complete name, address and/or e-mail address in order for us to notify you the response to your request; (ii) attached documents establishing your identity; and (iii) a clear and concise description of the PI with regard to which you seek to enforce any of your privacy rights.  If you request rectification, please indicate amendments to be made and attach documentation to back up your request.

10.3 Upon receipt of your privacy request, and after due review, we may then edit, deactivate and/or delete your PI from our products and services.  Please take into account that we may not be able to delete all of your data from our secure databases or the databases of third-parties to which your PI has already been disclosed.  If that is the case, please contact such third-parties directly in order to request enforcement of your privacy rights.  In case of secure databases under our control where deletion is impossible, we will make such information inaccessible.

  1. Lawful Disclosure of Information.

11.1 We must reserve our right to disclose your PI when we or our affiliates, clients, contractors, licensors, officers, agents and/or representatives reasonably believe it necessary to protect our interests, or where you result to be in breach of our Terms and Conditions of Use and/or this Privacy Policy.

11.2 Accordingly, we will have the right to disclose any and all collected PI and/or data, under the following circumstances:

  1. If required under applicable law, rules or regulations.
  2. In response to a valid request or subpoena from a government or law enforcement agency.
  3. To defend ourselves and our affiliates, licensors, officers, agents and representatives from legal claims and processes brought to us by third-parties (including takedown notices).
  4. To defend the property, rights and integrity of any of our users, advertisers or licensors.
  5. To stop or cause to cease any actions that we may consider to cause –whether allegedly or factually– a contingency or liability.
  6. Newsletters and Commercial Messages.

12.1 From time to time, we will ask you for express permission and consent to receive Commercial Electronic Messages (‘CEM’).  A CEM is a message in an electronic format (e.g. email, SMS, push notifications and other form of communications) which is then sent to an electronic address (e.g. email, mobile device) and that contains a message asking recipients to participate in commercial activities (e.g. purchase of products, services and invitations to participate in user research).

12.2 Our optional email newsletters are considered CEMs, and therefore you may subscribe or unsubscribe from them at will, usually on your account settings, or by following the unsubscribe links contained therein.

  1. Service Eligibility & Protection of Minors.

13.1 If you are still a minor (which may depend on the jurisdiction where you reside), you cannot use or access our products and services, even under the direct supervision of your parent or legal guardian.

13.2 Passerport does not knowingly collect any kind of information from persons under the age of thirteen (13), and if we learn or have reason to suspect that any user is under the age of thirteen (13), we will delete any PI under that user’s account.

13.3 The Site is not intended for persons under the age of majority in their jurisdiction.  Accordingly, Passerport does not solicit or collect personal information from or about children on the Site).  It is a violation of our policies and various laws for any person under the age of majority to use, access, or be featured on the Site or any other property of Passerport.

13.4 If you suspect that a minor has used, or is being featured on, any of our Sites, please contact us immediately at


  1. International Use & Disclosure.

14.1 We are headquartered in the United States of America (USA), and thus PI may be accessed by us or transferred to us and/or our affiliate companies in the USA.  Personal information is shared by us with our partners, businesses who use our service and service providers elsewhere in the world.  By providing us with personal information, you consent to this transfer.

14.2 We will protect the privacy and security of personal information according to this Policy, regardless of where it is processed or stored, however you acknowledge and consent to the fact that personal information stored or processed will be subject to the laws of in the USA, including the ability of their governments, courts or law enforcement or regulatory agencies to obtain disclosure of your personal information.

14.3 Upon the case where Passerport specifically undertakes the process of personal that is subject to national legislation that implements the EU Data Protection Directive (95/46/EC), by clicking the “I Accept” button or otherwise accepting the policies, terms and conditions of our services through a clickable action or similar action, you hereby acknowledge, agree and unambiguously consent to such transfer.

14.4 For the purposes of European Directive 95/46/EC and applicable national implementing laws in your jurisdiction, with respect to your data, we are a data controller.

14.5 Under the General Data Protection Regulation (GDPR) principles of PI notice, choice, onward transfer, security, data integrity, access, data erasure and enforcement, we strive to work so that our data security and data processing practices adhere in scope to such principles on data protection, and that you may exercise similar rights to those granted to data subjects under such principles.

  1. Amendments to this Privacy Policy.

15.1 We reserve the right to amend, change, suspend and/or update our platform, our products, our services, this Policy and/or our Terms, in whole or in part, from time to time and at our sole and final discretion.

15.2 Your continued use thereof after the last effective date of modifications thereof indicates your acceptance of such modifications.

15.3 We will post any updates on our platform, and may also send you an email or otherwise notify you of any material changes to this Policy.

  1. Contact Us.

16.1 If you have any questions or queries about us, our products, our services, our Terms and Conditions of Use and/or this Policy, please contact us as indicated in our Site.

Date of last effective update is July 9, 2018.