Privacy Policy for Passion Funnel

1. Introduction

This Privacy Policy explains how Independence284 Inc., 2035 Sunset Lake Road, Suite B-2 Newark, DE 19702 United States ("we," "us," or "our") collects, uses, and shares information about you when you use our Passion Funnel service ("Service"). We respect your privacy and are committed to protecting your personal data.

The data protection officer at the data controller is:

• Port Zero GmbH
• Artur Andretta
• Paul-Lincke-Ufer 7e
• 10999 Berlin
• Contact: privacy@passion.io

2. Service Users and End Users

2.1. This policy applies to:

• Service Users: Individuals or organizations who create and manage quizzes and landing pages
• End Users: Individuals who interact with quizzes and landing pages created by Service Users

2.2. Service Users are responsible for:

• Ensuring their own compliance with privacy laws
• Providing appropriate privacy notices to their End Users
• Obtaining necessary consents from End Users
• Preventing collection of prohibited data types

3. Information We Collect

3.1. From Service Users:

• Name
• Email address
• Phone number
• Content you create or upload
• Payment information (for paid services)

3.2. Information collected automatically:

• IP address
• Browser type and version
• Device information
• Usage data
• Cookies and tracking data

3.3. Prohibited Data Collection: The Service may not be used to collect:

• Information from individuals under 18
• Health or medical information
• Financial information
• Other sensitive personal information

4. Data Processing and Storage

4.1. Data Storage

We use Supabase, a secure cloud database provider, to store your information

All data is stored with appropriate security measures and encryption

Supabase's infrastructure is designed to meet high security and compliance standards

4.2. AI Processing

We use OpenAI's services to process certain content and enhance our Service

Content sent to OpenAI is not used for AI model training

We ensure appropriate safeguards are in place for all data processing

4.3. Third-Party Service Providers

We carefully select our service providers based on their security and privacy standards

All service providers are contractually bound to protect your data

We regularly review our providers' security practices

5. Data Sharing and Disclosure

5.1. We may share your information with:

• Passion.io and other subsidiaries
• Service providers (including Supabase and OpenAI)
• Payment processors
• Analytics providers
• Law enforcement when required
• Successor entities in case of business transfer

5.2. We do not sell your personal information to third parties.

6. Data Security

6.1. We implement appropriate technical and organizational measures to protect your data:

• Encryption in transit and at rest
• Regular security assessments
• Access controls and monitoring
• Secure data storage through Supabase
• Protected API communications

6.2. While we use commercially reasonable efforts to protect your data, no method of transmission over the Internet is 100% secure.

7. Your Privacy Rights

7.1. Rights for Service Users and End Users:

• Access personal data
• Correct inaccurate data
• Request deletion of data
• Object to processing
• Data portability
• Withdraw consent

7.2. For EU residents (GDPR):

We process your data based on consent or legitimate interests

You have the right to file a complaint with supervisory authorities

We serve as the data controller for your information

7.3. For California residents (CCPA):

You have specific rights regarding your personal information

We provide required notices and choices

You can request disclosure of specific information collection and sharing practices

8. Age Restrictions

8.1. The Service is not intended for:

• Users under 18 years of age
• Creating content targeted at individuals under 18
• Collecting information from individuals under 18

8.2. Service Users must:

• Implement appropriate age verification measures
• Prevent collection of information from minors
• Comply with all applicable children's privacy laws

9. International Data Transfers

9.1. Your information may be transferred to and processed in countries other than your own.

9.2. We ensure appropriate safeguards are in place for international transfers.

10. Changes to This Policy

10.1. We may update this Privacy Policy periodically.

10.2. We will notify you of material changes through the Service or via email.

10.3. Continued use after changes constitutes acceptance of the updated Policy.

11. Contact Information

For questions about this Privacy Policy or our privacy practices, contact us at:

Independence284 Inc. 2035 Sunset Lake Road, Suite B-2 Newark, DE 19702 United States

12. Additional Information

12.1. Data Retention:

We retain data as long as necessary for the purposes outlined in this Policy

You can request deletion of your data at any time

Some information may be retained for legal or legitimate business purposes

12.2. Third-Party Links:

Our Service may contain links to other websites

We are not responsible for third-party privacy practices

We encourage you to read third-party privacy policies

13. Service User Obligations

13.1. Privacy Compliance:

• Maintain appropriate privacy policies for end users
• Obtain necessary consents from end users
• Implement appropriate data retention practices
• Comply with applicable privacy laws in their jurisdiction

13.2. Cookie and Tracking Compliance:

• Disclose use of cookies to end users
• Implement appropriate consent mechanisms
• Maintain clear cookie policies
• Respect end user tracking preferences

13.3. Third-Party Integrations:

• Review privacy practices of integrated third-party services
• Ensure compliant data sharing practices
• Maintain appropriate data processing agreements
• Monitor third-party compliance

14. Contact Information

For questions about this Privacy Policy or our privacy practices, contact us at:

Independence284 Inc.
2035 Sunset Lake Road, Suite B-2 Newark
DE 19702 United States

privacy@passion.io