Last updated: April, 2026
Privacy Policy
This Privacy Policy ("Policy") describes the practices regarding the collection, use, and disclosure of personal information in connection with the mobile app PASS Money Transfer (also "App", "we", "us", or "our"). By using the App, you agree to the terms of this Policy. If you disagree, do not use the App.
We may update or change this Policy from time to time (for example, to comply with new laws). We will notify you of material changes (e.g. via in-app notice or email) and update the "Last updated" date above.
§ Controller & Data Protection Officer
- The controller (i.e. the party determining purposes and means of processing) is PASS Money Transfer.
- Data Protection Officer (DPO). Contact info: [email protected].
- For GDPR / EU users: This Policy is intended to comply with the EU General Data Protection Regulation (GDPR), as well as other applicable national laws (e.g. BDSG in Germany).
§ Personal Data, Processing Purposes & Legal Bases
We collect and process personal data only where permitted by law. Applicable legal bases include:
- Consent (Art. 6 (1)(a) GDPR) — e.g. for optional features or personalization
- Contract / pre-contract obligations (Art. 6 (1)(b) GDPR) — e.g. for delivering the app functionality you expect
- Legitimate interests (Art. 6 (1)(f) GDPR) — e.g. analytics, fraud prevention, improvement, and measuring the performance of our user acquisition campaigns
- Compliance with law (Art. 6 (1)(c) GDPR) — e.g. responding to legal requests
We collect and use data for the following purposes (where applicable):
- Core app functionality – to provide you with the features of PASS Money Transfer, including displaying FX rates, account management, and push notifications.
- Analytics / performance / diagnostics – to monitor, analyze, debug, and improve the App.
- Personalization – e.g. customizing user experience, content, and notifications.