Privacy Policy

Last updated: 13 March 2026

This Privacy Policy explains how passenmsg ("we", "us", "our") collects, uses, and protects personal data when you visit passenmsg.com or engage our services. We operate in compliance with the General Data Protection Regulation (GDPR – EU 2016/679) and the German Federal Data Protection Act (BDSG).

1. Controller

The data controller responsible for your personal data is:

2. Data We Collect

2.1 Data you provide directly

When you use our contact form or communicate with us by email, we collect:

• Name and email address
• Content of your message
• Any other information you voluntarily provide

2.2 Data collected automatically

When you visit our website, our servers automatically record:

• IP address (anonymised after 24 hours)
• Browser type and version
• Operating system
• Referrer URL
• Pages visited and timestamps

3. Legal Basis for Processing

We process your personal data on the following legal bases under Article 6 GDPR:

• Art. 6(1)(a) – Consent: where you have given explicit consent (e.g., cookie acceptance).
• Art. 6(1)(b) – Contract: where processing is necessary to fulfil a contract or take pre-contractual steps at your request.
• Art. 6(1)(c) – Legal obligation: where we are required by law.
• Art. 6(1)(f) – Legitimate interests: for fraud prevention, security, and improving our services.

4. Purpose of Processing

We use the data we collect to:

• Respond to enquiries submitted via our contact form
• Provide and manage the services you request
• Send transactional communications related to your project
• Comply with legal and regulatory obligations
• Analyse and improve website performance (using anonymised data only)

We do not use your personal data for unsolicited direct marketing without your prior consent.

5. Data Retention

We retain personal data only for as long as necessary for the purposes outlined above or as required by applicable law. Contact form submissions are retained for up to 3 years to support our legitimate business interest in managing client relationships. Server access logs are anonymised within 24 hours and deleted after 30 days.

6. Sharing of Data

We do not sell your personal data. We may share data with:

• Hosting and infrastructure providers (data processors under GDPR-compliant DPAs)
• Email service providers used for client communications
• Legal and accounting advisors where required by law
• Law enforcement or regulatory bodies if legally obliged to do so

All third-party processors are bound by data processing agreements ensuring GDPR compliance. Where data is transferred outside the EEA, we ensure appropriate safeguards are in place (e.g., Standard Contractual Clauses).

7. Your Rights

Under GDPR, you have the following rights regarding your personal data:

• Right of access (Art. 15) – Request a copy of the data we hold about you.
• Right to rectification (Art. 16) – Request correction of inaccurate data.
• Right to erasure (Art. 17) – Request deletion of your data ("right to be forgotten").
• Right to restriction (Art. 18) – Request that we restrict processing of your data.
• Right to data portability (Art. 20) – Receive your data in a structured, machine-readable format.
• Right to object (Art. 21) – Object to processing based on legitimate interests.
• Right to withdraw consent (Art. 7(3)) – Withdraw consent at any time without affecting prior processing.

To exercise any of these rights, contact us at info@passenmsg.com. You also have the right to lodge a complaint with your national data protection authority. In Germany, this is the Landesbeauftragte für Datenschutz und Informationsfreiheit (LDI) Nordrhein-Westfalen.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. Our website is served exclusively over HTTPS. Access to personal data is restricted to authorised personnel on a need-to-know basis.

9. Cookies

Our website uses cookies and similar technologies. For detailed information about the cookies we use and how to manage your preferences, please see our Cookie Policy.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page indicates when the policy was last revised. We encourage you to review this page periodically. Continued use of our website after changes are posted constitutes acceptance of the revised policy.

11. Contact

For any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact us at:
info@passenmsg.com