Privacy Policy

This privacy policy is applicable to the My Passport app for mobile devices, together with any related services operated by Riccardo Potroca (collectively, the "Application"). Riccardo Potroca is hereinafter referred to as the "Service Provider".

The short version

The Service Provider does not run a server, and no copy of your account exists anywhere but on your own device. Your trips, photographs, clips, stamps and notes are written to storage on your phone and are never uploaded to the Service Provider or to anyone else. The Application reaches the outside world in four places: signing in with Apple or Google; buying, restoring and checking your subscription; the screen that offers you the subscription; and, when something goes wrong, a crash report that helps the Service Provider fix it. Everything below explains those four, and what the Application keeps on your device.

Data Controller Information

Riccardo Potroca acts as the Data Controller responsible for the processing of your personal data.

• Name: Riccardo Potroca
• Address: Via San Donato 43, 10144 Torino (TO), Italy
• Email: support.mypassport@gmail.com

For data protection inquiries and to exercise your GDPR rights, please contact the Data Controller using the contact information above.

What information does the Application obtain and how is it used?

The Application and related services acquire the information you supply when you download, access, or use the service. Using the Application requires you to sign in with Apple or with Google and to hold an active subscription; it cannot be opened without both. What the sign-in returns is described under "Signing in" below.

The Service Provider does not send marketing communications and keeps no mailing list. If that ever changes, it will ask for your consent first, and you will be able to withdraw that consent at any time.

Legal basis for processing your personal data

Where the GDPR applies, the Service Provider relies on one or more lawful bases to process your personal data, including:

• Contract performance: processing necessary to provide the Application or fulfil a contract with you.
• Consent: where you have given explicit consent, such as allowing notifications or allowing access to your photo library. You may withdraw consent at any time without affecting processing that occurred before withdrawal.
• Legitimate interests: where processing is necessary for the Service Provider's specific legitimate interests, such as keeping subscriptions working, improving how the subscription is offered, finding and fixing crashes, and preventing fraud and abuse, provided those interests are not overridden by your data protection rights or fundamental freedoms.
• Legal obligation: to comply with laws or government requests.

Cookies and similar technologies

The Application does not use cookies, pixels, advertising identifiers, or any tracking technology, and it does not track you across other apps or websites. Its Apple privacy manifest declares no tracking and no collected data types. The subscription service described under "Do third parties see and/or have access to information obtained by the Application?" stores an identifier so that a purchase can be restored. Where required by law, the Service Provider will obtain your consent before using any non-essential technology of this kind.

What information does the Application collect automatically?

Only what keeps the Application working. The Application contains no advertising and no general analytics, and apart from the subscription screen it does not keep a record of how you use it. Three things are sent automatically: a check of your subscription with RevenueCat when the Application opens, and what happens on the subscription screen, both described under Subscriptions and payments; and a crash report when something goes wrong, described in the next section. Choices you make — your language, your units, whether clips may copy over mobile data, how many days before your trial ends you would like to be reminded — are saved on your device so that the Application remembers them, and are not sent anywhere.

Crash reports

When the Application crashes or runs into an error, it sends a crash report to Sentry, a crash-reporting service run by Functional Software, Inc. Reports are stored in Sentry's European data region, in Germany, and they exist only so the Service Provider can see what went wrong and fix it.

• What a report contains: the error and the part of the Application's code that was running, a short trail of what the Application did just before (for example which screen was open), the Application's version, your device model, your iOS version, your language, and similar technical details.
• Sessions: the Application also tells Sentry when it was opened and whether that session ended normally or in a crash, with the same technical details and nothing more, so the Service Provider can see how often it crashes overall.
• What a report never contains: your name, your email address, your account, your location, or anything you have put into a trip — no photographs, clips, stamps or notes. The Application is set up so that Sentry does not store your IP address. A report carries only a random identifier for the installation, which is not linked to your account.
• Legal basis and your choice: crash reports rest on the Service Provider's legitimate interest in keeping the Application working. You can object at any time by writing to support.mypassport@gmail.com.
• How long they are kept: Sentry deletes crash reports automatically, no later than 90 days after they are received.

Does the Application collect precise real time location information of the device?

No. The Application does not request access to your device's location and does not track where you are, at any time, in the foreground or the background.

Trips are placed on a map using the location tag your own camera wrote into a photograph when you took it. That tag is read on your device, is used only to work out which city a photograph belongs to, and is never sent anywhere. If a photograph has no location tag, nothing is looked up to find one.

What happens to the photos and videos I add to a trip?

They stay on your device. Nothing you add to a trip is uploaded to the Service Provider or to anyone else.

• Photographs you pick are copied into the Application's own storage on your device, so a trip keeps them even if you later remove them from your photo library.
• Clips are played from your photo library. The Application may also save its own copy in the background so that a trip still works when you have no signal. By default this uses whatever connection your device has, including mobile data; turning on Wi-Fi only in Settings restricts it to Wi-Fi. Either way the copy is written to your device and is not uploaded anywhere.
• Deleting a trip, or deleting your account, removes the Application's copies from your device. Your own photo library is never modified.

The Application asks for access to your photo library so you can choose what goes into a trip, and for the camera and microphone so you can take a photograph or film a clip from inside the Application. Nothing recorded this way is transmitted anywhere.

Signing in

The Application requires you to sign in with Apple or with Google. That sign-in happens between your device and Apple or Google; the Service Provider has no server in the middle and receives nothing.

• What comes back is an account identifier and, where you allow it, your name and your email address. Those three things are written to storage on your device and are shown to you on the Settings screen. They are not transmitted to the Service Provider.
• If you use Sign in with Apple you may choose to hide your email address, in which case Apple gives the Application a relay address instead of your own.
• Signing out, or deleting your account from the Settings screen, erases them from your device.
• Apple and Google process your sign-in under their own privacy policies: Apple and Google.

Subscriptions and payments

My Passport is sold as an auto-renewing subscription through the App Store. The Service Provider never sees or handles your payment details.

• Your purchase is made with your Apple ID, and Apple processes the payment.
• The Application uses RevenueCat, Inc. to check and restore subscriptions. When the Application opens, and when you buy or restore, it sends RevenueCat an identifier for you, together with your purchase records from Apple, the country of your App Store account, and technical details such as your iOS version and the Application's version. Like any online service, RevenueCat also sees your IP address when the Application connects to it. RevenueCat checks the purchase with Apple and answers whether your subscription is active, which plan you have, and when it renews. Before you sign in, that identifier is a random one created for this installation. Once you sign in, it is derived from the identifier Apple or Google gives the Application for you — never your name and never your email address — so that your subscription follows your account rather than the copy of the Application it was bought on, and is still yours on a new phone or after reinstalling. RevenueCat acts as a processor for the Service Provider under a Data Processing Agreement.
• The Application keeps that answer on your device so it knows what you have access to.
• The screen that offers you the subscription is shown through Superwall, Inc. Superwall records how that screen is used — which version of it you saw, whether you closed it or subscribed — so the Service Provider can see which version works best and try different ones. It receives a random identifier created for this installation, your device model, your iOS version, your language and region, and the Application's version, and like any online service it sees your IP address when the Application connects to it. It does not receive your name, your email address, or anything you have put into a trip. Superwall acts as a processor for the Service Provider under a Data Processing Agreement.
• The Service Provider does not receive your card number, your billing address, or your Apple ID.

Reminders

If you allow notifications, the Application books a single reminder on your device shortly before a free trial ends. It is scheduled and delivered by iOS itself: there is no push server, no device token is created, and nothing about it leaves your phone. You can refuse the permission, or withdraw it later in the iOS Settings app, and the Application continues to work.

Does the Application use Artificial Intelligence (AI) technologies?

The Application does not use Artificial Intelligence (AI) technologies to process your data or provide features.

Do third parties see and/or have access to information obtained by the Application?

The Application transmits no analytics, no usage data and no content to anyone. The only third parties involved are the ones described above: Apple and Google for signing in, Apple for taking payment, RevenueCat for checking and restoring your subscription, Superwall for the screen that offers the subscription, and Sentry for crash reports. None of them receives your trips, your photographs or your clips, because those never leave your device. Beyond this, the Service Provider may share information only in the ways described below.

International Data Transfers

The Service Provider or its third-party service providers may transfer personal data outside the European Economic Area (EEA). Where such transfers occur, the Service Provider will use an appropriate transfer mechanism required by GDPR Chapter V.

• Adequacy decisions by the European Commission
• Standard Contractual Clauses (SCCs) approved by the European Commission
• Other safeguards or derogations recognized under GDPR Chapter V, including consent where legally permitted

Countries outside the EEA may not provide the same level of data protection as the EEA. Where required by law, the Service Provider will apply appropriate safeguards and obtain any consent required for the transfer.

Please note that the Application utilizes third-party services that have their own Privacy Policy about handling data. Below are the links to the Privacy Policy of the third-party service providers used by the Application:

• Apple — Sign in with Apple, and App Store payments
• Google — Sign in with Google
• RevenueCat — subscription status and restoring purchases
• Superwall — the subscription screen and testing its versions
• Sentry — crash reports

The Service Provider may disclose User Provided and Automatically Collected Information:

• as required by law, such as to comply with a subpoena, or similar legal process;
• when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• with their trusted services providers who work on their behalf, do not have an independent use of the information the Service Provider discloses to them, and have agreed to adhere to the rules set forth in this privacy statement.

Where the GDPR applies, the Service Provider enters into Data Processing Agreements (DPAs) with third-party service providers that process personal data on its behalf, as required by Article 28 of the GDPR. These DPAs impose the same data protection obligations on those service providers as described in this Privacy Policy.

What are my opt-out rights?

You can delete your account, and with it every trip, photograph and clip the Application has stored, from the Settings screen inside the Application. Uninstalling the Application also removes everything it kept on your device. Neither affects your own photo library, which the Application never modifies, and neither affects records Apple holds about your subscription, which are governed by Apple’s own policy.

To request deletion of your personal data, withdraw consent, or exercise any of your rights, contact the Service Provider at support.mypassport@gmail.com.

What is the data retention policy and how can you manage your information?

The Service Provider retains personal data based on its necessity for the stated purposes:

• Everything you create in the Application — trips, photographs, clips, stamps, notes — is held on your device only, for as long as you keep it there. Deleting a trip, deleting your account, or uninstalling the Application removes it. The Service Provider holds no copy and therefore cannot restore one.
• Your account details from signing in are held on your device until you sign out or delete your account.
• Subscription records held by Apple and by RevenueCat are retained under their own policies, for as long as needed to keep your purchase restorable and to meet tax and accounting obligations.
• Crash reports are deleted by Sentry automatically, no later than 90 days after they are received.
• Records of how the subscription screen was used are held by Superwall under its own policy, for as long as needed to measure which version works best.
• Correspondence you send to the support address is kept for as long as needed to deal with it, and no longer than 24 months.

You can delete everything yourself, at any time, from the Settings screen inside the Application. If you would like the Service Provider to delete correspondence or anything else it holds about you, contact support.mypassport@gmail.com and it will respond within the time required by applicable law.

Data Deletion

Open Settings inside the Application and choose Delete account. This erases your account details, every trip, and every photograph and clip the Application copied, from your device immediately. Your own photo library is not touched. Because the Service Provider holds no copy, nothing needs to be requested and nothing can be recovered afterwards.

If you would rather write, or you want anything else the Service Provider holds about you deleted, contact support.mypassport@gmail.com. The Service Provider will process your request within the timeframes required by applicable law.

To cancel the subscription itself, use Manage Subscriptions in your App Store account settings — deleting your account inside the Application does not cancel billing, because only Apple can do that.

How does the Application address children's privacy?

The Application is not intended for children under 13 years of age, or where a higher age of digital consent is established under applicable law. The Service Provider does not knowingly solicit data from children or market the Application to them.

Where parental or guardian consent is required under applicable law, the Application is not intended for use without that consent. The Service Provider does not knowingly collect personally identifiable information from children under 13 years of age, or where a higher age of digital consent is established by applicable law, in violation of applicable law. In the event the Service Provider discovers that a child has provided personal information, the Service Provider will immediately delete it. If you are a parent or guardian and you are aware that your child has provided the Service Provider with personal information, please contact the Service Provider (support.mypassport@gmail.com) so that they will be able to take the necessary actions.

How is your information kept secure?

Because what you create stays on your device, its security rests mainly on your device: the Application stores it inside its own container, which iOS protects with the device passcode and encryption, and it is included in your encrypted device backups if you make them. The Service Provider keeps its App Store account protected with two-factor authentication, and requires any processor it uses to apply appropriate technical and organisational measures. No security system can prevent every possible breach.

Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, the Service Provider will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by applicable law. Where the breach is likely to result in a high risk to your rights and freedoms, the Service Provider will also notify you without undue delay, providing information about the nature of the breach, the categories of data affected, and the measures taken or proposed to address the breach.

How will you be informed of changes to this Privacy Policy?

The Service Provider may update this Privacy Policy from time to time. The Service Provider will notify you of material changes by posting the updated Privacy Policy with an effective date. Where required by law, the Service Provider will seek your consent to material changes before they take effect.

Previous versions of this Privacy Policy will be maintained and made available upon request by contacting the Service Provider at support.mypassport@gmail.com.

This privacy policy is effective as of 2026-09-15

What are your GDPR data protection rights?

Under the GDPR, you have the following rights:

• Right of Access: You can request access to your personal data.
• Right to Rectification: You can request correction of inaccurate data.
• Right to Erasure: You can request deletion of your personal data (the "right to be forgotten").
• Right to Restrict Processing: You can request that the Data Controller limits how they use your data.
• Right to Data Portability: You can request a copy of your data in a structured, commonly used, machine-readable format.
• Right to Object: You can object to processing based on legitimate interests. You have an absolute right to object to processing for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you can withdraw it at any time. You can withdraw it by turning the relevant option off in the Application's Settings screen, by revoking a permission in the iOS Settings app, or by contacting the Data Controller.
• Rights Regarding Automated Decision-Making: You have rights related to automated decisions that affect you.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local Data Protection Authority. Contact details for each country's Data Protection Authority can be found at: https://edpb.ec.europa.eu/about-edpb/members_en

If you are located in the United Kingdom, you may contact the Information Commissioner's Office at https://ico.org.uk

What are your California privacy rights (CCPA/CPRA)?

If you are a resident of California, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with additional rights regarding your personal information:

• Right to Know: You can request disclosure of the categories and specific pieces of personal information the Service Provider has collected about you.
• Right to Delete: You can request deletion of personal information the Service Provider has collected from you, subject to certain exceptions.
• Right to Correct: You can request correction of inaccurate personal information.
• Right to Opt-Out: You can opt out of the sale or sharing of your personal information for cross-context behavioral advertising. The Service Provider does not sell or share your personal information, and has never done so.
• Right to Limit Use of Sensitive Personal Information: You can limit the use of your sensitive personal information to essential purposes.
• Right to Non-Discrimination: The Service Provider will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise any of these rights, please contact the Service Provider at support.mypassport@gmail.com. The Service Provider will verify your request using the information you provide and respond within the timeframes required by law. You may designate an authorized agent to make a request on your behalf.

How do you give your consent?

Where processing is based on consent, you provide that consent by affirmatively opting in to the relevant feature or action. You may withdraw consent at any time without affecting processing carried out before withdrawal. Processing based on other lawful bases, including contract performance, legitimate interests, or legal obligations, is carried out as described above.

How can you contact the Data Controller?

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at support.mypassport@gmail.com.

To request deletion of your personal data or to exercise any of your rights, contact the Service Provider using the details provided above. The Service Provider will respond within one month of receiving your request, extendable by up to two months where necessary due to the complexity or volume of requests, as permitted by applicable law.

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