Privacy policy

Last updated: 15 October 2026

This policy explains what data PassFunk (passfunk.com), the service that lets shops create digital cards for Apple Wallet and Google Wallet, processes and how.

Data controller

Luca Rocchi, Rome (Italy). For any privacy request: support@passfunk.com.

Shop customers (people who add a card to their Wallet)

The card is anonymous: we don't ask for your name, email, phone number or date of birth.

• Technical card data: a random serial number, the card's QR code, and the identifiers Apple or Google assign to the card and device so it can be updated (on iPhone, the push notification token). They are only used to run the card and deliver the shop's offers.
• Use of offers and vouchers: when shop staff scan the card we record which offer or voucher was used and when, so it can't be used twice.
• Anonymous numbers for the shop: cards added and removed, counted per device through a non-reversible code (hash). The shop only sees totals.
• Location: the card contains the shop's addresses and the phone shows a reminder when you are nearby. This happens on the phone: your location is not sent to us or to the shop.

Legal basis: performance of the service you asked for by adding the card (Art. 6(1)(b) GDPR) and the shop's legitimate interest in aggregate numbers (Art. 6(1)(f)). You can stop at any time by removing the card from your Wallet or turning off notifications in its details. When you remove the card, the Wallet tells us and we stop updating it.

Shops (dashboard users)

• Sign-in: the identifier and email of your Google or Apple account, and your name if the provider shares it. We never receive your password.
• Business data: name, logo, images, location addresses, public contacts, offers and, if you enter them, billing details (company name, VAT number, tax code, address, PEC, SDI code).
• Subscription: payment happens on Stripe. We only receive the subscription status (active, cancelled, dates) and the customer and subscription identifiers. We never see or store your card details.

Legal basis: performance of the contract (Art. 6(1)(b)) and tax and accounting obligations (Art. 6(1)(c)).

Cookies

We only use technical cookies: the session that keeps you signed in to the dashboard, your language, and short-lived cookies during sign-in with Google or Apple. No profiling, advertising or third-party analytics cookies.

Providers processing data on our behalf

• Hetzner Online GmbH (Germany): servers and database.
• Cloudflare, Inc.: domain DNS and forwarding of support email.
• Apple Inc. and Google LLC: Apple Wallet, Google Wallet, notifications and Sign in with Apple or Google.
• Stripe: subscription payments. Stripe processes payment data as an independent controller under its own privacy policy.

Some providers are based in the United States: transfers rely on the EU-US Data Privacy Framework or the European Commission's standard contractual clauses.

How long

• Card data: as long as the shop uses PassFunk. When you remove the card from your Wallet we immediately delete the device data (such as the notification token); only the random serial number and the anonymous numbers remain.
• Shop data: for the life of the account. When it is closed we delete it, except billing records we must keep by law (10 years).
• Server logs (IP address, requested page): for a limited time, for security.

Your rights

You can ask for access, correction, deletion, restriction, portability, or object to processing by writing to support@passfunk.com. If you believe the processing breaches the GDPR you can complain to the Italian data protection authority (Garante per la protezione dei dati personali, garanteprivacy.it) or to the authority where you live.

The shop's role

Offers, vouchers and messages shown on the card are decided by the shop, which is responsible for their content. For questions about an offer, contact the shop.