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Privacy Notice

Last updated: September 2026

Introduction

This Privacy Notice explains how NetNodes Limited (“NetNodes”, “we”, “our”, “us”), trading as PassFlow, collects, uses, and protects personal information when you use our websites, applications, and digital pass services (collectively, the “Services”).

This notice applies globally to users in the UK, EU/EEA, the United States, and other regions.

PassFlow may be used by organisations to distribute and manage digital passes (e.g., access passes, membership passes, event passes). When organisations store or manage end-user data, NetNodes acts as a Data Processor.

1. Who We Are

NetNodes Limited is the Data Controller for data collected directly (e.g., website usage, registration).

PassFlow customers are Data Controllers for information they upload or manage within PassFlow.

Our Data Processing Agreement governs our role as Processor, and our sub-processors are published on the corporate site.

2. Information We Collect

A. Information You Provide

Account information

Payment information

Communications

Data entered by PassFlow customers

This may include:

This is controlled by the customer.

B. Information We Collect Automatically

C. Measurement of our websites

We measure how our public websites are used, so that we can see what is working and improve them.

We treat this at the level of the organisation, not the individual. In particular, we may use the IP address a request came from, on its own or matched against a list of address ranges we associate with customers and prospective customers, to record that an organisation visited - never to identify a person. Any such match is treated as an indication rather than a fact, because shared offices, mobile networks and VPNs all place many people behind one address.

Where we use analytics cookies for this, they are set only after you have consented, and are described in our Use of Cookies notice.

We rely on legitimate interests for this measurement. You can object at any time using the contact details in section 13, and you can decline analytics cookies without affecting your use of the Services.

D. Information from Third Parties

3. How We Use Information

To:

Marketing communications are optional and require consent where required by law.

4. How We Share Information

We may share personal data with:

We do not, and never will sell personal data.

May include:

PassFlow customers determine the lawful basis for their use of user data.

6. Your Rights (UK/EU/EEA)

You may have rights to access, correct, delete, object, restrict, or port your data.

Requests relating to data stored by a PassFlow customer must be made to the Data Controller (the customer).

Requests about data collected directly by NetNodes can be made to: privacy@netnodes.net

You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection, at ico.org.uk/make-a-complaint. We would ask you to raise it with us first, so that we have the chance to put it right.

Automated decision-making. We do not make decisions about you by automated means that produce legal effects or similarly significant effects, and we do not carry out profiling of that kind.

7. Rights for California / US Users

We comply with relevant state-level privacy laws (e.g., CCPA/CPRA).

You may have rights to access, delete, request information about categories of data, and opt out of sale/sharing.

We do not and never will sell your data.

8. International Transfers

Transfers outside the UK/EEA are protected by:

9. Security

Security measures include:

10. Data Retention

We retain personal data only as long as necessary.

PassFlow customers may set their own data retention periods for passholder data.

11. Children’s Privacy

PassFlow is not intended for children under 16 (or under local minimum age thresholds).

We do not knowingly collect such information.

12. Changes to This Notice

We may update this Privacy Notice periodically. Material changes will be communicated appropriately.

13. Contact Us

If you have questions about this notice or your personal data, please contact us at privacy@netnodes.net

Cookies

You can find out about cookies and how we use them here.

Specifically, we monitor how people use our site to find out how well it's doing, and to look for ways to improve it. We would like your permission to do that, but we understand if you'd prefer not.