Privacy Notice

1. Who is the controller#

The controller of Passly account data is [PENDIENTE: Razón social / nombre legal del titular] ([PENDIENTE: Tipo de persona y régimen]), with its address at [PENDIENTE: Domicilio completo (calle, número, colonia, C.P., ciudad, estado, país)] and RFC/tax identifier [PENDIENTE: RFC / Tax ID] (hereinafter, "Passly", "we").

Personal data officer or department: [PENDIENTE: Persona o departamento responsable de datos personales / DPO]. Privacy email: [PENDIENTE: Correo de privacidad (p. ej. privacidad@wepassly.com)]. General email: hola@wepassly.com.

If you are in the European Union or the United Kingdom, also see the EU and UK Notice (representatives and transfers). If you are in the United States, see the US Notice.

2. What this notice covers#

This notice covers the https://www.wepassly.com website, the Passly application (dashboard, editor, video studio, seating planner, event modules), digital invitations published with Passly, galleries and the event app, the door portal for staff, and the communications we send you.

It also covers invitations published on white-label subdomains or domains of our business customers (for example, tumarca.wepassly.com): even if you see the organizer's brand, the technology and technical processing are Passly's.

It does not cover third-party sites we link to (for example, Google Maps or the site of a vendor in the directory), which have their own policies.

3. Data we process about account holders#

Data marked as optional is not required to use Passly. The rest is: without it we cannot create your account, charge you or show you your events.

4. Guest data (what happens when someone RSVPs without an account)#

A guest does not need an account to open an invitation, RSVP, upload photos to the gallery or take part in the event app. Even so, their data is protected by this notice and by the Guest Notice.

4.1 Data the host may enter

First and last names, phone number, email, group or family, number of passes, companions, table and seat, whether they are a minor, whether they are a VIP guest, relationship to the host, notes, notes for staff, menu preferences, dietary restrictions, accessibility needs, lodging and transportation, and custom fields. The host can type them in manually, or import them from a file or from a photo with the help of AI.

4.2 Data the guest provides

• Their response (attending / not attending), how many people are coming and the names of their companions.
• An optional message for the host.
• On the invitation's open link: their name and, if the form asks for it, phone number or email to identify them.
• Optionally, dietary restrictions or accessibility needs. Because these may reveal health data, they are only stored if the person checks the express consent box shown next to the field.
• Requests to change a name or replace a companion.

4.3 Data generated when the invitation is used

The date an invitation was opened and the number of times a personal invitation was opened, the check-in record at the door (time and method, e.g. QR), and an encrypted fingerprint of the IP address to prevent abuse. Invitations do not load third-party analytics or advertising cookies.

4.4 Who can see that data

• The host and the members of their team with access to the event.
• Door staff authorized by the host with a PIN: they see name, table, number of passes, whether the person is a minor or VIP, menu, phone number and email, so they can identify each person at the entrance.
• Other guests only see what the invitation design displays (for example, the guest's name on their own personal invitation) and what each person posts in the gallery or the event app.
• Passly staff: only when necessary to provide you with support, maintain security or comply with a legal obligation, with logged access.

Passly never uses guest data for its own commercial purposes, never sends guests advertising and never sells their data. Passly does not send emails or messages to guests: WhatsApp messages are sent by the host from their own phone.

5. Gallery, games and event app#

In an event gallery, the photos a guest uploads, their name, their comments and their "likes" are visible to the host and to anyone who has the gallery link. Each person can delete their own photos; the host can delete any photo.

Before storing a photo, Passly removes location (GPS) and camera metadata from the displayed versions and from the original file. HEIC photos are converted and their original is not kept.

In games, Q&A activities and DJ requests, the name you enter, your table (if you provide it), your player selfie and your votes are visible to the other participants of the event. Game selfies are deleted 30 days after the event date.

Do not upload photos of other people without their permission or content you do not want other attendees to see.

6. Why we use data and on what legal basis#

In Mexico, primary purposes are necessary for the service; secondary purposes are optional and you can refuse them without affecting the service. For the EU and the UK we also state the legal basis (Art. 6 GDPR).

Sensitive data. Dietary restrictions and accessibility needs may reveal health information. When the guest provides them, they are stored only with the guest's express consent; when the host enters them, the host guarantees that it has that consent (Terms).

Automated decisions. Passly does not make decisions with legal or similarly significant effects on any person based solely on automated processing. The AI features propose content that you review and approve.

Today we do not send marketing communications. If we ever do, we will ask for your permission where the law requires it and you will always be able to unsubscribe with one click.

To refuse the secondary purposes, use the Cookie settings or write to us at [PENDIENTE: Correo de privacidad (p. ej. privacidad@wepassly.com)].

7. Artificial intelligence#

The AI features only run when you use them. We send the provider only what is necessary for that task. The details for each feature are on the Use of artificial intelligence page.

• The features that may contain personal data (importing guests, generating designs and texts with your event data, analyzing your reference photos) use Anthropic. Under its commercial terms, Anthropic does not use its API customers' content to train its models.
• Moonshot AI (Kimi) can only handle pure design requests (styles, palettes, layouts) that contain no personal data. By default every request is treated as containing personal data and goes only to Anthropic: Moonshot never receives guest lists, photos or your event details.
• Voice notes are transcribed with Groq (with OpenAI as a fallback).
• We do not cache AI outputs that contain guest data; the rest of the cache is deleted after 30 days.

AI-generated content may contain errors. Review it before publishing it.

8. Who we share data with#

We share data only with:

• Providers that help us deliver the service (sub-processors), under contract, bound by confidentiality and only for that purpose. The full, up-to-date list is in Sub-processors.
• The host and their team, with respect to the guest data for their event.
• Other attendees, only with respect to what each person posts in the gallery or the event app.
• Authorities, when a law or a valid order requires us to, first reviewing its lawfulness and notifying the affected person where the law allows.
• A buyer or successor, if Passly merges, is sold or reorganizes; it would remain bound by this notice and we would notify you beforehand.

Under the LFPDPPP, disclosures of data to our processors (remisiones) do not require your consent. Passly does not make transfers of personal data to third parties for those third parties' own purposes.

9. International transfers#

Our main servers are in the United States (database and files on AWS us-west-2, Oregon, through Supabase; Vercel application servers). If you use Passly from another country, your data will travel to the United States.

For data of people in the EU, the European Economic Area, Switzerland or the United Kingdom, we rely on each provider's data processing agreements with standard contractual clauses approved by the European Commission (and the UK addendum), or on the EU-U.S. Data Privacy Framework when the provider is certified. You can ask us for a copy of the safeguards at [PENDIENTE: Correo de privacidad (p. ej. privacidad@wepassly.com)].

We do not transfer personal data to China or to other countries without an adequacy decision beyond what is stated in this notice.

10. How long we keep data#

We keep each piece of data only for as long as necessary for its purpose, with specific periods that are applied automatically. The full table is in the Retention Policy. The essentials:

• Your account and your events: for as long as you keep the account. When you request deletion there are 14 days to change your mind; after that everything is deleted, including guests, photos and files.
• What you move to the trash (events, guests): purged after 30 days.
• Payment records: 5 years due to tax obligations, unlinked from your account if you delete it.
• Invitation open logs: 13 months.

11. Security#

We apply reasonable technical, administrative and physical measures: encryption in transit (HTTPS) and at rest, row-level access control in the database, unguessable invitation links, signed QR codes, rate limits, security logs without sensitive data and least-privilege staff access. The details, without revealing information that would help an attacker, are in Security.

No system is infallible. If a breach occurs that significantly affects your rights, we will tell you without undue delay and notify the authority where the law requires it (in the EU, within 72 hours at most).

12. Your rights and how to exercise them#

Depending on where you live, you have the right to:

• Access your data and know how we process it.
• Rectify it if it is inaccurate or incomplete.
• Cancel / erase it (delete it).
• Object to its processing or to certain purposes, and restrict its use.
• Portability: receive it in a structured, commonly used format.
• Withdraw your consent at any time, without retroactive effect.
• In California, to know, delete, correct and opt out of the sale or sharing of data (although we do not sell or share), without being discriminated against for exercising these rights.

How to do it

1. From your account: Settings → Privacy and data → "Download my data" or "Delete my account" (Ajustes → Privacidad y datos → «Descargar mis datos» o «Eliminar mi cuenta»).
2. From the Privacy Center: a form for any right, including if you do not have an account.
3. If you are a guest: the "Your data" ("Tus datos") link at the bottom of your invitation shows you what the host holds about you and lets you request correction or deletion.
4. By email: [PENDIENTE: Correo de privacidad (p. ej. privacidad@wepassly.com)].

We will respond within at most 20 business days (Mexico), 1 month (EU/UK) or 45 days (California), whichever is the shortest period that applies to you, and we will tell you if we need to extend it and why. It is free of charge. We may ask you to verify your identity in a proportionate way; an authorized agent may act on your behalf with your written authorization.

If your request concerns guest data for an event, we will forward it to the host, who is the one who decides about that data, and we will help you get it handled.

Authorities

If you are not satisfied with our response, you can contact the data protection authority: in Mexico, the Anti-Corruption and Good Governance Ministry (Secretaría Anticorrupción y Buen Gobierno); in the EU, the supervisory authority of your country; in the United Kingdom, the ICO; in California, the California Privacy Protection Agency.

13. Minors#

To create a Passly account you must be over 18 years of age. Passly is not directed at children under 13 and we do not knowingly collect their data directly from them.

Many celebrations involve minors (quinceañeras, baptisms, children's birthdays, families with children). When the host enters data or photos of minors, the host represents that it has the consent of the person who holds parental authority or guardianship. Minors who use the gallery or the event app must do so with the permission of their parents or guardians.

If you believe a minor gave us data without that permission, write to us at [PENDIENTE: Correo de privacidad (p. ej. privacidad@wepassly.com)] and we will delete it.

14. Cookies and similar technologies#

We use cookies and local storage that are necessary for Passly to work and —only if you give us permission— optional conveniences and aggregate analytics. Invitations do not use analytics. Full details and the list of every cookie are in the Cookie Policy.

We honor the Global Privacy Control (GPC) signal: if your browser sends it, we keep analytics turned off.

15. Communications#

We send you service emails (account confirmation, password recovery, email changes) and in-app notices (for example, new RSVPs, upcoming renewals or legal changes). These communications are necessary and cannot be turned off while you have an account, except for the notifications you can adjust in Settings (Ajustes).

WhatsApp messages to guests are sent by the host from their own phone via a link; Passly has no access to those conversations.

16. Changes to this notice#

If we change this notice, we will publish the new version with its date and a summary of the changes in this page's history.

• Material changes (new purposes, new categories of data, relevant new recipients): we will notify you within the app and, where appropriate, ask you to accept them before continuing.
• Informative changes (wording, corrections, contact details): you will see them in an unobtrusive notice.

17. Contact#

Controller: [PENDIENTE: Razón social / nombre legal del titular], [PENDIENTE: Domicilio completo (calle, número, colonia, C.P., ciudad, estado, país)].

Privacy: [PENDIENTE: Correo de privacidad (p. ej. privacidad@wepassly.com)] · Data officer / DPO: [PENDIENTE: Persona o departamento responsable de datos personales / DPO].

EU representative: [PENDIENTE: Representante en la UE (RGPD art. 27 / DSA art. 13): nombre y dirección]. UK representative: [PENDIENTE: Representante en el Reino Unido (UK GDPR art. 27): nombre y dirección].

General support: hola@wepassly.com.