1. Overview
This website uses privacy-focused analytics to understand performance and usage patterns. We aim to minimize
data collection and avoid tracking individuals.
2. Data Controller
The operator of this website is the data controller responsible for processing personal data under applicable
laws, including the General Data Protection Regulation (GDPR) and relevant U.S. privacy laws.
3. Analytics Processing
We use analytics services provided by Cloudflare (Cloudflare, Inc.).
- No cookies or similar tracking technologies are used
- No cross-site tracking is performed
- Data is processed in aggregated form
The purpose of this processing is to:
- monitor website performance
- detect errors and outages
- improve user experience
4. Data Collected
During normal operation, limited technical data may be processed, such as:
- IP address (processed transiently)
- browser and device type
- pages visited and interaction timing
- performance metrics (e.g. load times)
We do not use this data to identify individuals.
5. Legal Basis (EU)
Under the General Data Protection Regulation, processing is based on Article 6(1)(f) — legitimate interest —
to operate, secure, and improve our website.
6. U.S. Privacy Rights
Depending on your location (e.g. California under the California Consumer Privacy Act / CPRA):
- We do not sell personal information
- We do not share personal information for cross-context behavioral advertising
- Data is used only for operational and analytical purposes
You may have rights to request access, deletion, or information about data processing. Contact us using the
details below.
7. Data Sharing and Processing
Analytics data is processed by Cloudflare as a service provider (processor). Data may be processed in the
United States and other jurisdictions where Cloudflare operates.
Where required, appropriate safeguards such as Standard Contractual Clauses are used.
8. Data Retention
We retain analytics data only as long as necessary for aggregated analysis and system performance monitoring.
Raw or identifiable data, if any, is minimized and retained for a limited period.
9. Security
We implement technical and organizational measures to protect data, including encryption in transit and access
controls.
10. Your Rights (EU)
Under GDPR, you may have the right to:
- access your personal data
- request correction or deletion
- object to processing based on legitimate interest
- lodge a complaint with a supervisory authority
11. Contact
For privacy-related inquiries, contact:
privacy@passless-keysmith.com
12. Updates
This Privacy Policy may be updated from time to time to reflect legal or operational changes.