Effective Date: June  1, 2025

1. Introduction

Welcome to Second Pass ("we," "us," "our"). We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website secondpass.co (the "Site") and use our services, including signing up for our newsletter and using our citizenship eligibility assessment tool.

Please read this privacy policy carefully. Your use of the Site or our services signifies your acceptance of this Privacy Policy. If you do not agree with the terms of this privacy policy, please do not access the site or use our services.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Effective Date" of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates.

2. Information We Collect

We may collect information about you in a variety of ways:

• Personal Data Voluntarily Provided:

  • Newsletter Signup: We collect your email address when you subscribe to our newsletter.

  • Citizenship Eligibility Assessment: When you use our assessment tool, we collect personal information about you and potentially your ancestors to determine eligibility and potentially send relevant communications. This may include: Your Full Name, Email Address, Phone Number, Birth Year, Country of Birth, and corresponding details (Names, Birth Years, Countries of Birth) for relevant Ancestors.

• Usage and Interaction Data:

  • Server Logs: Our servers may automatically collect standard log information like your IP address, browser type, operating system, access times, and referring website addresses.

  • Website Analytics: We use website analytics services to help us understand how users interact with our Site. These services may capture behavioral metrics, heatmaps, and session replays to improve our website and user experience. This may involve collecting information such as mouse movements, clicks, scrolls, and pages visited.

• Cookies and Similar Technologies:

  • We and our third-party service providers may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site, improve your experience, and track usage. See Section 8 for more details.

3. How We Use Your Information

We use the information we collect for various purposes, including:

• Providing Services:

  • To assess your potential eligibility for citizenship based on the information you provide.

  • To send you our email newsletter if you have subscribed.

• Communication:

  • To communicate with you regarding your eligibility assessment, your account, or other inquiries.

  • To send you promotional content, updates, or offers via our newsletter that we believe may be relevant to you, potentially based on the information (including general ancestral origin context, if applicable) you provided. You can opt-out of promotional emails at any time.

• Improvement and Analysis:

  • To monitor and analyze usage and trends using website analytics tools to improve the Site's functionality and user experience.

  • To maintain the security and operation of our Site.

• Legal Compliance:

  • To comply with applicable laws and regulations or respond to valid legal processes.
    

    4. Disclosure of Your Information

We respect your privacy and limit the sharing of your information. We do not sell your personal information. We may share information we have collected about you as follows:

• Third-Party Service Providers: We share information with third-party vendors and service providers who perform services on our behalf to help us operate our Site and provide our services to you. These providers need access to certain information to perform their work for us. These may include:

• Email service providers: To manage and send our email newsletters (your email address is shared).

• Data storage and management services: To store and manage the personal and ancestral information submitted for citizenship eligibility assessments (names, contact details, birth years, countries of birth for you and ancestors may be stored here).

• Website analytics providers: To analyze website usage and user interaction (interaction data, potentially IP address, may be processed).

• These service providers have their own privacy policies and terms that govern their use of data. We rely on their stated commitments to data protection and security. We encourage you to review the privacy policies of these third parties to understand their practices.

• By Law or to Protect Rights: If required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

• With Your Consent: We may disclose your personal information for other purposes with your explicit consent.

Currently, we do not share the personal or ancestral information collected for citizenship eligibility with any other third parties beyond secure storage with our data storage providers and internal use as described herein, unless required by law or with your specific consent.

5. Data Storage & Security

We take the security of your data seriously.

• Storage: Your newsletter email address is processed by our email service provider. The personal and ancestral data you provide for citizenship eligibility is stored using data storage and management services. Website usage data is processed by our website analytics providers.

• Security Measures: We rely on the security measures implemented by our third-party providers for the data they process and store. We also implement administrative and technical measures within our control, such as limiting internal access to databases on an as-needed basis, to safeguard your data.

• Disclaimer: While we and our providers strive to use commercially acceptable means to protect your personal information, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

6. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

• Newsletter Data: We retain your email address for as long as you are subscribed. If you unsubscribe, your email address will be promptly removed from our active mailing list(s), and you will no longer receive marketing newsletters from us. To ensure we honor your request, your email address may be retained on a suppression list to prevent future unwanted communications.

• Citizenship Eligibility Data: We retain the personal and ancestral information you provide, stored with our data storage services, for as long as needed to provide the service and any follow-up communications, unless you request its deletion. Upon your request, subject to legal constraints, we will securely delete or anonymize your information.

7. Your Data Protection Rights

You have certain rights regarding your personal information, subject to local data protection laws. These may include the right to:

• Access: Request access to the personal data we hold about you.

• Rectification: Request correction of inaccurate or incomplete data.

• Erasure: Request deletion of your personal data, subject to certain exceptions.

• Restrict Processing: Request restriction of how we process your data in certain circumstances.

• Object to Processing: Object to processing based on legitimate interests or for direct marketing.

• Data Portability: Request transfer of your data to you or another party in a structured format (where technically feasible).

• Withdraw Consent: Withdraw your consent at any time where we rely on consent for processing (this does not affect past processing).

To exercise any of these rights, please contact us using the details provided in Section 13. You can unsubscribe from our promotional emails at any time by clicking the "unsubscribe" link in the email.

8. Cookies and Tracking Technologies

We use cookies and similar technologies (like web beacons or pixels) provided by us or by third-party service providers.

• What are Cookies: Cookies are small data files stored on your device that help us improve our Site and your experience, see which areas and features are popular, and count visits.

• How We Use Them: We use cookies for essential site functionality, performance analysis (understanding user behavior via analytics services), and potentially to support marketing efforts (e.g., tracking newsletter effectiveness via our email service provider).

• Your Choices: Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Site. You may need to consult the privacy policies of our third-party service providers for more information on their specific data collection and cookie practices.

9. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under this age without parental consent. If you believe we have collected information from a child under this age, please contact us immediately, and we will take steps to delete it.

10. International Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ. Our service providers may operate globally, meaning your data may be processed in the United States or other countries. We rely on the data transfer mechanisms and safeguards implemented by these providers. By using our Service, you consent to this transfer, storage, and processing.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Effective Date" and will be effective immediately upon posting. We encourage you to review this policy frequently.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please reach out to us at contact@secondpass.co