1 · Who we are
The data controller is Digikamu Oy, Helsinki, Finland. Contact: open the chat assistant in the corner of any page and click Email us; the message reaches us directly. We don't have a separate DPO; for GDPR requests, the founder is the contact point.
2 · What data we collect
We try to collect as little as possible. The categories below are everything we collect today.
- Account data — email address, hashed password (or one-time tokens used for invites and password resets), and a workspace name when you sign up.
- Workspace data — company name, business ID, country, optional VAT/EORI, optional public contact and registered address. These appear on your public passport pages when you choose to publish.
- Product / passport data — the product names, materials, photos, and other ESPR fields you enter. This is published only when you set a passport to Active.
- Scan data — aggregate, anonymous scan counts on your published passports (country-level, no IP storage, no cookies). Used to show you weekly scan totals.
- Site and app usage — aggregate page views, page performance and counts of actions such as starting signup or downloading a QR. Analytics events do not include your email, product name or a persistent visitor identifier.
- Signup attribution — the referring site and campaign tags visible on the signup page, plus the country your connection came from at signup (derived from IP; the IP itself is not stored). Kept with your workspace so we can tell which channels bring customers.
- Billing data — handled entirely by Stripe. We store only the Stripe customer ID and subscription state; we never see or store card details.
- Operational logs — Vercel keeps short-lived access logs for security and reliability. Sentry stores application errors and, when an error occurs, a session replay with all text masked and media blocked. Both retain data for 30–90 days.
3 · What we don't collect
- No advertising cookies or cross-site advertising trackers.
- No Google Analytics, no Meta pixel, no LinkedIn insight tag.
- No reading of your inbox, files, or anything outside the app.
- No sale of personal data to anyone — ever. (We don't even have a business model that would let us.)
4 · Where it's stored
Your data does not leave the EU, with one narrow exception listed below (internal notifications).
- Database & file storage: Supabase, Frankfurt (Germany).
- Web hosting & edge: Vercel, EU regions.
- Transactional email: Resend, EU.
- Error tracking: Sentry, hosted in the EU (Germany). When an error occurs, a session replay may be recorded with all text masked and media blocked; no replay is recorded for sessions without errors. If you prefer not to have errors logged at all, email us and we can disable it for your account.
- Billing: Stripe (Ireland).
- Internal notifications: Discord (US). When a workspace is created or its first passport goes live, the founder receives a short notification with the company name, country and signup source — never your email address or passport contents.
- AI assistance: Anthropic. When you use the AI-fill flow, the text or image you provided is sent to Anthropic's API (US-hosted) to generate the draft. Anthropic does not train on API traffic. We don't send your data to Anthropic outside that explicit feature use.
5 · Cookies
We use only strictly necessary cookies — the session cookie that keeps you logged in, and a CSRF protection cookie. No analytics cookies. No advertising cookies. Vercel Web Analytics and Speed Insights report aggregate page and performance data without analytics cookies. We do not store a marketing identifier or browsing history in your browser. When you sign up, we may record the referring site and campaign tags visible on that page.
6 · Legal basis for processing
- Contract (GDPR Art. 6(1)(b)) — account data, workspace data, product data are processed to deliver the service you signed up for.
- Legal obligation (Art. 6(1)(c)) — billing records retained for Finnish accounting law (6 years).
- Legitimate interest (Art. 6(1)(f)) — operational logs and error tracking, narrowly scoped, to keep the service available and secure.
7 · How long we keep it
- Account & workspace data: while your account is active and for 30 days after deletion (recoverable on request).
- Passport data: kept while the passport is a Draft, Live, Deactivated or Archived — a passport that has been published has to stay reachable for up to 10 years. Permanently deleting one removes it from the database and storage immediately.
- Billing records: 6 years (Finnish accounting law).
- Operational logs: 30–90 days, then automatically purged by the provider.
8 · Your rights under GDPR
You can ask us to:
- Access — a copy of the data we hold about you.
- Rectify — fix anything that's wrong.
- Erase — delete your data (subject to retention obligations above).
- Restrict — pause processing while a complaint is resolved.
- Object — to processing based on legitimate interest.
- Portability — receive your data in a structured, machine-readable format.
Open the chat assistant on any productpasses.com page and click Email us to send your request through to the team. We respond within 30 days. If you're not satisfied, you can lodge a complaint with the Finnish Data Protection Ombudsman (tietosuoja.fi) or your local supervisory authority.
9 · Public passport data
Anything you publish on a passport page (product details, materials, your company name as the brand) becomes public at productpasses.com/p/<slug>. That's the point — DPP is about consumer-visible traceability. Deactivated passports stay scannable for your grace period, then show a read-only “no longer active” page. They never 404. That read-only record (product name, subtitle, passport ID) stays public for the retention period above. Permanently deleting the passport is the only thing that removes the data.
10 · Children
productpasses.com is a business tool. We don't knowingly create accounts for anyone under 16. If you believe a child has created an account, email us and we'll delete it.
11 · Changes
When we update this page meaningfully, we'll bump the “last updated” date and notify existing customers by email. Cosmetic edits don't trigger a notification.
12 · Plain-English summary
We collect what we need to run your account. We store it in the EU. We don't sell it, don't track you across the web, don't set advertising cookies. You can delete your data whenever you want. Questions: ask the chat assistant on any page; if the bot can't answer, “Email us” in the chat routes to a human.