01Data controller
RefurbPassport (“RefurbPassport”) is responsible for processing the data described in this policy. Contact: contact@refurbpassport.com.
Version 2026-01
Privacy Policy
Last updated: June 21, 2026
02Data collected
We collect strictly necessary data: user account (email, name), organization membership, audit logs, consents, verification metadata. Sensitive identifiers (IMEI, serial number) are encrypted and hashed — never stored in the clear.
03Sensitive data protected
Full IMEIs and serial numbers are never publicly displayed or included in user exports. Any internal decryption is logged in the sensitive access register with reason, timestamp and actor.
04Purposes
Verification of refurbished devices, issuance of digital passports, fraud prevention, legal obligations, service improvement (with consent when required).
05Legal basis
Execution of the contract (account and services), legitimate interest (security, anti-fraud), consent (marketing, analytical cookies), legal obligation (conservation of audit logs).
06Data retention
Account data: account duration + 12 months after deletion. Audit logs: 24 months. Encrypted identifiers: duration of the active passport, then GDPR invalidation or anonymization.
07Your rights
Access, rectification, erasure, limitation, portability, opposition. Export JSON from Settings > Privacy. Account deletion with irreversible anonymization.
08Subcontractors & hosting
Infrastructure hosted in the European Union. Subcontractors subject to contractual clauses and security audits.
09Cookies
Essential cookies (session, security) without consent. Analytical cookies only with your consent via the banner or privacy settings.
10Claims
Contact us first at contact@refurbpassport.com. You can contact the competent supervisory authority in your country of residence.
Manage your preferences from privacy dashboard. See also the conditions of use.
A question about this document?Write to us at contact@refurbpassport.com