Privacy Policy

Last updated: 5 November 2026

1. Who is responsible

The controller of the personal data processed on passamo.com and in the Passamo course is Norholm, MB, company code 307698646, VAT code LT100020253510, Girulių g. 10, LT-12112 Vilnius, the Republic of Lithuania. We have not appointed a data protection officer; for any question about your data, write to support@passamo.com.

2. Visiting the website

When you open the website, the server receives the data your browser sends with every request: your IP address, the date and time, the page requested, the page you came from, and your browser and operating system. We use it to deliver the website and to keep it secure. The legal basis is our legitimate interest in a working and secure website (Art. 6(1)(f) GDPR). The website is hosted by Vercel Inc., which processes this data on our behalf.

3. The quiz and your readiness score

Your answers in the quiz, the readiness score calculated from them and the plan you choose are stored in your own browser (local storage), so that the quiz can continue where you left it. We also record, without your name, which steps of the quiz were completed and which answers were chosen, to see how the quiz is used and to improve it (see section 8).

If you enter your email address, we store it together with your readiness score and the plan you chose, in order to prepare your study plan and to write to you about it. The legal basis is taking steps at your request before a contract (Art. 6(1)(b) GDPR).

4. Order, account and learning

When you order a plan, we process your email address, the plan and its term, contract and payment data (amount, date, status and payment method), your login, and your learning progress in the course (answers and results). We need this data to perform the contract with you (Art. 6(1)(b) GDPR) and, for invoices and accounting records, to meet our legal obligations (Art. 6(1)(c) GDPR).

5. Payment

Payments are handled by the payment service provider named at checkout. Your card or account details go directly to that provider; we do not receive or store them. We receive the amount, the date, the status of the payment, the payment method and a reference for renewals. If you pay with PayPal, Apple Pay or Google Pay, those providers and your bank process your data under their own responsibility. The legal bases are Art. 6(1)(b) and (c) GDPR.

6. Emails

We send the emails needed for your contract, such as the order confirmation, access details and payment, cancellation and withdrawal confirmations (Art. 6(1)(b) GDPR). We send marketing emails only if you have separately agreed to receive them (Art. 6(1)(a) GDPR); you can withdraw that agreement at any time with the link in each email or by writing to us.

7. Contacting us

If you write to us, we process your message and your contact details to answer it and to handle your request (Art. 6(1)(b) or (f) GDPR).

8. Analytics and where you came from

We use PostHog to understand how the website and the quiz are used: which pages and steps are viewed, which answers are chosen, whether a plan is selected and whether a payment is started. PostHog processes this data on our behalf on servers in the European Union. Once you have entered your email address, these records are linked to it. Card details are never part of them.

If you arrive from an advertisement, the link you followed contains identifiers of that advertisement, and we record them to see which advertisements bring visitors. We do not use advertising pixels of social networks on this website.

The legal basis is our legitimate interest in understanding and improving our website and our advertising (Art. 6(1)(f) GDPR). You can object at any time by writing to support@passamo.com.

9. Cookies and local storage

We store in your browser what the website needs to work: your quiz answers, your readiness score, the plan you chose and the end of your discount period. PostHog also stores an identifier in your browser so that visits can be told apart. You can delete this data at any time in your browser settings; the quiz then starts again from the beginning. The fonts on this website are served from our own servers.

10. Who receives your data

We do not sell your data. It is passed on only to the service providers named in this policy, which process it on our behalf or under their own responsibility, and to tax advisers and authorities where the law requires it.

Vercel Inc. and PostHog Inc. are companies based in the United States, so access to data from there cannot be ruled out. Where data is transferred outside the European Economic Area, the transfer is based on the adequacy decision for the EU–US Data Privacy Framework, where the provider is certified, and on the standard contractual clauses of the European Commission (Arts. 45 and 46 GDPR).

11. How long we keep your data

• Invoices and accounting records: for as long as tax and accounting law requires, which is ten years.
• Your account and learning progress: until your contract ends, and after that until you ask us to delete them.
• Cancellations, withdrawals and proof of your consent: three years after the end of the year in which we received them.
• Your email address for marketing: until you unsubscribe.
• Quiz data without an order, usage records and messages to customer service: for as long as they are needed for the purposes described above.

12. Your rights

You have the right to access your data (Art. 15 GDPR), to have it corrected (Art. 16) or deleted (Art. 17), to have its processing restricted (Art. 18), to receive it in a portable format (Art. 20), and to withdraw a consent you have given, with effect for the future (Art. 7(3)). Where we rely on a legitimate interest, you may object to the processing (Art. 21); you may object to direct marketing at any time without giving a reason.

To use these rights, write to support@passamo.com. We answer within one month and may ask you to confirm your identity. You also have the right to complain to a supervisory authority, in particular in the country where you live. The authority responsible for us is the State Data Protection Inspectorate of the Republic of Lithuania (L. Sapiegos g. 17, LT-10312 Vilnius, vdai.lrv.lt).

13. Data we need, automated decisions and age

To conclude a contract we need your email address and your payment data; everything else is voluntary. The readiness score is calculated automatically from your answers, but we make no decisions about you by automated means that have legal or similarly significant effects (Art. 22 GDPR). Passamo is intended for adults; we do not knowingly process the data of anyone under 18.

14. Security and changes

The connection to the website and the course is encrypted, and access to personal data is limited to the people who need it for their work. We update this policy when our processing or the law changes; the version published here applies.