Last updated: March 13, 2020
(added information about Austrian Post)
Software Spinner ("us", "we", or "our") operates https://www.myexpatpassport.com (the "Site"). This page informs you of our policies regarding the collection, use, and disclosure of Personal Information we receive from users of the Site. We use your Personal Information only for providing a service and improving the Site. Our Site is independent of any party, institution, or interest groups. By using the Site, you agree to the collection and use of information in accordance with this policy.
1. Information Collection And Use
While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to your name ("Personal Information").
2. Personal Data
We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information about the Site. We will not share your data with other third parties, unless where necessary to use our services - so basically, when you file your tax returns through the Site, we have to share your information with the IRS.
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive. Like many sites, we use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, please be aware that you may not be able to use some portions of our Site.
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
6. Contact Us
You can reach out to us via email, the chat window in the bottom right corner, or through one of our social media sites, like Facebook, Instagram, Twitter or LinkedIn. Please note that if you reach out to us, we will store the data you provide us with to answer your requests. This will typically include only your name and email address (or other means by which to contact you), but depending on your specific inquiry we may have to ask for additional information.
Whatever data we collect through this contact, we will not share it with any third party without your express permission.
7. Log Data
Like many site operators, we collect information that your browser sends whenever you visit our Site ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
8. Matomo Analytics
This website uses Matomo Analytics. Matomo is an open source web analytics platform. A web analytics platform is used by a website owner in order to measure, collect, analyse and report visitors data for purposes of understanding and optimizing their website. If you would like to see what Matomo looks like, you can access a demo version at: https://demo.matomo.org.
Matomo is used to analyse the behaviour of the website visitors to identify potential pitfalls; not found pages, search engine indexing issues, which contents are the most appreciated… Once the data is processed (number of visitors reaching a not found pages, viewing only one page…), Matomo is generating reports for website owners to take action, for example changing the layout of the pages, publishing some fresh content… etc.
Matomo is processing the following personal data:
- IP address (anonymized)
- Title of the page being viewed
- URL of the page being viewed
- URL of the page that was viewed prior to the current page
- Pages generation time
Processing your personal data such as cookies is helping us identify what is working and what is not on our website. For example, it helps us identify if the way we are communicating is engaging or not and how we can organize the structure of the website better. Our team is benefiting from the processing of your personal data, and they are directly acting on the website. By processing your personal data, you can profit from a website which is getting better and better.
Without the data, we would not be able to provide you the service we are currently offering to you. Your data will be used only to improve the user experience on our website and help you find the information you are looking for.
he personal data received through Matomo are sent to us only. The data is hosted in a data center in France. We are keeping the personal data captured within Matomo for a period of six months.
As Matomo is processing personal data on legitimate interests, you can exercise the following rights:
- Right of access: you can ask us at any time to access your personal data.
- Right to erasure: you can ask us at any time to delete all the personal data we are processing about you.
- Right to object: you can object to the tracking of your personal data by using the following opt-out link.
You can also adjust Matomo tracking here:
If you have any questions, please contact us at firstname.lastname@example.org.
We use SendInBlue (https://www.sendinblue.com) for our newsletters.
If you subscribe to our newsletter, we will need your email adress and your explicit permission that you agree to receive our newsletter.
If you want to cancel your subscription, you may do so at any time either through the "Unsubscribe" link in one of our newsletter emails or by sending us an email to email@example.com.
10. Statutory regulations and data processing purpose
By using our Site and our services, you have entered your data willingly and we process your data with the purpose of:
- Determining service eligibility - are both parties able to enter a contract
- Contract fulfillment - allowing us to fulfill the service you signed up for
- Answering your inqueries
- Sending you additional information and newsletters (see chapter 10).
You may rescind your agreement to this at any point. Note that once your data has been deleted, we will no longer be able to fulfill our services. To rescind your agreement, please send an email to firstname.lastname@example.org.
11. Forwarding your data to third parties
The data you enter online is only used for our record-keeping and to deliver our services to you, but will not be shared elsewhere. To deliver our services per our contractual obligations:
- The forms and documents you send us via mail will be delivered to the US consulate in Vienna.
- Your address, name and email address will be shared with the Austrian Post to generate the appropriate postage for the return envelope and to enable you to get an email notification with the tracking information when your new passport is sent back to you.
Beyond that, we will only forward your data to legal authorities as dictated by law or if necessary to press legal claims of Software Spinner, especially if necessary to press claims regarding contractual obligations.
12. Legal information
Regarding all data relating to you, you have the right to get a report on it, correct it, have it deleted or amended. You may rescind your agreement to have your data transferred to any third party as well.
If you believe that processing your data by us is violating data protection laws or that your data protection claims have been violated in any kind, you may reach out to the appropriate authority. In Austria, this would be the "Datenschutzbehörde".