Consumer Privacy Policy

This Policy explains how the ProdIDPass operator identified in the Legal Notice (ProdIDPass, we, us) processes personal data when you use the consumer website, marketplace, accounts, Digital Product Passports (DPPs), credentials, reviews, Trust Points and support channels.

1. Controller and contacts

The controller for platform-operation processing is the following company, referred to by its ProdIDPass brand in this Policy:

Controller: WISHTECH, SAS (société par actions simplifiée), SIREN 878201367; 11 RUE DE LOURMEL, 75015 PARIS, France. Privacy contact: [privacy email or form]
Data Protection Officer, if appointed: [DPO contact]

A professional seller is normally a separate controller for its product listing, sale, fulfilment, warranty, safety, tax and customer-service processing. Its details appear with the offer and order. Payment providers, carriers, credential issuers and other services may also act as independent controllers for their own regulated activities. We will describe any materially different joint-controller arrangement where it applies.

2. Data we process and sources

Depending on the features used, we process:

identity, age or eligibility indicators, account profile, contact details, language and preferences;
authentication, device, IP address, session, security event and consent or legal-acceptance records;
delivery and billing addresses, VAT-related information, cart, order, seller, product, price, payment status and limited transaction references; we do not normally receive complete card data from the payment provider;
delivery, withdrawal, return, refund, complaint, warranty, product-safety and support communications;
public DPP identifiers and product records, ownership claims, DIDs, wallet and credential metadata, issuance, presentation and transfer events;
reviews, ratings, votes, moderation and appeal records, verified-purchase indicators and Trust Point balances and events;
newsletter subscription, confirmation, delivery, unsubscribe and campaign interaction data where lawfully enabled;
illegal-content notices, decisions and redress records; and
essential browser storage such as account/session, cart, checkout draft, language and security state, plus other cookies or similar technologies described in the interface.

We receive data directly from you; from sellers, payment providers, carriers, authentication and email providers; from credential issuers or holders; from public DPP or company records; and from technical interactions with the Service. If another person provides your data, we provide the required information directly or through the responsible party, subject to lawful exceptions.

Do not put unnecessary personal or sensitive data into public DPP fields, reviews or reports. Public content may be indexed, copied or shared by others.

3. Purposes and legal bases

We process data only where a legal basis applies:

Contract and requested steps: create and secure an account; maintain carts and checkout; route and record orders; provide wallet, credential, ownership, review, support and complaint functions; and communicate about the Service.
Legal obligations: retain transaction and acceptance evidence; respond to lawful orders; meet consumer, tax, accounting, product-safety, Digital Services Act and data-protection duties; and manage statutory rights.
Legitimate interests: secure the Service; prevent fraud and abuse; maintain reliable DPP and reputation data; moderate content; diagnose errors; establish or defend claims; and improve the Service. We balance these interests against your rights and expectations.
Consent: send electronic marketing or activate non-essential terminal storage where consent is required. You may withdraw consent at any time without affecting earlier lawful processing.
Vital interests or public interest: exceptionally, protect a person from an immediate serious threat or process data where a specific legal public-interest basis applies.

Where data is required for a contract or law, the relevant field will be identified. Without essential account, delivery, eligibility or transaction information, we may be unable to create an account, place or fulfil an order, issue a credential or resolve a request.

4. Sharing and recipients

We share only what is reasonably necessary with:

the seller responsible for an order, listing, withdrawal, return, warranty, safety issue or complaint;
payment and fraud-prevention providers, including the provider identified in the payment flow;
carriers, logistics, communication, email, authentication, cloud-hosting, database, monitoring and technical-support providers;
credential issuers, verifiers or holders when you request a credential operation;
professional advisers, auditors, insurers and prospective transaction counterparties subject to safeguards; and
courts, regulators, law-enforcement or other competent bodies where disclosure is required or legally justified.

Service providers acting as processors are contractually limited to documented purposes and appropriate security. We do not sell personal data. If a promotion or seller receives data for its own marketing, this requires a separate lawful basis and transparent notice.

5. International transfers

Some recipients or support access may be outside the European Economic Area. Where no adequacy decision applies, we use an approved safeguard such as European Commission standard contractual clauses, together with supplementary measures where necessary, or a specific lawful derogation. Contact us for information about the relevant safeguard and how to obtain a copy, subject to protection of confidential terms.

6. Retention

We keep personal data only for the period needed for the stated purpose and then delete, anonymise or place it in restricted archive where legally required. The applicable period depends on account activity, the transaction or credential lifecycle, statutory accounting and tax periods, product safety and recall needs, limitation periods, disputes, fraud and security evidence, and authority orders.

Typical criteria are: account data while the account is active plus a limited claims or reactivation period; cart and incomplete checkout data for a short operational period; order, invoice, acceptance and payment-reference data for the legally required accounting and contract-evidence period; support, complaint, moderation and report records until closure plus the relevant claims or regulatory period; and security logs for a proportionate risk-based period. Public content may remain until removed or no longer needed, with restricted evidence retained where lawful. A credential or DPP record may be technically persistent; we minimise personal data and distinguish a public product record from private account data.

Release blocker: the operator must approve and maintain a concrete internal retention schedule for every system and processor. This public description must be updated if the implemented periods materially differ.

7. Cookies and local storage

The Service uses cookies, local storage, session storage or similar terminal access for functions such as authentication, security, cart contents, checkout continuity, legal acceptance and language. Technologies strictly necessary for a service you request may be used without consent where law permits. Non-essential analytics, advertising or personalisation technologies must not activate before valid consent where consent is required. The interface must identify their purposes, providers and durations and make refusal and withdrawal as easy as acceptance.

8. Automated rules and profiling

Automated rules may check stock, transaction risk, abuse, eligibility and disclosed Trust Point requirements, or help prioritise and moderate content. They may result in a transaction being paused, an offer being unavailable or content being flagged. We use human review where required. If a decision is based solely on automated processing and produces legal or similarly significant effects under Article 22 GDPR, you may request human intervention, express your view and contest the decision, except where a lawful exception applies. Contact us with the relevant reference.

9. Your rights

Subject to conditions and exceptions, you may request access, rectification, erasure, restriction, portability and objection. You may withdraw consent at any time and object at any time to direct marketing. Where processing relies on legitimate interests, you may object based on your particular situation. You may also contest qualifying automated decisions and give instructions concerning personal data after death where national law provides.

Use [privacy rights form or email]. We may verify identity proportionately and will respond within the applicable period. You may complain to the supervisory authority in your habitual residence, workplace or place of the alleged infringement. For the French controller, this includes the Commission nationale de l'informatique et des libertés (CNIL), www.cnil.fr.

10. Security, children and updates

We apply risk-appropriate technical and organisational measures, including access controls, encryption where appropriate, logging, backups and incident procedures. No online service is risk-free. Protect credentials and report suspected compromise promptly.

The Service is not directed to children who cannot lawfully provide their own data or enter the relevant contract. A parent or guardian should contact us if a child's data was provided without valid authority.

We update this Policy when processing or law changes. The version and effective date appear above. We will provide additional notice where a change materially affects your rights or requires renewed consent. Earlier versions should remain available as evidence of the notice in force at the relevant time.

Chats, attachments and organization notes

To provide requested communications, we process message text, sender display names, goods/service references, attachments and file metadata, timestamps, status and read positions. Providing conversations relies on performance of the service and requested pre-contract steps; necessary security, abuse prevention and dispute handling rely on legitimate interests, and statutory retention and authority requests on legal obligations. Special-category data still requires an additional lawful condition. Do not send unrelated health, identity or other sensitive information.

Messages and sent attachments are available to the customer and authorized members of the target organization. Uploading an attachment without sending it does not share it with the other party. Internal organization notes are not displayed to customers; this does not exclude applicable data-rights requests. Enquiries do not automatically provide account email or telephone details to sellers, but information you put in messages or files is visible to recipients. Billing and contact data needed for a purchase is still supplied through the order process.

Chat attachments use restricted private storage, unlike public goods/service images. Downloads require permission checks and short-lived authorized links; anyone obtaining a valid link may access the file until expiry, and downloaded copies cannot be recalled. Do not forward links. Chat is not end-to-end encrypted. Authorized platform personnel access relevant data only as necessary for support, security, complaints, disputes or legal duties; infrastructure and email providers process data under the existing recipient rules, and notification emails may include message text.

Closing chat or hiding an unpaid order does not immediately erase personal data. Chats and files are retained according to conversation, transaction and complaint needs, applicable limitation periods, statutory retention and security investigations, then deleted, anonymised or restricted when no longer needed. Organizations must control member access and may not reuse received content for marketing or disclosure without a lawful basis.