Privacy Notice

Who we are and what this Notice covers

Passback Inc., a Delaware corporation, is responsible for personal information processed through soolra.com. This Notice covers the website, its support and business inquiry forms, privacy controls, and interactions that refer to this Notice.

This website Notice does not govern processing within the SOOLRA™ mobile app. The App Store identifies Soolra LLC as the app developer and links to the developer's separate app privacy policy. Amazon, Apple, Instagram, YouTube, game publishers and other linked services also operate under their own privacy notices. When you follow a link or complete a purchase through Amazon, that service independently determines how it processes information on its platform.

Information we collect

• Contact and support information you submit, such as name, email address, help topic, message, iPhone model, SOOLRA™ model or color, software version, order source and order number.
• Business inquiry information you submit for retailer, distribution, investment, media or partnership discussions.
• Device and network information, such as IP address, approximate country or region, browser, device type, operating system, requested URL, timestamps, referring page and security events.
• Website activity and performance information, such as page views, interactions and Web Vitals, when the applicable regional setting or your consent permits it.
• Advertising and campaign information, such as browser identifiers, referring campaign and events transmitted through Meta Pixel, only when the pixel is configured and applicable privacy choices permit it.
• Preferences stored on your device, including privacy, accessibility and motion settings.
• Amazon-related information only when Amazon makes it available to Passback Inc. as a seller or when you choose to provide it for support. Payment-card information is not collected by this website.

Sources of information

We collect information directly from you, automatically from your browser and device, from service providers that support the website, and from marketplaces or other partners when they are permitted to provide it. We do not ask you to submit passwords, full payment-card numbers, government identifiers or sensitive personal information through the support form.

Why we use information

• Provide, operate, secure, troubleshoot and improve the website.
• Respond to support, privacy, accessibility, retailer, investor and partnership requests.
• Verify product or order details you ask us to investigate and coordinate marketplace support.
• Measure website performance and understand aggregate use.
• Measure campaigns and show or evaluate advertising when legally permitted.
• Detect spam, fraud, abuse, security incidents and violations of our Terms.
• Comply with law, enforce agreements, establish or defend legal claims and protect users, Passback Inc. and others.
• Complete a merger, financing, acquisition, reorganization or sale of assets subject to appropriate safeguards.

Legal bases in the EEA and United Kingdom

Where the GDPR or UK GDPR applies, we rely on one or more legal bases: your consent for non-essential storage, analytics and advertising technologies; performance of a contract or steps requested before a contract; our legitimate interests in operating, securing, improving and supporting the website where those interests are not overridden by your rights; and compliance with legal obligations.

You may withdraw consent at any time through Privacy Choices. Withdrawal does not affect processing that was lawful before withdrawal.

How we disclose information

• Hosting, content delivery, security and performance providers, including Vercel.
• Email delivery and mailbox providers, including Resend and the provider for info@soolra.com.
• Analytics and advertising providers, including Google Analytics, Vercel Speed Insights and Meta, when enabled and permitted.
• Amazon and other marketplaces when necessary to address an order or support matter you initiated, subject to marketplace rules.
• Professional advisers, insurers, auditors and authorities when reasonably necessary for legal, compliance or security purposes.
• A successor or transaction participant in connection with a corporate transaction, subject to confidentiality and applicable law.

Sale, sharing and targeted advertising

Passback Inc. does not sell personal information for money. If Meta Pixel or another advertising technology is enabled, disclosure of browser or activity information for cross-context behavioral advertising may be considered “sharing,” “targeted advertising” or a “sale” under certain U.S. state laws even when no money is exchanged.

You may opt out through Privacy Choices. Where required, we also honor a recognized Global Privacy Control signal as an opt-out for the browser or device that sends it. We do not knowingly sell or share personal information of people under 16.

Retention

We retain information only as long as reasonably necessary for the purpose described, including providing support, maintaining business and legal records, resolving disputes, preventing abuse and meeting tax, accounting or other legal requirements. Retention depends on the nature and sensitivity of the information, the purpose of processing and applicable obligations.

Browser privacy and accessibility preferences remain on your device until you change them or clear browser storage. Support communications may be retained for the life of the request and a reasonable recordkeeping period afterward.

Security and international transfers

We use reasonable administrative, technical and organizational safeguards designed for the nature of the information processed. No transmission or storage system is guaranteed to be completely secure.

Passback Inc. and its providers may process information in the United States and other countries. Where cross-border transfer rules apply, we take steps designed to use an available lawful transfer mechanism and appropriate safeguards, taking into account the provider, information and destination involved.

Your privacy rights

Depending on your location and subject to legal exceptions, you may request access, confirmation, correction, deletion, portability or a copy of personal information; object to or restrict processing; withdraw consent; opt out of sale, sharing, targeted advertising or certain profiling; and appeal a decision about your request. EEA and UK residents may also complain to their local supervisory authority.

California residents may request the categories and specific pieces of personal information collected, sources, purposes and recipients; request correction or deletion; opt out of sale or sharing; limit certain uses of sensitive personal information where applicable; and receive equal service and pricing when exercising rights. We do not use or disclose sensitive personal information for purposes that require a limitation right on this website.

To exercise a right, email info@soolra.com with “Privacy Request” in the subject line or use the support form and select Privacy request. We may verify your identity and authority before completing a request. An authorized agent may submit a request where permitted by law. If we deny a request, our response will explain how to appeal where an appeal right applies.

Children’s privacy

The website is intended for a general audience and is not directed to children under 13. We do not knowingly collect personal information online from a child under 13 without legally required parental consent. If you believe a child has provided information, contact us so we can investigate and take appropriate action.

Cookies, controls and browser signals

Our Cookie Policy explains storage and tracking technologies in detail. Visitors in regions requiring prior consent are asked before optional analytics or advertising technologies load. In other regions, regional defaults may permit those technologies while preserving the ability to opt out at any time. If location cannot be determined, we use the more privacy-protective opt-in default.

A browser’s Do Not Track setting is not a uniform legal signal. We respond to Global Privacy Control where required and apply it to advertising technologies in that browser.

Changes and contact

We may update this Notice to reflect changes in law, technology, providers or business practices. Material changes will be presented with an updated effective date and any additional notice required by law.

Privacy questions and requests may be sent to Passback Inc. at info@soolra.com. Include enough information for us to understand the request, but do not email passwords or full payment-card details.