DDPP
Language: EN
Create account

Privacy Policy

Effective 19 September 2026. Updated 24 September 2026: payments for passport credits, cookies on the web Desk, and where the app sends what you scan. Updated 9 October 2026: who is responsible for the data of people in Türkiye, the Turkish KVKK notice, and Google Analytics, which runs only if you accept it (section 14). Updated 10 October 2026: passport credits bought in the DDPP app, through the App Store or Google Play (sections 4, 5, 6, 8, 9, 10 and 11). Updated 11 October 2026: the documents a business sends for DDPP's check of it, and the EU's VAT register, VIES (sections 4, 5, 6, 8 and 10). Updated 15 October 2026: NFC in the app, and the NFC tags and cards that lead to a passport (section 2). Updated 17 October 2026: an encrypted copy of our backups on a second server in Germany (sections 8, 9 and 15). Updated 17 October 2026: printed NFC cards and tags ordered from DDPP (sections 1, 4, 5, 6, 8, 9, 10, 11 and 14). Updated 22 October 2026: onboarding packages ordered from DDPP (sections 1, 4, 5, 6, 8, 10, 11 and 14). Updated 4 November 2026: passport credits bought on the web by organizations in Türkiye, which ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş. sells (sections 1, 4, 5, 6, 8, 9, 10, 11 and 14). Updated 6 November 2026: the encrypted copy of our backups is now on a second server in France (sections 8, 9 and 15).

This Privacy Policy explains how DDPP (Decentralized Digital Product Passport) uses personal data about the people it deals with: people who sign in to write product passports for an organization, people who scan and read passports, visitors to ddppeu.com and its earlier address dppeu.cloud, and people who write to us.

DDPP is a service for businesses. An organization records its products in the DDPP app and publishes a product passport for a model, a batch or a single item, which anyone can open by scanning its QR code or NFC tag.

In this policy, "you" means the person the data is about. An "organization" is a business set up in DDPP, and a "member" is a person with their own sign-in who acts for an organization. "We", "us" and "our" mean the two companies behind DDPP, ZincirX Inc. and ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş.; section 1 explains which of them is responsible for your data.

This policy gives the information required by Articles 13 and 14 of the EU General Data Protection Regulation (GDPR). If you are in Türkiye, our Turkish notice under Law No. 6698 (KVKK Aydınlatma Metni), at ddppeu.com/tr/kvkk, explains how ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş. processes your personal data and how to exercise your rights.

How organizations may use DDPP is set out in our Terms of Service.

1. Who is responsible for your data

ZincirX Inc., a corporation established in the State of Delaware, United States, with its address at c/o Legalinc Corporate Services Inc., 131 Continental Drive, Suite 305, Newark, DE 19713, United States, is the controller of the personal data this policy describes. For people in Türkiye, the controller is ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş., as explained below.

DDPP is operated for it by ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş., a joint-stock company established in Türkiye, at Gülbahçe Mah. Gülbahçe Cad. İYTE Sitesi No: 1/40 İç Kapı No: 51, 35430 Urla/İzmir, Türkiye. Its people build and run the service and can reach personal data in the course of that work, as a processor acting on ZincirX Inc.'s instructions. It does so under a data processing agreement between the two companies. The registration details of both companies are on our Legal Notice.

If you are in Türkiye, ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş. is the controller (veri sorumlusu) of your personal data under Türkiye's Law No. 6698 (KVKK), except for the records of the purchases of passport credits that ZincirX Inc. sells, which it keeps as the seller and controls. Our Turkish KVKK information notice (KVKK Aydınlatma Metni) sets this out. The two companies are separate controllers, not joint controllers.

Printed NFC cards and tags ordered from DDPP are sold to organizations in Türkiye by ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş., and to all other organizations by ZincirX Inc. Each keeps the records of the orders it sells, as the seller, and controls them. ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş. makes and sends all of them; for the orders ZincirX Inc. sells, it does so as the processor that operates DDPP for ZincirX Inc.

Onboarding packages for battery passports are sold in the same way: to organizations in Türkiye by ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş., and to all other organizations by ZincirX Inc. Each keeps the records of the orders it sells, as the seller, and controls them.

Passport credits bought on the web, in the Desk, are sold in the same way: to organizations in Türkiye by ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş., and to all other organizations by ZincirX Inc. Each keeps the records of the credits it sells, as the seller, and controls them.

For the content organizations put into DDPP, such as their products and passports, we act for the organization instead. Section 2 explains how.

For any question about this policy or your data, write to dpp@dppeu.cloud, call +90 536 587 41 81, or write to the address above. We have not appointed a data protection officer; privacy questions go to the people who handle them.

2. When we act for organizations

Organizations use DDPP to keep and publish their own product records: products and their data, passports, certifications and documents, events, with their descriptions, places, positions and photos, and the NFC tags and cards that lead to a passport.

The organization decides what goes into these records and what is published, so it is the controller of any personal data in them, and we process that data on its behalf, as its processor, under section 19 of our Terms of Service. We process it only to provide DDPP to the organization and on its instructions. We do not sell it, and we do not use it for purposes of our own.

The DDPP app uses your phone's camera, location and photos only with your permission:

The photos and positions you add become part of the organization's records.

The app also uses NFC, and only when you choose to read a tag or card or to write a passport's link to one. When it writes a passport's link to a chip, or reads a passport card's chip to set the card up, DDPP records the chip's ID with the passport and the member who did it, as part of the organization's records.

If your personal data appears in an organization's records, for example because you appear in a photo or your name is in a document, the organization decides how it is used. Please contact that business. If you contact us instead, we will pass your request to it and help it respond.

3. Public passport pages

When an organization publishes a passport, anyone who scans its code, opens its link or looks it up by the product's GS1 identifiers can see its public part, as a web page and in machine-readable form. Fields the organization's data marks as restricted or authority-only are not shown there.

The public part is the manufacturer's own record of its product. Organizations must not publish the personal data of consumers, meaning the people who buy or use their products, without those people's explicit consent, and should keep other personal data, such as the names of individual workers or positions that reveal where someone lives, off the public part.

After a passport is published, changes to its data are added as new revisions and earlier revisions are kept, and its events can only be added to. Where personal data in a published passport has to be corrected or removed, including from its earlier revisions, the organization can ask us at dpp@dppeu.cloud and we will do it.

A published passport stays online until the organization withdraws it. Its address then shows only that it was withdrawn.

We do not record who opens a passport page beyond the ordinary server logs described in section 10, and passport pages set no cookies.

If you believe a passport page contains illegal content, use the "Report this page" link on it, or write to dpp@dppeu.cloud with the page's address. A person reviews every report. Our Terms of Service explain what happens next.

4. The personal data we collect

As controller, we collect the following:

We use no advertising tools. Google Analytics runs only if you accept analytics cookies; section 14 says what it collects.

5. Where the data comes from

Most of it comes from you, when you sign up, set up an organization or write to us. Technical data is collected automatically with each request. If you sign in with Google or Apple, that provider gives us an account identifier and, depending on your settings, your email address and name. When an organization buys credits, Stripe or, for an organization in Türkiye, ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş.'s payment page at zincirx.com tells us whether the payment went through, and whether it was later refunded or disputed. When credits are bought in the app, Apple or Google confirms the purchase to us, and tells us if it is later refunded or revoked. When an organization in Türkiye pays for a print order, ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş.'s payment page at zincirx.com tells us whether the payment went through. For a business in the EU, the European Commission's VIES service tells us whether its VAT number is registered and, where the member state shares them, under which name and address. The delivery details of a print order come from the member who places it, who may name someone else as the person who receives the parcel. When an organization pays for an onboarding package, Stripe or, for an organization in Türkiye, ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş.'s payment page at zincirx.com tells us whether the payment went through and whether it was later refunded or disputed; a bank transfer is recorded by our staff when it arrives.

6. Why we use it and on what legal basis

For each purpose we give the legal basis under the GDPR and the processing condition under Article 5 of the KVKK.

Where we rely on legitimate interests, you can object, as section 12 explains. We make no decisions about anyone based solely on automated processing.

7. What you have to give us

To open an account you must give your name, an email address and a password, or sign in with Google or Apple. To set up an organization you must give its name and country, because every passport names the organization as the business responsible for the product. Without these we cannot provide DDPP. Everything else is optional.

8. Who we share it with

If you ask, we will tell you the names of the specific recipients of your personal data.

9. International transfers

ZincirX Inc. is in the United States, ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş. and the people who operate DDPP are in Türkiye, and DDPP's servers are in the European Union: in Lithuania, with an encrypted copy of the backups in France. Neither the United States nor Türkiye is in the European Economic Area, and the European Commission has adopted no general adequacy decision for either.

Where the GDPR applies, a transfer of personal data out of the European Economic Area is subject to Chapter V of the GDPR. When you sign in with Google or Apple, your data goes between your device and those companies under their own terms; Google LLC and Apple Inc. are certified under the EU–US Data Privacy Framework, for which the Commission adopted an adequacy decision in Implementing Decision (EU) 2023/1795. If you accept analytics cookies, Google Analytics data goes from your browser to Google LLC, which may process it in the United States (sections 8 and 14). When you buy credits for an organization outside Türkiye, your payment details go from your browser to Stripe, and the details section 8 lists go from us to Stripe. Stripe, Inc. is in the United States. Stripe's own privacy policy, at stripe.com/privacy, explains how Stripe handles payment details, the safeguards it uses when it transfers them and how long it keeps them. When you buy credits in the app, the purchase goes between your device and Apple or Google under their own terms, and Apple Inc. or Google LLC, both certified under the EU–US Data Privacy Framework, confirms it to us.

Personal data reaches Türkiye, where ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş. operates DDPP for us, and the United States, where ZincirX Inc. is.

Transfers of personal data out of Türkiye are subject to Article 9 of the KVKK, and we do not rely on your explicit consent for regular transfers abroad.

You can ask for details of these transfers by writing to dpp@dppeu.cloud.

For now, printed cards and tags are sent only to addresses in Türkiye, so their delivery details do not leave Türkiye.

10. How long we keep it

11. Deleting your account

You can delete your account in the DDPP app (open More, choose Delete my account and confirm) or on the web (the Desk, then Your account). The account is deleted at once. If you can use neither, write to dpp@dppeu.cloud from the email address of the account, and we will delete it within 30 days and confirm by email. The steps are also at ddppeu.com/delete-account.

When an account is deleted, we remove its name, email address, password, Google and Apple sign-in links, sign-in tokens, password reset links and memberships, and we revoke its Sign in with Apple authorization with Apple. Records the account created in an organization's content, such as products, passports, events and files, stay with the organization but no longer name the account.

Some records are kept:

12. Your rights

Depending on the law that applies to you, you have the right to:

To use any of these rights, write to dpp@dppeu.cloud or call +90 536 587 41 81. You can write in English, Turkish, German, Spanish, French, Italian, Dutch or Polish. We answer free of charge and without undue delay: under the GDPR within one month, which we may extend by two further months for complex requests, telling you why within the first month, and under the KVKK within 30 days. We ask for proof of identity only if we have reasonable doubts about who is asking. If we do not do what you ask, we tell you why and that you can complain to a supervisory authority or go to court.

For data an organization controls, such as the contents of a passport, we pass your request to that organization and help it respond.

13. Your rights under the KVKK

Under Article 11 of the KVKK, you have the right to:

You can apply in writing to the address in section 1, or by email to dpp@dppeu.cloud from the address you registered with us. We conclude applications free of charge within 30 days at the latest; if an action has a separate cost, we may charge the fee set by the Personal Data Protection Board. If we reject your application, you find our answer inadequate or we do not answer in time, you can complain to the Board within 30 days of learning of our answer, and in any case within 60 days of your application.

14. Cookies and storage on your device

You can change or withdraw your choice at any time with Cookie settings, a link at the bottom of every page of the site and of the Desk's sign-in and sign-up pages.

Strictly necessary (no consent needed)

We rely on the exemption for storage that is strictly necessary to provide the service you asked for.

Analytics, only with your consent

Only if you choose "Accept analytics" in the cookie notice, or switch Analytics on under Preferences, do the site's pages, the Desk's sign-in and sign-up pages and the page where a new account names its organization load Google Analytics 4, provided by Google LLC (USA), to count visits and see how they are used. It sets the cookies _ga and _ga_WM7TQV23M5, which are kept for up to 2 years. Google receives the address of the page you visit (without its query string, apart from campaign tags such as utm_source), the page you came from, your browser and device details and your IP address; if you create an account on the Desk, also that an account was made and how (email, Google or Apple), never your name or email address. Google may process this data in the USA; Google LLC is certified under the EU–US Data Privacy Framework. The measurements are kept in Google Analytics for at most 14 months. Without your consent the Google Analytics script is not loaded at all and nothing is sent to Google. Passport pages, the passport search at /find, GS1 Digital Links and the Desk's pages that show an organization's records never load it.

The legal basis for analytics cookies is your consent (GDPR Article 6(1)(a); for people in Türkiye, explicit consent under KVKK Article 5(1)). Withdrawing it is as easy as giving it: choose "Reject analytics" under Cookie settings, and Google Analytics stops and the _ga cookies we can reach are deleted. You can also delete cookies in your browser's settings. We use no advertising or marketing cookies.

15. Security

We protect personal data with measures that include encrypted connections (HTTPS, with TLS 1.3 and post-quantum key exchange where your browser supports it), passwords stored only as hashes, sign-in tokens that can be revoked, access limited by each member's role, a SHA-256 fingerprint on every uploaded file, a server environment separated from other services, and daily backups, with an encrypted copy on a second server in France. No system is completely secure. If you think your account has been misused, write to dpp@dppeu.cloud straight away.

16. Children

DDPP is a service for businesses and is not meant for children. We do not knowingly collect children's personal data. If you believe a child has given us personal data, please write to dpp@dppeu.cloud.

17. Changes to this policy

This version takes effect on 19 September 2026 and was last updated on 6 November 2026. We update the policy when DDPP or the law changes, and the date at the top shows the version in force. Before a significant change takes effect, we tell members by email. Before we use personal data for a new purpose, we will tell you.

18. Contact us

For questions about this policy or your personal data, write to dpp@dppeu.cloud or call +90 536 587 41 81. By post: ZincirX Inc., c/o Legalinc Corporate Services Inc., 131 Continental Drive, Suite 305, Newark, DE 19713, United States, or, in Türkiye, ZincirX Bilişim Teknoloji ve Danışmanlık A.Ş., Gülbahçe Mah. Gülbahçe Cad. İYTE Sitesi No: 1/40 İç Kapı No: 51, 35430 Urla/İzmir, Türkiye. Our full company details are on our Legal Notice.