END USER LICENSE AGREEMENT (EULA)
TERMS OF USE — PASSLOCALS
PassLocals OOD, UIC 208651716
Business location: Varna, Bulgaria
Email: legal@passlocals.com | support@passlocals.com
Document version: 1.0 (MVP/Beta)
Effective date: 12.05.2026
1. INTRODUCTORY PROVISIONS
1.1 These Terms of Use ("Terms") of PassLocals OOD, legal entity identification code (UIC) 208651716, Varna, Bulgaria ("PassLocals" or the "Company"), govern the mutual rights and obligations of the parties arising in connection with the purchase of a PassLocals NFC card set ("Product"), the use of the PassLocals mobile application ("Application"), and related materials (collectively, the "Service"). The Terms are binding on all users of the Service ("User").
1.2 By using the Service or placing an order on the Company's website, the User confirms that they have read and understood these Terms and accept them unconditionally. If the User does not agree with the Terms or any part thereof, they must immediately cease using the Service and refrain from placing an order.
1.3 PassLocals may unilaterally amend these Terms at any time. The current version of the Terms is published on the Company's website. The User is solely responsible for monitoring changes to the Terms by periodically consulting the current version on the website. Continued use of the Service after amendments take effect constitutes acceptance of the revised Terms.
1.4 The Service is intended exclusively for natural persons aged 18 or over who use it for personal purposes. Use of the Service in the course of business activity, for commercial purposes, or on behalf of a legal entity is not permitted. For corporate use, PassLocals plans to release a separate product with an appropriate licence.
1.5 These Terms are drawn up in Russian and English. In the event of any discrepancy between the language versions, the English version shall prevail, unless otherwise required by applicable law.
1.6 These Terms are governed by the laws of the Republic of Bulgaria. The choice of governing law does not deprive a User who is a consumer of the protection afforded by the mandatory provisions of the law of their country of habitual residence.
2. PRODUCT DESCRIPTION
2.1 The Company offers for sale the PassLocals set, which includes:
● three (3) PassLocals NFC cards intended for use with the Application;
● packaging;
● a reminder insert regarding the mandatory configuration of a backup device, with a QR code linking to the instructions page on the Company's website.
2.2 PassLocals NFC cards are passive data carriers and do not contain any pre-installed user data. All data is written to the cards exclusively by the User using the Application.
2.3 PassLocals cards work exclusively with the PassLocals Application. Use of the cards with any other application or software is not supported.
2.4 Product photographs and images on the website are for illustrative purposes only. The actual appearance of the packaging may differ slightly from the images shown on the website.
3. PLACING AN ORDER AND CONCLUSION OF CONTRACT
3.1 To place an order, the User selects the Product on the website and proceeds to checkout. When placing an order, the User provides the required information: first name, last name, delivery address, email address, and selects a payment method.
3.2 After an order is placed, the User receives an automatic acknowledgement of receipt. This acknowledgement does not constitute the conclusion of a contract of sale.
3.3 The contract of sale is deemed concluded at the moment the Company confirms acceptance of the order for fulfilment, which is sent to the User following successful receipt of payment. From that moment, the Company is obliged to deliver the Product to the User, and the User is obliged to pay for the Product.
3.4 The Company reserves the right to decline an order in the event of the Product being out of stock, the impossibility of delivery to the specified address, or the occurrence of other circumstances preventing fulfilment. In such cases, the Company notifies the User and refunds the amount paid in full.
3.5 The User may purchase a quantity of sets corresponding to their reasonable personal needs. Orders indicating an intention to resell the Product may be declined by the Company.
4. PRICE AND PAYMENT
4.1 The price of the Product is displayed on the Company's website at the time of placing the order. The price includes applicable taxes unless otherwise stated separately. Delivery costs are not included in the price of the Product and are displayed separately during checkout.
4.2 The Company reserves the right to change Product prices at any time. A price change after an order has been confirmed does not apply to already confirmed orders.
4.3 If a clearly erroneous price is displayed on the website (due to a technical error, typo, or other mistake), the Company reserves the right to cancel the order even after confirmation, notifying the User and refunding the amount paid in full.
4.4 4.4 Payment is processed through Stripe. Available payment methods may vary depending on the User’s country, currency, card issuer, Stripe availability, and technical availability. The available payment methods are displayed during checkout.
The Company does not store full payment-card details on its own servers. Payment information is processed by Stripe in accordance with Stripe’s own terms and privacy practices. The list of available payment methods may vary depending on the User's country and is displayed on the payment page during checkout.
4.5 The User’s payment obligation is considered fulfilled when Stripe confirms successful payment or when funds are otherwise credited according to the selected payment method. The Company begins processing and dispatching the order after receiving payment confirmation.
5. DELIVERY
5.1 The Company delivers the Product using DHL or another courier service selected by the Company. Available delivery countries, delivery options, estimated delivery times, and delivery costs are displayed during checkout.
5.2 Order processing time is up to 5 (five) business days from the moment payment is confirmed. Delivery times depend on the destination country, courier service, customs procedures, holidays, and other circumstances outside the Company’s reasonable control. Delivery times are estimates unless expressly stated otherwise.
5.3 Once the Product has been dispatched, the User may receive a tracking number to monitor the shipment. For consumers, the risk of loss of or damage to the Product passes to the User when the User, or a third party indicated by the User other than the carrier, physically receives the Product, unless applicable law provides otherwise.
5.4 For deliveries outside the European Union, customs duties, import duties, VAT/GST, taxes, brokerage fees, and other charges may apply in accordance with the laws of the destination country. Unless expressly stated otherwise during checkout, such costs are borne by the User. The Company is not responsible for delays caused by customs clearance, import procedures, or local authorities, except where applicable law provides otherwise.
5.5 The User should inspect the Product upon receipt. If external damage to the packaging is discovered, the User should photograph the package and notify the Company’s support team at support@passlocals.com without undue delay. This does not limit any mandatory consumer rights relating to damaged, defective, or non-conforming goods.
6. RETURNS
6.1 The User has the right to withdraw from the purchase of a Product of satisfactory quality and return it within 14 (fourteen) calendar days of receipt, without giving any reason, in accordance with applicable consumer protection legislation.
6.2 A return is permitted only if all of the following conditions are met:
● the cards have not been activated (have not been used with the Application);
● the Product is returned in its original, undamaged packaging with all items included in the delivery;
● the reminder insert and all components of the set are intact.
6.3 To initiate a return, the User sends a request to support@passlocals.com stating the order number. The Company provides return instructions within 5 business days.
6.4 The cost of return postage is borne by the User. Customs duties and charges paid at the time of the original delivery are non-refundable.
6.5 Upon receipt and inspection of the returned Product, the Company refunds the cost of the Product within 14 calendar days using the same payment method that was used for the original purchase.
6.6 Because activated cards may be cryptographically bound to the User’s device and may contain or have contained encrypted confidential information, they may no longer be suitable for resale or redistribution. Where permitted by applicable law, activation, writing data to the cards, missing components, damaged packaging, or use beyond what is necessary to inspect the Product may result in refusal of a change-of-mind return or a deduction from the refund for diminished value. This does not affect mandatory consumer rights relating to defective, damaged, or non-conforming goods. Defect and warranty claims relating to activated cards are assessed in accordance with Section 8.2.
7. WARRANTY
7.1 The Company provides a warranty on PassLocals NFC cards for a period of 12 (twelve) months from the date of the User's receipt of the Product. The warranty covers manufacturing defects in materials and workmanship only.
7.2 Warranty and defect claims relating to activated cards are subject to the post-activation assessment limitations described in Section 8.2. The Company may request reasonable external evidence of the issue, including photographs, videos, device and app information, compatibility information, physical inspection, a non-sensitive diagnostic report where available, and the User’s description of the issue. The Company will not request access to the User’s master passphrase, decrypted records, passwords, seed phrases, secure notes, or other confidential content.
7.3 To submit a warranty claim, the User must:
● send a request to support@passlocals.com describing the defect and including photographs of the card;
● ship the defective card to the address provided by the Company at the User's own expense.
7.4 Upon receipt of the card, the Company inspects it within a reasonable time. If a manufacturing defect is confirmed, the Company sends the User a replacement at its own expense.
7.5 A monetary refund instead of replacement is issued only if the Company is unable to provide a replacement.
7.6 The warranty does not cover:
● mechanical damage to the card (cracks, breaks, deformation);
● damage caused by exposure to moisture, chemicals, or extreme temperatures;
● demagnetisation caused by exposure to strong magnetic fields;
● defects arising from use of the card other than for its intended purpose or in violation of the Company's instructions;
● normal wear and tear.
7.7 After the 12-month commercial warranty period ends, the User may still have mandatory statutory rights where applicable.
8. SERVICE DESCRIPTION AND PRODUCT STATUS
8.1 PassLocals is an offline password and confidential data management system based on NFC cards. All data is stored exclusively on PassLocals NFC cards in encrypted form. The Company has no access to the User's data, does not store it on its own servers, and does not transfer it to third parties in the course of providing the core functionality of the Service.
8.2 Post-activation assessment limitation. Due to the security architecture of PassLocals, after a card is activated, the Company cannot access, decrypt, inspect, restore, or verify the User’s stored content or all actions performed by the User. The Company may therefore be unable to determine with certainty whether a malfunction, inaccessible data, or unusable card state was caused by a manufacturing defect, incorrect setup, unsupported device, third-party software, loss of credentials, physical damage, or another post-delivery event. Warranty and defect claims relating to activated cards will be assessed on the basis of available external evidence only, such as photographs, videos, physical inspection, device and app information, compatibility checks, non-sensitive diagnostic reports, and the User’s description of the issue. The Company is not responsible for issues caused by misuse, incorrect setup, unsupported use, failure to follow instructions, failure to maintain backups, loss of master passphrase, loss of cards or devices, unauthorised modification, third-party software, or physical damage, except where liability cannot be excluded under applicable law. Nothing in this clause limits mandatory consumer rights relating to defective or non-conforming goods.
8.3 Product status. The current version of the Service is an MVP (Minimum Viable Product) / beta release, meaning it is in active development:
• the Application's functionality is regularly expanded and improved;
• the Company makes every reasonable effort to ensure the stable operation of the Service, but cannot guarantee it on all supported devices and operating system versions at this stage;
• certain features of the Application may be updated as new versions are released.
The User accepts the current status of the product and understands that the use of a beta version is subject to the limitations ordinarily associated with this stage of development.
9. INSTALLATION AND GETTING STARTED
9.1 The PassLocals Application is distributed through official app stores (App Store, Google Play). Installation of the Application is free of charge unless otherwise stated in the description of the specific version in the app store.
9.2 The User does not need to create an account on the Company's servers to use the Service. The Application operates entirely offline. Device registration within the PassLocals system is performed locally on the device itself and is linked to a unique installation identifier.
9.3 On first launch, the Application assigns a unique identifier to the device. This identifier is used in the cryptographic operations that bind the card to the device and cannot be transferred to another device.
9.4 To begin using the Service, the User must complete the initial setup using a PassLocals NFC card in accordance with the instructions provided on the Company's website.
9.5 The User is solely responsible for keeping the master passphrase ("master passphrase") confidential; the master passphrase is set during the configuration of the Master role. The Company has no access to the master passphrase and cannot recover the User's data if it is lost. The master passphrase is not transmitted to or stored on the Company's servers.
10. ROLE SYSTEM AND FUNCTIONALITY
10.1 PassLocals implements a four-tier role-based access model. A role is assigned to a specific device and written to the NFC card as an encrypted file (blob) that is cryptographically bound to both the card and the device. A single physical card stores all blob files for all roles issued to different devices. To maintain separate, independent datasets (for example, personal data and family data), separate sets of cards must be used, each with its own master passphrase. The available roles are:
● Master — full access to data, role management, creation and editing of records;
● Reader — read-only access; data is available in decrypted form, but no changes can be written;
● Assistant — update-only access without data disclosure ("blind" update); the Assistant has no access to the content of records;
● Reserve Master — acts as an Assistant until the master passphrase is entered, at which point it acquires full Master rights; intended for emergency data recovery.
10.2 The User is solely responsible for the correct assignment of roles and for providing the corresponding cards to authorised persons. The Company is not liable for unauthorised access to data resulting from improper management of roles or physical card media.
10.3 Granting a device both read and update access requires separate assignment of the Reader and Assistant roles, each of which is written to the card as a distinct blob file.
11. MANDATORY BACKUP REQUIREMENTS
11.1 The User must create a minimum of two (2) identical backup NFC cards and store them in different physical locations. Creating three (3) backup cards is recommended. This requirement is critical to the use of the Service, as all data is stored exclusively on physical media with no duplication on the Company's servers.
11.2 The User must assign at least one Reserve Master role to a separate physical device other than the device used as the primary device.
11.3 Loss of all card copies or of all devices with assigned Master / Reserve Master roles will result in the irreversible loss of all stored data. The Company is not liable for data loss resulting from the User's failure to comply with the requirements of this section.
12. VERSION VERIFICATION AND RECEIPTS
12.1 When backup cards are updated via the Assistant role, the Application generates a receipt — a file confirming that data has been written to the card and containing the version of the written blob.
12.2 The User acting as Master is required to verify the receipt after every backup card update by loading it into the Application. The "Outgoing Updates" badge is cleared only after the receipt generated by the updated card has been successfully loaded.
12.3 The Company is not liable for data loss or corruption resulting from the User's failure to follow the receipt verification procedure.
13. APPLICATION LICENCE
13.1 The Company grants the User a non-exclusive, non-transferable, limited licence to use the Application solely for personal purposes in accordance with these Terms.
13.2 This licence does not include the right to copy, modify, decompile, disassemble, distribute, or create derivative works based on the Application.
13.3 The licence terminates automatically if the User breaches these Terms.
14. LIMITATION OF LIABILITY
14.1 The Service is provided "as is" and "as available" without any express or implied warranties, including but not limited to warranties of merchantability, fitness for a particular purpose, uninterrupted operation, or freedom from errors.
14.2 The Company is not liable for:
● data loss due to physical damage, demagnetisation, theft, or loss of cards;
● data loss due to loss of the master passphrase;
● data loss due to the User's failure to comply with the requirements of Section 11;
● Application failures caused by incompatibility with a specific device or operating system version;
● unauthorised access to the User's data resulting from compromise of the User's device;
● delivery delays caused by the courier service or customs authorities;
● indirect, incidental, special, punitive, or consequential damages.
14.3 The Company's total liability to the User shall not exceed the amount actually paid by the User for the Product, or EUR 50, whichever is greater.
15. PERSONAL DATA PROTECTION
15.1 As the Application operates entirely offline, the Company has no access to the data stored on the User's NFC cards.
15.2 The Company may process certain categories of the User's data (delivery address, email address provided when contacting support) in accordance with the PassLocals Privacy Policy published on the Company's website.
15.3 The processing of personal data is carried out in accordance with the GDPR (for users in the EU) and the CCPA (for users in the state of California, USA).
15.4 Requests regarding personal data may be submitted to: legal@passlocals.com.
16. INTELLECTUAL PROPERTY
16.1 All rights to the Application, source code, design, trademarks, and logos of PassLocals belong to PassLocals OOD.
16.2 The User may not use the PassLocals name, logo, or trademarks without the prior written consent of the Company.
17. DISPUTE RESOLUTION
17.1 Claims may be submitted to: legal@passlocals.com. The Company will consider requests within a period not exceeding 30 (thirty) calendar days.
17.2 If the parties are unable to resolve the dispute out of court, it shall be referred to the courts at the Company's place of registration (Varna, Bulgaria) in accordance with the laws of the Republic of Bulgaria.
17.3 Users who are consumers in the European Union may refer to the European Commission's online dispute resolution platform at: https://ec.europa.eu/consumers/odr/
18. GENERAL PROVISIONS
18.1 If any provision of these Terms is found to be invalid, this shall not affect the validity of the remaining provisions.
18.2 These Terms constitute the entire agreement between the User and the Company and supersede all prior arrangements on this subject matter.
18.3 The Company is not liable for any breach of the Terms caused by circumstances of force majeure beyond its reasonable control.
18.4 The Company's failure to act in respect of a breach of these Terms does not constitute a waiver of its right to take action in respect of subsequent breaches.
19. CONTACT INFORMATION
● Support enquiries: support@passlocals.com
● Legal enquiries: legal@passlocals.com
● Website: passlocals.com
PassLocals OOD UIC 208651716 Varna, Bulgaria
These Terms of Use are valid and take effect from 12.05.2026
PassLocals OOD, UIC 208651716
Business location: Varna, Bulgaria
Email: legal@passlocals.com | support@passlocals.com
Document version: 1.0 (MVP/Beta)
Effective date: 12.05.2026
1. INTRODUCTORY PROVISIONS
1.1 These Terms of Use ("Terms") of PassLocals OOD, legal entity identification code (UIC) 208651716, Varna, Bulgaria ("PassLocals" or the "Company"), govern the mutual rights and obligations of the parties arising in connection with the purchase of a PassLocals NFC card set ("Product"), the use of the PassLocals mobile application ("Application"), and related materials (collectively, the "Service"). The Terms are binding on all users of the Service ("User").
1.2 By using the Service or placing an order on the Company's website, the User confirms that they have read and understood these Terms and accept them unconditionally. If the User does not agree with the Terms or any part thereof, they must immediately cease using the Service and refrain from placing an order.
1.3 PassLocals may unilaterally amend these Terms at any time. The current version of the Terms is published on the Company's website. The User is solely responsible for monitoring changes to the Terms by periodically consulting the current version on the website. Continued use of the Service after amendments take effect constitutes acceptance of the revised Terms.
1.4 The Service is intended exclusively for natural persons aged 18 or over who use it for personal purposes. Use of the Service in the course of business activity, for commercial purposes, or on behalf of a legal entity is not permitted. For corporate use, PassLocals plans to release a separate product with an appropriate licence.
1.5 These Terms are drawn up in Russian and English. In the event of any discrepancy between the language versions, the English version shall prevail, unless otherwise required by applicable law.
1.6 These Terms are governed by the laws of the Republic of Bulgaria. The choice of governing law does not deprive a User who is a consumer of the protection afforded by the mandatory provisions of the law of their country of habitual residence.
2. PRODUCT DESCRIPTION
2.1 The Company offers for sale the PassLocals set, which includes:
● three (3) PassLocals NFC cards intended for use with the Application;
● packaging;
● a reminder insert regarding the mandatory configuration of a backup device, with a QR code linking to the instructions page on the Company's website.
2.2 PassLocals NFC cards are passive data carriers and do not contain any pre-installed user data. All data is written to the cards exclusively by the User using the Application.
2.3 PassLocals cards work exclusively with the PassLocals Application. Use of the cards with any other application or software is not supported.
2.4 Product photographs and images on the website are for illustrative purposes only. The actual appearance of the packaging may differ slightly from the images shown on the website.
3. PLACING AN ORDER AND CONCLUSION OF CONTRACT
3.1 To place an order, the User selects the Product on the website and proceeds to checkout. When placing an order, the User provides the required information: first name, last name, delivery address, email address, and selects a payment method.
3.2 After an order is placed, the User receives an automatic acknowledgement of receipt. This acknowledgement does not constitute the conclusion of a contract of sale.
3.3 The contract of sale is deemed concluded at the moment the Company confirms acceptance of the order for fulfilment, which is sent to the User following successful receipt of payment. From that moment, the Company is obliged to deliver the Product to the User, and the User is obliged to pay for the Product.
3.4 The Company reserves the right to decline an order in the event of the Product being out of stock, the impossibility of delivery to the specified address, or the occurrence of other circumstances preventing fulfilment. In such cases, the Company notifies the User and refunds the amount paid in full.
3.5 The User may purchase a quantity of sets corresponding to their reasonable personal needs. Orders indicating an intention to resell the Product may be declined by the Company.
4. PRICE AND PAYMENT
4.1 The price of the Product is displayed on the Company's website at the time of placing the order. The price includes applicable taxes unless otherwise stated separately. Delivery costs are not included in the price of the Product and are displayed separately during checkout.
4.2 The Company reserves the right to change Product prices at any time. A price change after an order has been confirmed does not apply to already confirmed orders.
4.3 If a clearly erroneous price is displayed on the website (due to a technical error, typo, or other mistake), the Company reserves the right to cancel the order even after confirmation, notifying the User and refunding the amount paid in full.
4.4 4.4 Payment is processed through Stripe. Available payment methods may vary depending on the User’s country, currency, card issuer, Stripe availability, and technical availability. The available payment methods are displayed during checkout.
The Company does not store full payment-card details on its own servers. Payment information is processed by Stripe in accordance with Stripe’s own terms and privacy practices. The list of available payment methods may vary depending on the User's country and is displayed on the payment page during checkout.
4.5 The User’s payment obligation is considered fulfilled when Stripe confirms successful payment or when funds are otherwise credited according to the selected payment method. The Company begins processing and dispatching the order after receiving payment confirmation.
5. DELIVERY
5.1 The Company delivers the Product using DHL or another courier service selected by the Company. Available delivery countries, delivery options, estimated delivery times, and delivery costs are displayed during checkout.
5.2 Order processing time is up to 5 (five) business days from the moment payment is confirmed. Delivery times depend on the destination country, courier service, customs procedures, holidays, and other circumstances outside the Company’s reasonable control. Delivery times are estimates unless expressly stated otherwise.
5.3 Once the Product has been dispatched, the User may receive a tracking number to monitor the shipment. For consumers, the risk of loss of or damage to the Product passes to the User when the User, or a third party indicated by the User other than the carrier, physically receives the Product, unless applicable law provides otherwise.
5.4 For deliveries outside the European Union, customs duties, import duties, VAT/GST, taxes, brokerage fees, and other charges may apply in accordance with the laws of the destination country. Unless expressly stated otherwise during checkout, such costs are borne by the User. The Company is not responsible for delays caused by customs clearance, import procedures, or local authorities, except where applicable law provides otherwise.
5.5 The User should inspect the Product upon receipt. If external damage to the packaging is discovered, the User should photograph the package and notify the Company’s support team at support@passlocals.com without undue delay. This does not limit any mandatory consumer rights relating to damaged, defective, or non-conforming goods.
6. RETURNS
6.1 The User has the right to withdraw from the purchase of a Product of satisfactory quality and return it within 14 (fourteen) calendar days of receipt, without giving any reason, in accordance with applicable consumer protection legislation.
6.2 A return is permitted only if all of the following conditions are met:
● the cards have not been activated (have not been used with the Application);
● the Product is returned in its original, undamaged packaging with all items included in the delivery;
● the reminder insert and all components of the set are intact.
6.3 To initiate a return, the User sends a request to support@passlocals.com stating the order number. The Company provides return instructions within 5 business days.
6.4 The cost of return postage is borne by the User. Customs duties and charges paid at the time of the original delivery are non-refundable.
6.5 Upon receipt and inspection of the returned Product, the Company refunds the cost of the Product within 14 calendar days using the same payment method that was used for the original purchase.
6.6 Because activated cards may be cryptographically bound to the User’s device and may contain or have contained encrypted confidential information, they may no longer be suitable for resale or redistribution. Where permitted by applicable law, activation, writing data to the cards, missing components, damaged packaging, or use beyond what is necessary to inspect the Product may result in refusal of a change-of-mind return or a deduction from the refund for diminished value. This does not affect mandatory consumer rights relating to defective, damaged, or non-conforming goods. Defect and warranty claims relating to activated cards are assessed in accordance with Section 8.2.
7. WARRANTY
7.1 The Company provides a warranty on PassLocals NFC cards for a period of 12 (twelve) months from the date of the User's receipt of the Product. The warranty covers manufacturing defects in materials and workmanship only.
7.2 Warranty and defect claims relating to activated cards are subject to the post-activation assessment limitations described in Section 8.2. The Company may request reasonable external evidence of the issue, including photographs, videos, device and app information, compatibility information, physical inspection, a non-sensitive diagnostic report where available, and the User’s description of the issue. The Company will not request access to the User’s master passphrase, decrypted records, passwords, seed phrases, secure notes, or other confidential content.
7.3 To submit a warranty claim, the User must:
● send a request to support@passlocals.com describing the defect and including photographs of the card;
● ship the defective card to the address provided by the Company at the User's own expense.
7.4 Upon receipt of the card, the Company inspects it within a reasonable time. If a manufacturing defect is confirmed, the Company sends the User a replacement at its own expense.
7.5 A monetary refund instead of replacement is issued only if the Company is unable to provide a replacement.
7.6 The warranty does not cover:
● mechanical damage to the card (cracks, breaks, deformation);
● damage caused by exposure to moisture, chemicals, or extreme temperatures;
● demagnetisation caused by exposure to strong magnetic fields;
● defects arising from use of the card other than for its intended purpose or in violation of the Company's instructions;
● normal wear and tear.
7.7 After the 12-month commercial warranty period ends, the User may still have mandatory statutory rights where applicable.
8. SERVICE DESCRIPTION AND PRODUCT STATUS
8.1 PassLocals is an offline password and confidential data management system based on NFC cards. All data is stored exclusively on PassLocals NFC cards in encrypted form. The Company has no access to the User's data, does not store it on its own servers, and does not transfer it to third parties in the course of providing the core functionality of the Service.
8.2 Post-activation assessment limitation. Due to the security architecture of PassLocals, after a card is activated, the Company cannot access, decrypt, inspect, restore, or verify the User’s stored content or all actions performed by the User. The Company may therefore be unable to determine with certainty whether a malfunction, inaccessible data, or unusable card state was caused by a manufacturing defect, incorrect setup, unsupported device, third-party software, loss of credentials, physical damage, or another post-delivery event. Warranty and defect claims relating to activated cards will be assessed on the basis of available external evidence only, such as photographs, videos, physical inspection, device and app information, compatibility checks, non-sensitive diagnostic reports, and the User’s description of the issue. The Company is not responsible for issues caused by misuse, incorrect setup, unsupported use, failure to follow instructions, failure to maintain backups, loss of master passphrase, loss of cards or devices, unauthorised modification, third-party software, or physical damage, except where liability cannot be excluded under applicable law. Nothing in this clause limits mandatory consumer rights relating to defective or non-conforming goods.
8.3 Product status. The current version of the Service is an MVP (Minimum Viable Product) / beta release, meaning it is in active development:
• the Application's functionality is regularly expanded and improved;
• the Company makes every reasonable effort to ensure the stable operation of the Service, but cannot guarantee it on all supported devices and operating system versions at this stage;
• certain features of the Application may be updated as new versions are released.
The User accepts the current status of the product and understands that the use of a beta version is subject to the limitations ordinarily associated with this stage of development.
9. INSTALLATION AND GETTING STARTED
9.1 The PassLocals Application is distributed through official app stores (App Store, Google Play). Installation of the Application is free of charge unless otherwise stated in the description of the specific version in the app store.
9.2 The User does not need to create an account on the Company's servers to use the Service. The Application operates entirely offline. Device registration within the PassLocals system is performed locally on the device itself and is linked to a unique installation identifier.
9.3 On first launch, the Application assigns a unique identifier to the device. This identifier is used in the cryptographic operations that bind the card to the device and cannot be transferred to another device.
9.4 To begin using the Service, the User must complete the initial setup using a PassLocals NFC card in accordance with the instructions provided on the Company's website.
9.5 The User is solely responsible for keeping the master passphrase ("master passphrase") confidential; the master passphrase is set during the configuration of the Master role. The Company has no access to the master passphrase and cannot recover the User's data if it is lost. The master passphrase is not transmitted to or stored on the Company's servers.
10. ROLE SYSTEM AND FUNCTIONALITY
10.1 PassLocals implements a four-tier role-based access model. A role is assigned to a specific device and written to the NFC card as an encrypted file (blob) that is cryptographically bound to both the card and the device. A single physical card stores all blob files for all roles issued to different devices. To maintain separate, independent datasets (for example, personal data and family data), separate sets of cards must be used, each with its own master passphrase. The available roles are:
● Master — full access to data, role management, creation and editing of records;
● Reader — read-only access; data is available in decrypted form, but no changes can be written;
● Assistant — update-only access without data disclosure ("blind" update); the Assistant has no access to the content of records;
● Reserve Master — acts as an Assistant until the master passphrase is entered, at which point it acquires full Master rights; intended for emergency data recovery.
10.2 The User is solely responsible for the correct assignment of roles and for providing the corresponding cards to authorised persons. The Company is not liable for unauthorised access to data resulting from improper management of roles or physical card media.
10.3 Granting a device both read and update access requires separate assignment of the Reader and Assistant roles, each of which is written to the card as a distinct blob file.
11. MANDATORY BACKUP REQUIREMENTS
11.1 The User must create a minimum of two (2) identical backup NFC cards and store them in different physical locations. Creating three (3) backup cards is recommended. This requirement is critical to the use of the Service, as all data is stored exclusively on physical media with no duplication on the Company's servers.
11.2 The User must assign at least one Reserve Master role to a separate physical device other than the device used as the primary device.
11.3 Loss of all card copies or of all devices with assigned Master / Reserve Master roles will result in the irreversible loss of all stored data. The Company is not liable for data loss resulting from the User's failure to comply with the requirements of this section.
12. VERSION VERIFICATION AND RECEIPTS
12.1 When backup cards are updated via the Assistant role, the Application generates a receipt — a file confirming that data has been written to the card and containing the version of the written blob.
12.2 The User acting as Master is required to verify the receipt after every backup card update by loading it into the Application. The "Outgoing Updates" badge is cleared only after the receipt generated by the updated card has been successfully loaded.
12.3 The Company is not liable for data loss or corruption resulting from the User's failure to follow the receipt verification procedure.
13. APPLICATION LICENCE
13.1 The Company grants the User a non-exclusive, non-transferable, limited licence to use the Application solely for personal purposes in accordance with these Terms.
13.2 This licence does not include the right to copy, modify, decompile, disassemble, distribute, or create derivative works based on the Application.
13.3 The licence terminates automatically if the User breaches these Terms.
14. LIMITATION OF LIABILITY
14.1 The Service is provided "as is" and "as available" without any express or implied warranties, including but not limited to warranties of merchantability, fitness for a particular purpose, uninterrupted operation, or freedom from errors.
14.2 The Company is not liable for:
● data loss due to physical damage, demagnetisation, theft, or loss of cards;
● data loss due to loss of the master passphrase;
● data loss due to the User's failure to comply with the requirements of Section 11;
● Application failures caused by incompatibility with a specific device or operating system version;
● unauthorised access to the User's data resulting from compromise of the User's device;
● delivery delays caused by the courier service or customs authorities;
● indirect, incidental, special, punitive, or consequential damages.
14.3 The Company's total liability to the User shall not exceed the amount actually paid by the User for the Product, or EUR 50, whichever is greater.
15. PERSONAL DATA PROTECTION
15.1 As the Application operates entirely offline, the Company has no access to the data stored on the User's NFC cards.
15.2 The Company may process certain categories of the User's data (delivery address, email address provided when contacting support) in accordance with the PassLocals Privacy Policy published on the Company's website.
15.3 The processing of personal data is carried out in accordance with the GDPR (for users in the EU) and the CCPA (for users in the state of California, USA).
15.4 Requests regarding personal data may be submitted to: legal@passlocals.com.
16. INTELLECTUAL PROPERTY
16.1 All rights to the Application, source code, design, trademarks, and logos of PassLocals belong to PassLocals OOD.
16.2 The User may not use the PassLocals name, logo, or trademarks without the prior written consent of the Company.
17. DISPUTE RESOLUTION
17.1 Claims may be submitted to: legal@passlocals.com. The Company will consider requests within a period not exceeding 30 (thirty) calendar days.
17.2 If the parties are unable to resolve the dispute out of court, it shall be referred to the courts at the Company's place of registration (Varna, Bulgaria) in accordance with the laws of the Republic of Bulgaria.
17.3 Users who are consumers in the European Union may refer to the European Commission's online dispute resolution platform at: https://ec.europa.eu/consumers/odr/
18. GENERAL PROVISIONS
18.1 If any provision of these Terms is found to be invalid, this shall not affect the validity of the remaining provisions.
18.2 These Terms constitute the entire agreement between the User and the Company and supersede all prior arrangements on this subject matter.
18.3 The Company is not liable for any breach of the Terms caused by circumstances of force majeure beyond its reasonable control.
18.4 The Company's failure to act in respect of a breach of these Terms does not constitute a waiver of its right to take action in respect of subsequent breaches.
19. CONTACT INFORMATION
● Support enquiries: support@passlocals.com
● Legal enquiries: legal@passlocals.com
● Website: passlocals.com
PassLocals OOD UIC 208651716 Varna, Bulgaria
These Terms of Use are valid and take effect from 12.05.2026
