Passes

Information you provide to us. Personal data is data that can be used to contact or identify you, such as your name, email address, phone number, etc. Personal data you may provide to us through our Services, or otherwise, includes:

Contact data, such as your first and last name, alias, email address, billing and mailing addresses, and phone number.
Profile data, such as the username and password that you may set to establish an online account with us, photograph, biographical information, links to your profiles on social networks, non-fungible token (“NFT”) holdings, digital wallet addresses, and any other information that you add to or is associated with your account profile.
Communications data, such as data that we exchange with you, including when you contact us with questions or feedback, through our Services, social media, or otherwise.
Payment and transactional data , such as data relating to, or needed to complete, your purchases on or through our Services (including payment card information and billing information) or to provide you with the funds from a sale on the platform, digital wallet information, and your purchase history.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them. User-generated content, such as photos, images, comments, questions, messages, and other content or information that you generate, transmit, or otherwise make available on our Services, as well as associated metadata.
Government-issued identification numbers, such as national identification number (e.g. Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card or any other data required for ‘Know Your Customer’ checks.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal data we receive from third party vendors and/or other commercially available sources with the personal data we collected. The third party sources from which we may receive personal data are:

Public sources, such as social media platforms and other publicly available sources.
Data providers, such as information services and data licensors that provide demographic and other information.
Third party vendors, such as service providers providing talent management services, fraud warnings, KYC or enrichment service providers to enhance and personalize your user experience.
Marketing partners, such as joint marketing partners and event co-sponsors.

If you choose to activate, access, or connect your account on or to a third-party platform or network, such as Facebook/Google/Twitter we may collect data from that platform or network, the data we collect may include your profile name, avatar, etc.

Automatic data collection. We may automatically collect data about you, your computer or mobile device while you access, browse, view or otherwise interact with our Services, the data we collect may include:

Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data on our Website , such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked on URLs that led you to our site.

Cookies and similar technologies. We use cookies and similar technologies (such as web beacons, pixels, tags and scripts) to improve and personalize your experience, provide our Services, analyze website performance and for marketing purposes. To learn more about how we use cookies and your control over these cookies, please see our Cookie Policy.

Data about others. Users of our Services may have the opportunity to refer friends or other contacts to us and share their contact data with us. Please do not refer someone to us, or share their contact data with us, unless you have their permission to do so.

We may use your personal data for the following purposes or as otherwise described at the time of collection:

Service delivery. We may use your personal data to:

develop, provide, operate and improve our Services and our business;
establish, maintain and service your user profile for our Services;
verify or maintain the quality or safety of the Services;
conduct Know Your Customer checks and other screens permitted by law when you set up an account;
verify your identity when you place a bid/purchase a NFT;
process your payments and complete transactions with you when you purchase or trade a NFT;
connect to your virtual wallet when you wish to add or withdraw funds from your virtual wallet;
facilitate invitations to friends who you want to invite to join our Services;
enable security features of our Services, such as (for example) by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages;
understand your needs and interests, and personalize your experience with our Services and our communications;
enable communication with other Service users; and
provide support for our Services, and contact you where requested or respond to your requests, questions and feedback.

Research and development. We may use your personal data for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified or anonymous data from personal data we collect. We make personal data into anonymous data by removing data that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Marketing and advertising.We may collect and use your personal data for marketing and advertising purposes:

Direct marketing. We may send you direct marketing communications about our products, services or promotions that may be of interest to you. Our processing of your personal data for marketing purposes is based on our legitimate interest, or on your consent, or as otherwise permitted by applicable laws. You have the right to prevent direct marketing of any form at any time, this right can be exercised by following the opt-out link attached to each communication or by sending an email to help@passes.com.
Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads on other online services. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) over time across our Services, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Advertising choices section below.

Compliance and protection. We may use your personal data to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
maintain appropriate business records;
enforce the terms and conditions that govern our Services;
and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal data, such as when required by law.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal data and other individuals whose personal data we collect. We make personal data into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve our Services, promote our business or marketing purposes.

We do not sell or rent your personal data to third parties for their marketing purposes without your explicit consent.

We may share your personal data with third parties as detailed below and as otherwise described in this Privacy Policy.

Affiliates. We may share your personal data with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Service providers. We share personal data with those third parties who provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).
Payment processors and fraud detection service providers. We share personal data with payment processors and fraud detection service providers for the purposes of facilitating payments done via the Services and securing the Services and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.
Advertising partners. We may share your personal data with third-party advertising companies for the interest-based advertising purposes described above. Data obtained through the Passes Messaging short code program will not be shared with any third-parties for their marketing reasons/purposes.
Creators. As a Creator, we may publicly identify you as a Creator with Passes, including in connection with our marketing and promotional materials. In addition, we may publicly share information related to your use and activity of the Services (including earnings, audience and viewership metrics, and other similar analytics); provided that we first aggregate that information with information from other Creators.
Third-party platforms and social media networks. Our Services may contain certain social media features, such as sharing content from Passes to external social media networks. If you have enabled features or functionality that connect our Services to a third-party platform or social media network (such as by linking your account to a third party’s services), we may disclose the personal data that you authorized us to share. We do not control the third party’s use of your personal data and such third party’s use will be in accordance with such party’s privacy policy. Professional advisors.
Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Government Agencies and regulators. We may share personal data with law enforcement agencies, public authorities or other parties: (i) in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; (ii) when we believe it necessary or appropriate to disclose personal data to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Privacy Policy; (iii) to respond to claims against us; and (iv) to protect the rights, property, or personal safety of Passes, our customers or the public.
In the context of a corporate transaction. Personal data may be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of Passes’ assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If all, or substantially all, of our assets are acquired by a third party, data held by us about our users will be one of the transferred assets.
Other users. Your personal data, such as your profile information and user-generated content and your email address may be visible to other users of our Services. For example, other users may have access to your profile or content through the course of your use of our Services, such as when you purchase an NFT. In addition, as a Fan, your email and other personal data that you have provided to Passes may be shared with each Creator to whom you subscribe. Where your personal data can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), we are not responsible for any such use of data.

You have the following choices with respect to your personal data.

Access or update your information. If you have registered for an account with us through our Services, you may review and update certain account information by logging into the account.

Delete your user data. If you wish to delete your user data, you can delete your account by visiting your Account Settings.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us through the contact details set out in the ‘How to contact us’ section below. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Advertising choices. You can limit use of your information for interest-based advertising by:

Browser settings. Blocking third-party cookies in your browser settings.
Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising:
- Google: https://www.adsettings.google.com
- Facebook: https://www.facebook.com/about/ads
Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
- Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance: optout.aboutads.info.
- AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.

You will need to apply these opt-out settings on each device from which you wish to opt-out.

Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked to above.

For UK/EU users:
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Passes, Inc. has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR through:

by using EDPO’s online request form: https://edpo.com/gdpe-data-request/
by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

UK General Data Protection Regulation (GDPR) - UK Representative:
Pursuant to Article 27 of the UK GDPR, Passes, Inc. has appointed EDPO UK Ltd as its UK GDPR representative. You can contact EDPO UK regarding matters pertaining to the UK GDPR through:

by using EDPO’s online request form: https://edpo.com/uk-gdpe-data-request/
by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit, allowing users to opt out of tracking by websites and only services. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com, or consult our Cookie Policy to understand how you can opt out of receiving cookies.

Declining to provide information. We need to collect personal data to provide certain services. If you do not provide that data we identify as required or mandatory, we may not be able to provide those services.

Third-party platforms. If you choose to connect to our Services through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.