Effective as of November 14, 2022.
If you are located in the European Economic Area or the United Kingdom, please consult the EEA/UK GDPR supplemental notice below.
Personal data we collect
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:
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:
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:
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.
How we use your personal data
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:
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:
Compliance and protection. We may use your personal data to:
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.
How we share your personal data
We do not sell or rent your personal data to third parties for their marketing purposes without your explicit consent.
You have the following choices with respect to your personal data. Users who are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”) can find additional information about their rights below.
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.
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:
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.
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.
Other sites and services
How long do we keep your personal data
We apply a general rule of keeping personal data only for so long as is required to fulfill the purpose for which it was collected. However, in some circumstances, we will retain your personal data for longer periods of time. We will retain personal data for the following purposes: (i) as long as it is necessary and relevant for our operations and to provide our Services, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and (ii) in relation to personal data from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Service terms and take other actions as permitted by law.
We implement a number of technical and organizational safeguards designed to maintain the security of our Services in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. However, security risk is inherent in all internet and information technologies and the transmission of personal data via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted through the Service. Users who have registered for our Services agree to keep their password in strict confidence and not to disclose such password to any third party.
International data transfer
Some of the personal data you provide to us will be stored or processed by us or on our behalf by third parties and may be located in other jurisdictions, such as the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in the United Kingdom and the EEA should read the important information provided in the EEA/UK supplemental notice below about transfer of personal data outside of the EEA and UK, as applicable.
Our Services are offered and available to users who are at least 13 years of age or older. Minors under 18 are only permitted to use our Services with consent by a parent or legal guardian with their appropriate permission. Minors under 13 are not permitted to use the Website or our Services. Passes does not knowingly collect personal data from children under 13. Parents or guardians should at all times supervise their children’s activities. If we learn that we have collected or received personal data from a child under 13, we will delete that personal data. If you believe we might have information from or about a child under 13, please contact us at email@example.com.
How to contact us