Privacy Policy

Effective as of November 14, 2022.


Passes is a social network which enables users to share their content; other users to enjoy content and for some to do both. We refer to those users who share content as “Creators” and those users who pay to view Creators’ content as “Fans”. This Privacy Policy describes the privacy practices of Passes, Inc. (“Passes” “we”, “us” or “our”) and how we handle your personal data when you visit our site www.passes.com (the “Website”), any related sites, pages, services and goods or any other website operated by Passes that links to this Privacy Policy (the “Services”). The purpose of this Privacy Policy is to provide you with a clear explanation of what personal data we collect, when, why and how we collect, use and share your personal data and it explains your statutory rights.


We strongly urge you to read this Privacy Policy and make sure you fully understand our practices in relation to personal data before you use our Services.


If you are located in the European Economic Area or the United Kingdom, please consult the EEA/UK GDPR supplemental notice below.


INDEX

  • Personal data we collect
  • How we use your personal data
  • How we share your personal data
  • Your choices
  • Other sites and services
  • How long do we keep your personal data
  • Security
  • International data transfer
  • Children
  • Changes to this Privacy Policy
  • How to contact us
  • EU/UK GDPR supplemental notice

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:


  • 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, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our Website, 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 links within them.

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 ourCookie 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.


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:

  • 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.


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.

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.
  • 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. 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.

Your choices


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:

  • 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.

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.


Other sites and services


Our Services may contain links to third party websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into websites or other online services that are not associated with Passes. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of each of the other third party websites, mobile applications and online services you visit.


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.


Security


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.


Children


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 help@passes.com.


Changes to this Privacy Policy


We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Website. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We recommend that you check this Privacy Policy periodically for any updates or changes.


How to contact us


To exercise any of your rights in connection with your personal data, please contact us at help@passes.com or 1 S.E. 3rd Avenue, Miami, FL 33131. If you have any questions (or comments) concerning this Privacy Policy, please contact us at help@passes.com or 1 S.E. 3rd Avenue, Miami, FL 33131.