Effective march 20, 2019
If you are a visitor to any Company-owned website, you may provide PII (e.g., name, address, telephone number, email address, company name, referring company name and/or referring contact) directly to us by completing a form, such as the contact us form on www.passagetechnology.com (link), to learn more about our Services, use interactive features of Company-owned websites, become a registered user of the Services, subscribe to a blog and emails, participate in surveys, contests, promotions or sweepstakes, or otherwise communicate with us. We may use the PII you provide to us and as directed by you to do the following: create an account, fulfill your request for a demo, subscribe you to marketing communications, reply to your contact request, process billing if you are a customer, provide referral attribution, or otherwise take action related to the purpose for which you have supplied us your PII. Our marketing communications may include contacting you by email or using other various methods of communication, to further contact you regarding your interest in our Services and to send you information regarding the Services, including information about promotions or events. Should you inquire about or purchase any Services utilizing a Company website, the information you supply during this process may be used to track details about those inquiries or purchases.
Personally Identifiable Information Collected Via the Services
Whenever you use our Services, we may collect non-identifying information from you, such as but not limited to: your IP address, job title, industry, how you first heard about us, interactions with the Services, query information, location information, pricing data, research history, location and GPS information, referring URL, browser, application interaction, mobile provider information, operating system, data usage, data transferred, and Internet Service Provider.
Please be aware that we me may collect and aggregate PII from our Services and may anonymize that information for our own research or internal purposes. Once such data has been anonymized, it cannot be traced back to you, the user.
Use of Your Information
This section explains how we plan on using your information submitted by us. In order to use our Services, you agree that we may use your PII:
- To enhance or improve your user experience.
- To share with users of the Services.
- To improve the Services.
- To email you newsletters and marketing as required.
- To understand how you communicate and use our Services.
- To contact and correspond with you and to respond to your inquiries.
- To establish an account and use the Services. We may ask for and collect PII about you such as your name, address, phone number, email address, company name and the like when you register for an account to use our Services, including when you are acting on behalf of a customer, typically an organization or company. In addition, if you are an individual authorized user of our Services pursuant to a Master Subscription Agreement or similar agreement (“MSA”) between Company and one of our customers, the MSA might impose additional restrictions on Company’s use or collection of PII. We communicate with our customers on a regular basis via email, and we may also communicate by phone to resolve customer cases,investigate suspicious transactions, or for promotion purposes. We may use your email address to confirm your opening of an account, to send you notices regarding payments, software updates, or to send notices and other disclosures as required by law. Generally, customers cannot opt out of informational communications relevant to their accounts.
Accessing, Editing, and Removing Your Information
If you have submitted information to our Services you will be unable to edit that information. When using our Services you may be able to access and edit your information via the Services dashboard. However, you will be unable to opt out of any of our data collection practices via the Services. If at any time, you have any questions or wish to review, change, opt out of certain data collection practices, or delete any of your information collected by us, please contact us at firstname.lastname@example.org. Additionally, if you would like us to permanently remove any accessible copies of your information, please follow the instructions listed within the “removal of information” section and contact us at email@example.com. After you have cancelled your account please be aware that we may keep inaccessible copies of your information for a commercially reasonable period of time for business and legal purposes
Removal of Information
If you wish to have any of your personal information stored by Company in connection with the Services removed, please contact us at firstname.lastname@example.org. With each removal request you must list the information you wish to have removed exactly as listed. Please be aware that removal requests are not processed instantaneously. There may be a reasonable delay in removing any information requested.
As Company collects data from multiple sources a single removal request may not eliminate all of your personal information listed in our database. Therefore, you may be required to submit multiple requests. If your information repeatedly reappears please contact us.
You may make a removal request by email at email@example.com, please label the subject of the email with the following “Removal Request – [Insert Your Full Name] and [Insert the Name of the Product You Ordered]”.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional Offers from Us. If you do not wish to have your contact information used by us to promote our own or third-parties' products or services, you can opt-out by sending us an email stating your request to firstname.lastname@example.org. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions, or, if available, use the unsubscribe/subscription update preferences links in the footer of the email.
We do not control third-parties' collection or use of your information to serve Interest-based advertising. However these third-parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative at: http://optout.networkadvertising.org/?c=1.
Cookies and Other Tracking
Third Party Access to Your Information
Although you are entering into an Agreement with Company to disclose your information to us, we do use third-party individuals and organizations to assist us, including contractors, web hosts, and others to allow you to access the Services.
You agree that we may disclose your information to authorities if compelled to by a court order. Additionally, you agree that we may disclose your information if we reasonably believe that you have violated any US laws or the terms of any of our agreements with you or if we believe that a third party is at risk of bodily harm. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you and release your information without receiving any request to third-parties where we believe that it is proper to do so for legal reasons, where your actions violate any laws of the US or any other country having jurisdiction over us, our services, or the Services. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants. We may release your information under the conditions listed in this paragraph whether it is to individuals or entities and to any state or national authorities, as required.
Commercial, Non-Commercial Communications and Do Not Track
If you decide to provide us with your contact information, you agree that we may send you communications via text, phone, and email. However, you may unsubscribe from certain communications by notifying email@example.com that you no longer wish to receive these communications, we will endeavour to promptly remove you from our notification listings once we have received that request. We currently do not offer website functionality for you to opt into any “do not track” listings. If you wish to opt out of certain communications or information collection, please contact us at firstname.lastname@example.org.
Company may post links to third party websites on our Services, which may include information that we have no control over. When accessing a third-party site through our Services, you acknowledge that you are aware that these third-party websites are not screened for privacy or security issues by us, and you release us from any liability for the conduct of these third-party websites.
We make reasonable attempts to protect your information by using physical and electronic safeguards. For these reasons Company employs SSL certificates. However, as our Services are hosted electronically we can make no guarantees as to the security or privacy of your information. For this reason, we recommend that you use anti-virus software, routine credit checks, firewalls, and other precautions to protect yourself from security and privacy threats.
Your California Privacy Rights
We intend to fully comply with American and international laws respecting children’s privacy. Therefore, we do not collect or process any information for any persons under the age of 18. If you are under 18 please do not access the Services. Our Services are not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on or through the Services or on or through any of its, use any of the interactive or public comment features of the Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18 please contact us at email@example.com. California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see the section entitled ‘Your California Privacy Rights’ for more information.
Merger and Acquisition
In the event that the Company is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. Please be aware that once the information is transferred your privacy rights may change.
Privacy Notice for European Citizens
Under the GDPR, the data controller has additional obligations to any users who submit PII to us. The GDPR affords the following rights to EEC citizens and persons residing in EEC territories.
Your Rights Under the GDPR
|Right to be informed||Company wishes to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data.|
|Right to access||You have the right to access your information at any time. Please contact us at firstname.lastname@example.org if you wish to access the personal information Company holds about you.|
|Right to rectification||If the information Company holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact us for more information: email@example.com.|
|Right to erasure||Sometimes called ‘the right to be forgotten’. You have the right to request that Company to erase all your personal data, if you wish to do so please our team: firstname.lastname@example.org.|
|Right to restrict processing||You have the right to ask Company to restrict how we process your data. This means we are permitted to store the data but not further process it. We will only keep enough data to ensure that we can accommodate any additional requests. Please contact our team at: email@example.com.|
|Right to data portability||Company must allow you to port and reuse your personal data for your own purposes across different platforms. Please contact our team if you wish to receive additional information on how to port your data elsewhere: firstname.lastname@example.org. This right only applies to personal data that you have provided to us as a data controller.|
|Right to object||You have the right to object to Company processing your data even if our processing is due to legitimate purposes as described in our Privacy Notice, if you have any objections please contact our team at: email@example.com.|
|Right to withdraw consent||If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and Company must stop processing your data. If you want to withdraw your consent, please contact our team at: firstname.lastname@example.org.|
Under the GDPR, you may exercise these rights by contacting us. If we process your information based on our legitimate interests or those of a third-party, or in the public interest, you can object to this processing, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. You can also object to our processing of your information by contacting us.
Additional Personal Information Collected
Legitimate Purposes for Collecting Your PII
The following are the specific legitimate purposes that we may use your PII for:
- Contract Administration - We may use your PII to (1) negotiate, execute, renew and/or manage a contract with you; (2) process billing information and payments related thereto; and/or (3) communicate with you in respect of the above (including sending (legal) notifications).
- Access and Communications to Our Services - We may use your PII to (1) set-up and manage the your account in connection with the Services; (2) interact with you through our Services (e.g. software updates, Service announcements, etc.): and/or (3) manage and respond to your questions (e.g. technical, commercial or administrative) or requests for maintenance and support.
- The Use of the Services - We may use your PII to (1) enable you to enjoy the use of, and easily navigate the Services; and/or (2) better understand your needs and interests; and/or (3) to learn how to use your installed application or to inform you on what features are or are not available with your installed product
- Salesforce, Inc.
- FreshBooks, Inc.
- FormStack, LLC
- Facebook, Inc.
- Twitter, Inc.
- Lanyon Solutions, Inc.
- HubSpot, Inc.
- Fifth-Third Bank
- Allowing Downloads from the Services - We may use your PII to allow you download data or content from the Services.
- Training & Improvements - We may use your PII to (1) train our employees or contractors to allow for a better Services experience; and/or (2) improve the Services.
- Direct Marketing - We may use your PII to contact you for additional products and services that you may be interested in.
- Information Third-Parties Provide About You - We may receive information from other businesses or users about you. For example, when other users submit a company inquiry or create a company profile they may include your information in such an inquiry. We require each of these users and businesses to have lawful rights to collect, use, and share your information before providing any information to us. If you wish to find an updated list of third parties we collect and share information with, please contact us.
Retention of PII
Company will only retain your PII for as long as required. We will keep your personal information:
- For any legally required duration.
- Until we no longer have a valid reason to keep or use your PII.
- Upon your request to eliminate, delete, or modify any of you PII stored with us.
Where you have requested modification or deletion of your PII, we may keep just enough of your personal information to ensure that we comply with your requests not use your personal information or comply with your right to erasure. If you require additional details regarding the retention of your PII please contact us.
Transfer of PII Outside of the EEC
Where your PII is transferred outside of the EEC to areas such as the United States, Company shall ensure that your PII shall have an adequate level of protection as required under the GDPR, including but not limited to executing Data Protection Agreements with our processors that process your information. These data transfers are necessary to provide the Services to you. We utilize standard contract clauses approved by the European Commission and/or the EU/US Privacy Shield to ensure that your PII is properly protected and in conformance with GDPR requirements.
Legal Basis for Processing Information
We collect, use, and share the information we have as described above:
- as necessary to fulfill our Master Subscription Agreement;
- consistent with your consent, which you can revoke at any time;
- as necessary to comply with our legal obligations;
- occasionally to protect your vital interests, or those of others;
- as necessary in the public interest; and
- as necessary for our (or others') legitimate interests, including our interests in providing an safe and profitable services to our users and partners, except where such interests would be overruled by your compelling interests to your data privacy.
Sharing of Data with Third Parties
If you are covered under this Privacy Notice and have any additional questions, please contact us at: email@example.com or at:
Passage Technology, LLC
100 S Saunders Rd #150
Lake Forest, IL 60045
Passage Technology, LLC Data Protection Officer: Beatriz Johnson at firstname.lastname@example.org.