Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed or otherwise anonymized.
Personal Information Voluntarily Collected
Non-identifiable Information Automatically Collected
Whenever you use our Platform, we may collect non-identifying information from you such as your IP address, interactions with the Platform, query information, pricing data, research history, referring URL, browser, application interaction, mobile provider information, operating system, data usage, data transferred, and Internet Service Provider.
Please be aware that we may collect and aggregate personal information from our Platform then 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.
Sharing and Use of Your Information
This section explains how we plan on sharing and using your personal information. You consent to our use of your personal information for the following purposes:
Contract Administration. We may use your personal information to: (1) negotiate, execute, renew and/or manage a contract with you; (2) process billing, quotes, license requests, or other information transactions and payments related thereto; and/or (3) communicate with you in respect of the above (including sending legal notifications).
Access and Communications to Our Platform and Services. We may use your personal information to: (1) set-up and manage your Passage Tech account; (2) interact with you through our Platform (e.g. software updates, Platform announcements, etc.): and/or (3) manage and respond to your questions (e.g. technical, commercial or administrative) or requests for maintenance and support.
Use of the Platform. We may use your personal information to: (1) enable you to enjoy the use of, and easily navigate the Platform; and/or (2) better understand your needs and interests. The legal basis is Art. 6(1)(f) of the EU General Data Protection Regulation (“GDPR”).
Sharing with Third Parties. We may use your personal information to share with our partner companies or future affiliates for research, marketing, and other purposes. We may also share your information with service providers with whom we contract such as contractors, web hosts, data providers and others so that we may provide you any services and allow you to access the Platform.
Allowing Downloads from the Platform. We may use your Personal Information to allow you download data or content from the Platform.
Training and Improvements. We may use your personal information to: (1) train our employees or contractors to allow for a better Platform experience; and/or (2) improve the Platform.
Direct Marketing and Inquiries. We may use your personal information to contact you for additional products and services that you may be interested in or to respond to an inquiry.
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.
Retention of Personal Information
Passage Tech will only retain your Personal Information 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 personal information. We retain the personal information we collect for as long as reasonably necessary to fulfill the purposes for which the information was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims.
Until we receive a request to eliminate, delete, or modify any of your personal information stored with us.
Legal Basis for Processing Information
Your information collected through the Platform may be stored and processed in the United States, Ireland, Germany, Denmark, the Netherlands, or any other country in which Passage Tech or its subsidiaries, affiliates, or service providers maintain facilities. We may transfer information that we collect about you, including personal information, to affiliated entities, or to other third-parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. We process and use your personal information, where required by law, for the following purposes:
- 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 a safe and profitable services to our users and partners.
Accessing and Editing Your Information
When using our Platform you may be able to access and edit some of your personal information via the Platform dashboard. If at any time, you have any questions or wish to review, change, or edit any additional personal information collected by us, please contact us at email@example.com.
Removal of Information
If you wish to have any of your personal information stored within the Passage Tech Platform removed, please contact us at firstname.lastname@example.org. Please be aware that removal requests are not processed instantaneously. There may be a reasonable delay in removing any personal information requested.
You may make a removal request by email at email@example.com. If you require additional details regarding the deletion or retention of your personal information please contact us. All removal or deletion requests are subject to Section 6 and subject to any applicable laws. Additionally, we will retain and use your personal information (even after a removal or deletion request), where required, so that we may fulfill our legal obligations, resolve disputes, and enforce our agreements.
Opting Out and Do Not Track
If you decide to provide us with your contact information, you agree that we may send you communications via text and email where you have consented. However, you may opt out of any communications and you may opt out of certain personal information submission where applicable. If you wish to opt out of certain communications or information collection, please contact us at firstname.lastname@example.org if the communication received or information collection does not already provide a mechanism for an opt-out.
We currently do not offer website functionality for you to opt out of any “do not track” signals or listings.
We make reasonable attempts to protect your information by using physical and electronic safeguards in accordance with industry standards. However, as our Platform is 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, robust passwords, 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 you are prohibited from accessing the Platform.
Merger and Acquisition
In the event that Passage Tech is involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal 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.
Transfer of Your Information to the United States
Please be aware that if you are located outside of the United States, your personal information shall be transferred and processed in the United States. If you are a citizen or resident of the European Economic Area (“EEA”), Passage Tech shall ensure that your Personal Information shall have an adequate level of protection, which may include executing Data Protection Agreements with our processors and that process your information. These data transfers are necessary to provide the Platform to you. Where we transfer your Personal Information outside of the EEA we may utilize standard contract clauses, the Swiss-US Privacy Shield, and other data protection mechanisms approved by the European Commission.
Privacy Notice for European Citizens
Passage Tech respects the rights of citizens or persons living within the EEA and the rights afforded to them under the GDPR this section addresses the privileges of EEA users. If you live in a country in the EEA the services are provided by Passage Technology, LLC 100 S Saunders Rd #150, Lake Forest, IL 60045, the data controller responsible for your information when you use our Platform. The GDPR affords the following rights to EEA citizens and persons residing in EEA territories:
Your Rights Under the GDPR
|Right to be informed||Passage Tech 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 email@example.com if you wish to access the personal information that Passage Tech holds about you.|
|Right to rectification||If the information Passage Tech 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.|
|Right to erasure||Sometimes called ‘the right to be forgotten.’ You have the right to request that Passage Tech to erase any and all of your personal data from our active databases.|
|Right to restrict processing||You have the right to ask Passage Tech 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.|
|Right to data portability||Passage Tech must allow you to port and reuse your personal data for your own purposes across different platforms. Please contact our team at firstname.lastname@example.org if you wish to receive additional information on how to port your data elsewhere. 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 Passage Tech processing your data even if our processing is due to legitimate purposes as described in our Privacy Notice.|
|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 Passage Tech must stop processing your data. You may withdraw your consent at any time.|
You may exercise these rights by contacting us at email@example.com. 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.
If you have any additional questions, please contact us at: Passage Technology, LLC, firstname.lastname@example.org or at Passage Technology, LLC 100 S Saunders Rd #150, Lake Forest, IL 60045