Pass Holdings LLC dba Pass (“Pass”) respects your privacy. This Online Privacy Policy describes the privacy practices for Pass’s websites and the services and products available on the Site (the “Services”). This Privacy Policy governs your use of the Services, regardless of how you access them, and by using the Services you consent to the collection, transfer, processing, storage and disclosure and other uses of your personal information as described in this Privacy Policy. By using the Site and any of the Services, you are accepting the practices described in this Privacy Policy. These practices may be changed, but any changes will be posted and changes will only apply to activities and information on a going forward, not retroactive basis. You are encouraged to review the Privacy Policy whenever you visit the Site to make sure that you understand how any personal information you provide will be used.

Collection of Information

Information may be collected from you in various ways when you use the Services. We automatically receive certain types of information when you interact with our Site, Services and other communications. This information includes your computer or digital device’s IP address, access times, your browser type and language. We may also collect information about the type of operating system you use, your account activity, and accessed pages. Pass uses unique identifiers and Google Analytics to measure usage and analyze trends, administer the website and collect information for its databases. To learn more about the privacy policy of Google Analytics and how to opt out click here.

We receive and store any information you enter on our Site, through any of the Services, or give us in any other way, including through email, telephone, or other communications with our customer service department. If you contact us for support, we will keep an internal record of what support was shared.We process personal data both as a Processor and as a Controller, each as defined in the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the “Directive”) and the General Data Protection Regulation (“GDPR”). The Customer which Customer End Users provided personal data to, with the assistance of the Service, will be the Controller for Customer End User Data. We will be the Processor of Customer End User Data. For Customer personal data, we will be the Controller.

We have a Data Protection Officer (as defined in the Directive and GDPR) who is responsible for matters relating to privacy and data protection. Our Data Protection Officer can be reached as follows:

Pass
Attn: Data Protection Officer
Pass, Inc.
1968 S Coast Hwy #4425
Laguna Beach, CA 92651
United States
privacy@Passgallery.com

You have the right to edit the personal information by emailing us or mailing us a written request. Although changes will take place within 30 days, information may still be stored in a web browser’s cache. We take no responsibility for stored information in your cache, or in other devices that may store information, and disclaim all liability of such.Non-Personal Information we collect may include the user’s operating system (Windows, Mac, etc.), type of web browser (Chrome, Internet Explorer, Firefox, etc.), IP address, monitor screen resolution and color depth, referring pages, and frequency of visits. This information is used to analyze how visitors browse the Site in order to make future improvements. To maintain our quality of service and to assist in the analysis of product performance, we may also gather data on connection information, including the timing and size of all packets sent over the Internet during a session. Pass also collects certain standard information about your computer for security and identification purposes. This information may include: IP addresses, domain names, access times, browser type and browser version, cookies, and other unique identifying information of machines that have our software downloaded and installed on them. This information is used for the operation of the Site, to identify and protect our customers and to control unauthorized use or abuse of our Services. All information is encrypted during transmission and is stored securely within our servers.

Personal Information collected from users of the Services may include first and last name, phone number, physical address, email address, comments, a Password, and permission from the user to add him/her to our mailing list. You are solely responsible for safeguarding the secrecy of your Password. All personal information remains private within Pass and is not distributed or sold to any outside organizations except as described in this Privacy Policy. We may use your personal information to provide you with Services, features and functionality or to contact you regarding Services. Your name, IP address location, website address, Facebook profile, other social media profile, and any other public demographic info you provide may be included as a profile within our public map of users. You may choose to remove your public profile from this map at any time by emailing privacy@Passgallery.com. Your email address may be used to send you periodic product newsletters, offers and usage tips from Pass. You can opt out of promotional emails at any time, but will still receive communications such as receipts, confirmation emails and customer service updates that are considered necessary to provide Services to you. We use the information collected to deliver and improve Services, update our records, communicate with you about products, updates and Services, personalize and improve your experience, and generally maintain your accounts with us. We will retain your information for as long as your account is active, as needed to provide you Services and to communicate with you about Services and products. While your account is active and even after it has been closed, we will retain your personal information as long as we deem it reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us at privacy@Passgallery.com. We will remove your personal information within 30 days. Deactivation of your account does not mean your personally identifiable information has been deleted from our database entirely.

Files

We collect and store the files you upload, download, or access with the Site (“Files“). If you add a file to your account that has been previously uploaded by you or another user, we may associate all or a portion of the previous file with your account rather than storing a duplicate.Since our Site and services are not directed to persons under 13, we do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that their child has provided us with personal information without their consent, they should delete the account. If we become aware that a child under 13 has provided us with personal information, we will suspend the account. For assistance, email privacy@Passgallery.com.

Cookie/Tracking Technology

The Site may use cookie and tracking technology depending on the features offered. Cookie and tracking technology are useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help customize the Site for visitors. Personal information cannot be collected via cookies and other tracking technology, however, if you previously provided personally identifiable information, cookies may be tied to such information. You can use your browser settings to instruct your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies you may not be able to use all portions of the Site or all of the functionalities of the Services. You can still review the Site if you choose to set your browser to refuse all cookies; however, session cookies must be enabled to establish an account and to download and install any of our software.

Sharing of Information and Files

One of the primary reasons people use Pass is to share Files with others. Your personal information may be used to enable you to communicate, collaborate and share Files. When you choose to collaborate or share Files with others, Pass will collect the email addresses and information of the other parties. Some information is retained only as long as necessary to provide requested Services; other information may be retained longer so we may provide the Services, comply with our legal obligations and enforce our agreements. If you do not want us to store metadata associated with Files you share on Pass (such as photos), please remove the metadata before uploading the Files.

Pass is not responsible if you volunteer personal information and Files online that are accessible to all or some of the public. Any personal information you choose to provide should reflect how much you want others to know about you. You may review, update, correct or delete personal information by emailing privacy@Passgallery.com and our customer support team will make the changes on your behalf. By submitting such information and Files, you assume the risks and sole liability arising as a result of such information and Files being displayed. You can control who has access to your Files, but you understand that any shared Files may be re-shared or copied. We cannot control the actions of other users with whom you share your Files. We cannot ensure that Files you share on the Site or through the Services will not become publicly available. You can reduce these risks by using common sense security practices such as choosing a strong Pass Password, using different Passwords for different services, and using up to date antivirus software.Although you are entering into an Agreement with Pass to disclose your information to us, we do use third party individuals and organizations to assist us, including contractors, web hosts, and others.

Throughout the course of our provision of our Service to you, we may delegate our authority to collect, access, use, and disseminate your information. For example, our web host stores the information that you provide us, and we may hire outside contractors to perform maintenance or assist us in securing our website.It is therefore necessary that you grant the third parties we may use in the course of our business the same rights that you afford us under this Privacy Policy. For this reason, you hereby agree that for every authorization which you grant to us in this Privacy Policy, you also grant to any third party that we may hire, contract, or otherwise retain the services of for the purpose of operating, maintaining, repairing, or otherwise improving or preserving our website or its underlying files or systems. You agree not to hold us liable for the actions of any of these third parties, even if we would normally be held vicariously liable for their actions, and that you must take legal action against them directly should they commit any tort or other actionable wrong against you. Without limiting the generality of the foregoing, you authorize us to collect, store, share, and otherwise use your information in conjunction with:

Google Analytics
Facebook
SlackIntercom.io
Campaign Monitor
Amazon Web Services
Pic-time
Bluesnap
Distribution of Information
We will not rent, sell or share your information with third parties without your consent except as provided in this Privacy Policy.

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law, including the EU Directive 95/46/EU of the European Parliament and the Council of 24 October 1995 (the “Directive”) and the General Data Protection Regulation (“GDPR”). We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including without limitation subpoenas), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical. We will also share your information to the extent necessary to comply with ICANN’s rules, regulations and policies.

We may share certain personal information we collect about you with our service providers who perform functions on our behalf. Examples include sending postal mail and email, analyzing data, and providing marketing assistance and customer service. These service providers are not authorized by us to use or disclose personal information except as needed to perform their functions or comply with legal requirements, and they may not use it for any other purpose. Further, they must process the personal information in accordance with this Privacy Policy EU Directive 95/46/EU of the European Parliament and the Council of 24 October 1995 (the “Directive”) and the General Data Protection Regulation (“GDPR”).

Third Parties

Third-party websites or services who are not Processors linked to the Site are not covered by this Privacy Policy. These websites may collect personally identifiable information about you and place a cookie on your browser. Pass is not responsible for the privacy practices of the third-party websites and companies or what they do with your information. You should make sure their privacy policies are acceptable to you. You may opt-out of third-party advertising cookies through the Network Advertising Initiative (NAI) website http://www.networkadvertising.org/managing/opt_out.asp.

Security Policy

The security of your information is important to us. Pass employs measures to protect information collected from loss, destruction, disclosure, unauthorized access, misuse and alteration. Although we strive to protect your personal information, Pass cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.

We have partnered with Bluesnap to offer safe and secure credit card and debit card transactions for our customers. Bluesnap is responsible for the security of these transactions. Bluesnap manages the complex routing of sensitive customer information through the credit card and debit card processing networks. Bluesnap adheres to strict industry standards for payment processing, including:

128-bit Secure Sockets Layer (SSL) technology for secure Internet Protocol (IP) transactions.Industry leading encryption hardware and software methods and security protocols to protect customer information.

Compliance with the Payment Card Industry (PCI) Data Security Standard.

For additional information regarding the privacy of your sensitive cardholder data, please read the Bluesnap Privacy Policy.

PayPal customers’ banking and credit card information is stored, transmitted to, accessed and managed exclusively by PayPal and we are not responsible for it in any way.We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it.

International Transfer

Personal Information, Non-Personal Information, Files, and other information that Pass collects and processes may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, you should be aware that Pass transfers all such Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to such transfer.

Contact Us Policy

If you have any questions, concerns, or comments about any of the above policies you may contact us using the information below:

Address:
Pass
1968 S Coast Hwy #4425
Laguna Beach, CA 92651
United States

Email: help@Passgallery.com

Support requests will be handled by our software Support Team.

When you contact us, we collect information that helps us categorize your question, respond to it, and, if applicable, investigate any breach of our Terms of Service or this Privacy Policy. We also use this information to track potential problems and trends and customize our support responses to better serve you.

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