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PASSPASS PRIVACY POLICY

PassPass LLC is committed to the privacy of your information. This Privacy Policy is meant to help you understand the information we collect, why we collect it, and how you can manage it. This Policy applies to our website at https://www.passpass.com/ (the "Site") and any related products, services, communications, or apps (the "Services"). By using our Site, or by purchasing our Services, you are acknowledging that you have read, understood, and accept this Privacy Policy.

 

In this Privacy Policy, any use of the words "you," "yours," or similar expressions refers to users of this Site and our Services, as well as any other individuals whose information we collect and process. References to "we," "us," "our" or similar expressions refer to PassPass.

 

This Privacy Policy does not extend to anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after this Site, and which are not governed by this Privacy Policy. We are not responsible for the data protection or privacy policies of any other websites, and accept no responsibility or liability for those policies. Please carefully check the policies of other websites and services you use before you visit or submit personal information.

 

  1. Information We Collect

  1. Information We Collect and Receive. In order for you to use our Site and Services, we need to collect and process certain types of information. Depending on your use of our Site and Services and whether you are a user or a member, this may include examples such as the following:

  1. Information you provide to us by completing forms: For example, your name, address, email address, phone number, social security number, and any other information you may provide in Site forms, in a form W-9, or otherwise through our Site or Services;

  2. Information you provide when you contact us: Any personal information you may provide to us when you email or call us, such as name, phone number, employer, and any other details you provide in your communications;

  3. Transaction information when you purchase Services from us: For example, if you purchase subscriptions or other goods or services with your credit card, we may use your credit card information for shipping, billing, and credit card validation purposes;

  4. Social media information: For example, if you provide us with your social media handle or name directly or by interacting with us on social media; 

  5. Prize award requirements: if you win a prize, we may be required to request and receive sensitive personal information from you in order to prepare and issue the required tax forms; 

  6. Login information, such as username and password, that you may use in connection with our Site or Services;

  7. Information about your activity through our Site or Services, including your device information, such as your IP address, the type of device or browser you use, and your actions on the Site;

  8. Physical characteristics or descriptions, such as if you provide us with photographs or video of you;

  9. Information about your geolocation, such as your physical location based on IP address, device data, or region.

 

We will only use personal information to provide you with information, products and/or Services you have requested, or for other purposes set out in this Privacy Policy. Please note that personal information does not include aggregate information from which individual identities have been removed.

 

  1. Information from Children. PassPass does not knowingly solicit or collect any personal information from anyone under 13 years of age, and children under 13 are not permitted to register for or use our Site or Services, including by subscribing to receive information from PassPass. Parents or guardians can contact our customer service department to access, change, or delete the personal information that has been submitted by a child. If we become aware that a child under the age of 13 has provided us with personal information, we will delete it.

 

  1. Cookies and Tracers. We and our partners may use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across the Site and different Services and devices and enable certain website features and functionalities.  A cookie is a small file that is placed onto your device (e.g., computer, smartphone or other electronic device) that stores information when you visit a website. Some of this information will be aggregated or statistical, which means that we will not be able to identify you individually.  You can control certain cookies through your browser settings and other tools. Neither the Site nor the Services respond to Do Not Track signals.

Specifically, we and our partners use cookies and other similar technologies on this website to:

  • Recognize you whenever you visit the Site (this speeds up your access to the Site as you do not have to log in each time);

  • Support security and any authentication features on our Site;

  • Obtain information about your access, activities, preferences, and use of our Site;

  • Carry out research and statistical analysis to help improve our content, and Services, and to help us better understand our customers' requirements; 

  • Improve the speed and performance of our Site and Services;

  • Make your online experience more enjoyable and efficient; and

  • Keep track of the items stored in your shopping basket and take you through the checkout process.

The cookies that we place on your device may include: 

  • Essential cookies: these cookies are essential for you to be able to navigate our Site and use its features. Without these cookies, the services you have asked for could not be provided.

  • Performance cookies: these cookies collect information about how you use our Site, for example, which pages you go to most often. These cookies do not collect personally identifiable information about you. All information collected by these cookies is aggregated and anonymous, and is only used to improve how our Site works.

  • Functionality cookies: these cookies allow our Site to remember the choices you make (such as your user name, language, last action, and search preferences) and provide enhanced, more personal features. The information collected by these cookies is anonymous and cannot track your browsing activity on other websites.

  • Marketing cookies: also known as advertising cookies, these cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement on our Site and help measure the effectiveness of the advertising campaign. This is sometimes referred to as online behavioral advertising. In some cases, our partners may use cookies for their own purposes or to provide us with information about your interactions with their services. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. Those third-party cookies would be subject to the third party service’s policies.

Managing Cookies: 

You can opt-out of all non-Essential cookies by clicking on the “Decline All” button on the cookie banner at the bottom of the Site homepage. In addition, your browser may give you the ability to control some types of cookies. If you want to customize the kinds of cookies you can control, you can change your browser settings so that certain types of cookies are not accepted. 

If you turn off any cookies, please be aware that you may lose some of the functionality of this Site. For more information about cookies and how to disable them please check the following resource: http://www.allaboutcookies.org/

For more information about targeted advertisements and/or to learn how to opt out of advertising cookies, please visit the below independent associations. You can visit these independent associations’ websites to opt out of all cookies served by their members. These independent websites are not sponsored by or affiliated with PassPass.

 

 

When opting out, a cookie will be set to let advertisers know not to use your data for targeted advertising purposes. You will still see advertisements, but they will not be tailored to your interests. If you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser or mobile device from which you accessed the opt-out. If you use multiple devices or browsers, you will need to opt-out each browser or device that you use.

 

Consent to Use Cookies: The first time you visit our Site, a cookie notice is displayed describing our use of cookies, and linking to this Privacy Policy. As described in that notice, the cookie choices you make the first time you visit our Site will be used for your future use of the Site. 

 

  1. How We Use Information

PassPass may use the personal information we collect for the following purposes:

  1. To deliver our Site, products, and Services;

  2. To allow you to log into and access your account;

  3. To provide customer service and our support services; 

  4. To process any financial transactions you make on our Site, such as when you take advantage of offers and deals;

  5. To verify eligibility for winning prizes and to issue applicable tax or other governmental forms;

  6. To keep your information secure such as by detecting security incidents, and to be able to verify your identity and contact information;

  7. To alert you about product updates, special offers, updated information, and other news and services from PassPass and our partners;

  8. To ensure our Site, products, and/or Services are relevant to you and your interests;

  9. For testing, research, analysis, and product development, including to develop and improve our content, Site, and Services;

  10. To protect against, detect, and investigate fraud;

  11. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and

  12. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.

  1. How Information May Be Shared

PassPass discloses your personal information as described below.  PassPass does not rent any of your personal information, and we do not share your personal information publicly without your consent. PassPass also does not disclose sensitive personal information for purposes other than those permitted by applicable law. 

  1. To our service providers: we may disclose your information to certain trusted third-party services to help us provide, improve, promote, or protect our Site or Services. For example, we may use data storage vendors or partner with other companies to process your payments or to store your personal information when necessary to support delivery of our Services and respond to customer service requests. Whenever we share data with third-party services, we require that they use your information only for the purposes we've authorized, and that they protect your personal information at least to the same standards we do.

  2. To our business partners: We may disclose your personal information to our business partners or allow them to collect your personal information to offer you certain products, services or promotions or to evaluate or improve our or their products, services, or marketing, including through cross-context behavioral advertising.  

  3. For a change in control: We may disclose personal information to other companies for the purpose of evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.

  4. As necessary or otherwise required by law: We also reserve the right to disclose personal information when it is reasonably necessary to conduct our business, protect PassPass's legal rights and property, and to comply with the law. 

  5. At your direction, request or consent: We may disclose or allow access to your personal information if you otherwise consent, request, or direct us to do so.  

  1. Protection of your Personal Information

We take the security of your personal information seriously, and follow industry-standard practices to protect the data we collect and process. PassPass has therefore put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the personal information that PassPass collects. Access to personal information will be restricted to our authorized personnel who require the information in order to perform their duties properly. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties.

Remember, the safety and security of your information also depends on you. Where you have chosen, or where we have given you a user name and password for access to certain parts of the Site or Services, you are responsible for keeping the user name and password confidential. No method of transmission over the internet or electronic storage is completely secure, so PassPass cannot guarantee its absolute security.

  1. Data Transfers

Because PassPass is a US-based company, your information may be collected and processed in the United States. Additionally, as part of the Services offered to you through our Site, the information which we collect about you may be transferred to, and stored in, one or more countries other than where you currently reside. For example, this may occur if any of our servers or third-party service providers are located in a country other than yours. These countries may have different data protection laws that are similar to your current residence. However, if we transfer your information in this way, we will put in place appropriate protection to make sure your personal data remains adequately protected and is treated in line with this Privacy Policy.

 

  1. Email and Mobile Device Notifications 

We give you the ability to opt-out of the marketing communications we may send. You can opt-out of receiving marketing emails or mobile device notifications from PassPass (other than certain required communications, such as messages confirming orders, and notifying you of any privacy policy updates, and the like), by 1) selecting the “unsubscribe” link at the end of our communications to you; 2) responding to any of our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT; 3) logging into the Site or Services and adjusting your user preferences in your account profile; or 4) sending us an email at Privacy@passpass.com stating your request. 

 

  1. Retention

We will hold your personal information on our systems for as long as is necessary to perform the relevant processing activity for that information, or as long as is set out in any relevant contract you hold with us. The relevant retention period is determined on a case-by-case basis because it depends on things like the nature of the data, why it is collected, why it is processed, and any relevant legal or operational retention needs. For example, we may retain your data for as long as you are a customer of ours so that we may process and complete any orders you may make with us. We may also be required to hold some types of information to fulfill legal purposes. We review our retention periods for personal information on a regular basis. When the relevant processing activity has been completed, we may destroy your data, or alternatively anonymize the data, such that the data is not personally identifiable.

 

  1. Questions, Comments, or Complaints

If you have questions or comments about this Privacy Policy, or if you are not completely satisfied with this Privacy Policy or its application by us, we invite you to contact us at Privacy@passpass.com. If you have an applicable disability, you may also contact us at the above email address to request access to this Privacy Policy an alternative format. We will reply as quickly as possible and inform you of the steps, if any, that have been or will be taken in order to address your concern or implement the suggestion. 

 

  1. Updates and Changes to this Privacy Policy

This Privacy Policy is effective as of May 1, 2025 We may update this Privacy Policy from time to time. Any updates to this Privacy Policy will not apply retroactively. If you keep using our Site or  Services after a change, that means you accept this Privacy Policy.

 

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