Website & Cookie Policy

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This Website and Cookie policy details what information is collected about you when you visit our Website (Passbase.com), including how we make use of Cookies.
Last Updated: January, 2020
PERSONAL INFORMATION WE COLLECT
When you interact with our Website, we may collect the following categories of personal information.
Information You Provide to Us
Registration and Your Information. 
If you want to use certain features of the Website, you will have to create an account (“Account”) using your email address. You may also receive an invitation to proceed with the registration via the email used to register an account.
Accuracy of Account Information.
It is important that you provide us with accurate, complete and up-to-date information for your Account and you agree to update such information to keep it accurate, complete and up-to-date. If you don’t, we might have to suspend or terminate your Account. You agree that you won’t disclose your Account password to anyone, and you’ll notify us immediately of any unauthorised use of your Account. You’re responsible for all activities that occur under your Account, whether or not you know about them.
Communications with Us.
We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, or otherwise communicate with us.
Surveys.
We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Interactive Features.
We may offer interactive features such as forums, blogs, chat and messaging services, and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive features, you assume the risk that the personal information provided by you may be viewed and used by third parties for their own purposes.
Customer Service and Support.
If you call or otherwise interact with Passbase’s customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes.
Information Collected Automatically.
Automatic Data Collection. We may collect certain information automatically when you use the Website. This information may include your registration date, Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Website, including the frequency and duration of your activities, and other information about how you use the Website. Information we collect may be associated with accounts and other devices.
Cookies, Pixel Tags/Web Beacons, and Analytics Information. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Website.
Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Website may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Website which collects information about engagement. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Analytics. We may use Google Analytics and other service providers to collect and process analytics information on our Website. 
For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the website by going to http://tools.google.com/dlpage/gaoptout.
Session Replay Providers. We use Hotjar for session replay analytics. Hotjar’s service allows us to record and replay an individual’s interaction with the Website. This helps us understand our user’s experience. For more information about Hotjar, please visit: https://www.hotjar.com/legal/policies/privacy. You can opt out of Hotjar’s processing of your information on our website by visiting: https://www.hotjar.com/legal/compliance/opt-out.
HOW WE USE YOUR INFORMATION
How We Use Automatic Collection Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:
Operationally Necessary. This includes Technologies that allow you access to our Website, applications, and tools that are required to identify irregular site behaviour, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
Performance Related. We may use Technologies to assess the performance of our Website, including as part of our analytic practices to help us understand how our users use the Website;
Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Website.
Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Website or on third party sites.
Technologies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalised advertisements on some mobile applications by following the instructions fo Android and iOS.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/ . Please note you must separately opt out in each browser and on each device.
Personal Information Use. Passbase shall use your personal information for a variety of business purposes, including:
To Provide Services or Information Requested, such as:
Initiating our contract with you;
Processing payment card and/or other financial information to facilitate your use of the Services;
Responding to questions, comments, and other requests;
Providing access to certain areas, functionalities, and features of our Website;
Answering requests for customer or technical support.
Administrative Purposes, such as:
Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Measuring interest and engagement in our services;
Developing new products and services;
Ensuring internal quality control and safety;
Communicating with you about your account, activities on our Website and Privacy Notice changes;
Preventing and prosecuting potentially prohibited or illegal activities;
Enforcing our agreements; and
Complying with our legal obligations 
Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.  Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalised advertising” including cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time by emailing [email protected]​
Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
De-identified and Aggregated Information Use. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
OUR LAWFUL BASIS FOR PROCESSING (EUROPEAN ECONOMIC AREA ONLY)
If you are located in the European Economic Area, Passbase’s processing of your personal information is supported by the following lawful bases:
Consent and Explicit Consent:  Passbase relies on your consent and/or explicit consent to process your personal information as detailed in the acceptance of our Terms of Service.
Compliance with our Legal Obligations: Passbase may process your personal information to comply with our legal obligations.
Performance of a Contract: Passbase may need to process your personal information to fulfil an agreement to provide our Services to you.
DISCLOSING YOUR INFORMATION TO THIRD PARTIES
Passbase does not share, sell, rent or loan Personal Information with independent third parties.  Nevertheless, we may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation or prosecution of suspected or actual illegal activity. Under such circumstances where the law, a court order or other legal process prohibits notice prior to disclosure, none shall be provided. 
We may share your personal information with the following categories of third parties:
Other Organisations at your Instruction. You may instruct Passbase to share your personal information, including your biometric data, with third parties for their own, independent purposes. Once you share your personal information with these parties, it will be subject to the privacy policy and practices of the receiving party. These third parties are not controlled by Passbase. We encourage our users to read the privacy policies of each third party with which they interact. We are not responsible for the privacy and security practices of such third parties. Disclosing your information to these third parties is at your own risk.
Service Providers. Passbase employs third party service providers. Where Personal Information is shared with a service provider each third party is required under contract with Passbase to secure all Personal Information with access permissions provided to only those employees who need it to complete a task on our behalf. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of information, products, and other services you have requested; (ii) marketing and advertising; (iii) payment and transaction processing; (iv) customer service activities; and (v) the provision of IT and related services.
Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
INTERNATIONAL DATA TRANSFERS.
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavour to safeguard your information consistent with the requirements of applicable laws. Further details can be provided upon request.
YOUR CHOICES.
General. You may have the right to opt out of certain uses of your personal information.
Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Service or this Privacy Notice).
Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect precise location information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
INDIVIDUAL RIGHTS IN PERSONAL INFORMATION.
For purposes of the California Consumer Privacy Act, we do not “sell” your personal information.
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to our processing of your personal information (v) restrict our uses of your personal information; (vi) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vii) withdraw your consent; and (viii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
If you are a California resident, you have the right not to receive discriminatory treatment by Passbase for the exercise of your rights conferred by the California Consumer Privacy Act.
DATA RETENTION
We store the personal information we receive as described in this Privacy Notice for as long as necessary to fulfil the purpose(s) for which it was collected, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. We will delete your data within three years of your last interaction with the Website.
SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable laws, we do not accept liability for unauthorised disclosure.
By using the Website, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Website. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
CHILDREN’S INFORMATION
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
SUPERVISORY AUTHORITY
If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority in your jurisdiction if you believe our processing of your personal information violates applicable law. This Privacy Policy is governed by the applicable laws in the State of New York.
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CHANGES TO OUR PRIVACY NOTICE
We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.
CONTACT US
Office of the Data Privacy Officer: [email protected]​
General questions about our privacy practices, or this Privacy Notice: [email protected]​
Passbase, Inc.:  179 Franklin St, New York, NY 10013
Passbase GmbH.: Monbijou Platz 2, 4th Floor, Berlin 10178, Germany 
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Website Terms of Service
Last modified 1yr ago