Last Modified: May 24, 2018
Collection of Information
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:
Attn: Data Protection Officer
1001 SW Emkay Drive
Bend, OR 97702
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.
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 email@example.com.
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 firstname.lastname@example.org 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.
Amazon Web Services
Distribution of Information
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.
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.
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.
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 dba PASS, 1001 SW Emkay Drive - Suite 100 - Bend, OR 97702
Support requests will be handled by our software Support Team.