Collection and Use of Personal Information
Personal information is data that can be used to identify or contact a single person.
Here are some examples of the types of personal information SafePass may collect and how we may use it:
What personal information we collect
- When you use our systems, purchase a product, download a software update, connect to our services, contact us or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information and credit card information.
- When you share your content or invite others to participate in SafePass services or forums, SafePass may collect the information you provide about those people such as name, mailing address, email address, and phone number. SafePass will use such information to fulfill your requests, provide the relevant product or service, or for anti-fraud purposes.
- In certain jurisdictions, we may ask for a government issued ID in limited circumstances including when setting up a wireless account and activating your device, for the purpose of extending commercial credit, managing reservations, or as required by law.
How we use your personal information
- The personal information we collect allows us to keep you posted on SafePass latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by updating your preferences.
- We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes. We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services. For certain online transactions we may also validate the information provided by you with publicly accessible sources.
- We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of SafePass account holders.
- From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with SafePass, you may not opt out of receiving these communications.
- We may also use personal information for internal purposes such as auditing, data analysis, and research to improve SafePass products, services, and customer communications.
- If you enter into a sweepstake, contest, or similar promotion we may use the information you provide to administer those programs.
Source of your personal information where they are not collected from you
We may have received your personal information from other persons if that person has shared their content with you using SafePass products, sent gift certificates and products, or invited you to participate in SafePass services or forums. We may also validate the information provided by you when creating a SafePass ID with a third party for security and fraud prevention purposes.
For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to re-identify individuals who may appear therein.
Collection and Use of Non-Personal Information
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
- We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where an SafePass product is used so that we can better understand customer behavior and improve our products, services, and advertising.
- We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.
- With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.
If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.
Cookies and Other Technologies
If you want to disable cookies and you’re using the Safari web browser, go to Safari preferences and then to the privacy pane to manage your preferences. On your SafePass mobile device, go to Settings, then Safari, scroll down to the Privacy & Security section, and tap on “Block Cookies” to manage your preferences. For other browsers, check with your provider to find out how to disable cookies. Please note that certain features of the SafePass website will not be available once cookies are disabled.
As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.
We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our products and services, and to gather demographic information about our user base as a whole. SafePass may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on the SafePass website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
Disclosure to Third Parties
At times SafePass may make certain personal information available to strategic partners that work with SafePass to provide products and services, or that help SafePass market to customers. For example, when you activate your mobile app, you authorize SafePass and your carrier to exchange the information you provide during the activation process to carry out service. If you are approved for service, your account will be governed by SafePass and your carrier’s respective privacy policies. Personal information will only be shared by SafePass to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.
SafePass shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever SafePass operates.
It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for SafePass to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
Protection of Personal Information
SafePass takes the security of your personal information very seriously. SafePass online services protect your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by SafePass, we use computer systems with limited access housed in facilities using physical security measures. Cloud data is stored in encrypted form including when we utilize third-party storage.
When you use some SafePass products, services, or applications or post on a SafePass forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.
The existence of Automated Decision-Making, Including Profiling
SafePass does not take any decisions involving the use of algorithms or profiling that significantly affects you.
Integrity and Retention of Personal Information
Access to Personal Information
For other personal information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if SafePass is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier.
To provide location-based services on SafePass products, SafePass and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your SafePass computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by SafePass and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.
Third‑Party Sites and Services
SafePass websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties.
Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
SafePass abides by the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies.
Our Companywide Commitment to Your Privacy
To make sure your personal information is secure, we communicate our privacy and security guidelines to SafePass employees and strictly enforce privacy safeguards within the company.
When a privacy question or question about personal information received in response to an access/download request is received we will triage the contacts and seek to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.