Last Updated: June 30, 2022.
PassKit, Inc. offers Wallet Pass Management software and services. PassKit is committed to protecting the privacy of Personal Information you provide to us. When referring to “Personal Information” in this Statement, we mean information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g. your name, email address, device information, IP Address). Accordingly, PassKit provides this privacy and information practices statement to inform you about our information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can correct or change such information (“Privacy Statement”).
This Privacy Statement applies to Personal Information that we collect when you: (i) visit websites we operate and that link to this Privacy Statement, including https://passkit.com and https://app.passkit.com (the “Sites”); (ii) use our demo mobile wallet passes, mobile applications (including the PassKit PassReader app), or any other software applications made available by us that link to this Privacy Statement; (iii) visit our branded social media pages; (iv) visit our offices; (v) receive communications from us, including emails, phone calls or texts; (vi) register for, attend and/or otherwise take part in our events or webinars; (vii) submit a job application to us; (viii) submit information to us in connection with a potential business relationship with us; or (ix) register to use the PassKit Platform as an authorized user (for example, as an employee of one of our customers who provided you with login access to the PassKit Platform) or contact us for support, referred to in this Statement as “Account Information”, (collectively, including the Sites, the “Services”). “You” refers to any individual who visits or uses the Services.
In general, with respect to the Personal Information we collect directly from the Sites or other Services, PassKit is a data controller. This means that as a data controller we determine the purposes for which and the manner in which the Personal Information we collect is to be processed.
With the exception of Account Information, this Privacy Statement does not apply to our security and privacy practices concerning the Personal Information we receive and process on behalf of our customers through PassKit's technology platforms and related services (collectively, “PassKit Platform”). In this capacity, we are acting in the role of a data processor or service provider on behalf of our customers, and our security and privacy commitments are detailed in and governed by our agreements with our customers, including the Terms of Subscription Service or such other applicable agreement entered into between our customer and PassKit and that is related to our customer's access to and use of the PassKit Platform. PassKit does not have control over and is not responsible for the data practices of our customers. For privacy information related to our customers' uses of the PassKit Platform in connection with their mobile applications, websites, emails, texts or other digital properties, please reach out to the respective customer directly.
In addition, the Services may contain links to other third party websites. The privacy statements and policies of such third party websites govern their respective personal information and security practices as provided in Section 11 of this Privacy Statement.
The Personal Information we collect will be determined by the type of interaction you have with PassKit, as described in further detail in the following categories:
Registering for and attending a meeting or an event. If you register to attend an event or meeting (whether in person or online), we may ask for your contact information (name and email address), job title, employer, and may retain copies of meeting audio and video recording in accordance with our Data Retention Policy and based on your consent to participate in a recorded meeting. If you attend an event, we may, with your consent, scan your attendee badge which will provide us with your information, such as name, title, company name, address, country, phone number,email address, and record of event attendance.
Your communications with us. We collect Personal Information from you such as name, email address, phone number, mailing address, job title, marketing subscription status, and information regarding your engagement with PassKit content and other publications when you request information about our Services, download or otherwise engage with our content and publications, request customer or technical support, apply for a job or engage with a job posting, or otherwise communicate with us.
Account Information for PassKit Platform. f you register to use the PassKit Platform as an authorized user or sign up for a free account, we collect Personal Information about you that may include name, email address, IP address, company name, company industry, and website name or information.
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 name, email address, employer, job title and other contact information.
Social media content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
Visiting our offices. If you visit our offices, you may be required to register as a visitor and provide your name, email address, phone number, company name and time and date of arrival.
Information from Other Sources. We may also receive other information including your Personal Information from other sources and third parties such as public databases, joint marketing partners, social media platforms, as well as from other third parties who provide us with contact information for prospects or leads. When acquiring information from third parties, we will obtain contractual or other legally compliant commitments from the third parties that the information was acquired lawfully and with the appropriate level of consent..
Billing Information. Through our third-party billing and payment processors, and to the extent we charge a fee for the Services, we may collect billing, payment, and contract related information from you if you are a business representative of one of our customers.
We use Personal Information that we collect about you or that you provide to us for a range of different business purposes. Depending on how you interact with us, we and our third-party service providers use Personal Information in a variety of ways, including:
Providing information and Services you requested. We may use the Personal Information about you to fulfill requests for programs, Services, or information that you may request such as information about potential or future Services, including to: (a) generally manage your information and accounts; (b) respond to questions, comments and requests; (c) provide access to certain areas and features of the Services; (d) link or combine information we get from others to help understand your needs and provide you with better Service; and (e) allow you to register for events, participate in a contest or promotion, post in a forum or participate in webinars, and provide related information and communications.
Marketing products and services. We may use Personal Information about you to provide you with materials about offers, products and services offered by us, including new content or information about future services. We may provide you with these materials by phone, postal mail, text or email, as permitted by applicable law. Such uses include: (a) to tailor content, advertisements, and offers; (b) to notify you about offers, products, and services that may be of interest to you; (c) to provide Services to you; (d) measure interest in the Services; (e) monitor and analyze trends, usage and activities in connection with our Services; (f) for other purposes disclosed at the time that you provide Personal Information; or (g) otherwise with your consent. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.
Research and development. We may use your Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products, processes and services.
De-identified and aggregated data. We may use your Personal Information and other information about you to create de-identified or aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Sites or other online Services, or other analyses we create. De-identified or aggregated information is used for a variety of functions, including the measurement of visitors' interest in and use of various portions or features of the Services. De-identified or aggregated information is not Personal Information, does not identify you or any individual, and PassKit may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within PassKit and with third parties for our or their purposes in a de-identified or aggregated form that is designed to prevent anyone from identifying you.
Public content. If you post any content to our website forums or social media accounts, we may publish this content and make it generally available to any user or visitor of our website.
Complying with legal obligations. We may use your Personal Information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligation under applicable laws to protect our rights or as necessary to protect against misuse or abuse of our Sites or Services, prevent potentially prohibited or illegal activities and fraud, promote safety and security of the Services and in protecting our rights and the rights of others, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
Other Uses. We may use your Personal Information for other purposes disclosed to you at the time you provide Personal Information, with your consent or to conduct our business and pursue our legitimate interests, such as registering and managing visitors to our offices, investigating and responding to any comments or complaints that you may send us, providing internal training, and recruiting, interviewing and hiring job candidates.
We disclose your information to third parties only as necessary to carry out your request, for a variety of our professional or legitimate business purposes, including to provide our Services, to protect us or others, in the event of a major business transaction such as a merger, sale, or asset transfer, as described below, or as otherwise required or permitted by law. Where we do transfer your personal data to third parties or service providers, appropriate safeguards will be in place in order to ensure correct and secure data processing in compliance with applicable data protection law.
Service Providers. PassKit may share Personal Information with our service providers that we have retained to perform Services on our behalf including (i) provision of IT, hosting, backup, storage, and related Services; (ii) provision of information and Services you have requested; (iii) payment processing and to collect amounts owed to PassKit; and (iv) customer service activities. These third-party service providers may have access to or process your Personal Information for the purpose of providing these services for us. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders. PassKit has executed appropriate contracts with our service providers that prohibit service providers from using or sharing your Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Business Partners. From time to time, PassKit may partner with other companies to jointly offer products, services or programs (such as webinars, events or downloadable content). If you purchase, specifically express interest in, or register for a jointly-offered product, service or program from or through PassKit, we may share your Personal Information with our business partners. PassKit does not control our business partners' use of shared Personal Information and their use of such Personal Information will be in accordance with their own privacy policies. If you do not wish for your Personal Information to be shared in this manner, you may opt not to purchase or to specifically express interest in a jointly-offered product or service, or you may otherwise opt-out through any mechanism offered at the time the Personal Information is collected.
Affiliates. We may share Personal Information with our affiliated companies.
Advertising Partners. Through our Services, we may allow third-party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. Please refer to Section 5 below for more information on how these technologies and tracking tools work. If you prefer not to share your Personal Information with third-party advertising partners, you may follow the instructions in Section 11 below.
Protection of PassKit and others. We may disclose Personal Information about you when we have a good faith belief that we are required to provide information: (a) if we are required to do so by law, court order or legal process; (b) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (c) under the discovery process in litigation; (d) to enforce PassKit policies or contracts; (e) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (f) if we, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs and other systems may be reviewed for security purposes (e.g., to detect unauthorized activity on the Services). In such cases, records containing Personal Information may be shared with service providers, third parties and law enforcement bodies in order that they may prevent fraud and/or identify users in connection with their investigation of the unauthorized activities.
Business Transfers. We reserve the right to disclose or transfer any Personal Information in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding).
We use common information-gathering tools for collecting usage data, cookies and similar technologies to automatically collect information that may contain Personal Information from your computer or mobile device as you navigate our Sites or use our Services.
Cookies. A cookie is a small text file that a website saves on your computer or mobile device when you visit the website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie, to develop a record of the user's online activity. When you visit our Sites, we or an authorized third party may place a cookie on your browser and/or device which collects information, including Personal Information, about your online activities over time and across different sites. Cookies allow us to track usage, determine your browsing preferences and improve and customize your browsing experience. For more information about cookies and web beacons, please visit https://www.allaboutcookies.org/.
Types of cookies on our Sites.
SDKs. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties, including analytics and advertising partners, to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you.
PassKit may collect Personal Information to enable individuals to use online social media resources offered either by PassKit or a third party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting and other similar providers to collect information regarding visitor behavior and visitor demographics on some of our Sites, and to develop website content. 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 Services by going to https://tools.google.com/dlpage/gaoptout. You can also opt out of our analytics partners by setting your preference in the Cookie Settings link at the bottom of the web page of the Site you are visiting.
We store Personal Information sent or collected via or by us in the United States or the European Economic Area, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. To facilitate our global operations, we may transfer, store and access such information from the locations where PassKit has operations – specifically the United Kingdom, Hong Kong SAR, or Thailand. Your Personal Information may be processed in any of these countries, and they may have data protection laws that are different or that may not provide the same level of data protection as your country. For such cases, we rely on international transfer mechanisms such as the European Commission approved Standard Contractual Clauses, adequacy decisions about certain countries, or we will ask you for your prior consent for the transfer of your Personal Information, as applicable. In addition, we ensure the recipient of your Personal Information has in place adequate levels of protection for your Personal Information. For more information about the protections in place and a sample copy of the model contractual clauses, please contact us at email@example.com.
The security of Personal Information provided to us is of utmost importance to us. We have implemented industry-standard technical, administrative, and physical safeguards to help protect information on our servers against unauthorized access, alteration, disclosure or destruction. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify us at firstname.lastname@example.org.
We retain the Personal Information we receive as described in this Privacy Statement for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.
Due to the nature of our business, Services are not marketed to or intended for minors under the age of 18. PassKit does not knowingly solicit or collect Personal Information from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us by using the Contact Us information below, and we will take steps to delete such Personal Information from our Services.
You have certain choices available to you when it comes to your Personal Information. Below is a summary of those choices, how to exercise them and any limitations.
Opt-out. Where you have consented to our processing of your Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this section. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out. Where your consent for the processing of Personal Information is otherwise required by law or contract, we will comply with the applicable law or contract. Note that, due to the nature of the Services or of the PassKit Platform, you may have to log in to your account or provide the email and/or other identifying value that is associated with your Personal Information in order for us to complete your request. Note that if you withdraw your consent to processing, some features of the Services may not be available.
Please note you must separately opt out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners' use of this information for interest-based advertising purposes.
Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. PassKit does not recognize or respond to browser-initiated DNT signals, whether that signal is received on a computer or a mobile device. For information about “do-not-track”, visit https://www.allaboutdnt.org.
Access, correct, amend, port, restrict processing, or delete Personal Information.You have the right to control or change certain uses and disclosures of your Personal Information, as set out in this Privacy Statement. Subject to any exemptions provided by law, you have the right to: seek confirmation regarding whether we are processing Personal Information about you; request access to Personal Information; request to know more details about the categories or specific pieces of personal information we collect; to ask that we correct, update, amend or delete your Personal Information; to ask that we do not sell your Personal Information (where “sale” is defined according to the local regulations in your state of residency); and to not be discriminated against for exercising these rights. Please note that we do not currently sell your Personal Information as sales are defined under the laws of Nevada or California, as further detailed below in the sections dedicated to those locations. We will respond to such requests within a reasonable timeframe.
You may log into your account or email email@example.com to exercise one of the individual rights outlined above with regard to Personal Information held about you by us. Such requests will be processed in accordance with local laws. We will respond to such requests within a reasonable timeframe. Although we make good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information. In addition, please note that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
EU residents. If you are located in the European Economic Area or the UK, in addition to the rights mentioned above,you also have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law. In addition, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”). Automated Decision-Making currently does not take place on our Sites or Services.
CA residents. If you are a resident of California, you have the following rights
You can exercise these rights by contacting us at privacy@PassKit.com with the subject line “California Data Rights Request” and providing us with your name and the email address associated with your account.
Colorado residents. If you are a resident of Colorado, you have the right to: opt out of the processing of Personal Information; seek confirmation regarding whether we are processing Personal Information about you; request access to Personal Information; request deletion of Personal Information; or obtain and transfer your Personal Information. You can exercise these rights by contacting us at privacy@PassKit.com with the subject line “Colorado Data Rights Request” and providing us with your name and the email address associated with your account.
Nevada residents. If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at privacy@PassKit.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.
Virginia residents. If you are a resident of Virginia, you have the right to: seek confirmation regarding whether we are processing Personal Information about you; request access to Personal Information; request corrections of inaccuracies in your Personal Information; request deletion of Personal Information; or to opt out of processing of your Personal Information for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. Please note that we do not currently sell your Personal Information or engage in profiling as those terms are defined in the Virginia Data Consumer Protection Act. You can exercise these rights by contacting us at privacy@PassKit.com with the subject line “Virginia Data Rights Request” and providing us with your name and the email address associated with your account.
Customer Data. If you are an individual seeking to exercise your data protection rights (including to seek access to, or to correct, amend, delete, port or restrict processing) in respect of Personal Information stored or processed by us on behalf of one of our customers within the PassKit Platform, then you should direct your request to our customer (the data controller). Upon receipt of a request from one of our customers for us to remove the personal data, we will respond to their request within provided in our agreements with the customer. We will retain Personal Information that we process and store on behalf of our customers for as long as needed to provide the services to our customers.
Redress, compliance and accountability. If, after reviewing this Privacy Statement, you would like to submit a request or you have any questions or privacy concerns, please contact: privacy@PassKit.com.
PassKit will address your concerns and attempt to resolve any privacy issues in a timely manner.
If you are an EU, Swiss or UK citizen and feel that PassKit is not abiding by the terms of this Privacy Statement, please contact us at the contact information provided below. If any request remains unresolved, you may contact the national data protection authority for your EU Member State, Switzerland or United Kingdom.
We may update this Privacy Statement from time to time as deemed necessary in our sole discretion. We will provide notification of any material changes to this Privacy Statement through our Sites or as otherwise required by applicable law. We encourage you to review this Privacy Statement periodically to be informed regarding how we are using and protecting your Personal Information and to be aware of any policy changes. Your continued relationship with us after the posting or notice of any amended Privacy Statement shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Statement take effect immediately after being posted or otherwise provided by us.
If you have any questions about our privacy practices or this Privacy Statement, or if you wish to submit a request to exercise your rights, please contact us at:
3D Golden Sun Centre
59-67 Bonham Strand West
Hong Kong SAR