Please contact us
in case of any related questions. IMPORTANT:
This policy applies immediately to new users who use or access the Service on or after the Effective Date and on the Effective Date to users who use or access the Service before the Effective Date. 1.1. Types of Personal Information We Collect
Pass4Success collects Personal Data about you when you provide it directly to us, when third parties such as our business partners (e.g. companies with whom we integrate our Service), service providers (such as our advertising service providers) provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Service. We collect the following Personal Data from you in connection with the Service:
• Contact Information: information we collect to identify or contact you, we collect typical "business card information" such as your first and last name, physical address, email address, telephone number, or Twitter handle. For example, this is the basic information that we collect when you register an account.
• Financial Account Information: information that you provide in connection with your purchase of the Service (or a purchase made through the Service), including credit card number, credit card expiration date, credit card verification code, bank account number, bank account title, bank name, branch location and routing number. You must only provide us with Financial Account Information for accounts and credit cards that you have the lawful right to access.
• Transaction Information: information related to transactions you conduct on the Service, including when you use our products or download special content and your interactions with the Service (for example the functionality you use and the links clicked on the Service).
• User Account Information: information that identifies you to the Service, such as your user name, email address, password and IP address. For example, we use this information to authenticate you when you log in to the Service and use the IP address to help maintain your web session security while using the Service.
• User Content: to the extent that you choose to input Personal Data as part of such content, images, comments and other content, information and materials that you post to or through the Service.
• Partner Information: information that our business partners, such as our content-providing partners, share with us - for example, if you use their services to purchase, preview and/or otherwise use their content when using our Service.
• Log Data: information automatically recorded by the Service about how a person uses our Service, such as IP addresses, device and browser type, operating system, the pages or features of our Website or Service to which a user browsed, the time spent on those pages or features, the frequency with which the Service is used by a user, search terms used by a user, the links on the Service that a user clicked on or used and other statistics.
We also collect usage and performance information that is not Personal Data or that we aggregate or de-identify so that it no longer personally identifies an individual. We also associate some data that is not Personal Data with Personal Data.
We collect Personal Data when a user (i) creates an account (a "User Account"); (ii) logs into the Service; (iii) interacts with the Service; (iv) uploads or generates User Content; (v) communicates with us; and (vi) responds to a communication or interaction from us. Some of the methods and tools we use to collect Personal Data are:
• Unique Identifiers: We use unique identifiers such as cookies, e-mail or your pseudonymized customer ID to track individual usage behavior on our Service, such as the length of time spent on a particular page and the pages viewed during a particular log-in period. Unique identifiers collect information about a user’s use of our Service on an individual basis.
• Mobile Device Identifiers: Mobile device identifiers are identifiers stored on your mobile device that track certain data and activities occurring on or through your device. Mobile device identifiers enable collection of Personal Data (such as media access controls) as well as non-personally identifiable information (such as usage and traffic data).
• Cookies, Web Beacons and Other Tracking Tools: We and our third party service providers collect information about you, your device and your use of the Service through cookies, clear gifs (a.k.a. web beacons/web bugs) ("Web Beacons") and other tracking tools and technological methods (collectively, "Tracking Tools"). Tracking Tools collect information such as computer or device operating system type, IP address, browser type, browser language, mobile device ID, device hardware type, the website or application visited or used before or after accessing our Service, the parts of the Service accessed, the length of time spent on a page or using a feature and access times for a webpage or feature. These Tracking Tools help us learn more about our users and analyze how users use the Service, such as how often users visit our Service, what features they use, what pages they visit, what emails they open and what other sites or applications they used prior to and after visiting the Service. Cookies:
Web Beacons help us better manage content on our Service by informing us what content is effective. Web Beacons are embedded in, or otherwise associated with, certain emails or other communications that you receive from us or our partners. Web Beacons help us track your responses and interests and deliver relevant content and services to you. For example, they may let us know when you take actions based on the emails that we send. Web Beacons also allow us to enhance our Behavioral Advertising (defined below), which is further discussed below. . Social Media Widgets:
We may use third-party services, such as open search tools and social networks, to obtain information about you (such as your name or company) and to enrich your personal information by obtaining publicly available information about you, such as your job title, employment history and contact information. Online Behavioral Advertising:
Some of our advertising ("Behavioral Advertising") involves using Tracking Tools to collect information about a user’s online activities over time and across non-affiliated websites and applications and providing ads to the user based the user’s interests (as inferred from the user’s online activity) or use of our Service. Behavioral Advertising may appear on our Service or on other websites or services. We work with third parties to provide Behavioral Advertising, such as advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third-party service providers (collectively, "Advertising Service Providers"). Advertising Service Providers perform services such as facilitating targeting of advertisements and measuring and analyzing advertising effectiveness on the Service (collectively, all such services, "Targeting Services"). Targeting Services help us display Behavioral Advertising, prevent you from seeing repeated ads and enable us to research the usefulness of ads.
We adhere to self-regulatory principles for online behavioral advertising issued by the Digital Advertising Alliance ("DAA") and the European Interactive Digital Advertising Alliance ("EDAA") (collectively, the "OBA Principles"). More information about the OBA Principles can be found at digitaladvertisingalliance
You have the option to opt out of Behavioral Advertising. For more information, see the related section. 1.2. Personal Data Usage
Pass4Success.com uses Personal Data to: (i) provide, administer and improve our Service; (ii) better understand your needs and interests; (iii) fulfill requests you make; (iv) personalize your experience; (v) provide Service announcements; (vi) provide you with information and offers from Pass4Success.com, Pass4Success.com Affiliates and our business partners; (vii) protect, investigate and deter against fraudulent, harmful, unauthorized, or illegal activity and (viii) comply with legal obligations.
For example, we use Personal Data to:
• Operate and improve the Service
• Learn more about our users and their internet behaviors
• Target offers to users
• Facilitate communications among and between users and the public in general
• Evaluate eligibility of customers for certain offers, products, or services
• Evaluate the types of offers, products, or services that may be of interest to users
• Provide user support
• Communicate with users regarding support, security, technical issues, commerce, marketing and transactions
• Facilitate marketing, advertising, surveys, contests, sweepstakes and promotions
• Administer the Service, User Accounts and transactions with respect to User Accounts
• Enforce our contracts, administering and carrying out our obligations under contracts and complying with the law
• Publish aggregated data about usage trends, which may be derived from Personal Data
• Complete corporate transactions such as mergers, sales of assets, or bankruptcies 2. Personal Data Processing
We will only use your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below.
• Contractual Necessity: We process the following categories of Personal Data because we need to process the data to perform under our User Agreement with you, which enables us to provide you with the Service. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Service that require such data:
• Contact Information
• User Account Information
• Financial Account Information
• Transaction Information
• User Content
• Legitimate Interest: We process the following categories of Personal Data when we believe doing so furthers the legitimate interest of us or third parties:
• Contact Information
• Financial Account Information
• User Account Information
• Transaction Information
• User Content
• Partner Information
• Log Data
• Examples of these legitimate interests include:
• Operation and improvement of our business, products and services
• Marketing of our products and services
• Provision of customer support
• Protection from fraud or security threats
• Compliance with legal obligations
• Completion of corporate transactions
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest. 3. Your Personal Data Sharing
We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the Service. These parties include:
• Third parties who act for us or provide services for us, such as billing and credit card payment processing, maintenance, sales, marketing, administration, support, data enrichment, hosting and database management services
• Outside professional advisors (such as lawyers and accountants) for purposes related to the operation of our business such as auditing, compliance and corporate governance
• Pass4Success.com Affiliates, including persons or entities that acquire some or all of Pass4Success.com or our assets
We also share Personal Data with third party service providers and agents when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
• Other users (when you use a "share link" to post information publicly, share or comment on content, or as otherwise necessary to effect a transaction initiated or authorized by you through the Service)
• Social media services (if you interact with them through your use of the Service)
• Third party business partners who you access through the Service
• Other parties authorized by you
• The owner and administrator(s) of the Service account that you use, or of the email address that you used to register with the Service (see "Use of Third-Party E-mail Address" immediately below). We also share Personal Data when we believe it is necessary to:
• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, or third parties, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and services
We also share information with third parties when you have given us consent to do so. 4. 3rd-party E-mail Address Usage
If you register for the Service using an e-mail address that we recognize to be either a part of a third-party Corporate Account for the Service (an "Corporate Account") or a potential enterprise Service purchaser (for example, your employer’s) (each, an "E-Mail Holder"), we may provide your name and email address to the E-Mail Holder and their administrator. In some cases, we will also consolidate your account(s) with the accounts of the E-Mail Holder and we provide your E-Mail Holder and their administrator with access to your User Account information and User Content. This may happen when the E-Mail Holder’s account is established after you register for your individual User Account. We make these transfers to allow users who are part of a larger organization to take advantage of the special features and security enjoyed by our Corporate Account holders and in order to help you and your organization comply with its internal security and email usage obligations. Please note that all accounts for the Service and all applicable subaccounts (which may include your User Account), are controlled by the account administrator. In certain cases (e.g. when we are aggregating all of the accounts under a current or potential Corporate Account), we will provide you with the ability to opt-out of consolidation with an E-Mail Holder’s Account (typically by changing the email address on your account to a non-E-Mail Holder email address).
Additionally, when an E-Mail Holder creates an Account, we may notify any individuals already using the Services under an email address with the same company domain as yours so that they can be migrated to your Corporate Account. 5. Business Transfers
Opting Out of Behavioral Advertising and Tracking Tools
You can opt-out of certain Behavioral Advertising activities by doing one or more of the following. Please note that you will need to opt-out of each browser and device for which you desire to apply these opt-out features.
• Service Provider Opt Out: You can opt-out directly from some Advertising Service Providers and providers of Tracking Tools by using their opt-out tools. Some of these service providers and links to their opt-out tools, are:
and opt out at google tools
• Industry Opt Out Tools: Some Advertising Service Providers or providers of Tracking Tools may participate in the Network Advertising Initiative's (NAI) Opt-Out Tool (networkadvertising
) and/or the Digital Advertising Alliance (DAA) Consumer Choice Page (aboutads
) and you can opt-out of certain services and learn more about your choices by visiting the links included there. Users in the EU can visit youronlinechoices
for more information about your choices and to opt out of participating service providers.
• Web Browser Controls: You can prevent the use of certain Tracking Tools, such as cookies, on a device-by-device basis using the controls in your web browser. These controls can be found in the Tools > Internet Options (or similar) menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to:
• Delete existing Tracking Tools
• Disable future Tracking Tools
• Set your browser to provide you with a warning each time a cookie or certain other Tracking Tools are being set
• Mobile Opt Out: Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for Behavioral Advertising. You may also opt-out of certain Tracking Tools on mobile devices by installing the DAA’s AppChoice app on your mobile device (for iTunes
visit Itunes, for Android visit Google Play
). For more information, please visit Apple Website
• Do Not Track: Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. The Service does not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Service and after you leave our Service.
Opting-out of Behavioral Advertising does not mean that you will no longer receive online ads. It only means that such ads will no longer be tailored to your specific viewing habits or interests. You may continue to see ads on and about the Service.
Emails: We will give you the ability to opt-out of marketing-related emails in the dashboard of your Pass4Success support@Pass4Success.com or clicking on a link at the bottom of each such email. You cannot opt-out of receiving certain non-marketing emails regarding the Service.
However, please note that opting-out of information sharing or collection may affect your ability to use some features of the Service. 7. Security
We believe the security of your information is a serious issue and we are committed to protecting the information we receive from you. We use commercially reasonable security measures to protect against the loss, misuse and alteration of your information under our control based on the type of Personal Data and applicable processing activity, such as data encryption in transit, data encryption at rest (for customers that elect to purchase our "private cloud" solution), pseudonymization and enforcement of least privilege and need-to-know principles.
To the extent the Service requires you to provide any Financial Account Information, such as when you purchase subscriptions to the Service, that information will be collected and processed by third-party PCI-compliant service providers. We do not store Financial Account Information transmitted through the Service, provided that we do store (or our payment processor on our behalf will store) just the last four digits of your credit card number, if you provide this to us, to comply with credit card processing requirements of authorizations, charges and chargebacks. 8. Data Retention
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with the Service and thereafter as set forth in our Service agreement with you (typically 30 days after termination of the Service, or sooner upon request (except as required by law)). In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. Upon disposal, we will destroy or render unreadable any such Personal Data. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally. 9. Interactions With Others
The Service contains areas where you may be able to publicly post information, communicate with others, submit media content and/or review goods, services, or vendors, such as discussion boards or blogs. Any information, including Personal Data that you post there, will be public and can be viewed by the public at large and therefore anyone who accesses such postings will have the ability to read, collect and further disseminate such information. We have no control over and take no responsibility for, the use, storage, or dissemination of information posted or otherwise made available on such portions of the Service. By posting Personal Data online in public forums, you may receive unsolicited messages from other parties. 10.1. Your Personal Data Accessing, Editing and Removal
You have certain rights with respect to your Personal Data and we want to help you review and update your information to ensure it is accurate and up-to-date. We may limit or reject your request in certain cases, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, if it is not required by law, or if the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question. In some cases, we may also need you to provide us with additional information, which may include Personal Data, to verify your identity and the nature of your request. We will take reasonable steps to respond to all requests within 30 days (or less!).
If you are an Pass4Success.com Account holder, you can accomplish most of the following by logging into your User Account or, for those using Corporate Accounts, by contacting your account administrator. You can also contact us directly
, if you have any additional requests or questions:
• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Erasure: You can request that we erase some or all of your Personal Data from our systems. Please note that if you request the deletion of information required to provide the Service to you, your User Account will be deactivated and you will lose access to the Service.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible. For the following, please email us:
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Service.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data. You also have the right to lodge a complaint about Pass4Success.com’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. 10.2. How to Cancel Your Account?
You may close an account and upon termination of your User Account, we will take reasonable steps to provide, modify, or delete your Personal Data as soon as is practicable. However, Pass4Success.com may nevertheless retain your Personal Data to protect the business interests of Pass4Success.com, Pass4Success.com Affiliates, vendors and other users and some information may remain in archived/backup copies for our records or as otherwise required by law. Those interests include without limitation the completion of transactions, maintaining records for financial reporting purposes, complying with our legal obligations, resolving disputes and enforcing agreements. 10.3. Users from California
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of Personal Data that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the proceeding calendar year. In particular, the law provides that companies must inform consumers about the categories of Personal Data that have been shared with third parties, the names and addresses of those third parties and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Pass4Success.com pursuant to Section 1798.83 of the California Civil Code, please contact as set forth above. 10.4. Non-US users
In operating the Site, we process data as a controller (as such terms are defined in EU General Data Protection Regulation). As a controller, the Site is committed to fulfill data subjects' ("Users") GDPR rights. 11. Implement and Expedient
Our Service is not intended for children under the age of 13 (16 in the EU) and therefore, Pass4Success.com does not knowingly acquire or receive Personal Data from children under the age of 13 (16 in the EU). If we later learn that any user of our Service is under the age of 13 (16 in the EU), we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Service. 14. How to Contact Us?
Cookies can either be "session Cookies" or "persistent Cookies". Session Cookies are temporary Cookies that are stored on your device while you are visiting our Website or using our Service, whereas "persistent Cookies" are stored on your device for a period of time after you leave our Website or Service. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent Cookies to store your preferences so that they are available for the next visit and to keep a more accurate account of how often you visit our Service, how often you return, how your use of the Service may vary over time. We also use persistent Cookies to measure the effectiveness of advertising efforts. Through these Cookies, we may collect information about your online activity after you leave our Service. 3. Cookies from 3rd-party
Some Cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Service, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party Cookies, however users may opt out from certain third party Cookies (e.g. Retargeting/Advertising cookies) by using our TrustArc cookie management solution (see Cookie Settings below). 4. What types of cookies do we use and for which purposes? 4.1. Essential Cookies
Essential (or "Required") Cookies that are required for providing you with features or services that you have requested. For example, certain Cookies enable you to sign in to secure areas of our Website or use a shopping cart feature within our Service. Disabling these Cookies may make certain features and services unavailable. 4.2. Functionality Cookies
Functional Cookies are used to record your choices and settings regarding our Service, maintain your preferences over time and recognize you when you return to our Service. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). 4.3. Performance & Analytical Cookies
Performance/Analytical Cookies allow us to understand how visitors use our Website and Service such as by collecting information about the number of visitors to the Website, what pages visitors view on our Website and how long visitors are viewing pages on the Website. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Service's content for those who engage with our advertising. 4.4. Retargeting & Advertising Cookies
Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. 5. Cookie settings
You can decide whether or not to accept Cookies. One way you can do this is through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some Service and functionalities may not work.
To explore what Cookie setting are available to you, look in the "preferences" or "options" section of your browser's menu. We also allow you the ability to opt out of certain types of Cookies by clicking on the cookie banner when you first enter the applicable website (for EU users), or by clicking here to adjust your cookie settings.