We may collect and use the following information about you:
1.1 Information you give us.
(a) You may give us information about you when you sign up to use the Service, e.g. when you provide us with your personal details, such as your name and email address. This also includes information you provide through your continued use of our Services, such as advertisements for Contractor services or Client work on our Site, and when you report a problem with our Services. The information you give us may include your name, address, e-mail address, phone number, financial information (including credit card, debit card, or bank account information), payment reason, geographical location, identification number, personal description and photograph.
1.2 Information we may collect.
With regard to your use of our Services we may automatically collect the following information:
(a) details of payment transactions or Contractor Agreements you carry out in connection with our Services, including geographic location from where such activity originates;
(b) technical information, including theInternet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
(c) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time of use); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support number.
1.3 Information we may receive from other sources.
We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them. For example:
(a) the banks or other payment service providers, including our Payment Service Providers, that you may use to transfer money to us or to receive money from us, may provide us with your basic personal information, such as your name and address, as well as your financial information such as your account details;
(b) business partners may provide us with your name and address, as well as financial information, such as card payment information;
(c) advertising and social media networks, analytics providers and search information providers may provide us with pseudonymised information about you, such as confirming how you found our Site;
(d) vendors or public sources that allow us to authenticate your identity or detect fraud; and
(e) government, law enforcement agencies, authorities and regulatory bodies to help RemotePass comply with its legal obligations.
2.2 We may use various social media and other third-party features on our Site. These features may involve the relevant companies using cookies or linking your visit with cookies previously placed by them on your computer in order for them to collect information relating to your visit to our website or your interaction with their services or otherwise.
2.3 You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The “Help” feature on most browsers provides information on how to accept cookies, disable cookies or to notify you when receiving a new cookie.
We use your information in the following ways:
(a) to carry out our obligations relating to our Terms of Service and to provide you with the Services;
(b) to comply with any applicable legal and/or regulatory requirements;
(c) to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(d) to notify you about changes to our Services;
(e) as part of our efforts to keep our Services safe and secure;
(f) to improve our Services and to ensure that they are presented in the most effective manner;
(g) to provide you with information about other similar goods and services we offer;
(h) to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;
(i) to allow you to participate in interactive features of our Services, when you choose to do so;
(j) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you; or
(k) to combine information we receive from other sources with the information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
4.1 We may share your information with selected third parties including:
(a) Payment Service Providers;
(b) affiliates, business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you;
(c) advertisers and advertising networks solely to select and serve relevant adverts to you and others; and
(d) analytics and search engine providers that assist us in the improvement and optimisation of our site.
4.2 We may disclose your personal information to third parties:
(a) to prevent and detect fraud or crime;
(b) in response to a subpoena, court order, or as otherwise required by law;
(c) to assess financial and insurance risks;
(d) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other applicable agreements; or to protect the rights, property, or safety of our Services, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
(e) to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
(f) to recover debt or in relation to your bankruptcy or insolvency proceeding;
(g) to develop customer relationships, services and systems; and
(h) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
4.3 If you would like further information about who we have shared your data with, or to be provided with a list specific to you, you can request this by writing to email@example.com.
As part of being a highly technical and innovative company, we may use Automated Decision Making (ADM) in order to improve your experience, or to help fight financial crime. For example, so that we can provide you with a fast and efficient service, we may use ADM to verify your identity documents, or to confirm the accuracy of the information you have provided to us. None of our ADM processes have a legal effect on you.
8.2 We will not delete data that is required to be kept by a relevant law.
8.3 Retention periods defined for the storage of your data [are].
9.1 You have the right to ask us not to contact you for marketing purposes by contacting us at firstname.lastname@example.org, or by adjusting your notification preferences in the my account setting section on our Site.
9.2 You may have the right to object to processing of your personal information by us.
9.3 You have the right to correct any personal information we hold on you that is inaccurate, incorrect, or out of date.
9.4 You may have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which to maintain it.
9.5 Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation.
Information We Collect
As described above, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).
Your Rights and Choices
Effective January 1, 2020, the California Consumer Act of 2018 (the “CCPA”) permits consumers who are California residents to ask businesses covered under the CCPA about personal data it has collected about the consumer, submit an access or deletion request, and opt-out of the sale of personal information, if applicable. These provisions do not apply to personal data collected, processed, shared, or disclosed by financial institutions pursuant to federal law such as the Gramm-Leach-Bliley Act. Therefore:
- You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
- You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
At the time your personal data is collected, we rely on legal bases for processing your information under Article 6 of the EU General Data Protection Regulation (the “GDPR”). For the purpose of the GDPR, RemotePass Inc. is the “data controller” of your personal data (as defined in the GDPR). We generally only process your personal data where we are legally required to, where processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), for our legitimate interests to operate our business or to protect RemotePass, or your, property, rights, or safety, or where we have obtained your consent to do so. You may exercise your rights under the GDPR to request a copy of your personal data or its deletion or correction.