Privacy Policy

Last updated: October 2, 2020

RemotePass Inc.(“RemotePass”) respects and protects the privacy of visitors to our Site and our Users. This Privacy Policy describes our information handling practices when you access our Services or Services. Capitalized terms used herein and not defined are defined in the RemotePass Terms of Service.

Please take a moment to read this Privacy Policy carefully. If you have any questions about this Policy, please submit your request to privacy@remotepass.com. By accessing and using our Site or Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue accessing the Site or use of our Services. Please note that information transmitted over the internet is never completely secure.  We may provide you with additional disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.  To keep up with changing legislation, best practice and changes in how we process personal information, we reserve the right to amend this Privacy Policy at any time without notice by posting a revised version on our Site. To stay up to date on any changes, check back periodically.  

1. Information we may collect from you

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. 

(b)   If you provide to us the personal data of any individual (other than yourself) during your use of our Services, you certify that you have obtained consent from such individual to disclose such data to us, as well his/her consent to our collection, use and disclosure of such personal data, for the purposes set out in this Privacy Policy.

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. Cookies 

2.1  Our Site may use cookies to distinguish you from other users. This helps us to provide you with a good experience and also allows us to improve our Services.  Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and transferred to your device.

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.

 

3. Uses made of the information we collect or receive

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. Disclosure of your information

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 privacy@remotepass.com.

5. Where we store your personal data

5.1 The data that we collect from you may be transferred to, and stored at, a destination outside of the United States. It may also be processed by our staff operating outside the United States who work for us or for one of our suppliers or Payment Service Providers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

 

6. Profiling and automated decision making

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.

 

7. Link to other sites

Our Service may contain links to other sites, Payment Service Providers, and other third parties that are not operated by us. We strongly advise you to review the Privacy Policy of every such party. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. 

8. Data retention

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. Your rights regarding your data

9.1 You have the right to ask us not to contact you for marketing purposes by contacting us at support@remotepass.com, 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.

 

10. Other

If you have any questions or comments about this Privacy Policy or the ways in which we collect and use your information, please do not hesitate to contact us at: privacy@remotepass.com.

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This PRIVACY NOTICE IS FOR CALIFORNIA RESIDENTS ONLY and supplements the Privacy Policy above.  

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.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: privacy@remotepass.com or by mail at RemotePass Inc., 6 Liberty Square 290, Boston, MA 02109, United States. We will not discriminate against you for exercising any of your CCPA rights.

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This PRIVACY NOTICE IS FOR EEA RESIDENTS (individuals who are located in the European Economic Area, United Kingdom or Switzerland) ONLY and supplements the information contained in the Privacy Policy above.

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.  

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal data, your choices and rights regarding such use, or wish to exercise your rights under the GDPR or applicable implementation statute, please do not hesitate to contact us at: privacy@remotepass.com.