How Does It Work?
- We try to know as little as possible about you.
- It's okay to use an anonymous email.
- Your info is not sold, traded or disseminated.
- Your email is used for emergencies, notifications and support only.
- Change the email associated with your account.
- Delete your account whenever you'd like.
- Ask us what information we have on file for you.
- Request that we delete all traces of you in our systems, including support emails.
This web site, Passpack.com, is administered by Passpack Srl. We appreciate your visit to our site and welcome your interest in our services. Passpack recognizes the importance of information by which you can be identified, such as your name, address, or e-mail address ("Personally Identifiable Information"). Privacy protection is, after all, our mission.
When you visit this web site, Passpack may collect Personally Identifiable Information about you, either directly (where you are asked to provide the data, for example during registration for the service) or indirectly, as explained further on. Passpack will, however, only use this Personally Identifiable Information in accordance with the purposes set forth in this Privacy Statement and is absolutely committed to safeguarding the personal information collected.
This is an official informative note pursuant to, and to the effect of, article 13 of Italian Personal Data Protection Code (Legislative Decree no. 196/2003) provided to whoever visits Passpack's web site or uses the Passpack service. Passpack is required by law to uphold this Privacy Statement.
By using the Passpack service and this website, you consent to the information practices described in this policy. Keep in mind that your use of the Passpack service is also subject to, and controlled by, the Passpack Terms and Conditions and the Passpack User Agreement.
Data Controller (this is us)
The Data Controller and Contact Person for Data Protection is Tara Lyn Kelly. Should you have any questions about this Privacy Statement or our data processing activities, recommendations or complaints concerning the protection and privacy of your Personally Identifiable Information, or should you want to exercise the rights mentioned here within, please contact us
via e-mail at: firstname.lastname@example.org
or via fax at the numbers listed here
to the attention of: Tara Lyn Kelly
By including the phrase "Privacy Request" in the subject link of your communication, you will help us service your request more quickly.
Data Processing Locations (these are our facilities)
Data processing associated with customer support for the Passpack website and service is located at the Data Controller's address and is subject to Italian Laws. The data center where Passpack's servers are housed is located in Canada, and is subject to Canadian Laws.
Rights of the Data Subject (that's you)
You can request a summary of the information that we have about you by emailing us at email@example.com. If you find any inaccuracies we will delete or correct them promptly.
These are your rights as set out by article 7 of the Italian Persona Data Information Protection Code (Legislative Decree no. 196/2003):
"A data subject shall have the right to
a) update, rectify or, where interested therein, integrate the data;
b) obtain erasure, anonymization or blocking of data that has been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) obtain certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected."
That means that if we have wrong information about you, you have the right to correct it. And if you feel that we wrongly used your data, or if you feel there is no longer any reason why we should have it (for example, if you delete your account), you can request that we remove every reference to you in our systems. Letter C is a little harder to explain, it states that you can request certification from Passpack that all of your information has indeed been removed. This is usually only applicable when the removal happens in person, as once we remove your data, we no longer have any means of getting in contact with you.
"A data subject shall have the right to object to, in whole or in part,
a) on legitimate grounds, to the processing of Personally Identifiable Information concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of Personally Identifiable Information concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys."
That means that you always have the right to object to the way your data is being treated, or even which data we require of you. Please keep in mind that Passpack only collects the minimum data needed to offer our service to you.
Changing or Removing Information
In an effort to facilitate your ability to enact your rights, and to ensure that you have appropriate control over your Personally Identifiable Information, the Passpack service includes an interface where you can change your Registration or Customer Information and notification preferences. You can access this interface by clicking on the "Account" tab from within your personal account on the Passpack service.
If at any time you would like to delete your Personally Identifiable Information from other systems outside of the Passpack service (for example, customer service emails) you can send an e-mail request to firstname.lastname@example.org. After receiving your request, such information will be deleted assuming (i) you are current with all payment obligations; (ii) Passpack does not believe it is reasonably necessary to keep such information for any pending legal action; and (iii) we are under no other legal obligation to retain such information. If such information is deleted, however, any unfulfilled subscriptions will be canceled without refund and you will have to re-register with Passpack in order to use the Passpack service. Because of the irreversible nature of account deletions, we will attempt to verify your identity as the proper account holder, or ask you to confirm your intent before proceeding.
Since Anonymous Information is by its very nature non-personally identifying, we have no way to locate Anonymous Information obtained by your use of the service. In addition, Anonymous Information is often aggregated. Therefore, we cannot remove Anonymous Information obtained from you or as a result of your usage of the website or service.
Personally Identifiable Information is information that can be used to locate you, contact you, or determine your specific identity. When other information is linked to Personally Identifiable Information, it also becomes Personally Identifiable Information.
In general, you can visit the Passpack web site without providing Personally Identifiable Information. It is Passpack's goal to collect as little Personally Identifiable Information as possible, however there may be some occasions where it may be collected. For example:
- When you register for the Passpack service, you are required to provide a User ID, or an equivalent third party authentication service. You may also optionally provide an Email address ("Registration Information"). An activation code will be sent to the email address provided to confirm its validity and to ensure that it was not accidentally mistyped. The Passpack application provides an interface where you can correct this information, request a new activation code to be sent, or even change the email associated with your account in the future. Should a valid email account not be provided and confirmed, Passpack may not be able to provide you with any customer support requests.
- When you place an order or subscribe to a paid version Passpack service, we may collect the appropriate billing information, including your credit card number, expiration date, and billing address ("Billing Information"). This information may associated with your Registration Information in a database and kept for future purchases.
- When you submit a request for more information, support or assistance, Passpack will keep a record of the request and the manner in which it was processed ("Customer Service Information").
- We may ask you for voluntary personal information at other times, including but not limited to when you provide opinions, enter a contest or promotion, or report a problem with the Passpack service ("Optional Information").
- Should you decide to comment on the Passpack blog, forum, or community board you may need to provide an email address - this will not be made visible to others. You may also optionally choose to provide your name and a URL - these will be made visible to others.
Your response to the above requests for information is strictly voluntary: if you do not provide the information we request, you can still visit the informative sections of our website but you may be unable to register or maintain an account with the Passpack service.
By submitting your information you consent to the use of that information as set out in this Privacy Statement.
Collection of Non-Personally Identifiable (Anonymous) Information
Whenever you visit the Passpack site, we may also automatically receive and record information from your browser, including your IP address, your computer's name, the type and version of your web browser, referrer addresses, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information.
This information is collected automatically by the system and the software procedures dedicated to the operating of this web site and requires no action on your part. With the exception of your IP address which is used to support various security related features (such as the Anti-phishing welcome message), this information is not associated with your Personally Identifiable Information.
This data enables us to become more familiar with which parts of the world visitors to our site come from, how often they visit, and what parts of the site they visit most often. We analyze this data for trends and statistics, we use them exclusively to help us better understand how our site is being used, to improve the value and user-friendliness of our web site and to detect any technical problems as early as possible. To help us record and understand our website traffic we may also use a third party service, such as Google Analytics or website page counters - in which case absolutely no Personally Identifiable Information is recorded by the third party service, nor associated with the aggregate anonymous website data.
Passpack does not specifically seek to collect sensitive Personally Identifiable Information (such as data revealing political opinions, religious beliefs or data concerning health or sex life) through this site. If Passpack does seek to collect such data, your prior consent hereto will be asked.
The very nature, however, of the Passpack service is to provide a place for you to store and protect sensitive data such as, but not limited to, passwords. The data you choose to store and manage via the Passpack application is not considered "collected" data in that it is encrypted and can not be decrypted or read by Passpack or any other third party. Only those with access to your private decryption key (also known as the Packing Key) can decrypt and read the data you store at Passpack.
Your Personally Identifiable Information will be processed manually and/or by automated systems that guarantee security and confidentiality, in strict accordance with, and complete respect of, the purposes described in this Privacy Statement.
Some pages on this site use "cookies," which are small files that the site places on your hard drive for identification purposes. Cookies are alphanumeric identifiers that we transfer to your computer's hard disk which help our servers recognize your computer when you visit again, so that it is easier for you to navigate on our web site and make the best use of your visit. You should note that cookies cannot read data off of your hard drive. Your web browser may allow you to be notified when you are receiving a cookie, giving you the choice to accept it or not.
Disclosure of Personally Identifiable Information
Your Personally Identifiable Information will not be matter of dissemination. The data will be disclosed to the employees or third parties expressly appointed by the Data Controller as Data processor and the individuals in charge for the data processing.
We will not provide, sell, barter or trade any information about you to/with any third parties, without your express permission and, above all, we will not sell this data to commercial users or make them available in any other form.
In general, we will not disclose your Personally Identifiable Information to unaffiliated third parties without your express consent. If we seek your consent to disclose your Personally Identifiable Information to a third party, we will do so unambiguously, explaining precisely what information we seek to disclose, the entity to whom we wish to disclose it, and the purpose for the disclosure.
There are, however, some limited circumstances in which we may need to disclose Personally Identifiable Information about a user, and we want you to know about them:
- We may employ other companies to perform functions on our behalf, such as fulfilling orders, providing customer service, processing credit card payments, or other functions necessary to our business. We may therefore need to share your Personally Identifiable Information to banks or financial institutions, service companies, consultants, contractors and to the relevant Authorities imposed by law. The data you submit may be transmitted abroad, even outside European Union, only to our affiliated companies, in compliance with the requirements set forth by the privacy laws in force. However, we will provide them with only that information necessary to perform their functions, and will not allow them to use that information for any other purpose.
- Responses to requests for information necessary to provide you with the products you purchase or subscribe to through the Passpack service may contain Personally Identifiable Information. Passpack will provide the authors of such products the information you supply in response to those requests. The information practices of those publishers are not covered by this Privacy Statement. Your name, address, phone number, and email address, will not be shared with the Authors.
- We may reveal a user's identity (or whatever information we know about that individual) if we believe that user is harming or interfering with other Passpack users, anyone else, or violating (either intentionally or unintentionally) our Terms and Conditions or infringing any of Passpack's legal rights.
- Passpack will reveal information, including Personally Identifiable Information, to the extent it reasonably believes it is required to do so by law. If we receive legal process calling for the disclosure of any of your personally identifiable information we will, if permitted by law, attempt to notify you via your e-mail address, if, and only if, we have one on record, within a reasonable amount of time before we respond to the request.
- Passpack may transfer information it collects, including any Personally Identifiable Information, in connection with a sale of all or most of the assets of the company. Should your Personally Identifiable Information be transfered as the result of such sale, you will be notified in your Account.
Use and disclosure of Anonymous Information
Anonymous Information is any information collected from you or by the Passpack service, other than Personally Identifiable Information, including aggregate information derived from Personally Identifiable Information.
Passpack may use Anonymous Information to improve the Passpack website and service, to monitor traffic and general usage patterns, and for other general business purposes.
Passpack may disclose Anonymous Information to third parties for a variety of business reasons, including to publishers to inform them as to what content is appealing to their readers, to advertisers to inform them of the usage habits or characteristics of the interested audience, and to potential investors so that they may better understand Passpack's user base, etc.
Anonymous Information will not include any Personally Identifiable Information and Passpack will not disclose any Personally Identifiable Information except as expressly stated elsewhere in this policy.
We employ reasonable and current security methods to prevent unauthorized access, maintain data accuracy, and ensure correct use of information. Your personal data will be stored within a database that is located behind a firewall. The server housing the database is physically protected at a secure data center.
Any transmission to the Passpack web site or service of Personally Identifiable Information or credit card information uses SSL encryption.
Other Web Sites
Please note that the informative note is given only for the Passpack web site and application: this Privacy Statement does not extend to third party sites linked to this web site.
The Passpack service is not directed to children (persons under the age of 18), and we do not knowingly collect, either online or offline, personally identifiable information from children.
From time to time, Passpack may change this Privacy Statement. If we make any changes regarding disclosure of Personally Identifiable Information to third parties, then we'll notify you by pop-up screen prior to the date the modified policy takes effect. We will also post conspicuous notice of the new policy on our home page. Any new policy will have prospective effect only, meaning it will not apply to information previously gathered without your express consent.
Please check this Privacy Statement from time to time for any changes.