Last Updated: November 22, 2023
HOW DO WE COLLECT INFORMATION FROM YOU?
We collect personally identifiable information we receive through your use of Passageways Websites in several ways: (i) when you register for Passageways’ Services through Passageways Websites, (ii) when you (or the Associated Entity) use the Services, and (iii) when you elect to contact us electronically to request a trial, ask a question or for other reasons.
WHAT INFORMATION DOES THE COMPANY COLLECT FROM YOU?
Via Passageways Websites, Passageways collects from you: (i) certain non-personal technical and other information and (ii) certain personally identifiable information.
All Visitors to Passageways Websites – In general, if you visit Passageways Websites without being a Registered User for any of the Services, you will be using Passageways Websites anonymously; no personally identifiable information is collected. Whether or not you are a Registered User, when you visit Passageways Websites various types of information are collected automatically and passively through cookies, log files and other tools as noted above under the caption “How Do We Collect Information From You,” including, but not limited to the following:
- the domain name and browser you use to access the Internet
- the date and time of your visit
- the pages you visited, and how many “hits” a particular item is receiving and links “clicked”
- the address of the web site you visited immediately prior to visiting Passageways Websites
- your IP address (a number assigned to your computer when you use the Internet)
- your operating system
- name of your internet service provider
- broad demographic data
- data relating to malfunctions or problems occurring when you use your computer with Passageways Websites and other customer service information
- information about your use of the Services, and particular features thereof, and how frequently you use them
Standing alone, cookies do not personally identify you; they merely recognize your computer. Unless you choose to identify yourself to Passageways, either by responding to a promotional offer, opening an account, becoming a Registered User or filling out a Web form (such as a “Contact Me” or a “30 Day Free Trial” Web form), you remain anonymous to Passageways.
Discretionary Contact With Us: Passageways Websites allow you to contact us electronically through e-mail, to request a demo or other information. Whenever you make such contact, you will be providing us with some or all of the following information: your name, email address, phone number and any information you choose to include in the text of your message. If you send an e-mail message to Passageways, initiate a chat session, or complete a questionnaire, form, or other online survey found on Passageways Websites, Passageways will maintain the information in its databases.
Registered Users –If you are a Registered User of the Services, you (or someone on your behalf) will be providing us with some or all of the following registration-related information: full name, address, phone numbers, e-mail address, website address, and financial qualification and billing information, such as billing name and address, payment information, and the number of employees and others within or associated with the Associated Entity.
In addition, Registered Users or authorized persons within the Associated Entity will provide to us data, documents, materials, and information to be posted, distributed, or received by Users of Passageways Websites Site(s) (collectively, “Posted Content”).
In addition, when you or other Registered Users use the Services, certain meta-data associated with your use of the Services will be collected, including, but not limited to:
- the number of meetings
- the number of agenda sections
- the number of files uploaded to the agenda
- the number of groups
- the number of active users
- the number of pending/inactive invites
- the number of approvals
- the number of attachments per approval
- the number of resources
- the number of announcements
- the number of actions in a meeting
Tracking: We do not engage in the collection of personally identifiable information about your online activities over time and across third party website or online services, and we do not allow third parties to collect personally identifiable information from Passageways Websites as part of their tracking of such online activities. Accordingly, we do not currently process or comply with any web browser’s “do not track” signal or other mechanisms that provide consumers with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third party website.
HOW IS YOUR INFORMATION USED?
Our Use of Information. We collect, retain, and use the information we collect via Passageways Websites for legitimate business purposes only. This not only allows us to provide the Services as they exist today, but it also allows us to provide you with innovative features and services we develop in the future. For example, we may use the information we receive about you:
to provide you with our Services;
- to help keep Passageways Websites safe and secure, and protect users’ rights or property;
- to correspond with you regarding our Services or matters relating to your use or potential use of Passageways Websites, or to inform you of developments in our company or with our Services that we believe may be of interest to you. For example, if you fill out a “Contact Me” Web form, Passageways will use the information provided to contact you about your interest in the Services. Passageways may also use information we collect for products and event information dissemination purposes.
Sharing of Information. Your trust is important to us, which is why we don’t share information we receive about you with others. Moreover, we do not sell or rent your personally identifiable information to third parties for marketing purposes.
However, notwithstanding the foregoing, we may share your personal information in limited situations as follows:
- to protect and defend our rights, property, or safety or those of our Registered Users, or others; and in connection with the enforcement of terms which may govern Passageways Websites or provision of the Services;
- when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities (such as for potential fraud or infringement);
- when required to do so by law or regulation, or in response to legal process (for example, a court order, search warrant or subpoena) or a request from a law enforcement or governmental agency or authority, and in other circumstances in which we have a good faith belief that a crime has been or is being committed by you or another User or that an emergency exists that poses a threat to the safety of you or another person; and
- aggregate statistical information with respect to “traffic” patterns and usage of Passageways Websites may be provided to our partners or affiliates; provided that such information has been rendered non-personally identifiable.
MODIFICATIONS TO INFORMATION
We strive to maintain the accuracy of any personally identifiable information that may be collected from you, and will use our commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. [We do not currently provide you with online access to your registration or account information, or the ability to edit this information.] It is your responsibility to ensure that such information is accurate, complete and up-to-date. You may obtain from us, by e-mail the registration information in our records and/or files. Information will be updated as soon as reasonably practicable.
YOUR RIGHTS TO ACCESS YOUR PERSONAL DATA AND LIMIT ITS USE AND DISCLOSURE
You have control over your personal data and how we collect, use and share personal data that you have provided to us. If you wish to access, correct, modify or delete your personal data or if you have any question regarding this policy, please contact us.
You can download a copy of your personal data or request a copy of the personal data you provided to Passageways by contacting us at [email protected]. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law.
If you ask to delete a personal account with Passageways, Passageways will initiate deletion of this data after 30 days. Please note there may be some latency in deleting this data from our servers and storage and we may retain this data if necessary, to comply with legal obligations, resolve disputes or enforce Passageways’ agreements.
For any concerns, requests, or to exercise your data protection rights, please email us at [email protected]
All emails will contain links allowing you to opt-out of receiving such information. In addition, you may opt out of receiving materials or other communications from us and our affiliates by contacting us via email at [email protected].
In compliance with the Children’s Online Privacy Protection Act, 15 U.S.C. §§ 6501-06 and 16 C.F.R. §§ 312.1-312.12, Passageways will not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use the services of Passageways Websites. If you are under 13, please do not use Passageways Websites or send any information about yourself to us, including your name, address, phone number, or email address. By using Passageways Websites, you represent that you are not under 13 years of age.
PROTECTING YOUR PERSONALLY IDENTIFIABLE INFORMATION
Passageways may, in the future, sell or otherwise transfer some or all of its assets to a third party. Your information, including personally identifiable information and technical and usage information we obtain from you directly or automatically via Passageways Websites, may be disclosed to any potential or actual third party purchasers of such assets and/or may be among those assets transferred. In such instance, we will use our best commercial efforts to provide you with written notice of such transfer.
USERS OUTSIDE THE UNITED STATES
When a user who is located outside the United States becomes a Registered User of our Services and make certain information available to Passageways, it is the Registered User who is responsible for ensuring whether such actions and the sharing of information with Passageways through Passageways Websites conforms to all local data protection laws. Passageways is not responsible under the local data protection laws for information obtained through Passageways Websites.
All sales of OnBoard Begin are final and we do not offer refunds. If you cancel your OnBoard Begin account, we will stop billing you, but will not refund past invoices.
EFFECTIVENESS AND POLICY MODIFICATIONS
DATA PRIVACY FRAMEWORK
Passageways complies with the EU-U.S. Data Privacy Framework (EU-US DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-US DPF Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Passageways has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Policy and the EU-US DPF Principles or Swiss-U.S. DPF Principles (collectively, the Principles), the Principles will take precedence. To learn more about the Data Privacy Framework, please visit https://www.dataprivacyframework.gov. You may view our self-certification on the Data Privacy Framework List.
Passageways is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. We also may be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requests.
Individuals in applicable jurisdictions, may request to access their User Data and HR Data, and to limit use and disclosure of this information, in accordance with the DPF Principles. To make such a request, please contact us at [email protected]. If your request involves personal information contained in User Data that we process on behalf of an enterprise customer, please direct your request to that enterprise customer.
Passageways is responsible for personal information that it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. Passageways complies with the DPF Principles for all such onward transfers of personal information, including the onward transfer liability provisions.
Individuals with inquiries or complaints regarding our compliance with the DPF Principles should first contact us at [email protected]. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit our U.S.-based third-party dispute resolution provider at https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. JAMS’ services are provided at no cost to you.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Passageways also commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (“DPAs”) and the U.K. Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to any unresolved complaints concerning our handling of human resources data in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.
For complaints regarding DPF compliance that are not resolved by any of the other DPF mechanisms, you may have the possibility, under certain conditions, to invoke binding arbitration before a Data Privacy Framework Panel.