Privacy Policy
Introduction
This Privacy Policy ("Policy") describes how SurePass, Inc. ("SurePass," "we," "our," or "us") collects, uses, discloses, and protects personal information when you use our websites, applications, and services (collectively, the "Services"). By accessing or using the Services, you agree to the terms of this Policy. If you do not agree, please do not use the Services.
Categories and Sources of Personal Information We Collect
We collect personal information from you, automatically from your device and browser, and from third parties. The following table summarizes categories of personal information we may collect, examples, whether we collect them, and typical sources.
| Category | Examples | Collected | Source |
|---|---|---|---|
| Identifiers | Name, email address, business contact information, postal address, account name, unique identifiers, IP address, device ID, government-issued ID | Yes | You; Your browser/device; Service providers |
| Personal information (general) | Contact information, payment card details (processed by a payment processor), employment and business profile info you provide | Yes | You; Service providers |
| Protected classification characteristics | Race, religion, sexual orientation, disability, etc. | No | Not applicable |
| Commercial information | Records of products/services purchased, obtained, or considered; purchase histories or tendencies | Yes | You; Service providers |
| Biometric information | Fingerprints, facial scans, voiceprints | No | Not applicable |
| Internet or network activity | Browsing and search history; interaction with our site, app, or ads; device and analytics data | Yes | Your browser/device; Analytics providers |
| Geolocation data | Approximate location inferred from IP; precise location if you enable it | Yes | Your browser/device; With your settings/consent |
| Sensory data | Audio, electronic, visual, or similar information | No | Not applicable |
| Professional or employment-related information | Role/title, employer, business contact details you provide | Yes | You; Your Employer |
| Education information (non-public) | Student records | No | Not applicable |
| Inferences | Profiles about preferences or characteristics | No | Not applicable |
| Age or date of birth | Age or date of birth if you provide it | Yes | You |
Information Collected Automatically (Cookies, Pixels, and Similar Technologies)
We and our service providers use cookies and similar technologies to operate, secure, analyze, and personalize the Services. A cookie is a small file placed on your device that helps remember your settings and collect analytics such as pages viewed, referring/exit pages, and clickstream data. You can manage cookies through your browser settings; if you disable cookies, some features may not function properly. If we use a cookie banner or preferences center, you can adjust preferences there (e.g., strictly necessary, performance, functional, and targeting cookies).
We may also use pixel tags (web beacons/clear gifs), local storage (HTML5), JavaScript, and permit third parties to use these technologies to provide analytics and advertising. Third parties are prohibited from using information for purposes other than providing services to us.
Information from Third Parties
We may receive information about you from third-party sites or applications where we post content or invite your feedback or participation, and from service providers who support our operations (e.g., analytics, fraud prevention, customer support, payment processing).
How We Use Personal Information
We use personal information for the following purposes, which are reasonably necessary and proportionate to provide and improve the Services and as otherwise permitted by law:
- Provide, operate, and maintain the Services and fulfill transactions and requests.
- Communicate with you, including responding to inquiries and sending service-related notices.
- Personalize content and experiences.
- Perform analytics, research, troubleshooting, and quality assurance.
- Improve and develop the Services and our business.
- Detect, investigate, and help prevent fraud, security incidents, and other malicious or unlawful activity.
- Protect our rights, users, and property; enforce terms and policies.
- Comply with legal obligations and respond to lawful requests.
- With your consent, send marketing communications you can opt out of anytime.
Disclosure of Personal Information
We disclose personal information to:
- Service providers who process information on our behalf under contracts restricting use to our instructions.
- Affiliates.
- Other parties at your direction or with your consent (e.g., social media platforms, partners you engage).
- Successors or assigns in connection with a corporate transaction (see "Transfer of Corporate Assets").
Service Providers
Service providers support functions such as:
- Hosting, technology, and communications
- Security and audits
- Analytics and research
- Marketing support (e.g., sending newsletters or surveys)
- Payment processing and fraud prevention
SurePass does not sell or share your personal information as those terms are defined under applicable U.S. state privacy laws.
Sensitive Personal Information
If we collect sensitive personal information, we use or disclose it only as reasonably necessary and proportionate to provide requested services and for other limited purposes permitted by law, such as security, fraud prevention, and short-term transient use. We do not use sensitive personal information to infer characteristics or for additional purposes without offering required choices.
De-Identified and Aggregated Information
Where appropriate, we apply data minimization by de-identifying information before processing or transferring it to fulfill certain requests. We maintain and use de-identified information without attempting to reidentify it, except solely to test and validate our de-identification processes.
Your Privacy Rights
Depending on your state of residence and subject to exceptions, you may have the right to:
- Know/access the categories and specific pieces of personal information we have collected about you, the categories of sources, purposes of use, categories of third parties to whom we disclose information, and categories of information disclosed.
- Delete personal information we collected from you.
- Correct inaccurate personal information we maintain about you.
- Know whether we sold or shared personal information and to whom.
- Opt out of sales or sharing of personal information (if applicable).
- Limit the use and disclosure of sensitive personal information (if applicable).
- Obtain your information in a portable, readily usable format (data portability).
- Be free from discrimination for exercising your rights.
How to Exercise Your Rights
- Submit our online request form: [Insert secure web form URL]
- Email: privacy@surepass.com
We will take steps to verify your request and identity. We will respond within 45 days where required by law, which may be extended by an additional 45 days where reasonably necessary, and we will inform you if we decline your request and explain why. If you use an authorized agent, we may require proof of authorization and direct verification by you where permitted.
Opt-Out Preference Signals
If your browser or device offers a recognized opt-out preference signal, configuring it to opt out of sale or sharing will be honored where required. If you clear cookies, change settings, or use a different browser or device, you may need to re-enable your signal.
Data Security
We implement commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, unlawful processing, and accidental loss, destruction, or damage. No security program can guarantee absolute security.
Data Retention
We retain personal information for as long as reasonably necessary and proportionate to achieve the purposes for which it was collected and other compatible purposes disclosed, and as required or permitted by law (including to meet legal, tax, accounting, or reporting requirements).
Children's Privacy
We do not knowingly collect personal information from children under 16. If we learn we have collected such information, we will delete it. If you believe a child under 16 provided personal information to us, please contact us at privacy@surepass.com.
Do Not Track and California "Shine the Light"
We do not currently respond to browser "Do Not Track" signals. California residents with an established business relationship may request certain information regarding our disclosures of personal information to third parties for their direct marketing purposes and may opt out of such disclosures.
International Users
If you are located outside the United States, please note that we may process and store information in the United States and other countries with different data protection laws. For EU/UK inquiries or to exercise rights available under applicable law, contact privacy@surepass.com.
Links to Third-Party Sites and Services
Our Services may link to third-party websites or services that are not controlled by SurePass. We are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party site or service you visit.
Transfer of Corporate Assets
We may transfer personal information in the event of a corporate transaction (e.g., merger, acquisition, financing, sale of assets, reorganization, bankruptcy, or receivership). Where feasible, we will require the recipient to honor this Policy or provide comparable protections.
Changes to This Privacy Policy
We may update this Policy to reflect changes in our practices, technologies, legal requirements, or other factors. If changes are material, we will provide notice as required by law, such as by posting a notice on our website, within our Services, or by contacting you directly.
Contact Us
- Email: privacy@surepass.com
- Address: SurePass, Inc., 6657 W Ottawa Ave, Ste B3, Littleton, CO 80128