PRIVACY POLICY
Last updated November 25th, 2024
This privacy notice for SurePass Inc. (“SurePass”, "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services, such as when you:
- Use our website (our “Sites”), download and use our mobile application (SurePass), or any other application of ours that links to this privacy notice (our “Apps”), use any of our other product and service offerings (collectively, our “Service” or “Services”)
- Engage with us in other related ways, including any sales, marketing, or events
If you're a resident of California, Colorado, Connecticut, Virginia, Utah, Texas or Nevada, you should read this policy and the applicable sections below for residents of California, Colorado, Connecticut, Virginia, Utah, Texas and Nevada.
By accessing or using our Sites, Apps, or other features of our Service, you signify that you have read and understood this Privacy Notice, so please review it carefully. Please note that this Privacy Notice does not apply to our processing of information about employees or job applicants. If you do not agree with our policies and practices, your choice is not to use our Service. By accessing or using our Service, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see “Changes to Our Privacy Notice” below). Any changes to this Privacy Notice will be effective immediately on posting the updated Privacy Notice unless otherwise stated or as required by applicable law (for example, notice and opt-in or opt-out consent may be required). Your continued use of this Service after we make changes is deemed to be acceptance of those changes to the fullest extent permitted by applicable law, so please check the policy periodically for updates.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@surepass.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information?
We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.
Do we collect any information from third parties?
We may collect information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.
How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe?
We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights?
The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. TRANSFER OF YOUR PERSONAL DATA
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
Personal Information: When we use the term "personal information," we mean any information that can be used to identify you, directly or indirectly, as an individual person.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, in connection with your visits to and use of the Service, or otherwise when you contact us.
This collection includes information that you provide in connection with the Service, information from third parties, and information that is collected automatically, such as through the use of cookies and other technologies. For further information on your choices regarding your information, see the "Control Over Your Information" section below.
Personal Information Provided by You
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- contact details (such as name, email and postal address and telephone number);
- business contact information (such as employer’s name and address, job title and business email address and telephone number), as well as employment and professional license information;
- digital images and videos (such as images from your mobile device camera);
- information about your use of the Services, including personal information typed into forms on our website, whether or not you submit the form; and
- survey information
Sensitive Information
When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
- biometric data such as digital images of fingerprints, irises and face);
- physical characteristics (such as gender and height);
- government-issued identification information (such as Social Security number, passport number, Alien Registration number and driver’s license number, as well as copies of government-issued identification documents);
- payment information (such as billing address and payment card details, including card number, expiration date and security code);
- financial information (such as financial account information and details that a consumer report may contain); and
- demographic details (such as date and place of birth, citizenship, travel habits and preferences, income level, education level, family status and employment status)
Application Data
If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, nfc hardware, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
- Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
- location information (such as GPS data from your mobile device to enable a location-based service)
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, and other outside sources.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our Website usage statistics and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Improve the services we provide to our users.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We use your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also use your information for other purposes with your consent.
We use your personal information for a variety of reasons, depending on how you interact with our Services, including:
We may use information to provide you with our Services
We may use the information collected from or about you to authenticate and manage your identity when you create an SurePass account, including to verify attributes of your identity including, but not limited to, community affiliations (e.g., military status, first responder, student, veteran status, etc.), memberships, social media accounts, educational degrees, and professional certifications, as well as to provide you with customer support and account updates. We may use this information to verify your identity with SurePass partners in both the public and private sector at your request and perform our contractual obligations with you or to ensure that our Services function properly.
We may use personal information to perform reporting with our public sector customers
In order to better serve our users, and to facilitate the identity verification process, SurePass may share a limited set of personal information - including first name, last name, date of birth, phone number, email address, and physical address as requested by a specific state or federal government agency - on behalf of users undergoing legal identity verification for a given government agency. The reporting may result in the transfer of user personal information between SurePass and the originating state or federal government agency, Personal Information transferred as part of this reporting function will be in service of agency outreach to individual users concerning their status along the identity verification process, as well as to facilitate agency reporting or other administrative functions required of a given state or federal agency. Your use of SurePass for legal identity verification with a state or federal government agency constitutes consent for the use of your personal information in reporting between SurePass and the originating state or federal agency.
We may use information to perform our contracts with you
If SurePass enters into a contract with you, including in instances where you may be a vendor or service provider to SurePass or our business partner, we may use your information to fulfill our contractual obligations.
We may use information for marketing purposes
We may use your information to send promotional messages and newsletters via email, or otherwise alert you to products or Services we think might be of interest to you. You may unsubscribe from receiving marketing communications from us at any time by sending an email to info@surepass.com.
We may use information to improve our Services
We use your information to monitor and improve the operation, delivery, and general accessibility of our Services. This may also include conducting internal research and development of our Services.
We may use information to maintain the safety and security of our Services
We may use your information to protect the rights and property of SurePass and others, and to comply with our legal obligations including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements.
We may use information as otherwise permitted by law
We may use your information to resolve disputes, enforce our agreements, and as otherwise permitted or required by law.
We may use your Biometric Information
We may use your Biometric Information to verify your identity for certain partners, as well as to detect and help prevent fraud. We also may use the information in other ways with your consent, such as when you choose to use a Service or participate in a program we may offer jointly with another entity. We will never sell, rent, or trade your Biometric Information.
For additional information on how SurePass collects and, uses, and protects your Biometric Information, please see our Biometric Information Privacy Policy.
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: SurePass will not sell, rent, or trade your personal information. We will only transfer your Personal Information at your request, and with your consent, for use by third parties to verify your identity or community eligibility, or as required for the prevention of fraud or otherwise permitted by law. We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
We may share your Personal Information with entities necessary to validate your SurePass Account and provide our Services to you
In order to verify your identity and eligibility to receive benefits from our partners and other service providers, we may provide your personal information to third parties such as government agencies, telecommunications networks, financial institutions or other trusted and reliable sources of information. Our provision of your personal information to the foregoing parties is solely to verify your identity and eligibility for SurePass Services. The personal information you provide to us will be transmitted using industry standard encryption tools, designed to protect such information from unauthorized access.
We may share your information in connection with a corporate transaction
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
We may share information with third parties who perform services on our behalf
We may share your information with unaffiliated companies or individuals we hire or work with that provide us with professional advice, business support, or perform services on our behalf, including customer support, web hosting, information technology, payment processing, direct mail and email distribution, and administration, and analytics services. These service providers are allowed to use your information to help us provide our Services and not for any other purpose.
We may share information as needed in order to comply with legal processes, to protect ourselves, or improve our Services
For example, we will share information when it is necessary for us to comply with applicable law or legal process, to respond to legal claims, to prevent fraud, or to protect our rights or the property or personal safety of our users, employees, or the public.
We also use third party service providers to track and analyze website usage and volume statistical information to administer our Website and constantly improve its quality.
We may share information as required with the United States federal government and certain state governments.
SurePass does not provide any government with direct and unfettered access to our user's data, and we do not provide any government with our encryption keys or the ability to break our encryption. We may share certain Personal Information associated with a SurePass account with government entities where we reasonably believe that account may be engaging in fraud.
If a government entity requires additional information related to a SurePass account, whether related to a suspected instance of fraud or otherwise, it must follow applicable legal processes. It must serve us with a subpoena, warrant, or present other legally compelling justification for the additional information associated with the account, the request must be targeted and specific in nature.
Our legal team will review all requests to ensure they are valid, reject those that are not valid, and only provide the data specified in the subpoena or similar court order.
4. TRANSFER OF YOUR PERSONAL DATA
In Short: We may transfer, store, and process your information in jurisdictions other than your own.
Your personal information and data is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. Your consent to this privacy policy followed by your submission of such information represents your agreement to that transfer. By providing your information to SurePass or visiting the website, you are consenting to the transfer of your information to the United States for processing and maintenance in accordance with this Privacy Policy and our Terms of Service. You are also consenting to the application of Delaware law and controlling U.S. Federal law in all matters concerning your use of the Website and SurePass Service.
The Company will take all steps reasonably necessary to ensure that your personal information and data is treated securely and in accordance with this privacy policy and no transfer of your personal information and data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Users may request that we delete certain personal information at any time at support@surepass.com. We acknowledge all such requests, however we reserve the right to retain data tied to certain high-risk transactions, particularly in government, exclusively for fraud prevention and government audit purposes.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@surepass.com.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
Withdrawing your consent
If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you have questions or comments about your privacy rights, you may email us at info@surepass.com.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:
Category |
Examples |
Collected |
|
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name |
YES |
|
Name, contact information, education, employment, employment history, and financial information |
YES |
|
Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data |
NO |
|
Transaction information, purchase history, financial details, and payment information |
NO |
|
Fingerprints and voiceprints |
YES |
|
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements |
NO |
|
Device location |
NO |
|
Images and audio, video or call recordings created in connection with our business activities |
NO |
|
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us |
YES |
|
Student records and directory information |
NO |
|
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics |
NO |
|
Biometric data |
YES |
We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
- Category A - As long as the user has an account with us
- Category B - As long as the user has an account with us
- Category E - As long as the user has an account with us
- Category H - As long as the user has an account with us
- Category I - As long as the user has an account with us
- Category L - As long as the user has an account with us
Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"
How We Use and Share Personal Information
Learn about how we use your personal information in the section, "HOW DO WE USE YOUR INFORMATION?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
- Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)
- Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)
- Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
- Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us by emailing us at support@surepass.com. Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at info@surepass.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
YOUR CALIFORNIA PRIVACY RIGHTS
Under the California Consumer Privacy Act, (known as the “CCPA”) amended in 2020, California residents have certain rights regarding their personal information. This includes:
- The categories of personal information we’ve collected, and the categories of sources where we got the information;
- The business purposes for which we’ve shared their personal information;
- The categories of third parties with whom we’ve shared their personal information;
- Access to the specific pieces of personal information we’ve collected and to request deletion of that personal information, subject to certain exceptions;
- The right to opt out of the sale of their personal information;
- The right to not be discriminated against for exercising their CCPA privacy rights;and
- The right to correct inaccurate personal information.
“Sensitive” Data is defined under California state law as:
- Social security, driver’s license, state identification card, or passport numbers;
- An account login, financial account, debit card, or credit card number in combination with any required security codes;
- Precise geo-location;
- Racial and ethnic origins, religious or philosophical beliefs, union memberships;
- Contents of mail, email, and text messages to unintended recipients;
- Genetic data;
- Biometric information if used to uniquely identify a person;
- Personal health information;
- Personal information related to a person’s personal life or sexual orientation;
For purposes of these rights, “sold” and “business purpose” have the meanings given in the CCPA. For example, if you submit an opt-out request, you will not be opted out from transactions that the CCPA does not deem to be sales. In addition, please note that the CCPA does not require us to delete personal information that we need to maintain for certain purposes.
California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
YOUR COLORADO PRIVACY RIGHTS
Under Colorado’s Consumer Privacy Act, Colorado residents have certain rights regarding their personal information. This includes:
- Access to the specific pieces of personal information we’ve collected, and to request deletion of that personal information;
- The right to opt out of the sale of their personal information;
- The right to opt-out of targeted advertising; and
- The right to request correction of inaccurate personal information and to request to limit disclosure or use of your sensitive personal information.
“Sensitive” Data is defined under Colorado state law as:
- Racial or ethnic origin;
- Religious beliefs;
- Sexual orientation;
- Citizenship or immigration status;
- Biometric or genetic data;
- Information regarding an individual’s medical history, mental or physical health condition, medical treatment, or diagnosis; and
- Personal data from a known child.
If you are a Colorado resident, you have the right to request that SurePass discloses the specific personal information and categories we have collected about you. If you are a Colorado resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
YOUR CONNECTICUT PRIVACY RIGHTS
Under Connecticut’s Data Privacy Act, Connecticut residents have certain rights regarding their personal information. This includes:
- Access the specific pieces of their personal information we’ve collected and to request deletion of that personal information;
- The right to opt out of the sale of their personal information;
- The right to opt-out of targeted advertising; and
- The right to request correction of inaccurate personal information and to request to limit disclosure or use of your sensitive personal information.
“Sensitive” Data is defined under Connecticut state law as:
- Racial or ethnic origin;
- Religious beliefs;
- Sexual orientation;
- Citizenship or immigration status;
- Biometric or genetic data;
- Information regarding an individual’s medical history, mental or physical health condition, medical treatment, or diagnosis;
- Personal data from a known child; and
- Precise geolocation at a radius of 1,750 feet or less.
If you are a Connecticut resident, you have the right to request that SurePass discloses the specific personal information and categories we have collected about you. If you are a Connecticut resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
YOUR NEVADA PRIVACY RIGHTS
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?". However, please know we do not currently sell data triggering that statute’s opt-out requirements.
YOUR TEXAS PRIVACY RIGHTS
Known as the Texas Data Privacy and Security Act, Texas residents will have certain rights regarding their personal information. This includes:
- Access the specific pieces of their personal information we’ve collected and to request deletion of that personal information;
- Confirm that the data controller is processing their data;
- Correct inaccuracies in their personal data;
- Delete their personal data;
- Obtain a copy of their data in a portable and readily usable format; and
- Opt out of having their data processed for the purpose of targeted advertising, the sale of their data, or profiling that produces a legal or significant effect on the consumer.
“Sensitive” Data is defined under Texas state law as:
- Racial or ethnic origin;
- Religious beliefs;
- Mental or physical health diagnosis;
- Sexual orientation;
- Citizenship or immigration status;
- Genetic or biometric data;
- Children’s data; and
- Precise geolocation data.
If you are a Texas resident, you have the right to request that SurePass discloses the specific personal information and categories we have collected about you. If you are a Texas resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
YOUR UTAH PRIVACY RIGHTS
Under Utah’s Consumer Privacy Act, Utah residents have certain rights regarding their personal information. This includes:
- Access the specific pieces of their personal information we’ve collected and to request deletion of that personal information;
- The right to opt out of the sale of their personal information;
- The right to opt-out of targeted advertising; and
- The right to request correction of inaccurate personal information and to request to limit disclosure or use of your sensitive personal information.
“Sensitive” Data is defined under Utah state law as:
- Racial or ethnic origin;
- Religious beliefs;
- Sexual orientation;
- Citizenship or immigration status;
- Biometric or genetic data;
- Information regarding an individual’s medical history, mental or physical health condition, medical treatment, or diagnosis;
- Personal data from a known child; and
- Precise geolocation at a radius of 1,750 feet or less.
If you are a Utah resident, you have the right to request that SurePass discloses the specific personal information and categories we have collected about you. If you are a Utah resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
YOUR VIRGINIA PRIVACY RIGHTS
Under Virginia’s Consumer Data Protection Act, Virginia residents have certain rights regarding their personal information. This includes:
- Access the specific pieces of their personal information we’ve collected and to request deletion of that personal information;
- The right to opt out of the sale of their personal information;
- The right to opt-out of targeted advertising; and
- The right to request correction of inaccurate personal information and to request to limit disclosure or use of your sensitive personal information.
“Sensitive” Data is defined under Virginia state law as:
- Racial or ethnic origin;
- Religious beliefs;
- Sexual orientation;
- Citizenship or immigration status;
- Biometric or genetic data;
- Information regarding an individual’s medical history, mental or physical health condition, medical treatment, or diagnosis;
- Personal data from a known child; and
- Precise geolocation at a radius of 1,750 feet or less.
If you are a Virginia resident, you have the right to request that SurePass discloses the specific personal information and categories we have collected about you. If you are a Virginia resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at info@surepass.com or contact us by post at:
SurePass Inc.
6657 W Ottawa Ave
Ste B3
Littleton, CO 80128
United States
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at support@surepass.com
.