Passen Inc. Privacy Policy

 

Updated: April, 18 2018

We are Passen Inc. (“Passen” or “we”, “us” or “our” as context dictates) and we allow consumers to obtain detailed body measurements and permit stores to provide consumers with the best possible fit for their clothing using our solution. This Privacy Policy (“Privacy Policy”) applies to our app, services, features, software, and website (together, the “Services”) unless specified otherwise, and  sets out our approach to any data that is collected upon the use of the Services by a user and which may be used to personally identify such user (“Personal Data”). 

We are committed to preserving the privacy of all individuals who use our Services and this Privacy Policy is designed to help you understand how your Personal Data is collected, used and disclosed when you engage with us on the Services.  Before registering, submitting any content or Personal Data, or otherwise using our Services, please make sure that you read this entire Privacy Policy as well as our terms of use (our “Terms”) here

Please keep in mind that in the course of engaging with us, you may use a third party’s intellectual property, tool or resource (e.g. for payment processing), or click on links to third-party websites, in which case such third party’s privacy policy may also apply to you. We encourage you to read and review each privacy policy that applies to you as our Privacy Policy terms may differ from the terms contained in third parties’ privacy policies. We do not endorse or in any way guarantee performance or accept liabilities with respect to such third-parties.  

If you have any objections to the terms in this Privacy Policy, you should not use the Services or provide us with any of your Personal Data. If you have any hesitations or are unsure about any of the terms, contact us at hello@passen.com

 

PART A – COLLECTION OF INFORMATION

Information contained on the Services is collected by Passen from consumers and from stores partnered with Passen (“Partners”). We obtain your express consent to use your information when you complete a Customer Profile with us, and we always obtain your express consent to collect your Personal Data when you require that your Customer Profile be updated.

We may collect additional Personal Data that you disclose to us through your use of the Services as well as other information as set out below.

 

1. Personal Data You Provide

Your voluntary disclosure of Personal Data may include, but not be limited to:

·  basic Personal Data, including your name, height, weight, gender, and age;

·  contact information, including phone number, email, and mailing address; and

·  any feedback you provide regarding our products and services which may have content which is Personal Data,

as you engage with the Services to assist with your shopping experience.

Collection of this Personal Data is necessary for us in order to carry out the applicable actions (as set out under Part B below). If you do not consent to certain uses of information, we may not be able to provide you with a particular benefit or service.

 

2.   Information Collected Automatically

During your interaction with the Services, we may collect and store anonymous information (“Automatic Information”) about you using various technologies including, without limitation, Cookies, which are alphanumeric identifiers that are stored on your device with which you access the Services, and Internet tags. Some of this information is automatically transmitted to us through your browser.

 

PART B – USE OF YOUR INFORMATION

To accomplish any of the purposes listed below, we may combine Personal Data and Automatic Information, and non-Personal Data collected through your use of our Services.  This information may be used in a variety of ways which are in keeping with the intent behind the collection of information. For instance, the Personal Data provided by you may be used:

·             to provide Partners with detailed information about your body measurements to assist in identifying outfits for you;

·             to identify shopping habits and better pinpoint suitable attire;

·             to provide recommendations for better fitting attire;

·             to perform internal reviews of the effectiveness of Passen software;

·             to prepare reports for Partners including aggregate data of their customer base; or

·             to improve our services or provide you with information you requested.

 

In addition, the Automatic Information collected may be used to, among other things:

·             monitor characteristics of and statistics on Services usage; and

·             refine our Services’ features and functionality.

 

We also reserve the right to use Personal Data and Automatic Information as set forth in our Terms, if applicable.

 

PART C – DISCLOSURE OF YOUR INFORMATION

 

1. To Help with Business Operations

In addition to the above-listed uses, we may disclose your information to the extent required to administer your benefits. For example, we may disclose your Personal Data to Partners other than the ones you currently shop with, but who may be of interest to you in the future. From time to time, we may engage companies or individuals for certain services on our behalf including, without limitation, conducting audits, performing legal services, collecting feedback, and providing customer service. Our Business Partners and any other third-party service providers will only have incidental access to Personal Data to the extent required to perform their services. They are prohibited from the use of your Personal Data for any purpose other than assisting with our business operations.

2. Safety and Security

We may also disclose your information as necessary to protect the safety or security of users of our Services, to detect and prevent fraud or abusive behaviour, or when otherwise required or permitted by law.

3. Transfer or Sale

In the event that we sell, transfer or otherwise dispose of our business to an affiliate, successor, assign or other third party entity, we may disclose Personal Data.  However in the event that such a transaction occurs, your information will remain subject to the terms of any pre-existing Privacy Policy.

4. Legal Requirement

We may disclose your information, if required, to:

·             supervisory authorities, tax authorities, police and other regulatory authorities as required by law or in response to a subpoena, court order, or other legally valid inquiry or order; and

·             to either prevent/minimize a criminal offense or to protect a person’s rights and personal and or financial health.

5. Consent
In addition to permissions already granted under this Privacy Policy by you, we may provide, disclose or transfer your Personal Data with your consent provided either as a part of the services you receive from us or in writing by you otherwise.

 

PART D–PROTECTING, RETAINING AND STORING YOUR PERSONAL DATA

1. Protection. In order to help prevent unauthorized access to, maintain data accuracy and ensure the correct use of your information, we have put in place commercially reasonable physical, electronic (e.g. SSL (secure socket layer) server authentication) and managerial procedures to safeguard and secure the information we collect through our Service.  That said, we cannot guarantee that information provided to us will remain private, or that the information you transmit to us over the Internet will not be intercepted.

2. Storage. We have strict safeguards in place to ensure that your personal information, in both paper and electronic form, is only accessed internally by those who need it to service users. All of our employees, agents and representatives are aware of the sensitive nature of the information we hold and have agreed in writing to keep personal information in their possession strictly confidential.

Your information is currently stored in Canada However, we retain the right to transfer your information to an affiliate or third party to protect the information or for internal business reasons as we see fit. BY AGREEING TO THIS PRIVACY POLICY, YOU AGREE AND CONSENT TO US DOING SO WITHOUT YOUR FURTHER CONSENT.

3. Identification. To help prevent unauthorized access to your Personal Data you are responsible for keeping the username and password (collectively, “ID”) that you receive upon opening any accounts with us private and confidential. You are solely responsible for preventing the unauthorized use of your ID.  If you suspect that your information has been compromised or that your account has been accessed without your consent, please contact us immediately at hello@passen.com

4. Retention: We may store your Personal Data from the date of collecting such information for a period of 5 years after your membership expires or service access is terminated, whichever period may be longer.  It is securely destroyed or anonymized thereafter.

 

PART E – ELECTRONIC COMMUNICATIONS

Should you submit an inquiry through our Services, or otherwise communicate with us electronically, you consent to us responding to such inquiries electronically. We cannot guarantee that information that we send to or receive from you over the Internet will not be intercepted.

 

PART F – ACCESSING AND MODIFYING YOUR PERSONAL AND ACCOUNT INFORMATION

We want to ensure your Personal Data is accurate and up to date. If you notice any inaccuracies, please let us know.  You can also access and modify your personal and account information using the tools provided in our Services. We will not modify your personal or account information.

At any time, you may request access to your Personal Data by contacting hello@passen.com. We will respond to your request within a reasonable time period, and process it “as appropriate under applicable law”. Your request may be subject to a processing fee as allowed under law.

 

PART G – CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy, and any other policies and procedures concerning our practices for managing collection and use of information, at any time without prior notice to you. If this Privacy Policy is modified, we will post the most current version to our Passen App. We will also post a notice of the change on any applications for four (4) weeks after any changes are made. At the top of the modified Privacy Policy we will include the date upon which it was last updated. Any changes that are made to this Privacy Policy will apply to both information that we hold prior to the effective date of the amended Privacy Policy and to any information collected on or after such effective date. Our successors and assigns may collect and use your Personal Data for substantially similar purposes as described in this Privacy Policy.

 

PART H – HOW TO CONTACT US

Any questions, comments or concerns relating to this Privacy Policy, and any requests to correct or access Personal Data collected during your use of the Services, should be directed to:

 

Attention: Customer Service

Passen Inc.
1313 – 1 Market St.
Toronto, ON M5E 0A2

Email: hello@passen.com