In general, you can visit PASSTIME’s web pages without telling us who you are or revealing any Personal Information about yourself, although our software may store your IP address. PASSTIME generally collects personally identifiable information, such as your name, address, telephone number, or e-mail address, only if you provide this information to us voluntarily. The voluntary information we collect is used for internal verification to complete transactions, ensure appropriate legal use of our products and licensed PASSTIME software, provide notification to licensees about updates to PASSTIME’s and our Affiliates’ (“Affiliates” includes both companies PASSTIME has a beneficial ownership interest in as well as third party providers of materials or services for PASSTIME) software, data, services, and to help provide technical and product support to our users. Where appropriate, PASSTIME may pass this data to a PASSTIME international distributor who provides the above services in your country, or to a PASSTIME Affiliate (for example, a cell phone carrier) whose software, data, and services provide solutions to meet your needs. Our Affiliates are also committed to protecting personally identifiable information as described in their privacy statements/policies.
PASSTIME may also use your name, address, and e-mail to send you marketing materials, user conference information, product updates, upcoming events, and newsletters — but you may Opt OUT from receiving this information by emailing us at firstname.lastname@example.org. While browsing the PASSTIME Website, you may be able to access the Websites of third parties through a hyperlink. PASSTIME assumes no responsibility for the privacy practices at such third-party Websites and suggests you review the privacy statements/policies on such Websites before sharing your personally identifiable data.
COLLECTION AND SOURCES
We may collect information about you and your account if you have one. This may include your name, address, postal address, email, account name or number, or other unique personal identifiers (including but not limited to login information, device serial number, demographic data, gender, username, password, VIN, etc). We may also collect certain information from and about your vehicle’s operation, including its GPS location and other functionality in certain occasions (e.g. speed, braking, battery charge, etc).
For certain products including InTouch and optional services you may have chosen, we may retain personal information including telephone numbers and credit card numbers if you voluntarily authorize us to do so. Otherwise, we will not retain that information.
We may collect personally identifiable information about you from various sources, including:
- Information provided by you such as, for example, information submitted via online forms which ask users to provide their names, e-mail addresses, and other information;
- Information about your interactions with us or others;
- Information we receive from third parties, such as an advertiser or other public or private data sources (including your dealer or finance company if the use of the PASSTIME service was a condition of obtaining financing); and
- Information we receive if and when you visit our PASSTIME or InTouch websites or mobile apps.
In addition, the websites or apps may collect certain information automatically, including, but not limited to, the type of device you use, your device’s unique device ID, the IP address of your device, your operating system, the type of Internet browsers you use, and information about the way you use the site or mobile apps.
If you do voluntarily authorize to store that information, PASSTIME will not share that information with anyone except to process payment of sums due and owing under the contract you have with us.
During the installation process for certain PASSTIME software, information may be stored on your computer or smartphone. This is done to enable the proper functioning of the software and ensure it is used only when properly licensed. Certain PASSTIME sites and software installation may require registration and user login to gain access to special services, license keys, or other features. This information will be used to provide support and deliver specialized services. We will not use this information except to carry out our services to you.
PASSTIME also collects personally identifiable information you provide if and when you order and register its line of products, supporting software, data, or services; order newsletters; register for training or conferences; or make requests that require a direct response to you.
PASSTIME does not sell your personally identifiable information (“PII”). We do share certain PII to allow us to perform and improve our services, for internal marketing analysis, and to comply with legal, contractual, or regulatory bodies’ requests.
You are solely responsible for any use of a PASSTIME plan involving your website identification even if you are not the one using it, and even if you later claim the use was not authorized.
HOW WE USE INFORMATION WE COLLECT
If you consent to use our services by registering to use them, you consent we may use the information we collect from you for any of the following purposes:
- to fulfill your requests for services (including but not limited to theft recovery), or follow up on requests previously made;
- to contact you when necessary, including with regard to our services;
- to review software and mobile app usage and operations;
- to troubleshoot our products and services;
- for internal marketing purposes, including new product releases, feature sets, and upcoming events;
- or to comply with legal, contractual, or regulatory bodies’ requests.
SHARING OF INFORMATION
PASSTIME will not share your personally identifiable information unless required to do so by law or in the good-faith belief it is necessary to: (1) conform to the edicts of the law or comply with legal process served on PASSTIME; (2) protect and defend the rights or property of PASSTIME; or (3) act under exigent circumstances to protect the personal safety of its customers or the public. We may share personally identifiable information:
- With our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them and have agreed to adhere to the rules set forth in this privacy statement
- In the event that our business or substantially all of the assets of the business are acquired, your personally identifiable information may be one of the transferred assets if allowed under applicable law.
- You also acknowledge and agree that PASSTIME may continue to contact you for the purposes of communicating information with regard to the mobile app, and also to augment, facilitate, complete, and/or confirm any transaction that you may enter into or in order to respond to an inquiry or request made to us by you.
- Subject to the above, PASSTIME will use confidential information received from you or your dealer/lender only to perform its obligations under any service agreement with you and will not use confidential information for any other purpose.
- PASSTIME will protect all confidential information in the same manner that is used to protect its own similar confidential information and represents and warrants its compliance with all applicable requirements of state and federal laws and regulations governing the protection of consumer and other confidential information whether existing now or in the future.
PASSTIME will at all times ensure that all confidential information be maintained, safeguarded, and disposed of in a safe and secure manner pursuant to the requirements of applicable laws, rules, and regulations, including Gramm-Leach-Bliley Act, General Data Protection Regulation, California Consumer Privacy Act (“CCPA” – see below for specific reference to CCPA), and other comparable federal and state laws or regulations.
We may share or sell certain of your information you, the dealer, or lender including any repossession team (if the device use is a condition of a loan), emergency service providers (law enforcement, roadside assistance, and emergency response such as fire and ambulance), marketing partners and cell carriers.
PASSTIME will contact you or send you marketing information about products, software, or services unless you notify PASSTIME that you do not wish to receive it. You may notify us by sending an email to email@example.com as indicated below. Keep in mind, however, that you may not receive information on the PASSTIME products and software or other valuable information as a result of your election to be removed from mailing lists.
California Residents: you may also elect to receive a list of the categories of information we have on you or the identity of specific information. You may also choose to request that we delete all of your personally identifiable information, and we will comply with this request to the extent we can under applicable laws yet still perform our services to you (or, if the device is a condition of a loan, to your dealer or lender).
Except as stated herein, PASSTIME’s corporate policy is not to rent, sell, or otherwise permit access by third parties to databases composed of your personally identifiable information.
ACCESS TO MINORS
As part of our business practices, we do not knowingly collect information from individuals under sixteen (16) years of age. No information should be submitted to PASSTIME provided by or on behalf of individuals under the age of sixteen (16) years.
PASSTIME will permit you to access information about yourself in our database by contacting at firstname.lastname@example.org . If you believe any of the information is incorrect or needs updating, please advise us. We will correct our records upon verification of the requested change.
PASSTIME will take reasonable and prudent precautions to ensure that your personally identifiable information is protected against unauthorized access, use, or disclosure.
DATA RETENTION POLICY, MANAGING YOUR INFORMATION
We will retain user-provided data for as long as you use the application and for a reasonable time thereafter. We will retain information for up to 24 months and thereafter may store it in aggregate.