Privacy Policy

Last updated: March 12, 2020

SocialPass.net provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use, protection, and disclosure of Personal Information received from your use of this website, located at https://socialpass.net (“Site”), as well as all related websites including our applications and other services provided by us (collectively, together with the Site, our “Service”), and in connection with our customer, vendor, and partner relationships. This Privacy Policy also tells you about your rights and choices with respect to your Personal Information, and how you can reach us to update your contact information or get answers to questions you may have about our privacy practices.

In addition to the activities described in this Privacy Policy, we may process Personal Information on behalf of our commercial customers when they use the Service. We process such Personal Information as a data processor of our commercial customers, which are the entities responsible for the data processing. To understand how a commercial customer processes your Personal Information, please refer to that customer’s privacy policy.

If you are a California resident, our Privacy Notice for California Residents includes additional information about your rights and how we collect, use, and share information.

Registration with, use of, and access to the Service is subject to this Privacy Policy and our Terms of Use located at https://socialpass.net/auth/terms. All terms not defined in this Privacy Policy will have the meanings set forth in the SocialPass.net Terms of Use.

1. Personal information we may collect

For the purpose of this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual. We obtain Personal Information relating to you from various sources described below.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Service if that information is necessary to provide you with the service or if we are legally required to collect it.

2. Personal information provided by you

Registration
If you desire to have access to certain restricted sections of the Site or request to receive marketing materials, you may be required to become a registered user, and to submit the following types of Personal Information to SocialPass.net: your name, email address, phone number, full user name and password.

Customer Support
We may collect information through your communications with our customer support team or other communications that you may send us and their contents.

Making a Purchase
When you make payments through the Service, you will need to provide Personal Information such as your credit card number and billing address.

Social Media
In order to allow you to post to your social media platforms, we may ask you to provide your username, account ids, social handle, timezones, and email address.

Other
We may also collect your contact details when you provide them in the context of our customer, vendor, and partner relationships.

3. How we may use your personal information

We may use the Personal Information we obtain about you to:

  • create and manage your account, provide our Service, process payments, and respond to your inquiries;
  • manage account authentication such as two-factor authentication
  • communicate with you to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance, including by periodically emailing you service-related announcements;
  • tailor our Service (e.g., we may use cookies and similar technologies to remember your preferences);
  • publish your content, comments or messages on social media platforms;
  • provide tailored advertising, for SocialPass.net services, via Google AdWords;
  • aggregate your Personal Information for analytical purposes;
  • provide customer support;
  • operate, evaluate and improve our business (including by developing new products and services; managing our communications; determining the effectiveness of our advertising; analyzing how the Service is being accessed and used; tracking performance of the Service; debugging the Service; facilitating the use of our Service);
  • send you marketing communications about products, services, offers, programs and promotions of SocialPass.net, and affiliated companies;
  • ensure the security of our Service;
  • manage our customer, service provider and partner relationships;
  • enforce our agreements related to our Service and our other legal rights; and
  • comply with applicable legal requirements, industry standards and our policies.

If you are located in the European Economic Area, we may process your Personal Information for the above purposes when:

  • you have consented to the use of your Personal Information, For example, we may seek to obtain your consent for our uses of cookies or similar technologies, or to send you marketing communications.
  • we need your Personal Information to provide you with services and products requested by you, or to respond to your inquiries,
  • we have a legal obligation to use your Personal Information, or
  • we have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to ensure and improve the safety, security, and performance of our Service, to anonymize Personal Information and carry out data analyses.

4. How we share personal information

We may disclose the Personal Information we collect about you as described below or otherwise disclosed to you at the time the data is collected, including with:

Social Media Platforms
Our primary purpose for using information is to publish your content on social platforms, allow you to track metrics for analytical purposes, and engage with customers through public replies and conversations (direct messages or “DMs”). We may allow you to link your account on SocialPass.net with an account on a third party social network platform, such as Twitter or Facebook, and to transfer your information to and from the applicable third party platform. Once you share your content to a social media platform, its use will be governed by that platform’s privacy policy.

Service Providers
We engage certain trusted third parties to perform functions and provide services to us, including hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer relationship, database storage and management, and direct marketing campaigns. We may share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.

Compliance with Laws and Law Enforcement
SocialPass.net cooperates with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of SocialPass.net or a third party, to protect SocialPass.net against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Service and any equipment used to make the Service available, or to comply with the law.

Business Transfers
SocialPass.net may sell, transfer or otherwise share some or all of its assets, including Personal Information, in connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, or in the event of insolvency or bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.

Other Third Parties
We may share Personal Information with our headquarters and affiliates, and business partners to whom it is reasonably necessary or desirable for us to disclose your data for the purposes described in this Privacy Policy. We may also make certain non-Personal Information available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and functionality available through the Service.

5. How we protect personal information

SocialPass.net cares deeply about safeguarding the confidentiality of your Personal Information. We employ administrative and electronic measures designed to appropriately protect your Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. Please be aware that no security measures are perfect or impenetrable. We cannot guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our administrative, physical, and electronic safeguards, subject to requirements under applicable law to ensure or warrant information security.

We will make any legally-required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information to you via email or conspicuous posting on our Site in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system , and any other disclosures that may be required under applicable law.

We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

6. Your rights and choices

If you decide at any time that you no longer wish to receive marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. You may also opt out from receiving commercial email from us by sending your request to us by email at info@socialpass.net. Please be aware that, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.

In certain jurisdictions you have the right to request access and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or object to the processing of your Personal Information, to have the information blocked, anonymized or deleted, as appropriate, or to exercise your right to data portability to transfer your Personal Information to another company. Those rights may be limited in some circumstances by local law requirements. For example, California residents can refer to the separate California Resident Privacy Notice to learn more about their California privacy rights. In addition to the above-mentioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.

Where required by law, we obtain your consent for the processing of certain Personal Information collected by cookies or similar technologies, or used to send you direct marketing communications, or when we carry out other processing activities for which consent may be required. If we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

To update your preferences, ask us to remove your information from our mailing lists, delete your account or submit a request to exercise your rights under applicable law, please contact us as specified in the “How to Contact Us” section below.

7. Data transfers

SocialPass.net is based in the United States. Personal Information that we collect may be transferred to, and stored at, any of our affiliates, partners or service providers which may be inside or outside the European Economic Area (“EEA”) and Switzerland, including the United States. By submitting your personal data, you agree to such transfers. Your Personal Information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. When we transfer or disclose your Personal Information to other countries, we will protect that information as described in this Privacy Policy.

Individuals Located in the EEA or Switzerland
If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, we comply with applicable legal requirements for the transfer of Personal Information to countries outside of the EEA, the United Kingdom, and/or Switzerland. In particular, SocialPass.net has filed its certification of adherence to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the Department of Commerce and the European Commission, and the Swiss Federal Data Protection and Information Commissioner, respectively, with respect to the processing of certain Personal Information transferred from the EEA, the United Kingdom and Switzerland to SocialPass.net. For additional details on our compliance with the EU-US privacy Shield Framework and the Swiss-US Privacy Shield Framework please visit: https://socialpass.net/privacy-shield. SocialPass.net has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. In addition, we may enter into Standard Contractual Clauses issued by the European Commission with our commercial customers where appropriate.

8. Children's privacy

The Site is not directed to persons under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at info@socialpass.net. We do not knowingly collect Personal Information from children under 16. If we become aware that a child under 16 has provided us with Personal Information, we will delete such information from our files.

9. Updates to this Privacy Policy

This Privacy Policy may be updated from time to time for any reason; each version will apply to information collected while it was in place. We will notify you of any modifications to our Privacy Policy by posting the new Privacy Policy on our Site and indicating the date of the latest revision. You are advised to consult this Privacy Policy regularly for any changes.

In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. Your continued use of the Service after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of this Privacy Policy.

10. Your California privacy rights

California law affords California residents certain additional rights regarding our collection and use of your personal information. To learn more about your California privacy rights, please visit our Privacy Notice for California Residents.

11. How to contact us

SocialPass.net is the entity responsible for the processing of your Personal Information. If you have any questions or comments regarding this Privacy Policy, or if you would like to exercise your rights to your Personal Information, you may contact us by emailing us at info@socialpass.net or by writing to us at:

SocialPass.net
245 Palmyra Dr

Indianapolis, IN 46239

This Privacy Policy is effective as of May 01, 2020.

If you have any thoughts or questions about this Privacy Policy please let us know.



California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under California law.

1. Personal Information Collection, Disclosure, and Sale

For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

  • Lawfully made available from government records.
  • De-identified or aggregated.
  • Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, sold, or used for business or commercial purposes in the preceding twelve months since this notice was last updated, as well as the categories of sources from which that information was collected, and the categories of third parties with whom we shared Personal Information. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.


In the preceding twelve months, we have not sold any California resident’s Personal Information.

2. Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:

1. Providing Services: Providing our services.
2. Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.
3. Social Network Support: Updating your status on social networks, sending messages on your behalf to your social networks, and providing other features and services to you.
4. Connecting Third Party Services: Facilitating the connection of third-party services or applications, such as social networks.
5. Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.
6. Personalization: Personalizing your experience on our services such as presenting tailored content.
8. Facilitating Payments: Facilitating transactions and payments.
9. De-identification and Aggregation:De-identifying and aggregating information collected through our services and using it for any lawful purpose.
10. Safety Issues: Responding to trust and safety issues that may arise.
11. Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
12. Auditing Interactions: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
13. Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
14. Debugging: Debugging to identify and repair errors that impair existing intended functionality.
15. Transient Use: Short-term, transient use.
16. Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
17. Research: Undertaking internal research for technological development and demonstration.
18. Product Improvement: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
19. Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
20. Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

3. Collection and Disclosure of Personal Information

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:


Pursuant to our Privacy Policy, we may share your Personal Information with the following categories of third parties:

1. ISPs: Internet service providers.
2. Analytics Providers.
3. OS/Platform Provider: Operating systems and platforms.
4. Social Networks.
5. Affiliates.
6. Vendors: Vendors and service providers.
7. Integrated Third Parties: Third parties integrated into our services.
8. Third Parties as Legally Required: Third parties as required by law and similar disclosures.
9. Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.
10. Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.

4. Your California Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you during the past twelve months.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please provide us with the email address associated with your SocialPass.net account and the last 4 four digits and expiration date of the payment card that’s linked to the SocialPass.net account. If you are a non-paying customer please provide us with the email address associated with your SocialPass.net account and the phone number used for two-step authentication.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light. You may request information once per calendar year about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us in writing using the Contact Information section below.

Submit Requests. To exercise your rights under the CCPA, please contact us by email at info@socialpass.net or write to us at the following address:

SocialPass.net
245 Palmyra Dr
Indianapolis, IN 46239


Authorizing an Agent: To authorize an agent to make a request to know or delete on your behalf, please send a written authorization signed by you and the authorized agent to us via info@socialpass.net.

5. Do Not Track

There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

6. Contact Information

If you have any questions, comments, or concerns about our processing activities, or you would like to exercise your privacy rights please email us at info@socialpass.net.com or write to us at:

SocialPass.net
245 Palmyra Dr
Indianapolis, IN 46239


Last updated: May 01, 2020