Foxpass, Inc.
Privacy Policy

This Privacy Policy (“Policy”) explains how we collect, use, disclose, and protect the User’s (also “you” or “your”) personal information when you use our product and services (“Product”) or when you visit our website (the “Site”). This Policy is incorporated into and forms part of our Terms and Conditions, which outline the terms and conditions you agree to when using our Product. We will only collect, use, and disclose your Personal Data in accordance with this Policy.

We may revise this Policy from time to time. It is strongly recommended you check this page often, referring to the date of the last modification listed at the bottom. Unless stated otherwise, the then-current Policy applies to all Personal Data the Data Controller (Foxpass) has about you. The most current version of the Policy will govern our use of your Personal Data and will always be at www.foxpass.com. By continuing to access or use the Product after those changes become effective, you agree to be bound by the revised Policy. We recommend that you review the Policy each time you visit the Site to stay informed of our privacy practices.

Further explanation regarding each type of Personal Data collected is provided in the dedicated sections of this Policy or by specific explanation texts displayed prior to the Data collection.

What information do we collect and how do we use it?

As part of our normal business practice, we collect and use the information you voluntarily provide to the Owner (Foxpass). Information such as your name, phone number, email address, and other pertinent contact information is collected for the following purposes:

  • Product Related Data:
  • Product Use, Product Experience, and Product Improvement
  • Business Related Data:
  • Customer Support
  • Business Operations
  • Communication and Marketing.

Product Related Data

The types of Personal Data that This Application collects, by itself or through third-parties, include cookies, usage data, email address, social media identifiers, first name, last name, phone number, and company name. By default, passwords are stored but encrypted using the bcrypt hashing algorithm with a random salt, which means that it cannot be recovered or disclosed by anyone.

You may freely provide the Personal Data, or in case of Usage Data, collected automatically when using This Application. All Data requested by This Application is necessary, and failure to provide this Data may make it impossible for This Application to provide its services. In cases where This Application specifically states that some Personal Data is not necessary, you are free to exclude this Personal Data without any consequences on the availability or the functioning of the service. If you are uncertain about what Personal Data is necessary, we invite you to contact Foxpass using the contact information provided in the Contact Us section of this Policy.

Cookies (3rd Party and This Application)

Any use of Cookies, or of other tracking tools, by This Application or by the third-party services used by This Application, serves the purpose of providing the service required by you as well as any other purposes described in this Policy. This Application uses cookies for authentication. We use the local storage to store your session so when you authenticate the first time; you do not have to reauthenticate every-time you visit This Application.

Mode and place of processing the Data

Methods of processing

Foxpass properly processes your Personal Data and takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data.

Place

The Personal Data is processed in the US at our operating offices and in any other places where the parties involved in the processing are located.

Retention time

Personal Data processed by us will not be kept for longer than is necessary for the intended process or purposes. You have the right to request your information be deleted, once the request has been verified, the data will be removed within 30 days.

Business Related Data

We collect your Personal Data to allow us to provide our services, as well as for the following purposes: Customer Support, Business Operations, and Communications and Marketing. The Personal Data used for each purpose is outlined in the specific sections of this document.

Customer Support (Managing Support and contact requests)

The type of Personal Data we collect, (either by itself or through a third-party), include name, phone number, email address, and social media identifiers. These types of services allow us to manage support and contact requests efficiently via email or by other means, such as a contact form. The Personal Data processed depends on the information provided by you in the messages and the methods used for communication (e.g., email address). For technical problems, we use system diagnostic data to troubleshoot the reported issues effectively.

Interaction with live chat platforms

This type of service allows you to interact with third-party live chat platforms directly from the pages of the website, for contacting and being contacted by This Application’s support service. If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if you do not actively use the service. Moreover, live chat conversations may be logged.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with you. These services may also collect data concerning the date and time when the message was viewed by you, as well as when you interacted with it, such as by clicking on links included in the message.

Business Operations

We use Personal Data to efficiently conduct business such as using email to send order forms, contracts, invoices, or payment confirmations. In addition, we develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. Payment processing services enable us to process payments by credit card, bank transfer or other means. To ensure greater security, Foxpass shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to you, such as emails containing invoices or notifications concerning the payment.

Communications and Marketing

We use your Personal Data to deliver and personalize our communication. For example, we may contact you by email or other means of electronic communication to:

  • provide you company information about Foxpass
  • inform you of any live or in-person Foxpass customer events or promotions,
  • provide you timely communication regarding relevant product updates, or
  • invite you to participate in product surveys.

By providing us with your Personal Data via a contact form you authorize Foxpass to use these details to reply to your requests for information, or any other kind of request as indicated by the relevant form’s header. Personal Data collected includes your company’s name, your email address, country, name, phone number, and various types of Personal Data as specified in the Policy of the service.

Foxpass will only send you direct marketing communications where you have explicitly consented to receive them. You can opt-out of receiving direct marketing communications from us by following the unsubscribe instructions which are included in every Marketing email sent from Foxpass to you. If you would like to opt-out of Marketing email subscriptions and promotional communications, you can also do so by accessing this link: https://www.foxpass.com/unsubscribe.

Foxpass will continue to communicate with you regarding changes in Terms and Conditions, this Privacy Policy, product updates, and routine customer service or business operation related messages.

Interaction via external social networks and platforms

This type of service allows interaction with social networks or other external. The interaction and information obtained are always subject to your privacy settings for each social network. This type of service might still collect traffic data, and is subject to their privacy policies, for the pages where the service is installed, even when you do not use it.

Interaction via www.foxpass.com and console.foxpass.com

Any browser visiting the www.foxpass.com and/or console.foxpass.com sites may receive cookies from us. We use cookies and other technologies to ensure everyone who visits the Site has the best possible experience. By continuing to visit or use our services, you agree to the use of cookies and similar technologies for the purposes we describe in this Policy. Browser manufacturers provide help pages relating to cookie management in their products. Please follow their instructions for cookie management for those products. You can avoid certain cookies by configuring your browser settings or opting-out directly with the third-party that operates and controls the cookie. You can also opt-out of third-party personalized advertising cookies. To learn more, or to opt-out of the use of such third-party personalized advertising cookies in the EU, please visit www.youronlinechoices.eu.If you reside in the United States, please visit http://youradchoices.ca/choices.

Additional Information

Legal action

When legally required, strictly necessary for the performance of the services or to protect our rights, or the rights of our partners or users, we may disclose your personal information to law enforcement authorities, investigative organizations, our affiliates, or in legal proceedings.

Your Personal Data will be used for legal purposes by Foxpass, in Court or in the event of possible or actual legal action arising from improper use of This Application or the related services. You understand and agree that Foxpass may be required to, and may reveal your Personal Data upon request of public authorities.

Disclosures

Foxpass retains ownership of your data, as the Data Controller, and any information processing involving your data will be done by processors held to the same data privacy compliance standards as us. We agree that we will not rent, sell or otherwise provide your information to outside parties whom do not meet the appropriate compliance standards.

In the event of a sale, merger, consolidation, liquidation, reorganization, or acquisition we may transfer your information. In that instance, any acquirer will be subject to our same obligations under this Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our website.

System logs and maintenance

For operation and maintenance purposes, This Application and any third-party services may collect files that record interaction with This Application (System logs) or use for this purpose other Personal Data.

Information not contained in this Policy

More details concerning the collection or processing of Personal Data may be requested from Foxpass at any time. Please email us or contact us using the contact information provided at the end of this document.

User Rights

We rely on you to ensure that your personal information is complete, accurate and current. You can contact us at privacy@foxpass.com with the subject line “Subject Access Request” to request access, to or inform us of any changes to, or inaccuracies of, your personal information. The request is free of charge, and we will respond to your request as soon as possible but certainly within 30 days

Before providing personal information to you, or your designated agent on your behalf, we may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information.

Once your identity has been verified, you can consult with Foxpass to:

  • know what Personal Data has been stored,
  • verify accuracy,
  • cancel, update, or correct your information,
  • transform your Personal Data into an anonymous format,
  • block any Personal Data held in violation of the law, as well as to oppose their treatment for all legitimate reasons.

You are entitled to withdraw your consent at any time; however, such consent may result in the inability for you to use This Application.

You have the right to a) object to us processing your Personal Data if we are not entitled to use it anymore, b) to have your information deleted if we are keeping it too long, or c) have its processing restricted in certain circumstances.

If you would like to exercise any of these rights or lodge a complaint, please contact us using the contact information provided in the Contact Us section of this Policy.

Definitions and Legal References

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including your first name, last name, a personal identification number, your email, phone number, company name, or IP Address.

Usage Data

Information collected automatically from This Application (or third-party services employed in This Application), which can include: the IP addresses or domain names of the computers utilized by the individuals that use This Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by your, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or your IT environment. As part of the services provided by This Application, we may also collect: your name, your email address, your user name, and a password.

User (You)

The individual using This Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of This Application. The Data Controller, unless otherwise specified, is Foxpass (the Owner of This Application).

This Application

The hardware or software tool by which your Personal Data is collected.

Cookies

A small piece of data stored on your device.

Legal Information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Arts. 13 and 14 of EU Regulation n. 2016/679, and under the provisions of e-Privacy Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

General Data Privacy Regulation (“GDPR”)

Foxpass has taken steps to ensure we are in compliance with the GDPR legislation and related data privacy laws (“European Data Privacy Law”). In an effort to better protect and secure your data, we have updated our data collection, data security, and data retention/destruction processes to reflect the standards established by the GDPR.

We value your privacy and want to be transparent about the data we collect, how we use it, and your rights to control that information. In general, as part of our normal business practices, we collect information you voluntarily provide to us, such as your name, phone number, email address, and any other pertinent contact information. As more fully detailed in this Privacy Policy, Foxpass may use personal data for purposes including but not limited to:

  • Product Experience and Improvement;
  • Customer Support;
  • Business Operations; and
  • Communication and Marketing.

ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

These additional disclosures for California residents apply only to individuals who reside in California.The California Consumer Privacy Act of 2018 (“CCPA”), as updated by the California Privacy Rights Act of 2020 (“CPRA”), provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

CALIFORNIA NOTICE OF COLLECTION

In the past 12 months, we or our service providers may have collected the following categories of personal information enumerated in the CCPA in connection with your use of the Product(s):

  • Identifiers, including name, address, email address, IP address – and an ID number assigned to your account.
  • Customer records, phone number, billing address, credit or debit card information.
  • Commercial information, including purchases and engagement with the Product(s).
  • Internet activity, including history of visiting and interacting with our Product(s), browser type, browser language and other information collected automatically.
  • Geolocation data.
  • Inferences, including information about your interests, preferences and favorite brands and products.

For more information on information we collect, including the sources we receive information from,review the “What information do we collect and how do we use it?“section. We collect and use these categories of personal information for the business purposes described above, including to provide, manage and improve our Product(s).

Foxpass does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA or CPRA is interpreted to include advertising technology activities such as those disclosed herein, and we will comply with applicable law as to such activity. Foxpass discloses the following categories of personal information for commercial purposes: identifiers, commercial information, internet activity, geolocation data and inferences. We use and partner with different types of entities to assist with our daily operations and manage our Product(s)

RIGHT TO KNOW AND DELETE

If you are a California resident, you have the right to delete personal information we have collected about you and you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the:

  • categories of personal information we have collected about you;
  • categories of sources from which the personal information was collected;
  • categories of personal information about you we disclosed for a business purpose or sold;
  • categories of third parties to whom the personal information was sold or disclosed for a business purpose;
  • business or commercial purpose for collecting or selling the personal information; and
  • specific pieces of personal information we have collected about you.

To exercise any of these rights, please submit a request to us by or emailing us at privacy@foxpass.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

If personal information about you has been processed by us as a service provider on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.

RIGHT TO OPT OUT

To the extent Foxpass sells your personal information as the term “sell” is defined under the CCPA & SPRA, you have the right to opt out of the sale of your personal information by us to third parties at any time. You may submit a request to opt out of advertising technologies we use on the Services by clicking "Do Not Sell My Personal Information" below and following the instructions in that form. Otherwise, you may submit opt out requests by emailing us at privacy@foxpass.com. We do not knowingly “sell” the personal information of California minors under 16 years old.

Click here: https://www.foxpass.com/donotsell

AUTHORIZED AGENT

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

RIGHT TO NON-DISCRIMINATION

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

SHINE THE LIGHT

California Civil Code Section 1798.83 permits customers of this website who are California residents to request certain information regarding our disclosure of personal information as defined by the statute to our affiliates and third parties for their own direct marketing purposes. For inquiries regarding our disclosure policy, please call or write us at:

Foxpass, Inc.

c/o Legal Department

548 Market Street, Suite 15487

San Francisco, California 94104-5401

Telephone: (415) 805-6350

 

PRIVACY SHIELD FRAMEWORK

Foxpass complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Foxpass has certified to the U.S. 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 compliance with the Privacy Shield Principles, Foxpass commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Foxpass at: 

Foxpass, Inc.

c/o Legal Department

548 Market Street, Suite 15487

San Francisco, California 94104-5401

Telephone: (415) 805-6350

Foxpass has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.

The Federal Trade Commission has jurisdiction over Foxpass’s compliance with the Privacy Shield.

You may also have the option to select binding arbitration for the resolution of your complaint under certain circumstances. To find out more about the Privacy Shield's binding arbitration scheme please see https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

If we have received your personal information in the United States and subsequently transfer that information to a third party acting as an agent, and such third party agent processes your personal information in a manner inconsistent with the Privacy Shield Principles, we will remain liable unless we can prove we are not responsible for the event giving rise to the damage.

Contact Us

If you have any questions, suggestions, or to lodge a complaint, please contact us at:

Foxpass, Inc.

c/o Legal Department

548 Market Street, Suite 15487

San Francisco, California 94104-5401

Telephone: (415) 805-6350

Email: privacy@foxpass.com

This Policy was last reviewed and updated on February 26, 2021.