This privacy statement applies to all personal information we collect when you access or use our websites, products, services, or otherwise interact with us or our representatives. This statement does not apply to data that is not personal information, including anonymous, deidentified, or aggregated data.
Information We Collect
The types of information we collect about you depends on your use of our products, services, and the ways that you interact with us. This may include information about:
- How you use or visit our website.
- How you use our services and products and interact with us.
- Contact, billing, and other information you provide.
- Data brokers from whom we purchase marketing lists and business data.
- Business partners with whom we jointly offer products or services.
- Publicly available sources, such as open government databases.
The personal information we collect can include the following:
- Contact details such as your name, email address, mailing address, and telephone numbers.
- Employment information such as your job title and other business or company information.
- Credentials such as your username, passwords, and similar security information used for authentication and access to SurePassID products and services.
- Demographic information such as your gender and country.
- Web form information you provide in our web forms, which indicate whether the information requested is mandatory or voluntary.
- Payment information to process payments, such as your payment instrument details.
- Account history information related to the products or services you purchase, and the activities associated with your account.
- Cookie and tracking information such as IP address, device identifier, location data, browser type and language, access times, the Uniform Resource Locator (URL), and other unique identifiers and technical data that may uniquely identify your device, system, or browser.
- Error reports and performance information of your products and services, as well as any problems you experience, including error reports.
- Troubleshooting and help information when you contact SurePassID for technical support or customer support services.
- Feedback you provide to us via customer surveys and other mechanisms.
How We Use and Share Your Information
We use and share your information to:
- Authenticate you.
- Detect and prevent fraud.
- Manage and protect our networks, services, and customers.
- Deliver and maintain our products and services.
- Establish and maintain your account.
- Measure credit and payment risk.
- Provide account-related services and information.
- Help you with customer service and technical support issues or questions.
- Help us improve and personalize our products and services.
- Better predict content and marketing offers that may interest you, which includes sending promotional communications and presenting you with relevant offers.
- Meet our legal obligations.
We use the following technologies in the following ways:
- Cookies. Cookies are alphanumeric identifiers that we transfer to your device hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our website and services, while others are used to enable a faster log-in process or to allow us to track your activities at our website and services. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the website and services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our website and services.
- Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
- Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs, also known as web beacons, are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your device hard drive, clear GIFs are embedded invisibly on web and application pages. We may use clear GIFs in connection with our website and services to, among other things, track the activities of website visitors and application users, help us manage content, and compile statistics about website usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
- Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section, such as by disabling cookies.
Your Privacy Rights
You may have the following consumer privacy rights under applicable state laws, including California privacy laws:
- Right to Know. You may have the right to request information about the personal information we have collected about you and for what purpose.
- Right to Access. You may have the right to request information about how we process your personal information and to obtain a copy of that personal information.
- Right to Portability. You may have the right to receive your personal information, in a structured, commonly used, and machine-readable format, and to have that information transmitted to another organization in certain circumstances.
- Right to Deletion. You may have the right to request the deletion of your personal information that we have collected from you.
- Right to be free from discrimination. SurePassID will not discriminate against you for exercising your consumer privacy rights.
Special Considerations for California Residents
If you are a California resident, you have certain consumer privacy rights which you can learn about and exercise as described here.
Your Marketing Choices
You have choices about how SurePassID reaches you with customer and marketing communications, such as email messages. These choices include opting out of such communications entirely or choosing which types of communications you wish to receive. These choices are available via links in every SurePassID email or by sending an email to firstname.lastname@example.org.
Links to Third-Party Websites and Services
We may sometimes provide links to third-party websites. The information practices of those third-party websites linked to our website are covered by the third party’s own privacy statements and we encourage you to read those.
- Feedback from our customers, regulators, industry, or other stakeholders.
- Changes in our privacy practices, products, or services.
- Changes in applicable privacy laws.
Contacting Us About Privacy
If you have a privacy question, concern, or complaint, please contact us at email@example.com or write to us at:
Attention: Privacy Officer
360 Central Avenue
First Central Tower
St. Petersburg, FL 33701
Acceptable Use Policy
The SurePassID Acceptable Use Policy (“AUP”) is intended to foster responsible use of SurePassID’s website, infrastructure, networks, systems, products, services, website, and facilities by our customers and other Users. Users consent to be bound by the terms of this AUP. SurePassID reserves the right to modify this AUP in its discretion at any time. Modifications will be effective when posted and Users are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on each User. Use of the SurePassID website after we make modifications constitutes acceptance of our modifications.
Suspension and Termination
If SurePassID determines that any User has violated any portion of this AUP, SurePassID may terminate the Users use of the website. SurePassID will suspend service for violation of the AUP on the most limited basis as SurePassID determines is reasonably practical under the circumstances to address the underlying violation. SurePassID will attempt to notify User prior to suspending service for violation of the AUP (which may be via email or any other notification). However, SurePassID may suspend service without notice if SurePassID becomes aware of a violation of this AUP or any applicable law or regulation that exposes SurePassID to criminal or civil liability, or that exposes SurePassID or any third-party property to harm. Harm may include, but is not limited to, risk of having one or more IP addresses placed on blacklists. SurePassID may take any further action as SurePassID deems appropriate under the circumstances to eliminate or preclude repeat violations. SurePassID is not liable for any type of damages that Users or third parties may suffer resulting in whole or in part from SurePassID’s exercise of its rights under this AUP. This exclusion of liability does not include SurePassID’s liability for death or personal injury caused by its negligence, or any other liability that SurePassID cannot exclude or limit by law.
Users may only use the SurePassID website for its intended purpose. Users must not use the SurePassID website for any unlawful purposes.
Users must not use the SurePassID website to transmit, distribute or store content: (a) in violation of any applicable law or regulation, including export or encryption laws or regulations; (b) that may adversely affect the SurePassID website or other SurePassID customers; or (c) that may expose SurePassID to criminal or civil liability.
Users must not use the SurePassID website to transmit, distribute or store material that is inappropriate, as reasonably determined by SurePassID, or material that is obscene (including child pornography), defamatory, libelous, threatening, abusive, hateful, racially or ethnically offensive, harassing, humiliating to other people (publicly or otherwise), or otherwise objectionable. To be absolutely clear, Users must not store (either permanently or temporarily), process or transmit through the SurePassID website pornographic content of any kind.
Intellectual Property Rights
Material accessible through or contained within the SurePassID website may be subject to protection under privacy, data protection or confidentiality laws, and may contain intellectual property rights owned by SurePassID or third parties. The intellectual property may include, but is not limited to, copyright, patents, trademarks, trade names, trade secrets, or other proprietary information. Users must not use the SurePassID website in any manner that would infringe, dilute, misappropriate, breach, or otherwise violate any of these rights or laws. Users are responsible for ensuring that they have all necessary rights and licenses for all content that they place on the SurePassID website. Users must fully indemnify SurePassID with respect to any claims by third parties brought against SurePassID based on an allegation that User failed to comply with its obligations under this paragraph.
Malicious Content and Conduct
Users must not use the SurePassID website to transmit, distribute, or store material that may be harmful to or interfere with the SurePassID website or any third party’s networks, systems, services, or web sites. Malicious content includes, but is not limited to, viruses, worms, and Trojan horses.
Users must not use the SurePassID website to conduct activities that may be harmful to or interfere with the SurePassID website or any third party’s networks, systems, services, or Web sites, including, but not limited to, flooding, mail bombing, or denial of service attacks. Users are prohibited from violating or attempting to violate the security of the SurePassID website or the computers, accounts, or networks of another party. Users are also prohibited from any activity considered a precursor to attempted security violations, including, but not limited to, any form of scanning, probing, or other testing or information-gathering activity. Inappropriate activity may result in civil or criminal liability. SurePassID may investigate such activity and may involve and cooperate with law enforcement authorities in prosecuting Users involved in such activity.
Fraudulent and Misleading Content
Users must not use the SurePassID website to transmit or distribute material containing fraudulent offers for goods or services, or any advertising, or promotional, or other materials that contain false, deceptive, or misleading statements, claims, or representations, or which does not comply with any applicable advertising laws or standard business practice. Users must not use the SurePassID website to mask their true identity or to pretend to be someone or something that they are not.
Collecting Personal Information
Users must not use the SurePassID website to collect, process, or store, or attempt to collect, process or store, personal data relating to any third parties in violation of applicable law. If Users collect third party personal data, then Users must comply at all times with applicable data protection laws and regulations.
Email and Unsolicited Messages
Users must not use the SurePassID website to transmit unsolicited e-mail messages, including, without limitation, unsolicited bulk email (“spam”), or emails intended to harass or annoy others. Further, Users must not use the service of another provider to send spam to promote a website hosted on or connected to the SurePassID website.
Responsibility for Content
SurePassID has no responsibility for any User-provided content or content that User may access on or through the SurePassID website. SurePassID is not obligated to monitor or exercise editorial control over that content. If SurePassID becomes aware that any content may violate this AUP, expose SurePassID to civil or criminal liability, or both, then SurePassID may block access to that content and suspend or terminate provision of the SurePassID website to any User creating, storing or disseminating such material. SurePassID may also cooperate with legal authorities and third parties in any investigation of alleged wrongdoing.
SurePassID requests that any person who becomes aware of a violation of this AUP reports this information to SurePassID by email to firstname.lastname@example.org. SurePassID may take any appropriate action as it reasonably deems appropriate in its sole discretion in respect of such violations.
Notification of Copyright Infringement Concerns
If any User believes that its copyrighted work has been copied and is accessible on the SurePassID website in a way that constitutes copyright infringement, please send a notice to:
Attn: Legal Officer
360 Central Avenue
First Central Tower
St. Petersburg, FL 33701
Notices must include each of the following:
- The electronic or physical signature of the owner of the exclusive right that is allegedly infringed, or the electronic or physical signature of someone authorized to act on the owner’s behalf.
- Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site.
- Identification of the material claimed to be infringing or to be the subject of infringing activity, for which disabling of access or removal is sought, and information reasonably sufficient to permit us to locate the material.
- If the infringement claimed is by reason of intermediate and temporary storage, or caching, of material, include also a statement confirming that the infringing material has been removed from the originating site or access to it has been disabled or that a court has ordered that the material be so removed or that access to such material be disabled.
- If the infringement claimed is by reason of referring or linking users to an online location containing infringing material or infringing activity, by using information location tools, then, instead of the identification under paragraphs (3) or (4), provide identification of the reference or link, to the claimed material or activity, that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate that reference or link.
- Information reasonably sufficient to permit us to contact you, such as an address, telephone number, and, if available, an electronic mail address at which you may be contacted.
- A statement that you has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.
- A statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
Last Updated: December 3, 2020
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