Privacy Policy

iPass Inc., having a principal place of business at 3800 Bridge Parkway, Redwood Shores, CA 94065, USA ("iPass"), and its group companies including iPass (U.K.) Ltd., iPass Holdings Pty Ltd., iPass Japan, Inc., iPass Asia Pte Ltd (collectively, "iPass") take your privacy seriously. This Privacy Policy explains the steps iPass takes to ensure information about you is kept secure and confidential.

Please read this Privacy Policy carefully. Once you use this web site ("Web Site") or the iPass connectivity services ("Service") you will be deemed to have read and consented to the uses of your personal data set out in this Privacy Policy. You must not use Our Web Site or any iPass Service if you do not accept this Privacy Policy.

A. What Information iPass Collects

1. To use the iPass Service, and to obtain information offered on our web site, you will be asked to provide varying amounts of personal information. In some cases, you will be required to provide information in order to use the Service, obtain information, or participate in special offers. Each activity or Service requires or requests different types of information in order for you to participate. We try to limit our requests for personal information to only that information we believe is minimally necessary to achieve our stated collection purposes.

1.1 When requesting information from iPass regarding the iPass Service, to attend a seminar or register for an event or training course, or to access special content such as demos, you will be asked to provide iPass with the following information:

(a) your name;
(b) your title;
(c) your company name;
(d) your telephone number;
(e) your email address
(f) your company address (including street, city, state and country).

1.2 When registering to obtain a free trial account to test the iPass Service, you must provide iPass with the following information:

(a) your name;
(b) your title;
(c) your company name;
(d) your telephone number;
(e) your email address
(f) your address (including street, city, state and country)

This information is required in order to use the iPass Service.

1.3 In order to use the iPass Service through an iPass reseller, or as an authorized user of a direct iPass enterprise customer, you must provide the following information

(a) your user name/identification;
(b) your domain/realm;

This information is required in order to use the iPass Service.

1.4 By virtue of providing you with the iPass Service, iPass may come into possession of information and data regarding you, and anyone you allow to use the iPass Service which is necessary for the billing and maintenance of the Service. This information and data ("Data") includes,

(a) Authentication domain and user name/identification;
(b) Date, time and duration of session;
(c) Technical or network data provided to or obtained by iPass in connection with the provision of Services
(d) Country, state, and city where the Service was used:

B. Purposes For Which iPass Uses the Information
1.Use of the Service: iPass will use information and Data collected in connection with your use of the iPass Service only for purposes of providing you with the Service(s) ordered or requested by you. iPass will use and process your Data (including intra-group transfers and transfers to iPass subsidiaries): (a) in connection with provisioning of the Services; (b) to incorporate your Data into databases controlled by iPass for the administration, provisioning, billing and reconciliation, verification of your identity and solvency, maintenance, support and product development, fraud detection and prevention, customer and customer use analysis and reporting. iPass may also use information to contact third parties in connection with inappropriate use of the iPass Service or violation of the iPass Service Use Restriction. You warrant that you have obtained and will obtain all legally required consents and permissions from anyone you allow to use the iPass Services for the use, processing and transfer of Data as described in this policy.

2.Information Requests: The following list describes how iPass may use information provided by you through the Web Site or otherwise in connection with your request for information or other requests to iPass:

(a) In order to receive phone, mail or email correspondence from iPass;
(b) In our internal surveys to obtain feedback on our products, our web site, or on other aspects of our business that impact you as an iPass customer;
(c) To notify you of new iPass products or services that may be of interest;
(d) To send promotional materials (including by e-mail) about iPass products and service;
(e) To contact you regarding ordering the iPass Service;

Should you want to opt out from receiving new product or service notifications or promotional materials please contact privacy@ipass.com.

3. Location technology: Please note that when you use our service we will be able to identify where you are located. This information is required to supply our services to you (including support services) and for billing and invoicing of the services. Location technology will not be used for any purpose other than providing you our services and ensuring legitimate use of those services. iPass considers our ability to locate where you are when you use the iPass Services to be fundamentally necessary to enable iPass to provide those services. Therefore if you object to iPass' use of location identification technology, do not use the Services.

4. Data passed to an end user's employer: Use of the Services is enabled when you submit your proper credentials (user name and password) to iPass. iPass will then ask your employer, your service provider or other relevant iPass account holders to authenticate your session. Details of time, date, location and length of time you use the Service used may also be held by us and passed to your employer or service provider in connection with your use of the iPass Service.

5. Job applications: Personal information that is collected in connection with job opportunities will be used for processing your application and to consider the eligibility of candidates.

6. Overseas transfers of your Data: Information submitted by you to iPass may be transferred to iPass subsidiaries and other third parties identified in this policy who are located in other countries that do not provide equivalent statutory protections for personal information (of particular importance for our European customers are transfers made to the USA.) This information will only be transferred abroad for the purpose of performing the purposes for which it was disclosed as set forth in this policy.

C. Sharing Your Details with Third Parties
1. Except as detailed below, iPass does not sell or disclose your personal information or Data to any third parties nor otherwise provide your personal information or Data to third party marketing organizations or to any non-affiliated iPass entity.

2. iPass will share your personal information with third parties in various, limited ways.

2.1 In connection with your use of the iPass Service, iPass will only disclose Data and personal information about you to third parties (such as its authorized resellers) to enable iPass to provide you with the Service, including provisioning the Service, billing and reconciliation, verification of your identity, maintenance, support, fraud detection and prevention. You understand that iPass will not be able to provide you with the Service if you do not consent to iPass use of personal information and Data in this manner.

2.2 In connection with information you have submitted to iPass through the iPass web site, iPass may disclose the information to selected iPass authorized resellers so that they can market products and services which they think that you may be interested in. Communications may be sent to you by e-mail. Once you have given consent you can, at any time, ask iPass to cease passing on your personal information or using it for marketing purposes by contacting privacy@ipass.com.

2.3 iPass may disclose information about you if you breach this Privacy Policy or the iPass Web Site Terms and Conditions. We may also disclose your details to a state, federal, or international government agency if required to do so by law or requested to do so by any Governmental or law enforcement agency.

D. Requests To Cease Use Of And Access To Your Details
1. As detailed above you may request that iPass stop using your personal information for certain activities by sending an e-mail to privacy@ipass.com or by writing to Privacy, iPass Inc., 3800 Bridge Parkway, Redwood Shores, California 94065 USA giving specific details of your request. If you request that your personal information no longer be processed for purposes which are necessary for us to supply the Service to you, then iPass will cease providing you with the Service.

2. If you have any complaints relating to this Privacy Policy or how we deal with your personal information please contact us at e-mail to privacy@ipass.com or by writing to Privacy, iPass Inc., 3800 Bridge Parkway, Redwood Shores, California 94065 USA.

3. You may request access to and correct your personal information held by us. To obtain more details about making such a request please contact us by e-mail to privacy@ipass.com or by writing to Privacy, iPass Inc., 3800 Bridge Parkway, Redwood Shores, California 94065 USA.

Please note that in order to better protect you and safeguard your information, iPass takes steps to verify your identity before granting access or making corrections to your information.

E. Security
1. Keeping information about you secure is very important to iPass. To this end, iPass uses encryption, firewalls and other technology and security procedures to help protect the accuracy and security of your personal information and to help prevent unauthorized access or improper use. For example, you will note that while using some features of the iPass web sites and online services, you will need to submit a password or some other type of authenticating information.

2. While iPass strives to protect your personal information, no data transmission over the Internet can be guaranteed to be totally secure and therefore iPass cannot ensure or warrant the security of any information you send to us. You include any information via this Web Site at your own risk.

F. Cookies
1. We may also use "cookies" and similar technology to obtain information about your visits to our sites or your responses to e-mail from us—both individually and in aggregated data that does not identify you. These reporting tools tell us the parts of our web sites or e-mails in which you showed an interest or took some action, and help us improve the quality and usefulness of our sites. iPass primarily uses cookies to determine what services or promotions you are interested in. Cookies help iPass to improve your experience while visiting our Website and customize our communications to the services. By using this Website and/or using any Services provided via it you agree to the above use of cookies.

1.1 If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of iPass' website if you do so. In particular, you may be required to accept cookies in order to complete certain actions on our website. You do not need to have cookies turned on, however, to use/navigate through many parts of the Website and to access certain of iPass' web pages may require a login and password.

G. Links
1. iPass' website contains links to other sites. iPass does not share your personal information with those websites and is not responsible for their privacy practices. We encourage you to earn about the privacy policies of those companies.

H. A Note to Children and Parents.
iPass intends the iPass web site for use by adults. iPass does not knowingly collect personal information from children under the age of 16. If we learn that we have personal information on a child under the age of 16, we will delete that information from our systems. iPass encourages parents to go online with their kids. Here are a few tips to help make a child's online experience safer:

Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.

• Know the sites your kids are visiting and which sites are appropriate.
• Look for Web site privacy policies. Know how your child's information is treated.
• Please visit the website for the Federal Trade Commission for more tips on protecting children's privacy online.

The iPass Customer Privacy Policy is subject to change at any time. We encourage you to review the privacy policy regularly for any changes. Last update: September 2003

All Web Site material is owned by iPass Inc. There must be no reproduction of any of this material without the prior consent of iPass Inc.