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Privacy Policy

Effective as of 01/01/2014

Overview

Your privacy is important to iPass Inc. (hereinafter “iPass”). This privacy policy (the “Policy”) applies to use of the iPass website: www.ipass.com (and any associated iPass Service web sites) (collectively the “Web Site”) as well as the use of the iPass service (the “Service”). This Policy is intended to inform you about how information, including personal information, is collected, used and disclosed while visiting the Web Site or using the Service and explains how iPass protects and stores such information. This Policy also includes iPass’ European Union Safe Harbor Privacy Statements.

iPass complies with the U.S. — E.U. and U.S. — Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from European Union member countries and Switzerland. iPass has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view iPass’ certification, please visit http://www.export.gov/safeharbor.

We self-certify compliance with
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By using the Web Site or the Service you agree to the terms of this Policy and you expressly consent to the processing of Information and Session Data according to the terms contained herein. Your only remedy, if you do not accept the terms of this Policy, is to discontinue your use of the Service as well as the Web Site. iPass reserves the right, in its sole discretion, to make changes to this Policy. We encourage you to continually check this Policy for any updates.

Validate TRUSTe privacy certification

iPass has been awarded TRUSTe’s Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s Program Requirements and the TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program only covers information that is collected through this Web Site and the Service, and does not cover information that may be collected through mobile devices or downloadable software. TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@ipass.com. If you are not satisfied with our response you can contact TRUSTe here. The TRUSTe program does not cover information that may be collected offline or through our mobile applications. 

Use of the iPass web site

What information does iPass collect when I use the Web Site?
When you use the Web Site, iPass collects two (2) general types of information: (1) Personal Information; and (2) Anonymous Information (collectively “Information”)

  1. “Personal Information” as used herein means data that allows someone to identify or contact you, including, your name, telephone number, e-mail address, title, company name, as well as any other non-public information about you that is associated with or linked to any of the foregoing information.
  2. “Anonymous Information” means data that is not associated with or linked to your Personal Information; Anonymous Information does not permit the identification of specific individual persons.

How does iPass collect Information from the Web Site and how will it be used?
iPass collects information from you in various ways when you use the Web Site:

Active Information Collection: If you provide us feedback, contact us via e-mail, register for an account or our hotspot finder service, request a free trial or respond to an employment opportunity posted on the Web Site, we will collect information such as your name, phone number and e-mail address, as well as any other content included in the e-mail and any information that you submit to us. iPass may then use that information for feedback purposes, marketing purposes, hiring purposes, statistical purposes, and/or for new product development.

Passive Information Collection: As you navigate through the Web Site, certain Anonymous Information and non-anonymous information can be passively collected (that is, gathered without your actively providing the information) using various technologies, such as cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, click-stream). Your Internet browser automatically transmits to the Web Site some of this Anonymous Information, such as the URL of the website you just came from and the Internet Protocol (IP) address and the browser version your computer is currently using. The Web Site may use such passively collected Anonymous Information to provide better service to Web Site visitors, customize the site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the Web Site for your use.

iPass may also use “cookies” and similar technology to obtain information about your visits to the Web Site 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 Site or e-mails in which you showed an interest or took some action, and help us improve the quality and usefulness of our Web Site. iPass primarily uses cookies to determine what services or promotions you are interested in. We use both session ID cookies and persistent cookies on this Web Site. A session ID cookie expires when you close your browser. A session ID cookies helps iPass to improve your experience while visiting the Web Site. A persistent cookie remains on your hard drive for an extended period of time. We set a persistent cookie to store your passwords, so you don’t have to enter it more than once. By using the Web Site and/or using any Service provided via the Web Site you agree to the above use of cookies.

The use of cookies by our partners, affiliates, tracking utility company, and service providers is not covered by our privacy policy. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company and service providers use session ID cookies to understand usage patterns on the Website.

If you prefer not to receive cookies while browsing the Web Site, 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 the Site if you do so. In particular, you may be required to accept cookies in order to complete certain actions on the Web Site. You do not need to have cookies turned on, however, to use/navigate through many parts of the Web Site and to access certain parts of iPass’ Web Sites you may be required to use a login and password.

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. If you no longer wish to receive our newsletters you can follow the unsubscribe instructions contained in the communications you receive.

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email.

Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Our Web Site includes Social Media Features (“Features”), such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Use of the services

What information does iPass collect when I use the Service?
iPass will collect: (a) your username/login-id; (b) your domain/iPass realm; and (c) other information as provided. While using the Service, iPass may collect Session Data. “Session Data” as used herein means that information and data regarding you and anyone you allow to use the Service which is collected by virtue of providing you with the iPass Service and is necessary for the billing and maintenance of the Service. This may include, by way of example only: (a) authentication domain and user name/identification; (b) date, time and duration of session; (c) amount of data transferred during the session; (d) technical or network data provided to or obtained by iPass in connection with the provision of Services; (e) location where the Service was used, as well as the name of a Wi-Fi hotspot or hotel internet connection used by you; (f) information about the make, model, operating system and other characteristics of the device on which you use the Service; (g) the location of your device when you use the Service; and (h) the identity of software applications running on your device while the Service is being provided.

How does iPass use the Session Data it collects?
iPass will use Session Data in connection with your use of the iPass Service only for purposes related to providing you with the Service or otherwise so as to improve the Service. iPass will use and process your Session Data: (a) in connection with provisioning of the Service; (b) to incorporate your Session Data into databases controlled by iPass for 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 and customer-directed application of policies as part of our service delivery. iPass may also use Session Data to contact third parties in connection with inappropriate use of the Service or violation of iPass policy.

Use of the Service through an iPass channel partner or as an employee of an iPass enterprise customer (an iPass enterprise customer and channel partner together “iPass Business Clients”)
iPass will collect information under the direction of its Business Clients and has no direct relationship with the individuals whose personal data it processes. iPass works with its Business Clients to help them provide notice to their customers or employees concerning the purpose for which personal information is collected.

Choice
We collect information for our Business Clients, if you are a customer of one of our Business Clients and would no longer like to be contacted by one of our Business Clients that use our service, please contact the Business Client that you interact with directly.

Service Provider, Sub-Processors/Onward Transfer
iPass may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Business Clients.

Access to Data Controlled by our Business Clients
iPass has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the iPass’ Business Client (the data controller). If the Business Client requests iPass to remove the data, we will respond to their request within 30 business days.

Data Retention
iPass will retain personal data we process on behalf of our Business Clients for as long as needed to provide services to our Business Client. iPass will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

End User Liable Users
When you directly register to use our Open Mobile Service you will be asked to provide information in order to set up a Service account. As part of this process, iPass will collect personal information related to your account such as: (a) your email address; (b) password; (c) login-id; (d) credit card information; and (e) billing address.

How does iPass use and store my payment information as an individual Open Mobile Service User?
If you pay for the Service directly through your personal credit card, iPass’ third party payment processing vendor will collect your credit card information, billing address and other necessary billing information and Personal Information.

General terms

Does iPass share any of my Information or Session Date with third parties?
Except as otherwise stated herein, iPass does not sell, trade, or share your Personal Information with third parties unless you ask or authorize iPass to do so.

Subject to the terms of this Policy, iPass may share Information or Session Data with third parties for provisioning of the Service, billing and reconciliation, verification of your identity, an email service provider to send out emails on our behalf, maintenance and support, and fraud detection and prevention. When you sign up for our services, we will share your personal information only as necessary for the third party to provide that service.

If you are using the Services through an iPass Business Client, iPass may share Information and Session Data with them in order to: (a) authenticate your use of the Service; and (b) for billing, reporting and marketing purposes.

iPass may disclose Information and Session Data if you breach this Policy, or any other applicable iPass policy related to the Service and/or the Web Site in order to enforce protection of iPass’ rights and those of third parties. iPass may also disclose Information and Session Data to any state, federal or international governmental agency if required to do so by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process.

iPass may share Information or Session Data with any of its affiliates, in which case, any such affiliate shall honor the terms of this Policy.

iPass reserves the right to transfer all Information and Session Data in its possession to a successor entity in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of iPass’ assets or business. Other than to the extent ordered by a court, the use and disclosure of all transferred information will be subject to this Policy or to a new privacy policy if you are given notice of that new privacy policy. Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor entity. You will be notified via prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information.

How can I request iPass to cease using and collecting my Information?
If you have any complaints relating to this Policy, or if you would like request access to, correction of, or deletion of your Personal Information, or if you would like to request that iPass stop using your Personal Information for certain activities, including for marketing purposes, send an e-mail to privacy@ipass.com or write to Privacy, iPass Inc., 3800 Bridge Parkway, Redwood Shores, California 94065, USA giving specific details of your request. With respect to any request for deletion, please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We will respond to requests for access within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How does iPass keep and protect my Information?
Keeping information about you secure is very important to iPass. To this end, iPass uses commercially reasonable protection technology such as encryption (when you provide us with sensitive information such as login credentials), firewalls and other security procedures to help protect the accuracy and security of the Information and Session Data and to help prevent unauthorized access or improper use. For example, you will note that while using some features of the Web Site, you will need to submit a password or some other type of authenticating information.

While iPass strives to protect the Information it gathers, 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 or Session Data obtained. You provide information via use of the Web Site at your own risk. If you have any questions about security on our Web site, you can contact us at
privacy@ipass.com.

Further Disclosures
Our Web Site may contain publicly accessible blogs or community forums. You should be aware that any information provided in these areas may be read, collected and used by others who access them. To request removal of any Personal Information for our blog or community forum, contact us at privacy@ipass.com. In some cases iPass may not be able to remove your Personal Information, in which case iPass will let you know if its unable to do so and why.

When you use the Service, iPass may be able to identify your location. Location information may be required in order to provide and bill for the use of the Service and shall not be used for any purpose beyond what is necessary for iPass to provide the Service.

Because of the global nature of our services, there are some places where you cannot access the iPass network. In these places, you may connect to other people’s Wi-Fi networks. Third parties are under no obligation to comply with this Policy with respect to information that you provide directly to those third parties or that those third parties collect for themselves. Further, iPass does not control the third-party sites that may be accessible through this Web Site or through the use of the Services. Thus, this Policy does not apply to information provided to third-party sites or gathered by the third parties that operate them. Before visiting a third-party site and before providing any information to any third party, you should inform yourself of the privacy policies and practices (if any) of the third party, and should take those steps necessary, in your discretion, to protect your privacy.

We may update this Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Web Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions regarding our privacy policy or practices you can contact us at privacy@ipass.com or via postal mail at iPass Inc., 3800 Bridge Parkway, Redwood Shores, CA 94065, Attn: Legal Counsel.