Privacy Policy

Category of Personal Data	Examples	Sourcepass uses this personal data to:
Contact and Account Information	Name, username, email address, phone number, IP address, and any other identifiers a user provides when accessing or using the Service   Account holders’ usernames and account numbers   Billing name and address for paid Services   Phone number, language preference, title, department	Create a Client account   Provide Services   Communicate with a Client   Respond to requests for support   Market to potential Client
Information about use of non-Sourcepass services through integrations or otherwise	Social media account information, single-sign-on service tokens, Google/ Apple/Microsoft sign in tokens	Create a Client account   Provide Services   Communicate with a Client Respond to requests for support   Market to potential Clients
Payment information	Billing name, address, and credit card or other payment information   Offering, price and other information about your purchase	Bill account holders who purchase Services

Category of Personal Data	Examples	Sourcepass uses this personal data to:
Service Usage Data	Internet Protocol (“IP“) address, MAC address, other device ID (UDID), device type, operating system type and version, client version, type of camera, microphone or speakers, connection type and other related information User feedback ratings, internal feature usage analytics, usage logs, cookie identifiers   Traffic data about the communications that take place through our platform (such as chat, video conferencing), network monitoring data   Fraud data such as blacklist history and security logs   Metadata such as session logs and join & leave time of participants Log data including IP address, Internet Service Provider (“ISP“), browser type, referring/exit pages, operating system, date/time stamp, and/or clickstream data Publicly available data from End User accounts	Connect you to and optimize your experience using our Website, Apps, and Services   Provide Clients dashboards and reports   Respond to requests for support Conduct fraud and threat analysis   Monitor performance of our data centers and networks   Conduct analytics to improve Website, App and Service performance
Geolocation information	Information about where you are located when using the Service	Provide the Service Communicate with users about the service Respond to requests for support Market products and services to account holders and/or other potential users

Category of Personal Data	Examples	Sourcepass uses this personal data to:
End User Personal Data	Name, username, email address, phone number, IP address, cookie identifiers and any other identifiers a user provides when accessing or using the Service   Other forms of personal information we collect on behalf of the relevant Client such as title, role, organization, phone number and other related information   Other forms of personal information we collect as necessary to offer the relevant Website, App or Service such as IP address, cookie identifiers and other related information	Provide the Services to the Client on whose behalf we collect or store the information   Communicate with a Client   Respond to requests for support For other legitimate business purposes permitted by our agreement with the relevant Sourcepass Client

Certain Sourcepass products and services may also access and store personal information about you from a Client’s social media accounts or accounts a Client may have with other third-party services, when the Client chooses to connect its Sourcepass accounts with its other accounts. This personal information may include name, email, geolocation and any other publicly available information on these platforms. With respect to social media, only personal information that an End User has directly provided to the relevant Sourcepass Client or that an End User has designated as publicly accessible will be accessed or stored. We use this personal information in connection with providing our Services to our Clients. For example, we use this personal information to enable Sourcepass Clients to respond to social media posts and messages from within their Sourcepass accounts, and to enable Sourcepass Clients to track and analyze their interactions with End Users via social media.

Cookies and other similar technologies:

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. This data often consists of a string of numbers and letters that uniquely identifies your computer, but it can contain other information as well. Some cookies are placed by third parties acting on our behalf which we have called out below in the Third-party cookies section. Our cookies help provide additional functionality to the Websites, track the traffic patterns for our Websites, combat potential fraud, and study how our users use and interact with the Websites and Services.

How we use cookies

We use cookies and similar technologies for several purposes, depending on the context or product, including:

Recognizing you if you sign in to use our offerings. This allows us to provide you with recommendations, display personalized content, and provide other customized features and services.

Keeping track of your specified preferences. This allows us to honor your likes and dislikes, such as your language and configuration preferences.

Detecting and preventing fraudulent activity and improving security.

Conducting research and diagnostics to improve our offerings.

Reporting, which allows us to measure and analyze the performance of our offerings.

First-party cookies

Strictly Necessary cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are often set in response to actions made by you, which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

Functional cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages.

Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.

Targeting cookies: These cookies may be set through our site and may be used to build a profile of your interests and show you relevant adverts on other sites.

Third-party cookies

In addition to our own cookies, we may also use various third-party cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

What are your choices regarding cookies?

Browser settings: You can manage browser cookies through your browser settings. The ‘Help’ feature on most browsers will tell you how to remove cookies from your device, prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. Check the support site for your browser to understand privacy settings available to you. If you block or reject some of our cookies through your browser’s settings, you might not be able to use certain offerings that require you to sign-in to an account and some features and services may not work. You might also have to manually adjust your preferences or settings every time you visit our websites.

Information we collect from third parties:

We may collect the names, e-mail addresses, postal addresses and city of residence of individuals from third parties to market our products / services to these individuals. This collection of information and marketing is always carried out in compliance with applicable law. We only collect this information where we have checked that these third parties either have your consent or these third parties are otherwise legally permitted or required to disclose your personal information to us.

For our Clients and account holders, we may collect personal information about you (such as names, e-mail addresses, postal addresses and city of residence) from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have, in accordance with applicable laws. This helps us to update, expand and analyze our records, identify new Clients, and provide products and services that may be of interest to you. For our End Users, we do not use the data we collect about you when you use our services for marketing without your consent.

We may collect personal information about you from other applications you may use if you choose to integrate Sourcepass Apps or Services with other Apps or Services.

We and our third-party marketing service providers may also use the information Clients send to us for our marketing purposes, if this is in accordance with your marketing preferences and applicable law. However, you may opt out of our marketing. For further information, see below.

Lawful basis for processing personal information (EEA and UK only)

When we collect personal information from you in connection with offering our Website, Apps or Services within the European Economic Area (EEA) and the United Kingdom (UK), our lawful basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

We will normally collect personal information from you where we need the personal information to perform a contract with you (i.e. to provide the Services), or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question (i.e. Service Usage Data) or we may process your personal information where we have your consent to do so.

If we ask you to provide personal information to comply with a legal requirement or enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our or a third party’s legitimate interests and those interests are not already listed above (see the “Personal Information We Collect and Use” section), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” section below.

SHARING AND DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

We will not rent or sell personal information about you. We may share and disclose personal information that we collect (as identified in the “Personal Information We Collect and Use” section) with the following third parties, solely for legitimate business or legal purposes and in accordance with applicable law:

Sourcepass or any of its worldwide affiliates consistent with this Policy.

Business partners, contractors, vendors, and authorized third party agents, to:

Operate, deliver, improve and customize our Websites, Apps, and Services

Provide support and technical services;

Send marketing and other operational communications related to our Websites, Apps, and Services;

Enforce our acceptable use policy;

Conduct analytics in order to better the user  experience and improve Sourcepass Websites, Apps and Services

Provide offers and advertisements to Clients based on their interests and interactions with us.

Any third parties as part of or in connection with an actual or prospective corporate business transaction, such as a sale, merger, acquisition, joint venture, financing, corporate change, reorganization or insolvency, bankruptcy or receivership;

Law enforcement agencies, regulatory or governmental bodies, or other third parties in order to respond to legal process, comply with any legal obligation; protect or defend our rights, interests or property or that of third parties; or prevent or investigate wrongdoing in connection with the Website, Apps or our Services;

Other third parties with your consent.

 

YOUR PRIVACY RIGHTS

Requests from End Users regarding personal information we process on behalf of our Clients as a Data Processor

In general, when processing the content of communications such as voicemails, faxes, recordings etc. in connection with our Services, we do so on behalf of our EEA/UK Clients and in accordance with their instructions as a data processor. This means that if you believe Sourcepass may have collected or stored personal information about you on behalf of a Sourcepass Client as a data processor or if you wish to access, review, modify or delete any content of your communications, under applicable EEA/UK law or otherwise, you should contact that Client directly with your request. We will then help them to fulfill that request in accordance with their instructions.

Update and access to your information

Where we process personal information collected via our Website or Apps or via our Services as a data controller for our own account and service management, billing or marketing purposes and where required by applicable law, we provide individuals with the opportunity to access, review, modify, and delete any such personal information that we process.

Your Privacy Rights as a data subject protected by EEA/UK law or as a California Resident

If you are a person located in the EEA/UK or if you are a California resident, you may have broader rights to access and delete your personal information, to object to or restrict processing of your personal information, to correct your personal information, or request portability of your personal information.

Access: You can request more information about the personal data we hold about you. You can request a copy of the personal data.

Rectification: If you believe that any personal data we are holding about you is incorrect or incomplete, you can request that we correct or supplement the data. You can also correct some of this information directly by logging into your Service account, if you are a Client. Please contact us as soon as possible if you discover any inaccuracy or incompleteness.

Objection: You can let us know that you object to the collection or use of your personal data for certain purposes.

Erasure: You can request that we erase some or all of your personal data from our systems. You can also delete some of this information directly by logging into your Service account, if you are a Client.

Restriction of Processing: You can ask us to restrict further processing of your personal data.  (This just means you can ask us to stop using it for what we have been using it for.) This may mean that we have to delete your account.

Portability: You can ask for a copy of your personal data in a machine-readable format. You can also request that we transmit the data to someone else where it’s technically possible.

Withdrawal of Consent: If you have consented to our use of personal data for a specific purpose, you have the right to change your mind at any time. Any such decision will not affect any processing that has already occurred nor will it affect processing of your personal information conducted in reliance of lawful processing grounds other than consent. Withdrawing your consent may mean your access to the Services will be limited or suspended, and your accounts may be terminated, as applicable. Where you withdraw your consent, but we are using your information because we or a third party (e.g. your employer) have a legitimate interest in doing so, or we have different legal basis for using your information (for example, fulfilling a contract with you), we may continue to process your information, subject to your rights to access and control your information.

Right to File Complaint: You have the right to lodge a complaint about Sourcepass’ practices with respect to your personal data with the supervisory authority of an EU Member State, or the California Attorney General.

You can submit a request to us directly. We will consider and handle all requests in accordance with applicable laws.

Additional Privacy Rights as a California Resident

If you are a California resident and receive Sourcepass Services or visit our Website or Apps solely as a private individual—in other words, not as the member or representative of a company or other organization—you may have the right to receive a free, yearly accounting of:

Information identifying each third-party company to whom we may have disclosed, within the past year, personal information pertaining to you for our own direct marketing purposes; and

A description of the categories of personal information disclosed.

You may have the right to know more about personal information that we have collected, disclosed, or sold, including:

The categories of personal information that we have collected or shared about you in the preceding 12 months,

The categories of sources from which we have collected that information in the preceding 12 months

The commercial or business reason(s) we have collected or shared that information,

The categories of third parties with whom we have shared or to whom we have sold that information in the preceding 12 months, and

Pursuant to a verifiable request, the specific pieces of information that we have collected about you.

Depending on the nature of your request, we may need additional information to verify your identity.

To make a request, please contact our Privacy Team at Legal@sourcepass.com.

Unsubscribe from our mailing list

We give you the choice of receiving a variety of information related to our Apps and Services. You can manage your communication preferences through the following methods:

By following the instructions included in each promotional email from us to unsubscribe from that particular mailing.

Sending us an email at Legal@sourcepass.com.

These choices do not apply to service notifications or other required communications that are considered part of certain Apps/Services, which you may receive periodically unless you stop using or cancel the App/Service in accordance with its terms and conditions.

 

THIRD-PARTY SITES  

This Policy does not apply to, nor are we responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Website links including but not limited to social media sites. The inclusion of a link on the Website does not imply our endorsement of the linked site or service. You should check the privacy Policies of those sites before providing your personal information to them.

BLOGS AND FORUMS

Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas is public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely. To request removal of your personal information from our blog or community forum, you can submit a request to Legal@sourcepass.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. We encourage all users to exercise caution when providing personal information in blogs and community forums.

SECURITY

Keeping your information secure is important to us. Like all businesses, we cannot guarantee the security of the personal information we collect and process in connection with our Websites, Apps and Services. We have, however, taken certain steps designed to reduce the risk that your personal information will be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction. Sourcepass has no control over or responsibility for the security or privacy policies or practices of other sites on the Internet you might visit, interact with, or from which you might buy products or services, even if you visit them using links from our Website.

DATA RETENTION

We will retain your personal information for no longer than is necessary to fulfill the purposes for which the information was originally collected unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes.

Where we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.

CHILDREN’S PRIVACY

Sourcepass does not knowingly provide products or services directly to children under the age of 16, or knowingly collect or solicit personal information from or about children under the age of 16 outside of the school offering. If you believe that a child under the age of 16 has disclosed personal information to Sourcepass outside of the school offering, please contact Legal@sourcepass.com.

UPDATES TO THIS POLICY

We may update this Policy from time to time in response to changing legal, technical, or business developments. If we make nonmaterial changes to our Policy, we will post those changes on this page in addition to updating the “Last Updated” or effective date at the top of this webpage. If we make material changes, we will notify you more directly, for example by emailing you prior to such material changes taking effect. We encourage you to review this Policy regularly to stay informed of the latest modifications.

CONTACT US

If you have any questions, comments or concerns about this Policy, please e-mail us at Legal@sourcepass.com. Or, you can write to us at:

Sourcepass, Inc.
Attn: Legal Department
81 Larkfield Road
East Northport, NY 11731