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Privacy Policy
LAST UPDATE: February 27, 2023
provide our Application to you, to analyze and improve our Application, and to
communicate with you. This Privacy Policy (the “Privacy Policy”) covers our treatment of
the personally identifiable information (“Personal Information”) that we gather when you
From time to time, we may revise or amend this Privacy Policy to reflect changes in law,
our personal data collection and use practices, the features of the Application, or
advances in technology. This Privacy Policy does not cover the practices of entities we
don’t own or control, or people we don’t manage.
1. Who we are
Our Privacy Policy applies to our and all services we offer, but excludes any products,
applications or services that have separate privacy policies which do not incorporate
this Privacy Policy. For the purposes of data protection laws of the United States (“US”)
(i.e., the company who is responsible for, and controls the processing of, your personal
data).
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TermiPass ( “we”, “our” or “us”) collects information about you from various sources to
and the European Union (“EU”) (“Data Protection Laws”), TermiPass is a data controller
access or use our services, currently offered at TermiPass Application (the “Application”).
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2. Information we collect and for what purpose
We gather various types of Personal Information from our users and Application visitors,
and we use this Personal Information internally for a variety of purposes, including but
not limited to business reasons, marketing, Application maintenance and statistics, and
research and product development.
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Information you provide – when you interact with our Application you may
voluntarily provide us with Personal Information, such as your name (including
business entity name), date of birth, postal address, email address, phone
number, physical location and trading activity. You may provide this Personal
Information to us when you contact us, create an account with us, inquire about
careers with us, or request information about our Application. You may provide
this Personal Information to us directly or through third-party identity verification
services or social media. We may also request and collect additional
documentation to support and verify the Personal Information you provide,
including: identification documents such as passports, drivers’ licenses or
national identification cards; official letters and statements proving place of
residence; and self-portrait photographs.
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Information Automatically Collected – we may also automatically collect other
technical information about your use and interaction with our Application, which
may be collected through cookies, web beacons and other similar technology as
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described in Section 5 (how we use cookies and other tracking technology to
collect information).
3. How we collect information
To the extent permissible under applicable Data Protection Laws, we collect information
about you and any other party whose details you provide to us when you:
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Access or use our Application;
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Create an account with our Application;
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Complete online forms (including call back requests), take part in surveys, post
on any forums, download information such as white papers or other publications
or participate in any other interactive areas that appear within our Application;
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Interact with us using social media;
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Provide your contact details to us when registering to use or access any services
we make available or when you update those details; and
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Contact us or otherwise connect with us, online or offline.
We will also collect your information where you only partially complete and/or abandon
any information inputted into our Application and/or other online forms and may use this
information to contact you to remind you to complete any outstanding information and/or
for marketing purposes.
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We may also collect information from your devices (including mobile devices) and
applications you or your users use to access and use our Application (for example, we
may collect the device identification number and type, location information and
connection information such as statistics on your page views, traffic to and from the
sites, referral URL, ad data, your Internet Protocol (IP) address, your browsing history
and your web log information) and we will ask for your permission before we do so. We
may do this using cookies or similar technologies (as described in Section 5 below).
If you intend to give us Personal Information about someone else, you are responsible
for ensuring that you comply with any obligation and consent obligations under
applicable Data Protections Laws. Insofar as required by applicable Data Protection
Laws, you must ensure that beforehand you have their explicit consent to do so and that
you explain to them how we collect, use, disclose and retain their Personal Information,
or direct them to read our Privacy Policy.
4. How we use your information
To the extent permissible under Data Protection Laws, we use your information to:
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Provide any information or services that you have requested or ordered;
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Compare information for accuracy and to verify it with third parties;
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Provide, maintain, protect and improve our Application;
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Manage, monitor, and administer your use of the Application and provide an
enhanced, personal, user experience;
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Manage our relationship with you (for example, customer services and technical
support activities);
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Undertake internal testing of our Application or systems to test and improve their
security and performance (in these circumstances, we would de-identify any
information used for such testing purposes);
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Provide you with any information that we are required to send you to comply with
our regulatory or legal obligations;
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Comply with applicable Know Your Customer and Anti-Money Laundering
regulations;
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Detect, prevent, investigate or remediate, crime, illegal or prohibited activities or
to otherwise protect our legal rights (including liaison with regulators and law
enforcement agencies for these purposes);
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Contact you to see if you would like to take part in our customer research (for
example, feedback on your use of our applications, products and services);
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Monitor, carry out statistical analysis and benchmarking (provided that in such
circumstances it is on an aggregated basis which will not be linked back to you or
any living individual);
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Deliver advertising, marketing (including in-product messaging) or information
which may be useful to you; and
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Deliver joint content and services with third parties with whom you have a
separate relationship (for example, social media providers).
In addition to the commercial uses listed above, we may be required to provide any and
all of your Personal Information to governmental authorities as necessary to comply with
the law. To the extent required by Data Protection Laws, or where we have a legitimate
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and lawful purpose for doing so, we retain information about you after your withdrawal
of funds from the Application, the closure of your account, if your application for an
account is declined or if you decide not to proceed with the application.
Our Application may contain technology that enables us to:
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Check specific information from your device or systems directly relevant to your
use of the websites, applications or Application against our records to make sure
the Application services are being used in accordance with our end-user
agreements and to troubleshoot any problems;
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Obtain information relating to any technical errors or other issues with our
Application;
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Collect information about how you use the features of our Application; and
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Gather statistical information about the operating system and environment from
which you access our Application.
In addition to the purposes described in this section 4, we may also use information we
gather to deliver targeted and interest-based advertising, marketing (including
in-product messaging) or information to you which may be useful, based on your use of
the Application or any other information we have about you (depending on the
Application, you may able to configure these features to suit your preferences).
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5. How we use cookies and other tracking technology to
collect information
Cookies are small text files which are transferred from our Application and stored on
your device. We use cookies to provide personalized service, and to help make our
Application easier for you to access. Our cookies may be; 1) temporary session cookies
(cookies that identify and track users within our Application that are deleted when you
close your browser or leave your session in the application or service); or, 2) persistent
cookies (cookies that enable our Application to “remember” who you are and to
remember your preferences within our Application and which will stay on your computer
or device after you close your browser or leave your session in the applicable Service).
We use the following different types of cookies:
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Strictly necessary cookies - these cookies are needed for our Application to
function properly, for example, these cookies allow you to access secure areas of
our Application.
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Performance cookies and analytics technologies - these non-identifying cookies
collect statistics about how visitors interact with our Application, for instance
which functionality visitors use most often, and if they get error messages from
areas of the websites, applications or Application.
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Functionality cookies - these cookies allow our Application to remember choices
you make (such as your username, language or region) and allow us to provide
enhanced personalized features.
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Targeting or advertising cookies - these cookies are used to deliver adverts
tailored to you and your interests. They are also used to limit the number of times
you see an advertisement as well as help measure the effectiveness of an
advertising campaign. They are usually placed by advertising networks with our
permission.
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Web beacons and parameter tracking – we use cookies and similar software
known as web beacons to count users who visit our Application after clicking
through from our advertisements on other websites or in emails. These web
beacons collect limited information which does not identify particular individuals.
It is not possible to refuse the use of web beacons. However, because they are
used in conjunction with cookies, you can effectively disable them by setting your
browser to restrict or block cookies.
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IP Address and traffic data – we keep a record of traffic data which is logged
automatically by our servers, such as your IP address, device information, the
website that you visited before ours and the website you visit after leaving our
Application. We also collect some site, application and service statistics such as
access rates, page hits and page views. We are not able to identify any individual
from traffic data or site statistics.
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Google Analytics – Google Analytics uses cookies to help the Application
analyze how visitors use our services. The information generated by the cookie
will be transmitted to, and stored by, Google, on servers in the United States.
Google will use this information for the purpose of evaluating your use of the
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Application by compiling reports on website activity for website operators and
providing other reports relating to website activity and internet usage. Google
may also transfer this information to third parties where required to do so by law,
or where such third parties process the information on Google’s behalf. Google
will not associate your IP address with any other data held by Google. To find out
more, see “How Google uses data when you use our partners’ sites or apps,”
(located at
www.google.com/policies/privacy/partners
,
or any other URL Google
may provide from time to time).
If necessary to comply with applicable law, we will ask for your consent to use cookies
on your device. Once your consent has been provided, this message will not appear
again when you revisit. If you, or another user of your computer, wish to withdraw your
consent at any time, you can do so by altering your browser settings.
6. How we use mobile data
We may obtain information through mobile applications that you install on your mobile
devices to access and use our Application. These mobile applications may be our own
mobile applications or those belonging to third parties. Where the mobile application
belongs to a third party, you must read their privacy policy as it will apply to your use of
that third-party mobile application. We are not responsible for such third-party mobile
applications and their use of your Personal Information.
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7. How we share your information
We intend to keep your data and information confidential, in compliance with our legal
obligations. We may share your information with, where permitted by applicable law:
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Our corporate family, affiliates and subsidiaries;
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Our service providers and agents (including their sub-contractors) or third parties
which process information on our behalf (e.g. internet service and platform
providers, payment processing providers and those organizations we engage to
help us send communications to you);
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Partners, including system implementers, resellers, value-added resellers,
independent software vendors and developers;
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Third parties used to facilitate payment transactions, for example clearing
houses, clearing systems, financial institutions and transaction beneficiaries;
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Third parties where you have a relationship with that third party and you have
consented to us sending information (for example social media sites or other
third-party application providers);
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Third parties for marketing purposes;
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Third party credit reference and fraud prevention agencies;
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Third parties to enforce our legal rights and satisfy our legal obligations, including
without limitation any reporting or disclosure obligations under applicable law or
regulations or subpoena, court order or other judicial or administrative process,
or when we believe in good faith that disclosure is legally required or otherwise
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necessary to protect our rights and property, or the rights, property or safety of
others;
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Third parties to comply with the rules, regulations and guidelines of the payment
networks in which transactions are processed;
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Our professional advisors and auditors for the purpose of seeking professional
advice or to meet our audit responsibilities;
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Third parties to transfer information and/or assets in the event of a joint venture,
collaboration, financing, merger, acquisition, sale, bankruptcy filing, change of
legal form or other corporate restructuring;
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Another organization to whom we may transfer our agreement with you; and
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Third parties for any other purpose permitted under applicable law and regulation
or agreed to in this Privacy Policy or disclosed at the time the information is
collected.
If you follow a link from our Application to another site or service, this Privacy Policy will
no longer apply. We are not responsible for the information handling practices of
third-party sites or Application and we encourage you to read the privacy notices
appearing on those sites or Application.
8. Legal basis for processing in the EU
In the EU, we collect your personal data for the following purposes:
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Where necessary to perform any contract we enter into, or have entered into,
with you to provide services or access to our Application;
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Where necessary for our legitimate business interests (or those of a third party)
and your interests and fundamental rights do not override those interests; and
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Where we need to comply with a legal or regulatory obligation in the EU.
If you require details about the specific legal basis we are relying on to process your
personal data please contact us at
[email protected]
.
9. How we store and protect your information
We will endeavor to keep your information secure by taking appropriate technical and
organizational measures against its unauthorized or unlawful processing and against its
accidental loss, destruction or damage. We will take commercially reasonable steps to
protect your Personal Information but we cannot guarantee the security of your
information which is transmitted to our Application or to other website, applications and
Application via an internet or similar connection.
For individuals based in the EU or Switzerland, we store personal data for as long as
necessary to fulfil the purposes for which we collect the data (see above under
"Information we collect and for what purpose"), except if required otherwise by Data
Protection Laws. Please note that we may transfer information, including Personal
Information, to a country and jurisdiction that does not have the same Data Protection
Laws as your jurisdiction, and you consent to the transfer of information to the U.S. or
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any other country in which we or our parent, subsidiaries, affiliates or service providers
maintain facilities and the use and disclosure of information about you as described in
this Privacy Policy.
If you believe your account has been compromised, please contact us at
[email protected]
.
10. Your choices
a. Personal Information
You may provide us with instructions on what to do with your Personal Information.
Users have choices and control over their Personal Information. Where we need to
collect Personal Information and you fail to provide that data when requested, we may
have to close your account and/or block your access to the Application. Since your
choices and instructions may result in loss of access to the Application and services,
please review your options carefully.
b. Other information
If you have any questions about your Personal Information, our use of this Personal
Information, or your rights when it comes to any of the foregoing, contact us at
[email protected]
.
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c. Your rights in respect to your Personal Information if you are
located in the EU or Switzerland
If you are located in the EU or Switzerland, you have the following rights in respect to
the Personal Information that we hold:
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Right of access – the right to obtain access to your personal data;
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Right to rectification – the right to obtain rectification of your Personal Information
without undue delay where the data is inaccurate or incomplete;
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Right to erasure – the right to obtain the erasure of your Personal Information
without undue delay in certain circumstances, such as where the data is no
longer necessary in relation to the purposes for which it was collected or
processed;
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Right to restriction – the right to restrict data processing undertaken by us on
your Personal Information in certain circumstances, such as where the accuracy
of the personal data is contested by you, for a period enabling us to verify the
accuracy of that personal data;
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Right to portability – the right to portability allows you to move, copy or transfer
Personal Information easily from one organization to another; and,
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Right to object – you have a right to object to data processing based on
legitimate interests and direct marketing.
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Right to withdraw consent – you have a right to withdraw your consent to our
processing your data. If you exercise this right, we may not be able to provide
services to you.
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If you wish to exercise one of these rights, please contact us at
[email protected]
and we will respond within 30 days of the request. If you request access to your
personal data, we will provide all information to you by email in addition to context
regarding data use. If you request erasure of your personal data, we will respond with a
confirmation of erasure by email within 30 days of the request. If your request is
deemed unfounded and/or excessive, under the GDPR we retain the right to refuse to
respond to the request or to charge a reasonable fee if your request is clearly
unfounded, repetitive, or excessive. If we refuse to respond, or charge a reasonable fee,
we will provide our reasons for doing so. If you are not satisfied with the reasons, you
may complain to the relevant supervisory authority, the Information Commissioners
Office.
If you feel your Personal Information has been inappropriately handled, you can lodge a
complaint to your local data protection authority. Further information about how to
contact your local data protection authority is available at
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
.
d. Other Choices
In addition, the browser you use may provide the ability to control cookies or other types
of local data storage. We do not control these choices, or default settings, which are
offered by makers of your browser.
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11. Changes to our privacy policy
We may change our Privacy Policy from time to time. We will update this Privacy Policy
on our website, so please try to read it when you visit the website (the ‘last modified’
reference tells you when we last updated our Privacy Policy).
12. Further Information
If you have any queries about how we treat your information, the contents of this notice,
your rights under local law, how to update your records or how to obtain a copy of the
information that we hold about you, please email us at
[email protected]
, subject
line: “Data protection officer” in the subject header.
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