Your privacy is important to iPass Inc. (hereinafter "iPass" or "we"). This privacy policy (the "Policy") applies to use of the iPass service, including the iPass mobile application (collectively, the "Service"). This Policy is intended to inform you about how information, including personal and location information, is collected, used and disclosed while using the Service and explains how iPass protects and stores such information.
By using the Service you agree to the terms of this Policy and you expressly consent to the processing of Session Data, as defined below, in accordance with 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. iPass reserves the right, in its sole discretion, to make changes to this Policy. We encourage you to periodically check this Policy for any updates.
Does this Policy comply with the European Union’s ("EU") Safe Harbor Framework for privacy?
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.
What information does iPass collect when I sign up for and use the Service directly with iPass?
In addition to the Session Data, described below, iPass will also collect personal information related to your iPass account such as your: (a) name; (b)
email address; (c) login-ID; (d) password; (e) billing address; and (f) credit card information (collectively, "Personal Information").
What information does iPass collect when I sign up for and use the Service through my employer?
While using the Service through an employer sponsored plan, iPass will collect Session Data. "Session Data" as used herein means information and data
regarding you and anyone that you allow to use the Service which is collected by virtue of providing 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 the Wi-Fi hotspot or venue used; (f) information about the make, model, operating system and other characteristics of the device on which
you used the Service; (g) the location of your device when you use the Service; and (h) the identity of certain software applications running on your
device while the Service was being provided.
Does iPass store my payment information?
No, if you sign up for the Service directly with iPass, iPass’ third party payment processing vendor will collect and store your credit card information.
How does iPass use the Session Data it collects?
iPass will use Session Data collected in connection with your use of the Service: (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; (c) verification of your eligibility to
use the Service; (d) maintenance; (e) support; (f) product development; (g) fraud detection and prevention; (h) customer use analysis and reporting; and
(i) to provide you with product and Service updates and other information to enhance your use of the Service. iPass may also use Session Data to contact
third parties in connection with inappropriate use of the Service or violation of iPass policy.
Can the Service track my location?
When you use the Service by attempting to connect to and/or connecting to an iPass hotspot, iPass may be able to identify your location. Location
information is required in order to provide and bill for the use of the Service. Location information may also be used to provide you with iPass Service
updates and other information intended to enhance your use of the Service, such as local hotspot information.
How does iPass keep and protect my Information?
Keeping Session Data and Personal Information secure is very important to iPass. To this end, iPass uses commercially reasonable protection technology such
as encryption, firewalls and other security procedures to help protect the accuracy and security of the Personal Information and Session Data collected and
to help prevent unauthorized access or improper use of the Service.
How long does iPass keep and store the Personal Information and Session Data collected?
We will retain Personal Information and Session Data for as long as necessary to provide you with the Services. In addition, we will retain and use your
information as necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.
Does iPass share any Personal Information or Session Date with third parties?
Except as otherwise stated herein, iPass does not sell, trade, or share your Personal Information and/or Session Data with third parties unless you ask or
authorize iPass to do so.
Subject to the terms of this Policy, iPass may share Personal Information or Session Data with third parties for: provisioning of the Service; billing and reconciliation; verification of your identity; maintenance and support; and fraud detection and prevention. We may also use an email service provider to send out emails on our behalf. When you sign up for the Service, we will share your Personal Information only as necessary to provide the Service.
If you are using the Services through an employer sponsored plan, iPass may share Session Data with your employer in order to: (a) authenticate your use of the Service; and (b) for billing, reporting and marketing purposes.
iPass may disclose Personal Information and Session Data if you breach this Policy, or any other applicable iPass policy related to the Service in order to enforce and protect iPass’ rights and those of third parties. iPass may also disclose Personal 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 Personal 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 Personal 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. Personal Information and Session Data 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 up to 30 days of any such change in ownership or control of your personal information.
Does iPass control the hotspots that make up the iPass network?
No, iPass does not own, manage or control the hotspots that make up the iPass network. iPass also does not control the third-party sites that may be
accessible 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 that third party, and should take those steps necessary, in your discretion, to protect your privacy.
Do other third party privacy policies apply to the use of the Service?
Yes, your use of the Service may also be governed by the privacy policies of any applicable third party content and service providers, including the Google
Maps API Privacy Policy: http://www.google.com/policies/privacy/. Such third party agreement(s), if
any, shall not limit, encumber or otherwise restrict iPass’ rights and remedies and/or your obligations under this Policy.
How can I be made aware of changes to this Policy?
iPass may update this Policy, from time to time, in order to reflect changes to its privacy practices. It is your responsibility to periodically review
this Policy for any updates and the latest information on our privacy practices. Changes to this Policy will also be posted on the iPass web site at http://www.ipass.com/.
How can I request that iPass cease using and collecting my Personal 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. If you do not want iPass to collect any Session Data, do not use the Service.
Effective as of: 06.04.13