PREPASS® ONLINE PRIVACY POLICY

Last Modified: 17 Sep 2024

This PREPASS® ONLINE PRIVACY POLICY (“Privacy Policy”) is incorporated by reference into the PrePass® Online Terms of Use (together, with any documents expressly incorporated by reference, the “Terms of Use”) for PrePass® Safety Alliance, an Arizona non-profit corporation (together with its affiliates and subsidiaries, “PrePass®”). Capitalized terms used in this Privacy Policy shall have the meaning set forth in this Privacy Policy or the Terms of Use. To the extent there are conflicts between the Privacy Policy and the Terms of Use, this Privacy Policy will control.

1. DEFINITIONS

• “Application” means the PrePass® Mobile Application (including all related documentation).
• “ByPass Event Data” means all data collected during the normal course of PrePass® site operations.
• “Carrier” means the person or entity that has agreed to and qualifies as a customer under the terms of the PrePass® License Agreement, maintains a master billing account with PrePass® and is ultimately responsible for any such associated account(s).
• “End User” means any individual or entity that accesses and utilizes the functions of the Application.
• “End User Data” has the meaning set forth in the “Information PrePass® Collects About the End User” section.
• “Location Information” means location data that is automatically generated on the Application when the Services interact with cell towers and Wi-Fi routers. Location Information may also be generated by Bluetooth services, network devices, and other technology, including GPS satellites.
• “PrePass®” has the meaning set forth in the preamble above.
• “PrePass® Products” means the PrePass® suite of services including but not limited to PrePass® Weigh Station Bypass (“PrePass® Bypass”), PrePass® Plus, PrePass® Tolls, PrePass® Toll Management Services (“Toll Violation Prevention” and/or “Toll Violation Settlement”), PrePass® app, and/or PrePass® AG.
• “PrePass® Properties” means the Services, the Software, and all content therein (excluding End User Data).
• “Privacy Policy” has the meaning set forth in the preamble above.
• “Services” means the PrePass® Products, the Website, the Application, and other services including, but not limited to the features, functionality, and content accessible on or through the Application and which may be hosted on the Website.
• “Software” means the programs and other information that operates the Services.
• “Telematic Service Provider” means a provider that offers an electronic system used to transmit or receive data from a moving vehicle.
• “Terms of Use” has the meaning set forth in the preamble above.
• “User Account” means a uniquely identified username and password created by the End User and administered by PrePass® in order to establish access with the Application, its information and to utilize the services.
• “Website” means the PrePass® website located at www.prepass.com.

2. GENERAL

PrePass® is committed to the privacy and security of the End User Data (see Section 4 below). All End Users are required to register a User Account via the Application to utilize the PrePass® Products. This Privacy Policy describes:

• the types of information PrePass® may collect or that the End User provides when the End User downloads, installs, registers with, accesses, or uses the Services.
• the types of information PrePass® may collect from the End User when the End User accesses and uses the Services.
• the PrePass® practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies only to information PrePass® collects in the Application, on the Website, and in email, text, and other electronic communications sent through or in connection with the Application.

The Privacy Policy DOES NOT apply to information that:

• PrePass® collects offline or on any other PrePass® apps or websites, including websites the End User may access through the Services.
• the End User provides to or is collected by any third party.

Other third parties have their own privacy policies, which PrePass® encourages the End User to read before providing information on or through them.

Please read this Privacy Policy carefully to understand the PrePass® policies and practices regarding End User information and how PrePass® will treat it. If the End User does not agree with the PrePass® policies and practices, the End User’s choice is to not use the Services.

By using the Services, the End User authorizes PrePass® to gather, parse, and retain data related to the provision of the Services and collect, use and disclose information as described in this Privacy Policy. This Privacy Policy may change from time to time (see Section 8 below). The End User’s continued use of the Services after PrePass® makes changes is deemed to be an acceptance of those chances, so please check the Privacy Policy periodically for updates.

3. CHILDREN UNDER THE AGE OF 13

The Services are not directed to individuals under the age of thirteen (13), as required by the Children’s Online Privacy Protection Act. PrePass® does not knowingly collect End User Data from children under 13. If the End User is under 13, do not use or provide any information on the Services, or through any of its features. If PrePass® learns PrePass® has collected or received End User Data from a child under 13 without verification of parental consent, PrePass® will take steps to delete that information. If the End User believes PrePass® might have any information from or about a child under 13, please contact PrePass® at [email protected].

4. INFORMATION PREPASS® COLLECTS ABOUT THE END USER:

The Services collect several types of information from and about End Users, including, but not limited to:

“End User Data” means information the End User provided to PrePass®, which is not readily available to the public or accessible through other means and is used for the purpose of accessing or interacting with the PrePass® Properties, Services, the Website, the Software and or the Application; and that alone or in combination with other information may be used to readily identify, contact, or describe the End User. This information includes, but is not limited to:

• Legal Name
• Mailing Address
• Email Address
• Phone Number
• Date of Birth
• Biometric Records
• Driver’s License Information
• Such other information as PrePass® may request from time to time.

Bypass Event Data. Bypass Event Data is collected and retained to monitor that PrePass® carriers are not subjected to a higher level of regulatory compliance screening than non-PrePass® carriers. Bypass Event Data is attributable to a specific carrier or vehicle and is collected by PrePass® with authorization from the individual carrier.

Location Information. The Application collects and stores real-time information about the End User’s location. The collection of this information is necessary for the proper functionality of the Application and allows notifications to be sent to the End User to ensure proper compliance with weigh station stops, traffic, and other important safety information. End User must allow the Application to collect Location Information to continue using the Application. Collection of this information may improve the provision of the Application and provide End User with full functionality. PrePass® may utilize cookies, automatic data collection, GPS functions, and related technologies. The Application collects and stores information that is generated automatically as End User uses it, including End User’s preferences and anonymous usage statistics. Location Information can be based on things like precise device location, IP addresses, and information from End User and others’ use of the Services.

PrePass® does not consider End User Data to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual. PrePass® collects this information:

• directly from the End User when End User provides it to PrePass®.
• automatically as the End User navigates through the Services. Information collected may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• from third parties, for example, the PrePass® business partners and Telematic Service Providers

Information the End User Provides to PrePass®

The information PrePass® collects on or through the Services includes, but is not limited to:

• information that the End User provides by filling in forms. This includes information that the End User provides when the End User creates User Account required to utilize the Services or requesting further assistance.
• information that the End User provides when the End User make payments associated with the Services.
• records and copies of the End User’s correspondence (including email addresses) if the End User contacts PrePass®.
• the End User’s search queries on the Services.

Information PrePass® Collects Through Automatic Data Collection Technologies

As the End User navigates through and interacts with the Services, PrePass® may use automatic data collection technologies to collect certain information about the End User’s equipment, browsing actions, and patterns, including:

• Device Attributes. Information such as the operating system, hardware, software versions, device carrier, and display sizes.
• Device Operations. Information about operations and behaviors performed on the Services, such as whether a window is foregrounded or backgrounded, or mouse movements.
• Usage Data. Usage data may include information such as the End User’s personal device’s IP address, browser type, browser version, the pages of the Services the End User visits, the time and date of the End User’s visit, the time spent on those pages, unique device identifiers and other diagnostic data.
• Identifiers. Unique identifiers, device IDs, and other identifiers such as associated provider account identifiers.
• Data from a Mobile Device. PrePass® may collect data including the type of mobile device being used, the End User’s mobile device unique ID, the IP address of the End User’s mobile device, the End User’s mobile operating system, the type of mobile Internet browser the End User uses, unique device identifiers and other diagnostic data.
• Data from Device Settings. Information the End User allows PrePass® to receive through device settings, such as access to the End User’s GPS location, camera, or photos.
• Network and Connections. Information such as the name of the End User’s mobile operator or ISP, language, time zone, and IP address.
• Fleet Tracking Data. Information PrePass® receives about the End User’s vehicle from Telematic Service Providers such as speed, trip distance, fuel consumption, etc.

The information PrePass® collects automatically is only statistical data and does not include End User Data, but PrePass® may maintain it or associate it with End User Data PrePass® collects in other ways or receive from third parties. It helps PrePass® to improve the Services and to deliver a better and more personalized service, including by enabling PrePass® to:

• Estimate PrePass® audience size and usage patterns.
• Store information about the End User’s preferences, allowing PrePass® to customize the Services according to the End User’s individual interests.
• Speed up the End User’s searches.
• Recognize the End User when the End User returns to the Services.

The technologies PrePass® uses for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of the End User’s computer. The End User may refuse to accept browser cookies by activating the appropriate setting on the End User’s browser. However, if the End User selects this setting, the End User may be unable to access certain parts of the Services. Unless the End User has adjusted the End User’s browser setting so that it will refuse cookies, the PrePass® system will issue cookies when the End User directs the End User’s browser to the Services.

5. THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications, including advertisements, on the Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about the End User when End User uses the Services. The information they collect may be associated with End User Data or they may collect information, including End User Data, about the End User’s online activities over time and across different websites and other online services. They may use this information to provide the End User with interest-based (behavioral) advertising or other targeted content.

PrePass® does not control these third parties’ tracking technologies or how they may be used. If the End User has any questions about an advertisement or other targeted content, the End User should contact the responsible provider directly.

6. BUSINESS PURPOSES FOR COLLECTING INFORMATION

How PrePass® Uses End User’s Information. The Services use End User Data and aggregate information:

• To provide requested services to the End User;
• To personalize features and content to make suggestions for the End User;
• To provide the End User with useful content;
• To ensure the proper functioning of the Services;
• To analyze site operations;
• To conduct state and site activity reports;
• To offer and improve the Services;
• To conduct product research and development of the Services;
• To test the functionality of the Services;
• To provide the End User with requested information or technical support;
• To facilitate the End User’s movements during the End User’s use of the Services;
• To diagnose problems with the End User’s servers or the Services;
• To do a better job of advertising and marketing the Services;
• To help PrePass® partners measure effectiveness and distribute their ads and services;
• To verify accounts and activity;
• To detect and prevent spam;
• To promote safety and security on and off the Services;
• To administer PrePass® websites;
• To communicate to the End User;
• To bill the End User for the Services;
• In any other way PrePass® may describe when the End User provides this information; and
• For any other purpose as provided in the updated versions of this Privacy Policy.

PrePass® may share any End User Data collected about the End User through the Services to facilitate and improve the Services along with the internal user site-related purposes including sending background location-based messages regarding app specific messages (such as tolling, weigh station information and road safety information).

Internal and Application-Related Usage. PrePass® uses information, including End User Data, for internal and Service-related purposes and may provide it to third parties. PrePass® may use and retain any data PrePass® collects to make and provide improvements.

Communications. PrePass® may send an email to the email address the End User provides to PrePass® to verify the User Account and for informational and operational purposes, such as account management, customer application, or system maintenance. PrePass® may also email the End User in response to activity on the Services. PrePass® may use information, including End User Data, to enable advertising and marketing, including to others both online and through other means.

Disclosure of Information. PrePass® may disclose aggregated information about PrePass® End Users, and information that does not identify any individual, without restriction.

PrePass® may disclose End User Data that PrePass® collects, or the End User provides, as described in this Privacy Policy:

• To Third Parties. PrePass® works with third-party partners who help PrePass® provide and improve the Services. PrePass® will not sell or give End User Data to third parties for their use for purposes unrelated to PrePass® without the End User’s permission.
• To Affiliated Companies. PrePass® may share End User Data about the End User with affiliated companies. PrePass® also may share End User Data with PrePass® suppliers, contractors and agents who perform functions on behalf of PrePass®, or in connection with the Services offered by PrePass® or a request made by the End User, including partners who use PrePass® analytics services and measurement partners.
• To Vendors and Service Providers. PrePass® provides End User Data and content to vendors and service providers who support PrePass®, such as by providing technical infrastructure services, analyzing how the Services are used, providing customer service, facilitating payments or conducting surveys.
• To Legal and Governmental Authorities for Legal Compliance. PrePass® may disclose End User Data as PrePass® considers necessary to comply with the law or governmental authorities, in connection with litigation or dispute resolution. PrePass® may access, preserve, and share End User Data with regulators, law enforcement or others in response to a legal request (like a search warrant, court order, or subpoena) if PrePass® has a good faith belief that the law requires PrePass® to do so. This may include legal requests from jurisdictions outside of the United States when PrePass® has a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
• To Protect PrePass®. PrePass® may access, preserve, and share End User Data with regulators, law enforcement or others when PrePass® has a good faith belief of fraud, violations of the PrePass® terms or policies, or other harmful or illegal activity; to protect PrePass® (including PrePass® rights, property, or products), the End User or others, including as part of investigations or regulatory inquiries, or to prevent death or imminent bodily harm. End User Data PrePass® receives about the End User can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of the PrePass® terms or policies, or otherwise to prevent harm.
• During a Merger, Sale, or Other Asset Transfers. If PrePass® is involved in a change in control, merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale assets, or transition of PrePass® to another provider, the End User information may be sold or transferred as part of such a transaction as permitted by law and/or contract. PrePass® cannot control how such entities may use or disclose such information. PrePass® will provide notice of any merger, sale, or asset transfer.
• For Other Purposes. PrePass® may disclose End User Data for any other purpose disclosed by the End User when the End User provided the End User Data or as provided in the updated versions of this Privacy Policy.

Retention. PrePass® will retain End User Data only for as long as is necessary for the purposes set out in this Privacy Policy. PrePass® will retain and use End User Data to the extent necessary to comply with PrePass® legal obligations, resolve disputes, and enforce PrePass® legal agreements and policies.

Generally, Bypass Event Data collected during Service operations shall be retained for a period not to exceed 90 days beyond the end of the billing period, which normally covers a calendar month period, unless PrePass® is otherwise required by law or regulation to retain End User Data for longer. Bypass Event Data will be anonymized with respect to a specific carrier or vehicle only after (a) payment by or on behalf of the specific carrier of an unprotested billing has been received by the PrePass® Service Center, or (b) a protested billing has been resolved. Other data will be anonymized after the 90-day period.

End User Data is processed at PrePass® operating offices and in any other places where the parties involved in the processing are located. End User Data may be transferred to, and maintained on, computers located outside of the End User’s state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in the End User’s jurisdiction. The End User’s consent to the Privacy Policy followed by the End User’s submission of such information represents the End User’s agreement to that transfer.

Security. PrePass® will take all steps reasonably necessary to ensure that End User Data is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and PrePass® cannot ensure or warrant the security of any information the End User provides to PrePass®. PrePass® does not accept liability for unintentional disclosure. Do not share any information on or through the Services if End User is concerned about the unauthorized access to such information by a third party.

By using the Services or providing End User Data to PrePass®, the End User agrees that PrePass® may communicate with the End User electronically regarding security, privacy, and administrative issues relating to the End User’s use of the Services. If PrePass® learns of a security system’s breach, PrePass® may attempt to notify the End User electronically by posting a notice on the Website and the Application or by sending an email to the End User. The End User may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw the End User’s consent from receiving electronic notice), please notify PrePass® at [email protected].

International Users. By using the Services, the End User agrees to transfer data to the United States.

Choice of Law. By choosing to visit the Services or otherwise provide information to PrePass®, the End User agrees that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the State of Arizona and the dispute resolution provisions set forth in the Terms of Use. If the End User is visiting from the European Union or other regions with laws governing data collection and use, please note that the End User is agreeing to the transfer of End User’s information to the United States and processing globally. PrePass® has employees, customers and suppliers in other countries. The management, operational and technical processes and systems used by PrePass® may involve transfer of information across borders. For example, End User Data the End User gives to PrePass® may be sent to systems outside the country in which the End User initially provided the information, and it may be processed and stored in a different country. Regardless of where the End User provides End User Data, PrePass® will take steps to handle it in a secure manner in accordance with this Privacy Policy and all applicable laws. These protections will be extended to any other future companies in which PrePass® operations take place. By providing the End User’s information the End User consents to any transfer and processing in accordance with this Privacy Policy.

7. END USER’S RIGHTS & CHOICES

Cookies & Tracking Data. The Services are using the minimum amount of cookies required without the option to restrict. However, if more cookies are used, the End User may restrict PrePass® ability to use cookies and certain other types of data files by managing the cookie settings on the End User’s device or browser. Please note that if the End User creates such restrictions, all, or parts of the Services may not operate as intended (or at all).

Access. The End User may request information about End User Data PrePass® collected from the End User and how PrePass® used the End User Data in the last 12 months. If the End User makes such a request, then PrePass® will provide the End User with the categories of End User Data PrePass® collected in the last 12 months, along with the categories of any third parties with which PrePass® shared the data, the specific pieces of that data, as well as any other information of which PrePass® is required to provide to the End User by applicable law. PrePass® will respond within 45 days of receiving an End User Data request. Please note that the End User may only make an End User Data request twice within a 12-month period and PrePass® will need to collect information to verify the End User’s identity.

End User Data Used for a Business Purpose. In connection with any End User Data PrePass® discloses to a third party for a business purpose, the End User has the right to know the categories of information disclosed, categories of third parties to whom information was disclosed, and the categories of End User Data that PrePass® disclosed about the End User for a business purpose.

Deletion. The End User may request that PrePass® delete End User Data from PrePass® systems. PrePass® will comply with that request within a reasonable period, unless PrePass® has a legal right to retain that data (for example, to continue providing the Services to the End User, or to complete a transaction which the End User or Carrier initiated in the PrePass® systems).

Exercising End User’s Rights. If the End User wishes to withdraw the End User’s consent for the use and sharing of End User Data pursuant to this Privacy Policy, then the End User will need to cease all use of the User Account via the Services and deactivate the User Account by sending an email to [email protected]. The End User may opt out of having End User Data sold by selecting the “Do Not Sell My Personal Information” link located on the homepages of the Application and the Website.

Update End User’s Information/Pose a Question or Suggestion. If the End User would like to update or correct any End User Data that the End User has provided to PrePass® through the End User’s use of the Application or otherwise, or if End User has suggestions for improving this Privacy Policy, please send an email to [email protected].

Rights Under the European Union’s General Data Protection Regulation (GDPR). If the End User is a “Data Subject” under the GDPR, then in addition to the rights outlined elsewhere in this Privacy Policy, the End User has the rights outlined in this section. If the End User has questions about any of these rights or if the End User would like to exercise any of these rights, please contact PrePass® using the contact information at the bottom of this Privacy Policy. Also please note that certain portions of the Services will not work for the End User unless the End User provides PrePass® with End User Data.

• The End User has the right to be informed about what data PrePass® collects and how PrePass® uses it.
• The End User has the right to request access to End User Data.
• The End User has the right to have PrePass® rectify End User Data if it is inaccurate or incomplete.
• The End User has the right to have PrePass® erase, remove, or delete End User Data.
• The End User has the right to restrict PrePass® processing of End User Data as provided in the GDPR.
• The End User has the right to object to certain uses of End User Data as provided in the GDPR.
• The End User has the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the GDPR.
• To the extent the End User provided consent to PrePass® processing of End User Data, the End User has the right to withdraw that consent at any time. However, such withdrawal will not be effective with respect to lawful processing based upon consent that occurred prior to the End User’s withdrawal. (PrePass® requires only the information that is reasonably required to enter a contract with the End User. PrePass® will not require the End User to provide consent for any unnecessary processing a condition of entering a contract with PrePass®.)
• PrePass® will only retain End User Data for as long as necessary for the purposes outlined in this Privacy Policy and the Terms of Use.

Rights Under the Personal Information Protection and Electronic Documents Act (PIPEDA). If the End User is a resident of Canada, then in addition to the rights outlined elsewhere in this Privacy Policy, the End User has the rights outlined in this section. If the End User has questions about any of these rights or if the End User would like to exercise any of these rights, please contact PrePass® using the contact information at the bottom of this Privacy Policy.

• The End User has the right to know the name, title, and contact information of the person who is accountable for the PrePass® privacy policies and practices as outlined under PIPEDA.
• The End User has the right to know the name, title, and contact information of the person to whom access requests should be sent.
• The End User has the right to any documents that explain the PrePass® policies, standards, or codes.
• The End User has the right to know how the End User can gain access to End User Data.
• The End User has the right to be informed about what End User Data PrePass® collects and its intended purpose.
• The End User has the right to know what End User Data is disclosed to other organizations, including any third parties and subsidiaries, and why.
• The End User has the right to withdraw consent, including consent given when privacy practices have been updated (subject to legal or contractual restrictions).
• The End User has the right to have PrePass® rectify End User Data if it is inaccurate or incomplete.
• The End User has the right to request access to End User Data. PrePass® is required to respond to the End User’s request within 30 days.
• The End User has the right to have PrePass® erase, remove, or delete End User Data.
• The End User has the right to submit complaints to PrePass® regarding the compliance with any of the Fair Information Principles.

8. POWER TO AMEND THIS PRIVACY POLICY

PrePass® reserves the right to revise this Privacy Policy at any time, so review it periodically.

Posting of Revised Privacy Policy. PrePass® will post any adjustments to the Privacy Policy on this page of the Website and Application, and the revised version will be effective when it is posted unless otherwise specified as set forth at the top of this Privacy Policy. PrePass® will notify the End User any adjustments to the Privacy Policy via the email address the End User has provided to PrePass®. If the End User is concerned about how the End User’s information is used, bookmark this page and read this Privacy Policy periodically. The End User is responsible for ensuring the End User’s continued acceptance of this Privacy Policy and the End User’s continued use of the Services following a change in the Privacy Policy will subject the End User’s use to any such change to the new provisions of this Privacy Policy.

New Uses of End User Data. From time to time, PrePass® may desire to use End User Data for uses not previously disclosed in the Privacy Policy. If the PrePass® practices change regarding previously collected End User Data in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time PrePass® collected the information, PrePass® will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

9. CONTACT

If the End User has any questions or comments about this Privacy Policy, how PrePass® collects and uses the End User’s information, or the End User’s choices regarding the same, then the End User may contact PrePass® at:

Email: [email protected]

Phone Number: 1-800-PREPASS (1-800-773-7277)

By using the Services, the End User agrees that the End User’s use is subject to the terms of this Privacy Policy and the End User consents to the collection, use and storage of End User Data by PrePass® in accordance with this Privacy Policy and as may be more specifically explained on the Website and Application. PrePass® may change this Privacy Policy at any time and will display the changes here. Because the End User’s use of the Services after changes have been posted indicates the End User’s agreement with those changes, PrePass® encourages the End User to visit this Privacy Policy on a regular basis. If the End User is not comfortable with using the Services in accordance with this Privacy Policy, please cease all use of the Services immediately.

FAQs

I. What kinds of information does PrePass® collect?

Things the End User and others do and provide.

Information and content the End User provides including, but not limited to: End User Data, and the content, communications, and other information the End User provides when the End User creates a User Account. This can include information in or about the content the End User provides (like metadata), such as the date a file was created, file dimensions, file types. PrePass® systems automatically process content and communications the End User and others provide to analyze context and what is in them for the purposes of improving user experience.

Device Information.

As described below, PrePass® collects information from and about the computers, phones, and other web-connected devices the End User uses that integrate with the Services, and PrePass® combines this information across different devices the End User uses.

Information PrePass® obtains from these devices includes, but is not limited to:

• Device attributes;
• Device operations;
• Usage data;
• Identifiers;
• Data from a mobile device;
• Data from device settings;
• Network and connections; and
• Cookie data.

II. How does PrePass® use this information?

PrePass® uses the information PrePass® has (subject to choices the End User makes) as described below and to provide and support the Services. The information PrePass® collects is used:

• To provide requested services to the End User;
• To personalize features and content to make suggestions for the End User;
• To provide the End User with useful content;
• To ensure the proper functioning of the Services;
• To analyze site operations;
• To conduct state and site activity reports;
• To offer and improve the Services;
• To conduct product research and development of the Services;
• To test the functionality of the Services;
• To provide the End User with requested information or technical support;
• To facilitate the End User’s movement during the End User’s use of the Services;
• To diagnose problems with PrePass® servers or the Services;
• To do a better job of advertising and marketing the Services;
• To help PrePass® partners measure effectiveness and distribute their ads and services;
• To verify accounts and activity;
• To detect and prevent spam;
• To promote safety and security on and off of the Services;
• To administer PrePass® websites;
• To communicate to the End User;
• To bill the End User for the Services;
• In any other way PrePass® may describe when the End User provides this information; and
• For any other purpose as provided in the updated versions of this Privacy Policy.

III. How is this information shared?

The End User’s information is shared with:

• Third-Party Partners.
• Affiliate Companies
• Vendors and Service Providers
• Legal and Governmental Authorities for Legal Compliance
• Legal and Governmental Authorities to Protect PrePass®
• Companies During Sale or Merger Transfers
• Others as provided in the updated versions of this Privacy Policy.

IV. How can End User’s manage information about themselves?

PrePass® provides the End User with the ability to access, rectify, port and erase the End User’s data.

When the End User deletes the End User’s account, PrePass® deletes things the End User has posted, such as the End User’s photos or posts, and the End User will not be able to recover that information later. Information that others have shared about the End User is not part of the End User’s account and will not be deleted.

If the End User wishes to update the End User’s information, pose a question or suggestion, or withdraw the End User’s consent for the use and sharing of End User Data, please send an email to [email protected]

V. How does we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law enforcement or others:

• In response to a legal request (like a search warrant, court order or subpoena) if PrePass® has a good faith belief that the law requires PrePass® to do so. This may include legal requests from jurisdictions outside of the United States.
• When PrePass® has a good faith belief it is necessary to: detect, prevent and address fraud, unauthorized use of PrePass® products, violations of PrePass® terms or policies, or other harmful or illegal activity; to protect PrePass® (including PrePass® rights, property, or products), the End User or others, including as part of investigations or regulatory inquiries, or to prevent death or imminent bodily harm.

VI. How will PrePass® notify End User’s of changes to this policy?

PrePass® reserves the right to update this Privacy Policy at any time. At a minimum, this Privacy Policy is updated annually. PrePass® will post changes on the Website and Application and send an email to the email address the End User provides to PrePass® to notify the End User of any changes to this Privacy Policy. The End User will receive an opportunity to review the revised Privacy Policy.