

Please read this Privacy Policy carefully.
Once you use this iPass Inc. (“iPass”) web site (the “Site”) or the iPass services (“Service”) you will be deemed to have read and consented to the use of your personal data as set out in this Privacy Policy. You must not use the Site or any iPass Service if you do not accept the terms of this Privacy Policy.
This Privacy Policy explains our practices regarding the Personal Data we collect from users of our Site and/or Services.
“Personal Data” as that term is used in this policy, means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not permit the identification of individual persons. We may collect both Personal Data and Anonymous Data, as described below.
This Site is governed solely by applicable U.S. laws and governmental regulations. Use of this Site constitutes your consent to application of such laws and regulations. Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.
The Site is not intended to be used by Children. We will not knowingly collect data or information from any person under the age of 18.
A. What Information iPass Collects
1. To use the iPass Service, and to obtain information offered on our Site, you will be asked to provide personal information. In some cases, you will be required to provide such information in order to use the Service, obtain information, or participate in special offers. iPass tries to limit our requests for personal information to only that information we believe is minimally necessary.
1.1 When requesting information from iPass regarding the iPass Service, to attend a seminar or register for an event or training course, or to access special content such as demos, you will be asked to provide iPass with the following information:
(a) your name;
(b) your title;
(c) your company name;
(d) your telephone number;
(e) your email address
(f) your company address (including street, city, state and country).
1.2 When registering to obtain a free trial account to test the iPass Service, you must provide iPass with the following information:
(a) your name;
(b) your title;
(c) your company name;
(d) your telephone number;
(e) your email address
(f) your address (including street, city, state and country)
(g) You may be asked to provide some additional data about your company such as number of office locations, number of employees and mobile device users, etc.
1.3 In order to use the iPass Service through an iPass reseller, or as an authorized user of a direct iPass enterprise customer, you must provide the following information
(a) your user name/identification;
(b) your domain/realm;
1.4 By virtue of providing you with the iPass Service, iPass may come into possession of information and data regarding you, and anyone you allow to use the iPass Service which is necessary for the billing and maintenance of the Service. This information and data (”Data”) includes:
(a) Authentication domain and user name/identification;
(b) Date, time and duration of session; amount of data transferred during the session
(c) Technical or network data provided to or obtained by iPass in connection with the provision of Services;
(d) Location where the Service was used, as well as the name of a Wi-Fi hotspot or hotel internet connection used by you;
(e) Information about the make, model, operating system and other characteristics of the device on which you use the iPass service
(f) The location of your device when you use the service
(g) The identity of software applications running on your device while service is being provided
Active Information Collection
If you provide us feedback or contact us via e-mail (e.g., in response to an employment opportunity posted on this Site), we will collect your name and e-mail address, as well as any other content included in the e-mail and any information that you submit to us, such as a resume.
Secured Areas
Use of any areas of the Site secured by a user name/login screen (“Secured Areas”), including but not limited to downloads of software, phonebook file updates, and installation and user documentation is governed by the terms and conditions of a separate agreement. Any collection of your Personal Data through a Secure Area is not governed by the terms of this Privacy Policy.
iPass Service
iPass provides iPass services (“iPass Service”) to corporate entities and not to individuals. Any collection of your Personal Data through your use of the iPass Service is not governed by this Privacy Policy. If you are an individual accessing the iPass Service through a corporate entity, please request the applicable privacy policy from the corporate entity. We are not responsible for such corporate entity’s privacy practices.
Passive Information Collection
As you navigate through this Site, certain anonymous and non-anonymous information can be passively collected (that is, gathered without your actively providing the information) using various technologies, such as cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, click-stream). Your Internet browser automatically transmits to this Site some of this anonymous information, such as the URL of the website you just came from and the Internet Protocol (IP) address and the browser version your computer is currently using. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of this Site might not work without cookies. This Site may use such passively collected anonymous information to provide better service to site visitors, customize the site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the site for your use.
We may also use “cookies” and similar technology to obtain information about your visits to our sites or your responses to e-mail from us—both individually and in aggregated data that does not identify you. These reporting tools tell us the parts of our Site or e-mails in which you showed an interest or took some action, and help us improve the quality and usefulness of our sites. iPass primarily uses cookies to determine what services or promotions you are interested in. Cookies help iPass to improve your experience while visiting our Website and customize our communications to the services. By using the Site and/or using any Services provided via it you agree to the above use of cookies.
If you prefer not to receive cookies while browsing the Site, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of the Site if you do so. In particular, you may be required to accept cookies in order to complete certain actions on the Site. You do not need to have cookies turned on, however, to use/navigate through many parts of the Site and to access certain of iPass’ web pages may require a login and password.
B. Purposes For Which iPass Uses the Information
1. Use of the Service: iPass will use information and Data collected in connection with your use of the iPass Service only for purposes of providing you with the Service(s) ordered or requested by you or otherwise so as to improve the service. iPass will use and process your Data (including intra-group transfers and transfers to iPass subsidiaries): (a) in connection with provisioning of the Services; (b) to incorporate your Data into databases controlled by iPass for the administration, provisioning, billing and reconciliation, verification of your identity and solvency, maintenance, support and product development, fraud detection and prevention, customer and customer use analysis and reporting and customer-directed application of policies as part of our service delivery. iPass may also use information to contact third parties in connection with inappropriate use of the iPass Service or violation of the iPass Service Use Restriction or AUP. You represent and warrant to iPass that you have obtained and will obtain all legally required consents and permissions from anyone you allow to use the iPass Services for the use, processing and transfer of Data as described in this policy.
2. Information Requests: The following list describes how iPass may use information provided by you through the Site or otherwise in connection with your request for information or other requests to iPass:
(a) In order to receive phone, mail or email correspondence from iPass;
(b) In our internal surveys to obtain feedback on our products, on The Site, or on other aspects of our business that impact you as an iPass customer;
(c) To notify you of new iPass products or services that may be of interest;
(d) To send promotional materials (including by e-mail) about iPass products and service;
(e) To contact you regarding ordering the iPass Service;
Should you want to opt out from receiving new product or service notifications or promotional materials please contact privacy@ipass.com.
3. Location technology: Please note that when you use our service there are occasions where we will be able to identify where you are located. This information is required to supply our services to you (including support services) and for billing and invoicing of the services. Location technology will not be used for any purpose other than providing your company with our services as contracted and ensuring legitimate use of those services. iPass considers our ability to locate where you are when you use the iPass Services to be fundamentally necessary to enable iPass to provide our services. Therefore, if you object to iPass’ use of location identification technology, do not use the Services.
4. Data passed to an end user’s employer: Use of the Services is enabled when you submit your proper credentials (user name and password) to iPass. iPass will then ask your employer, your service provider or other relevant iPass account holders to authenticate your session. Details including but not limited to time, date, location and length of time you use the Service and related details may also be held by us and passed to your employer or service provider in connection with your use of the iPass Service.
5. Job applications: Personal Data that is collected in connection with job opportunities will be used for processing your application and to consider the eligibility of candidates.
We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Products and services and improve site navigation. iPass reserves the right to use and disclose Anonymous Data to third party in its discretion.
C. Sharing Your Details with Third Parties
1. Except as detailed below, iPass does not sell or disclose your Personal Data to any third parties nor otherwise provide your Personal Data to third party marketing organizations or to any non-affiliated iPass entity.
2. In connection with your use of the iPass Service, iPass will only disclose Data and personal information about you to third parties (such as its authorized resellers) to enable iPass to provide you with the Service, including provisioning the Service, billing and reconciliation, verification of your identity, maintenance, support, fraud detection and prevention. You understand that iPass will not be able to provide you with the Service if you do not consent to iPass use of personal information and Data in this manner
3. iPass may disclose your Personal Data to selected iPass authorized resellers so that they can market products and services which they think that you may be interested in. Communications may be sent to you by e-mail. You can, at any time, ask iPass to cease passing on your Personal Data or using it for marketing purposes by contacting privacy@ipass.com.
4. iPass may disclose information about you if you breach this Privacy Policy, the Site Terms of Use or the AUP to enforce protection of our rights and those of third parties. We may also disclose your details to a state, federal, or international government agency if required to do so by law or requested to do so by any Governmental or law enforcement agency.
5. We may share some or all of your Personal Data with any or our affiliates, in which case we will require our affiliates to honor this Privacy Policy. If another company acquires iPass or our assets, that company will possess the Personal Data collected by it and us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
6. Information submitted by you to iPass may be transferred to iPass affiliates and other third parties identified in this policy who are located in other countries that do not provide equivalent statutory protections for Personal Data. This information will only be transferred abroad for the purpose of performing the purposes for which it was disclosed as set forth in this Privacy Policy.
D. Requests To Cease Use Of and Access to Your Details
1. As detailed above you may request that iPass stop using your Personal Data for certain activities, including for our or third party marketing purposes, by sending an e-mail to privacy@ipass.com or by writing to Privacy, iPass Inc., 3800 Bridge Parkway, Redwood Shores, California 94065 USA giving specific details of your request.
2. If you have any complaints relating to this Privacy Policy or how we deal with your Personal Data please contact us by e-mail to privacy@ipass.com or by writing to Privacy, iPass Inc., 3800 Bridge Parkway, Redwood Shores, California 94065 USA.
3. You may request access to, correction of, or deletion of your Personal Data held by us. To obtain more details about making such a request please contact us by e-mail to privacy@ipass.com or by writing to Privacy, iPass Inc., 3800 Bridge Parkway, Redwood Shores, California 94065 USA. 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.
E. Security
1. Keeping information about you 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 your Personal Data and to help prevent unauthorized access or improper use. For example, you will note that while using some features of the Site, you will need to submit a password or some other type of authenticating information.
2. While iPass strives to protect your Personal Data, no data transmission over the Internet can be guaranteed to be totally secure and therefore iPass cannot ensure or warrant the security of any information you send to us. You provide information via use of the Site at your own risk.
F. Links
iPass’ Site may contain links to other sites. When you click on such a link, you will leave our site and go to another site and this Privacy Policy no longer applies. During this process, another entity may collect Personal Data or Anonymous Data from you and its privacy policy may apply. iPass does not share your Personal Data with those websites and is not responsible for their privacy practices. We encourage you to earn about the privacy policies of those companies.
G. General
The iPass Privacy Policy is subject to change at any time in accordance with the Terms of Use. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to delete your information with us. Continued use of our Site, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes. We encourage you to review the privacy policy regularly for any changes.
Last update: March 2010
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