This Privacy Policy was last updated effective October 5, 2024.

We are PASport Software Programs, Inc. (PASport Profiles) of 20 Liberty Ship Way, Suite 200, Sausalito CA, 94965, USA. All references to "we", "us", or "our" shall be construed to mean PASport Profiles. To comply with European General Data Protection Regulation (GDPR) laws around international data transfer mechanisms, we self-certify under the EU-U.S. and SW-US Privacy Shield.

PASport Profiles designs and manages the site you are viewing. PASport provides a range of Internet-based assessment tools to support the individual and organizational training and development needs. This privacy statement covers the sites www.PASport.com and www.clickac.com. If you have questions or concerns regarding this statement or our privacy practice, you should first contact the PASport Webmaster by email at info@pasport.com. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you then can contact The American Arbitration Association (AAA) at http://www.adr.org/FileACase. AAA will then serve as a liaison with the web site to resolve your concerns. AAA is an independent, not-for-profit organization whose mission is to develop and provide prompt, effective and economical methods of conflict management and dispute resolution. As a last resort, privacy complaints that remain unresolved after pursuing these and other channels may be subject to binding arbitration before the Privacy Shield Panel to be created jointly by the US Department of Commerce and the European Commission. PASport commits to cooperate with EU data protection authorities (DPAs) with regard to human resources data transferred from the EU in the context of the employment relationship.

PASport 's sites (www.pasport.com and www.clickac.com) comply with the EU - U.S. and SW-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom and Switzerland, as applicable) to the United States in reliance on Privacy Shield. PASport has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. The Federal Trade Commission has jurisdiction over PASport ’s compliance with this Policy, the EU-US and SW-US Privacy Shield Framework. To learn more about the Privacy Shield program, and to view PASport’s certification, please visit https://www.exportprivacyshield.gov/ and search for Persona Global and PASport will be listed under Other Covered Entities section.

In compliance with the Privacy Shield Principles, PASport commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact PASport at:
* e-mail: info@pasport.com * phone: +1 (415) 331-2606  * mailing address: 20 Liberty Ship Way, Suite 200, Sausalito, CA 94965

PASport has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.

Because PASport wants to demonstrate its commitment to users' privacy, it has agreed to disclose its information practices and have its privacy practices periodically reviewed for compliance. This Privacy Statement addresses the following privacy issues: Information Collection and Use PASport is the owner of the information collected on the Sites covered by this Privacy Statement. In order to use full functionality offered by the Sites, a user may be required to provide certain personal information (such as job title and email address) aside from providing information about personal feedback, perceptions, or assessments. We use this information to score individual or team feedback reports in subjects such as, but not limit to, Candidate, Communication, and Sales Profiles. Sometimes, it is required for the user to provide demographic information (such as job level and gender) in some of our on-line surveys and this practice is necessary so we can provide a more personalized assessment analysis for the users, or be able to average perceptions or experience scores for each and all demographic groups. Profiles Information provided by users of the Sites is stored in a user profile in our database. Subsequently collected information related to that user profile that we collect through cookies, log files, and/or third parties is tied to the profile to improve the content of the site for the user. This profile is used to tailor a user's visit to the Sites and to direct pertinent content to them. We do not share your profile with other third parties. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, PASport is potentially liable. PASport will cooperate with public authorities if requirements requests PASport to disclose personal information in response to lawful requests including to meet national security or law enforcement requirements. Correcting/Updating/Deleting/Deactivating Personal Information If a user's personally identifiable information changes (such as email address or job title), or if a user no longer desires his/her user profile to be kept in our database, we provide a way to correct, update or delete/deactivate users' personally identifiable information. User has the right of individuals to access their personal data. The user should contact PASPORT by one of the following methods: * e-mail: info@pasport.com * phone: +1 (415) 331- 2606  * mailing address: 20 Liberty Ship Way, Suite 200, Sausalito, CA 94965. PASport will respond to your request within 10 business days in the US or within 30 business days outside the US.

Cookies

A cookie is a piece of data stored on the user's computer tied to information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site except when personal information is stored on a voluntary basis through the process of logging into the Web Site with a user name and password, in which case the information can be used to pre-populate user information into form fields presented by the Web Site. We use both session ID cookies and persistent cookies in the PASport Internet Sites.

Sharing

Though we make industry standard and reasonable effort to preserve user privacy, we may need to disclose personal information when required by law where we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on the Sites. We do not share personal information with Third Parties except as otherwise noted in this Statement.

Choice/Opt-out

Our users are given the opportunity to `opt-out' of having their information used for purposes not directly related to our Sites at the point where we ask for information. Users who provide information requested by the Sites, or who continue to use the Sites after having an opportunity to review this Privacy Statement, thereby consent to the terms of this Privacy Statement and to PASport's use of the information it collects as described in this Privacy Statement. Those who do not agree to this Privacy Statement may not use the Site. Users of the Sites are always notified when their information is being collected by any outside parties. We do this so our users can make an informed choice as to whether or not they should proceed with services that require an outside party.

Security

The Sites take industry standard and reasonable precaution to protect our users' information. When users submit sensitive information via the Sites, their information is protected both online and offline. When registration or order forms ask users to enter sensitive information (such as credit card number and/or user ID/password), that information is encrypted and is protected with SSL. While we use SSL encryption to protect sensitive information online, (we also provide reasonable and timely effort to protect user-information offline). All of our users' information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job are granted access to personally identifiable information. Those employees are required to respect the confidentiality of our visitor's personal data. The servers that store personally identifiable information are in a secure environment in a locked facility. Changes to the Privacy Statement: We will occasionally update this Privacy Statement. If we are going to use users' personally identifiable information in a manner different from that stated at the time of collection we will notify users by posting a notice on our Web Site (home page) for 14 days.

Complaints Resolution

If you are concerned about how your personal information is being used, you have a right to complain and to expect your complaint to be handled in a sensitive and effective manner. At any time, you can contact us to inquire about the handling, use or disclosure of your personal information by sending an email to the persons listed under Contact Information. We will investigate your complaint and advise you of the outcome of the investigation in a timely manner. Contact Information: For questions or concerns regarding this statement, please contact: Webmaster PASport Profiles 20 Liberty Ship Way, Suite 200, Sausalito, CA 94965, U.S.A. +1 (415) 331- 2606 info@pasport.com