Privacy Policy
Passage Inc. including all of its affiliates and subsidiaries (collectively “Passage”, “we” or “our”), are committed to maintaining the accuracy, security and privacy of Personal Information in accordance with applicable legislation. This Privacy Policy is a statement of principles and guidelines concerning the protection of Personal Information of our clients, service providers and other individuals ("you”). This Privacy Policy applies to any Personal Information that we collect, use, and disclose (collectively “process”) about you, including through the websites and mobile applications that are owned and/or operated by Passage and through telephone, written, and in-person interactions.
1. Consent
By submitting Personal Information to Passage or its service providers and agents, you agree that we may collect, use and disclose such Personal Information in accordance with this privacy policy and as permitted or required by law. If you do not agree to this Privacy Policy, please do not access the website or mobile applications or otherwise use the products or services.
Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the purposes identified in this Privacy Policy at any time by contacting Passage’s Privacy Officer. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain products or services or information which may be of value to you. If you provide Passage or our service providers and agents with Personal Information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such Personal Information for the purposes set forth in this Privacy Policy.
Our products, services and websites are not targeted or directed at children under the age of 16. No one under age 16 may use the products or services or provide any Personal Information to our websites. We do not knowingly collect Personal Information from children under the age of 16. If you believe we might have any information from or about a child under 16, please contact us using the contact details as provided in the “Contact Us” section below. We will take steps to delete that information as soon as possible.
We may also collect additional consents and provide supplemental information about our data collection or privacy practices in disclosure about specific products, services or circumstances, or in some cases, at the time we collect Personal Information from you.
2. What Personal Information Do We Process?
Personal information means any information which relates to a natural person and allows that person to be identified directly, or indirectly in combination with other information (hereinafter, “Personal Information”). It does not include information from which all references to the identity of the relevant individual have been removed (i.e., anonymous Personal Information).
Without limitation, any of the following categories of information (which may constitute Personal Information) may be collected by us:
- Identity information: includes name, date of birth, gender, marital status, job title, profession, social insurance number, tax identification number, government-issued ID documents and numbers (including driver’s license and passport), demographic information, biometric data, username and password;
- Contact information: includes email, address (mailing and primary residence), postal code, telephone numbers and emergency contact, reference letter provider and guarantor details;
- Product information: includes information about products/services you have utilized in the past including the date of your usage and the fees paid and information about products/services that you prefer or that interest you;
- Financial information: includes credit/debit card or account information, financial information, bank statements, income, housing status, information about credit worthiness and other information necessary for a lender to make a credit decision based on your request (including information from credit bureaus, business partners, affiliates and other companies);
- Preference information: includes information regarding your personal interests, such as related products and services you use, skills, biographical information, both academic and employment aspirations, reviews of users, products or services, groups that you have joined and information from your social networking sites;
- Technical information: includes internet protocol (IP) address and geolocation information, web browser type and version, operating system and/or device, cookies and other technology on the devices you use to access this web site;
- Internet activity information: includes session information, such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
- Education information: includes application information, institution, programs, grades, resume, cover letter, statement of purpose, references, status, standardized test scores (including GMAT, TOEFL, IELTS, PTE, SAT and ACT) and other information and documents you choose to add to your profile or otherwise provided;
- Visa information: includes application information, legal status and other information and documents you choose to add to your application or otherwise provided; and
- Employment information: includes employment status, title, credentials, application information and history, skills, certifications, resume, information about the person that referred you for a position, the legal status that allows you to work in Canada, renumeration, disciplinary matters and other information and documents you choose to add to your profile or otherwise provided.
3. How Do We Collect Your Personal Information?
We may use different methods to collect Personal Information from and about you including through:
- Direct interactions. You may give us Personal Information by corresponding with us or by using our products or services, including without limitation our web site’s and mobile application’s features, products and services. This includes Personal Information you may provide if you (or your personal representative):
- sign-up for a user account on our web site or mobile application and update such user account;
- contact us through telephone, mail, email, social networking services, messaging applications (e.g. WhatsApp, Telegram and Messenger) or a chat-box on our web site or mobile application;
- input or upload any Personal Information through one of our web sites or mobile application, including in connection with you applying for, utilizing and purchasing any products or services;
- utilize third party payment providers or otherwise make a payment;
- choose to share or sync your contacts with Passage;
- choose to grant us permission to access your device’s precise geolocation;
- subscribe to our newsletter or marketing materials, respond to a survey, fill out a form, participate in a sweepstakes, or otherwise input or upload information or files through our website or mobile application, by telephone, or in person; and
- posts, comments or direct messages on or through our website or mobile application. - Automated technologies or interactions. As you interact with our web site or mobile application, we will automatically collect technical information and internet activity information about your equipment and browsing actions and patterns. We collect this information by using cookies, pixels, server logs and other similar technologies. We may also receive technical information about you if you visit other web sites or mobile applications employing our cookies.
- Third Party Services. If you use third party services like Facebook, Google or Apple to log in to Passage or if you connect a third party account to your Passage account at any time, then we will collect Personal Information from that third party service. The specific information shared with us will depend on the third party’s privacy practices, agreements we have with the third party and any choices that you may make in sharing your personal information. We may also receive information from data providers and public sources.
- Indirectly: Authorize us (including our service providers on our behalf) to collect personal information about you from our partners (which may include loyalty partners, referral partners, recruiters, academic institutions, financial institutions, contractors, landlords, employers, registries, governmental agencies (including the Canada Revenue Agency, Canada Border Services Agency and Immigration, Refugees and Citizenship Canada), and debt collectors) and credit bureaus.
4. Why Do We Process Your Personal Information?
In general, Passage processes Personal Information in order to provide you with products and services, and for the purpose of evaluating applications and deciding whether to establish (and subsequently to manage or terminate) an employment, contractual relationship or partnership. More specifically, we process your Personal Information for the following purposes:
| Purpose | Category of Personal Information |
|---|---|
Establish and manage customer relationships, perform services and fulfill our duties. This includes developing, enhancing, marketing, selling or otherwise providing Passage’s products and services, and understanding and responding to customer, partner, supplier and other third party needs and preferences, such as to contact and communicate with those parties and to conduct surveys, research and evaluations This may also include the sharing of Personal Information by and between Passage personnel and affiliated companies and partnerships for such purposes. |
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Consider whether Passage should establish a commercial relationship with customers, partners, suppliers and other third parties, including to evaluate credit standing and to match credit bureau or credit reporting agency information. This includes establishing and maintaining commercial relationships with customers, partners, suppliers and other third parties, including to issue invoices, administer accounts, lend funds, collect and process payments, and to fulfill contractual obligations as well as to facilitate academic, employment and visa processes and to provide other products and services such as Passage’s “Life GPS” service. This may also include the sharing of Personal Information by and between Passage personnel and affiliated companies and partnerships for such purposes. |
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Establish, manage and terminate employment, contractual and partnership relationships. |
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Distribute Passage’s newsletters and other informational e-mail communications, and other material to individuals on our mail and e-mail lists, including via third party mailing houses and e-mail service providers. |
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| Detect and protect Passage and other third parties against error, negligence, breach of contract, claims, misuse, fraud, theft and other illegal activity, to audit compliance with Passage’s policies and contractual obligations, and to manage compliance with AML and KYC regulations. |
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| Engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Passage. |
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As permitted by, and to comply with, any legal or regulatory requirements or provisions, legal inquiry, and for any other purpose to which you consent. |
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| To help us improve content and functionality; to better understand our customers and partners; to maintain and improve our products and services; to develop new products and services; to ensure the security of our IT systems, architecture, and networks; and to protect our rights, for our legal defense, privacy, safety, or property, and/or that of our affiliates, you, or other third parties. |
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5. To Whom Do We Disclose Your Personal Information?
From time to time, Passage may disclose your Personal Information to:
- Passage’s subsidiaries and affiliates, as required to provide our products and services;
- service and payment providers, including an organization or individual retained by Passage to perform functions on its behalf or in connection with our products and services;
- an organization or individual retained by Passage to evaluate your creditworthiness or to collect debts outstanding on an account;
- a financial institution, investor, donor or lender, on a confidential basis and in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements;
- a financial institution, investor, donor or lender, on a confidential basis and in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements;
- a person who, in the reasonable judgment of Passage, is providing or seeking the information as your agent;
- to our insurers and to regulatory agencies such as insurers or others in connection with regulatory or other activities relating to the obligations of Passage;
- to personnel in Passage, government authorities, insurers, benefits providers, consultants or agents as reasonably required to establish, manage or terminate employment, contractual relationships and partnerships and to facilitate the products and services;
- to professional advisors, such as lawyers, auditors, bankers and insurers in the course of the professional services they render to Passage;
- to respond to court orders and legal investigations, or as required by applicable law;
- to an acquiring entity in connection with the consummation or proposal of a business transaction (including liquidation, realization, seizure or repossession), concession, merger, business combination or any other type of acquisition, liquidation, transfer, translative contract or financing of Passage, in whole or in part, or of any property, stock, asset, share or business of Passage; and
- any third party or parties (including Passage’s business partners), where you consent to such disclosure or where disclosure is required or permitted by law.
Based on your settings, content you post on Passage, such as posts, replies, recommendations, messages and certain of your profile information may be visible to other members, businesses, governments, academic institutions, employers, agencies or the public.
By providing us with Personal Information, you acknowledge and agree that such Personal Information may be transferred to other jurisdictions for processing and storage, including in servers located across Canada and in the United States, where laws regarding the protection of Personal Information may be less stringent than the laws in your jurisdiction. Further, such Personal Information may be accessible to law enforcement, national security authorities, and the courts of such jurisdictions. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the Personal Information.
6. Your Rights
Subject to certain exemptions, to the extent permitted by applicable law, you have the following rights in relation to the Personal Information we hold about you:
- Your right of access. At your written request we will inform you whether we hold Personal Information relating to you and if we do, you have the right to receive a general account of our processing of such Personal Information. If your request is made in writing, subject to applicable laws and the provisions of this Privacy Policy, we will also provide you with access to your Personal Information that is in our possession. A reasonable fee may be levied if you request the transcription, reproduction or transmission of such information and you will have to provide information or documentation to verify your identity. We will inform you of the approximate cost before proceeding to respond to your request. Your rights to access your Personal Information are not absolute. Access can be denied for several different reasons under applicable legislation. If we deny your request for access to your Personal Information, we shall explain why.
- Your right to rectification. If we hold Personal Information about you and you believe that it is not accurate, complete and up-to-date, you can request to have it rectified (or rectify it yourself via your account information page, if available). If we discover that information is not accurate, complete and up-to-date, we will take reasonable steps to rectify it. We will also send any information that has been amended, where appropriate, to any third parties that have access to the information.
- Your right to withdraw consent. If we rely on your implicit or explicit consent as our legal basis for processing your Personal Information, you may have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You may not be able to withdraw your consent during the term of certain products and services.
7. How Do We Protect Your Personal Information?
To help protect the confidentiality of your Personal Information, Passage employs physical, administrative and technological safeguards appropriate to the sensitivity of your Personal Information. Where Personal Information is sent to a third party for processing, we take reasonable steps, through our contacts with them, that all Personal Information is kept secure. We operate secure data networks protected by industry standard firewall and password protection systems. However, no internet or email transmission is ever fully secure or error free.
8. How Long Will We Retain Your Personal Information?
We only keep Personal Information for as long as reasonably necessary and for the reasons it was collected, or for as long as required to comply with any applicable legal obligation and our document retention policies. The length of time Personal Information is kept varies according to the nature of the information, and it may extend beyond the end of the relationship between an individual and us.
When the Personal Information collected is no longer required by us, the necessary procedures for destroying, deleting, erasing, or converting it into an anonymous form are applied.
9. Our Websites
- Cookies. When an individual visitor accesses the Passage website or mobile application, we may use a browser feature called a 'cookie' to collect information such as the type of Internet browser and operating system the visitor uses, the domain name of the Website from which the visitor came, date and duration of the visit, number of visits, average time spent on our website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor's browser, but not necessarily the visitor; to our computers each time our website is visited. Unless a visitor specifically informs us (e.g. by registering for an event or sending us correspondence from the website), we will not know who the individual visitors are. In addition to the identified purposes described in our Privacy Policy, we may use this website information and share it with other organizations with whom we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website. Our systems are not currently configured to accept browsers’ “Do Not Track” signals, as no industry-wide standard for handling them has been adopted.
- Links. Our website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than Passage, and Passage has no responsibility for such third party websites.
- Analytics. We and/or our third-party partners may employ various tracking technologies, such as analytics software, that help us better manage content by informing us what content is effective (e.g. Google Analytics, Amplitude and Segment).
- Browser Extensions. You may be provided with the option to install browser extensions and if used, Personal Information will be collected and used in connection with extension as set out in the notice and consent presented when the extension is installed.
10. E-mail Communications
Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful, including information about the products and services of Passage and other third parties with whom we have a relationship. In this process, we may collect certain information such as the date/time you first opened our e-mail communications, the number of times you open our e-mail communications, the number of click-throughs per article, total click-through activity on the contents of our e-mail communications and compile generally the related statistics. We may combine and store any such information to manage and improve our e-mail communications to you. We will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future marketing or promotional e-mails from Passage.
11. When You Integrate Social Networking Services
One of the features of our products and services is the ability to connect your Passage account to various social networking services like LinkedIn, Facebook, Twitter, Academia, GitHub and ResearchGate. By directly integrating social networking services, we aim to make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission to connect via the relevant social networking services. When you add a social networking service account to our products and services or log in to our products and services using your social networking services account (or Google and Apple), we will collect relevant information necessary to enable our products and services to access that social networking service and your data contained in such social networking services or sites, subject to an in accordance with your authorizations and consents. As part of this integration, the social networking services or sites will provide us with access to certain information that you have provided to the social networking services or sites, and we will use, store, and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which social networking services or sites use, store, and disclose your information is governed by the policies of such third parties, and we have no liability or responsibility for the privacy practices or other actions of any social networking services or sites that may be enabled within our products and services. You may also have the option of posting your account activities to social networking services when you access content through our products and services (for example, you may post to Facebook that you performed an activity using our products or services). You acknowledge that if you choose to use this feature, your friends, followers, and subscribers on any social networking services you have enabled will be able to view such activity.
12. Changes to the Privacy Policy
Passage reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post such changes on our website and, to the extent required by applicable law, we will notify you of the change, for example by email to the address provided in your profile. Changes take effect immediately upon posting or notice to your email, as applicable. Your continued use of our products and services after any changes or revisions to this Policy shall indicate your agreement with the terms of such revised Privacy Policy.
When used in this Privacy Policy, the term “include”, “includes” and “including” will be deemed to be followed by the phrase, “without limitation”. Headings and sections are for convenience only and do not affect the interpretation of the rest of this Privacy Policy.
13. Contact Us
For any questions or concerns about this Privacy Policy, or to exercise any of the rights that you have in relation to your Personal Information, please contact:
Passage Inc.
Attn: Privacy
151 Charles Street West, Suite 100
Kitchener, Ontario
Canada, N2G 1H6
Email: privacy@passage.com