Terms and Conditions


Background

This agreement applies as between you, the User of this Website and iPass Ltd trading as iPass ID and iPass Pro, the owner of this Website. Your agreement to comply with and be bound by Clauses 1, 2, 5 – 12 and 16 – 26 of these Terms and Conditions is deemed to occur upon your first use of the Website. Clauses 3, 4, and 13 – 15 apply only to the sale of Goods. If you do not agree to be bound by these Terms and Conditions, you should stop using the Website immediately.

No part of this Website is intended to constitute a contractual offer capable of acceptance. Your order constitutes a contractual offer and Our acceptance of that offer is deemed to occur upon Our sending an order confirmation email to you indicating that your order has been fulfilled and is on its way to you.


Definitions and Interpretation

Account : means collectively the personal information, Payment Information and credentials used by Users to access Paid Content and / or any communications System on the Website;

Carrier : means any third party responsible for transporting purchased Goods from our Premises to customers;

Content : means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Website;

Goods : means any products that iPass ID advertises and / or makes available for sale through this Website;

Service : means collectively any online facilities, tools, services or information that we make available through the Website either now or in the future;

Payment Information : means any details required for the purchase of Goods from this Website. This includes, but is not limited to, credit / debit card numbers, bank account numbers and sort codes;

Premises : means our places of business located at 71-75 Shelton Street, London, WC2H 9JQ, United Kingdom;

System : means any online communications infrastructure that we make available through the Website either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;

User / Users : means any third party that accesses the Website and is not employed by us and acting in the course of their employment;

Website : means the website that you are currently using https://ipass.id

We/Us/Our : means iPass Ltd. trading as iPass ID and iPass Pro, a company registered in England and Wales, whose Company number is 12402898 with registered office at 71-75 Shelton Street, London, WC2H 9JQ, United Kingdom


Age Restrictions

Although our website is a general audience site, we restrict the use of our service to individuals age 18 and above


Intellectual Property

Subject to the exceptions in Clause 6 of these Terms and Conditions, all Content included on the Website, unless uploaded by Users, including, but not limited to, text, graphics, logos, icons, images, sound clips, video clips, data compilations, page layout, underlying code and software is the property of artpass ID Ltd, Our affiliates or other relevant third parties. By continuing to use the Website you acknowledge that such material is protected by applicable United Kingdom and international intellectual property and other laws.

Subject to Clause 7 you may not reproduce, copy, distribute, store or in any other fashion re-use material from the Website unless otherwise indicated on the Website or unless given Our express written permission to do so.


Third Party Intellectual Property

Unless otherwise expressly indicated, all Intellectual Property rights including, but not limited to, Copyright and Trademarks, in product images and descriptions belong to the manufacturers or distributors of such products as may be applicable.

Subject to the fair use of intellectual property you may not reproduce, copy, distribute, store or in any other fashion re-use such material unless otherwise indicated on the Website or unless given express written permission to do so by the relevant manufacturer or supplier.


Fair Use of Intellectual Property

Material from the Website may be re-used without written permission where any of the exceptions detailed in Chapter III of the Copyright Designs and Patents Act 1988 apply.


Links to Other Websites

This Website may contain links to other sites. Unless expressly stated, these sites are not under the control of iPass Ltd or that of Our affiliates. We assume no responsibility for the content of such websites and disclaim liability for any and all forms of loss or damage arising out of the use of them. The inclusion of a link to another site on this Website does not imply any endorsement of the sites themselves or of those in control of them.


Use of Communications Facilities

When using System on the Website you should do so in accordance with the following rules. Failure to comply with these rules may result in your Account being suspended or closed:


- You must not use obscene or vulgar language;

- You must not submit Content that is unlawful or otherwise objectionable. This includes, but is not limited to, Content that is abusive, threatening, harassing, defamatory, ageist, sexist or racist;

- You must not submit Content that is intended to promote or incite violence;

- It is advised that submissions are made using the English language as we may be unable to respond to enquiries submitted in any other languages;

- The means by which you identify yourself must not violate these Terms and Conditions or any applicable laws;

- You must not impersonate other people, particularly employees and representatives of iPass Ltd or Our affiliates;

- You must not use Our System for unauthorised mass-communication such as “spam” or “junk mail”.

- You acknowledge that we reserve the right to monitor any and all communications made to Us or using Our System.

- You acknowledge that we may retain copies of any and all communications made to Us or using Our System.

- You acknowledge that any information you send to Us through Our System may be modified by Us in any way and you hereby waive your moral right to be identified as the author of such information. Any restrictions you may wish to place upon Our use of such information must be communicated to Us in writing, in advance and We reserve the right to reject such terms and associated information.


Privacy

iPass Ltd collects and processes personal data relating to visitors to this website, and in relation to the services we provide. The data we process differs depending on your interactions with us, as detailed more fully below.

Where we act as a controller of personal data, the following items apply:

Details of the controller and data protection officer: the controller of the personal data we process is iPass Ltd, located at 71-75 Shelton Street, London, WC2H 9JQ, United Kingdom and which is registered with the UK Information Commissioner’s Office under number ZA633666. Our data protection officer can be contacted by email at dpo@ipass.id.

Transfers outside of the EEA

As part of our group operations and to help us manage the personal data that We process, we transfer personal data of Users outside of the EEA subject to appropriate safeguards including European Commission adequacy decisions and model clauses approved by the European Commission on the basis of Art. 26(4) of Directive 95/46/EC.


Your rights

You can request that we correct, erase, or grant you access to the personal data we hold relating to you, or (where processing is based on your consent) withdraw your consent to our processing of your personal data. In many cases, the most effective way to exercise these rights will be to mail our dedicated inbox at mypersonaldata@ipass.id.

If you are concerned that we are handling your personal data improperly, you also have the right to make a complaint to our data protection regulator, the UK Information Commissioner’s Office.


Information collection and use

The information we collect, and the ways in which we use it, varies in line with the use cases below:


- Visitors to iPass.id and iPass Pro

- Candidates for jobs with iPass Ltd

- Our anti-money laundering, sanctions and adverse media data

- Business contacts


Visitors to iPass ID and iPass Pro

When you browse this website

Data on how you use the site

The pages you visit, the means you use to visit (browser version, time zone, operating system, etc.), how long your visit and pageviews last, the frequency of your visits, and information on how you navigate the site.

Data that identifies you

Your IP address, unique identifiers tied to cookies.

Site optimisation

Analysing aggregated data to update our site’s content and layout to improve relevance for visitors.

Legitimate interests

Using insights from visitor behaviour to improve the way we market our services.

Data holding periods are determined by cookie expiry times.

Within iPass Ltd group companies

Personal information will be available for our global marketing teams, and other iPass Ltd personnel who have a need to access this data for the purposes set out above.

Outside of iPass Ltd

- CRM and marketing automation providers

- Website analytics vendors


When you provide us with information by completing forms, subscribing for email updates

We use this information to contact you for the purpose specified for the form and in any opt-in boxes selected by you while completing.

This information is added to, and managed through, our CRM. A member of our sales team may contact you if we determine through your submission that you may be interested in our services. We analyse our CRM data to understand, track, and improve how we market and sell our services.

Consent

We’ll send you our email newsletters only with your consent.

Taking steps at your request prior to entering into a contract

If you request that we contact you to provide more information on our services to you, we’ll process your data and contact you on this basis.

Legitimate interests

We’ll retain and analyse information gained from our interactions with you as part of understanding, tracking and improving how we market and sell our service. We retain some records of consent-based and other processing in order to demonstrate our historic compliance with data protection law.

Email newsletters

We’ll keep your details on this list until you unsubscribe, at which point we’ll move your details to an opted-out list to ensure that we don’t send you marketing emails from other sources in future.

Sales process

We retain information relating to our sales interactions with you for up to five years following our determination that we’re not an appropriate sales fit. We use this period as service contracts in our industry often last for 3-5 years, so a new opportunity may arise during the retention period.

General

We retain historic information relating to any consent you provided, or other bases for processing that have since lapsed, for six years from the date that the basis for processing lapsed.

Within iPass Ltd group companies

Personal information will be available for our marketing and sales personnel, as well as customer success and other teams as necessary to fulfil the purposes set out above.

Outside of iPass Ltd

Our cloud storage providers, CRM, marketing


Job candidates

Recruitment information you provide to us

We use your data to:

- contact you in relation to your candidacy

- assess suitability for future vacancies

- assess your suitability for the vacancy you applied for

Legitimate interests

We want to build the best team we can, and we carry out this processing as part of the hiring process that enables this.

Compliance with a legal obligation

For roles where we conduct a resident labour market test to enable us to apply for visas, and subsequently hire someone who needs a visa on this basis, we retain unsuccessful applicant information as part of the related record-keeping requirements.

General

You information is stored in our applicant tracking system 12 months after we disqualify your candidacy for the role applied for. Successful candidates’ information becomes subject to our employee privacy policy/notice.

Legal record-keeping

If we hire someone subject to a resident labour market test for a role you applied for, we’ll retain your personal data until the expiry of the applicable record-keeping requirement (currently one year following the end of our sponsorship of the visa in question).

Within iPass Ltd group companies

Personal information will be available for the hiring and recruitment teams.

Outside of iPass Ltd

- Our applicant tracking system

- Providers of any aptitude testing systems used as part of the hiring process


Recruitment-related data we collect

- Publicly available information relevant to your potential suitability to work with iPass Ltd

- Any information provided by someone who introduced you to us

- Feedback from interviews and assessments.

We use your data to:

- contact you in relation to current vacancies

- For roles where we conduct a resident labour market test to enable us to apply for visas, and subsequently hire someone who needs a visa on this basis, we retain unsuccessful applicant information as part of the related record-keeping requirements.

Compliance with a legal obligation

If you are actively involved in our a recruitment process for roles where we conduct a resident labour market test and subsequently hire someone who requires a sponsored visa, we retain unsuccessful applicant information as part of the related record-keeping requirements.

You information is stored in our ATS 1 year after final interview if unsuccessful, or subject to our legal record-keeping requirements if needed for our compliance with immigration law.

Within iPass Ltd group companies

Personal information will be available for the hiring team and our recruitment personnel.

Outside of iPass Ltd

- Our applicant tracking system

- Providers of any aptitude testing systems used as part of the hiring process

- Our cloud file storage systems

- External recruiters with whom you dealt as part of the recruitment process

- Government and legal service providers involved in the visa application process


Our anti-money laundering, sanctions and adverse media data

Sanctions, warnings, fitness & probity

Information related to and available on publicly-available government lists covering sanctions, the prevention and detection of unlawful acts, and other protective functions. This will generally include a full name, a year or date of birth, reasons for appearing on the list, and the period covered by the data subject’s appearance on the list.

Politically exposed persons

We collect publicly available information relating to individuals in prominent public positions, and their family members, close associates, and business interests. Names, dates or years of birth, position(s) held or connection(s) that we think may give rise to a PEP designation, country of nationality, residence and service, photographs (if available) and the period for which that designation would have been active (e.g. active service dates).

Adverse media

We collect links to publicly available news articles that our systems determine to name individuals in connection with financial crime, terrorist financing, other relevant unlawful acts, improper conduct, dishonesty, etc. We will also extract information relating to age from these articles to determine approximate years of birth.

Consolidated profiles

We structure the data collected into profiles consolidating the information outlined above.

Sharing with clients

We uphold a strict privacy policy ensuring that our clients' personal information remains confidential. Access to another client's information is strictly governed and only facilitated with prior consent from the individual whose details are being requested. Our commitment to privacy means we do not permit direct searches for personal information of our clients without express authorization.

Legitimate interests

Our existing and prospective clients have legitimate interests in gaining access to high-quality and easily manageable data of the type we process in order to optimize their sanctions and anti-money laundering compliance. We also pursue our own legitimate interests in develop and improve products and services to serve this market.

Politically exposed person data

Different jurisdictions’ regulations vary on how they treat politically exposed persons (PEPs) after they leave office. As some of the jurisdictions that we serve consider a PEP to always be a PEP, we retain this information indefinitely.

Backups

Where we remove personal data from this database (for example, where we become aware that the information is not, or is no longer, relevant), it will remain in our backups for 30 days.

- Other data controllers on whose behalf we act as processors, who search for information matching given profiles

- iPass Ltd group employees

- Our hosting and cloud storage providers

- Vendors we use to monitor the accuracy and performance of the data


Business contacts

Information we receive from you (e.g. business cards, correspondence during the sales process)

A member of our sales team may contact you if we determine through your submission that you may be interested in our services. This information – along with details of our interactions including phone calls and correspondence – is added to, and managed through, our CRM. We analyse our CRM data to understand, track, and improve how we market and sell our services. We save some correspondence to provide precedents and examples to other members of the team, and add your personal information to our e-signing and billing systems if appropriate.

Taking steps at your request prior to entering into a contract

If you request that we contact you to provide more information on our services to you, we’ll process your data and contact you on this basis.

Legitimate interests

We’ll retain and analyse information gained from our interactions with you as part of understanding, tracking and improving how we market and sell our services.

We process data in relation to billing and contracting in order to operate the legal and financial elements of our business.

We retain records of consent-based and other processing in order to demonstrate our historic compliance with data protection law.

Email newsletters

We’ll keep your details on this list until you unsubscribe, at which point we’ll move your details to an opted-out list to ensure that we don’t send you marketing emails from other sources in future.

Sales process

We retain information relating to our sales interactions with you for up to five years following our determination that we’re not an appropriate sales fit. We use this period as service contracts in our industry often last for 3-5 years, so a new opportunity may arise during the retention period.

General

We retain historic information relating to any consent you provided, or other bases for processing that have since lapsed, for six years from the date that the basis for processing lapsed.

Within iPass ltd group companies

Personal information will be available for our marketing and sales personnel, as well as customer success and other teams as necessary to fulfil the purposes set out above.

Outside of iPass Ltd

Our cloud storage providers, CRM, sales and marketing automation tools, and customer support/servicing tools.


Information we collect as part of the sales process

- Name, contact details, professional activity

- Publicly available information relevant to your position in your organisation, and industry events you’re attending

A member of our sales team will contact you if we determine to discover more information your organisation’s anti-money laundering and sanctions compliance operations, and gauge your organisation’s potential interest in our services. This information – along with details of our interactions including phone calls and correspondence – is added to, and managed through, our CRM. We analyse our CRM data to understand, track, and improve how we market and sell our services. We save some correspondence to provide precedents and examples to other members of the team, and add your personal information to our e-signing and billing systems if appropriate.

Legitimate interests

- Identifying stakeholders in organisations with requirements for software similar to that provided by iPass Ltd.

- To hold as a reference point should you make any further applications within the retention period.

We’ll retain and analyse information gained from our interactions with you as part of understanding, tracking and improving how we market and sell our services.

Sales process

We retain information relating to our sales interactions with you for up to five years following our determination that we’re not an appropriate sales fit. We use this period as service contracts in our industry often last for 3-5 years, so a new opportunity may arise during the retention period.

General

We retain historic information relating to any consent you provided, or other bases for processing that have since lapsed, for six years from the date that the basis for processing lapsed.

Within iPass Ltd group companies

Personal information will be available for our marketing and sales personnel, as well as customer success and other teams as necessary to fulfil the purposes set out above.

Outside of iPass Ltd

Our cloud storage providers, CRM, sales and marketing automation tools, and customer support/servicing tools.


The Website uses the following cookies for the purposes described herein.

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of each of our websites, to use a shopping cart or to use our services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way in which our website work, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to any of our websites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to each of our websites, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests.

If you wish to opt-out of our placing cookies onto your computer or device, please adjust your internet browsers settings to restrict cookies as detailed in your internet browsers help menu. You may also wish to delete cookies which have already been placed. For instructions on how to do this, please consult your internet browser’s help menu.


Disclaimers

We make no warranty or representation that the Website will meet your requirements, that it will be of satisfactory quality, that it will be fit for a particular purpose, that it will not infringe the rights of third parties, that it will be compatible with all systems, that it will be secure and that all information provided will be accurate. We make no guarantee of any specific results from the use of Our services.

No part of this Website is intended to constitute advice and the Content of this Website should not be relied upon when making any decisions or taking any action of any kind.

No part of this Website is intended to constitute a contractual offer capable of acceptance.

Whilst We use all reasonable endeavours to ensure that the Website is secure and free of errors, viruses and other malware, you are strongly advised to take responsibility for your own internet security, that of your personal details and your computers.


Changes to the Service and these Terms and Conditions

We reserve the right to change the Website, its Content or these Terms and Conditions at any time. You will be bound by any changes to the Terms and Conditions from the first time you use the Website following the changes. If We are required to make any changes to these Terms and Conditions pertaining to the sale of Goods by law, these changes will apply automatically to any orders currently pending in addition to any orders placed by you in the future.


Availability of the Website

The Website and any Service provided therein is provided “as is” and on an “as available” basis. We give no warranty that the Website or any Service will be free of defects and / or faults. To the maximum extent permitted by the law We provide no warranties (express or implied) of fitness for a particular purpose, accuracy of information, compatibility and satisfactory quality.

We accept no liability for any disruption or non-availability of the Website resulting from external causes including, but not limited to, ISP equipment failure, host equipment failure, communications network failure, power failure, natural events, acts of war or legal restrictions and censorship.


Limitation of Liability

To the maximum extent permitted by law, We accept no liability for any direct or indirect loss or damage, foreseeable or otherwise, including any indirect, consequential, special or exemplary damages arising from the use of the Website or any information contained therein. You should be aware that you use the Website and its Content at your own risk.

Nothing in these Terms and Conditions excludes or restricts our liability for death or personal injury resulting from any negligence or fraud on the part of us.

Nothing in these Terms and Conditions excludes or restricts our liability for any direct or indirect loss or damage arising out of the incorrect delivery of Goods or out of reliance on incorrect information included on the Website.

In the event that any of these terms are found to be unlawful, invalid or otherwise unenforceable, that term is to be deemed severed from these Terms and Conditions and shall not affect the validity and enforceability of the remaining Terms and Conditions. This term shall apply only within jurisdictions where a particular term is illegal.


No Waiver

In the event that any party to these Terms and Conditions fails to exercise any right or remedy contained herein, this shall not be construed as a waiver of that right or remedy.


Previous Terms and Conditions

In the event of any conflict between these Terms and Conditions and any prior versions thereof, the provisions of these Terms and Conditions shall prevail unless it is expressly stated otherwise.


Communications

All notices / communications shall be given to Us either by post to Our Premises (see address above) or by email to contact@ipass.id. Such notice will be deemed received three days after posting if sent by first class post, the day of sending if the email is received in full on a business day and on the next business day if the email is sent on a weekend or public holiday.

We may from time to time, if you opt to receive it, send you information about Our products and/or services. If you do not wish to receive such information, please click on the Unsubscribe link on any email you receive from us.


Law and Jurisdiction

These Terms and Conditions and the relationship between you and us shall be governed by and construed in accordance with the Laws of the England and Wales and both we and you agree to submit to the exclusive jurisdiction of the Courts of the England and Wales.