Privacy Statement

Last Updated: 02-Dec-2024

Passport Unlimited, Inc. ("Passport", "we", "us", "our") is a U.S.-based company located and operating only in the United States. Any personal information submitted or uploaded to us or our services is processed in the United States and not transferred outside the United States. This Privacy Statement covers all of your interactions with our websites and mobile app and the data we gather when you use these services.

We are committed to your privacy. This Privacy Statement describes what information we collect from you and how we use it; how you can update, export, and delete your information; and how we keep the personal information you share with us safe.

Specific client membership programs that we operate may utilize program- or employer-specific Privacy Statement language. Please visit your membership program website to view the statement and terms specific to your membership.

Our websites and mobile app include links to other websites on the internet. These links are provided for your convenience only. We have no control over such websites, and we are not responsible for the availability of such external websites. We do not endorse and are not responsible or liable for any content, advertising, products, or other materials on or available from such websites. We are not responsible for any privacy or other practices of the third parties operating those websites. We will not be responsible or liable, directly, or indirectly, for any damage or loss caused or alleged to be caused by, in connection with or resulting from, your use of or reliance on any such content, goods, or services available on or through any such website. We strongly encourage you to review any separate terms of use and privacy notices governing those third-party websites.

The Personal Information We Collect & Where We Get It

From you. To populate your member profile, we always collect your first and last name, local region (e.g.: city/state), and email address. In some cases, we may also collect your company name, mailing address, and phone number.

When visiting our website or using our mobile app, the IP address of your device and other clickstream data (such as hardware, OS, and browser information) is collected in our temporary system logs. When using our mobile app, we also collect the geolocation (if location permissions are enabled) and a unique notification identifier for your device.

We also collect your personal information when you perform any of the following:

Register or update your member profile
Submit a survey
Contact member support

From a primary member or account holder. When a primary Passport Unlimited member or account holder adds additional members to the membership account, we obtain contact and identification information for these members from the primary Passport Unlimited member or account holder.

Via your employer or sponsor entity. In some cases, elements of your profile information are verified or provided by your employer (or sponsor entity through which your membership was made available), such as through a single-sign-on workflow using existing external account credentials or via a data file provided by your employer or sponsor which we use to validate that you are eligible to participate in the program.

Through emails or web forms. We use web forms throughout our website and mobile app for customer comments and suggestions. Any information we collect from emails or web forms is used for the purpose of responding to your questions or comments. We may also retain your comments to improve our programs, or review and discard the information.

From chat, text (SMS), or phone calls. When you use the chat features on our services or communicate with us through text messages (SMS), you provide consent for us to collect the content of your chat or text messages (that is, the words you type into the chat feature and the responses you receive). We record and store chat transcripts and text messages for a period of time after you interact with us by text or chat.

You can stop text messages (SMS) and mobile notifications. We will only send you SMS (text) communications if you consent to receive them. We will also send you SMS (text) messages in case of emergency, urgent product notices and other limited (non-marketing) instances as permitted or required by law. You can reply “STOP” to any SMS (text) message to cancel. We also may send push notifications or alerts to your mobile device through our app. You can stop these notifications by changing the settings on your mobile device.

We may record your call if you contact our member support department. We will notify you before the call starts if we are going to record so that you can decide if you want to proceed with the call or contact us using a different communication method.

How We Use the Information We Collect

We use the information we collect, including your personal information, for the following purposes:

Personalization. To understand you and your preferences, to enhance your experience and enjoyment using our product and offerings and personalize your online experience and the offers you see when you use Passport.

For example, we use your personal information in combination with the local region (e.g.: city/state) in your member profile to provide you with a personalized experience. We use your device geolocation, the publicly available geolocation associated to your Internet Protocol (IP) address, in conjunction with the local region (e.g.: city/state) in your member profile to display localized content when you are browsing our website or using our mobile app.

We will use your past searches, past location history, mobile device location, redemption history, and click history to make recommendations of other content that might be of interest, curate content and personalize the service.

When you install our mobile app (or anytime thereafter), you may choose not to share (or to stop sharing) your geolocation by disabling the location permission(s) for our app on your device.

We also collect information about the type of device you use, the operating system in use and/or the browser you use. This information is aggregated and used to help inform future product design decisions. This information is also used when you use the service to provide an experience optimized to your unique device hardware, operating system, or browser.
Customer support. To send you information and notices about your membership such as updates, security alerts, and support and administrative messages. Also, when you contact us, we keep a record of your communication to help answer questions and resolve any issues you might encounter. These communication records are associated with your member profile to facilitate our support of your membership.
Marketing and offerings. The activities you perform within the Passport websites and mobile app will be stored in association with your member profile and will be used to curate suggestions, populate lists, and personalize marketing communications.

Based on the email preferences you configure, we will use your personal information to send you emails, information about Passport, or other promotional materials directly related to your membership.

Based on the notification settings on your device(s), we will use the unique notification identifier for your device(s) to deliver "push" notifications targeted to the device(s) associated with your membership.
Business operations. When your membership is provided by an employer or sponsor entity, elements of your personal information are periodically used to verify your continued membership eligibility by your employer (or entity through which your membership was made available). Independent of your email preference settings, we may occasionally send notices or messages of a transactional or relationship nature (e.g.: receipts, renewal notices or activity summaries).
Product improvement, development, and research. To improve our products, develop new products or features, and conduct research.
Legal, security and safety reasons. For legal, security and safety reasons, such as to protect our rights and the rights of our customers and members, protect the security of our systems and networks, enforce our policies, communicate product recalls or safety notices, or address legal and regulatory compliance obligations.

If you are a consumer in the European Union, we will only process your personal information when we have a legal basis to do so. When we process your personal information, we will do so with your consent or because the processing is necessary: for the performance of a contract with you; to comply with our legal obligations; to pursue our legitimate interests; or to establish or defend a legal claim.

Statement on the Use of Artificial Intelligence

Our platform may use enterprise generative AI (Artificial Intelligence) to create custom content and recommendations for you based on your interests and activity history within the Passport services. We will never use or share your personal information within the language model or text inputs uploaded to our AI resources unless you explicitly share your personal information when using a generative AI feature on our service.

Personal Information We Share & Why

We do not provide any personal information to third parties for their own direct marketing purposes. Additionally, we will not disclose your personal information to a third-party unless:

It is a request from the entity through whom you obtained your membership (e.g. your employer, sponsoring entity or the person who shared or purchased your membership as a gift)
With your explicit consent
To comply with our legal requirements
To enforce our Terms of Use
It is to a third-party service provider that we use to perform tasks on our behalf (e.g. our data hosting provider). Unless we tell you differently, our third-party service providers do not have any right to use your personal information beyond what is necessary to assist us.

We may use non-identifying and aggregate information to better design our website and to share with advertisers and internet analytical companies. For example, we may tell an advertiser that a certain number of individuals visited a specific page on our website, but we would not disclose any personal information to a third-party that could be used to identify individuals.

Employer-provided memberships. If your membership was provided by your employer as an employee benefit, we may disclose your name, email address, membership number and/or status with your employer. In cases where your employer subsidizes a portion of your purchase (e.g.: co-pay transactions), your offer redemption history for those transactions may also be shared with your employer.

Sponsor entity-provided memberships. If your membership was provided by a sponsor entity (e.g.: your financial institution, alumni organization, or other membership club), we may disclose your name, email address, website and mobile app activity, membership number and/or status to the sponsor entity. You may receive communication directly from the sponsor entity of your membership based on your website and mobile app activity in our program.

Family-share and gift memberships. Some memberships may be shared with additional individuals using a “family-share” or “gift membership” feature. If your membership was provided by invitation from a primary membership account holder (person authorized to add and remove additional household or business associate members and make account-management decisions), we may disclose your name, email address, offer redemption history, membership number and/or status to the primary membership account holder.

Our Network Service Providers. We may also transmit and store your personal information with third-party service providers (or “data processors”) such as our cloud computing provider as part of the IT infrastructure necessary for us to provide our services to you. Unless we tell you differently, they do not have any right to use your personal information beyond what is necessary to assist us. Passport Unlimited and the service providers that we use are located in the United States and any information we collect about you or that you provide to us will therefore be processed and stored within the United States.

Business transaction. If Passport Unlimited or a portion of our business are sold, your personal information may be among the assets transferred. The purchasing party would be required to apply this Privacy Statement to their use of your personal information should such information be included in the purchase.

Cookies and Other Digital Tracking Technologies

Some device data, service data and third-party source data is collected through the use of first- or third-party cookies and similar technologies. When you access our website, we place small data files called "cookies" on your computer to support functionality of the features available within our website.

We encode our cookies so that only we can interpret or access the information stored in them. You are free to block or delete our cookies, but doing so may interfere with how you interact with our website or app.

Our website and app contain links to a variety of external / third-party websites hosted by participating merchants and restaurants. When linking to these websites, you may also encounter cookies from those third parties. Please note that we have no control over the privacy practices of any external website, or the cookies created by any external website and such files are outside the scope of this Privacy Statement.

Digital trackers. We also use third-party digital trackers to provide a seamless user experience. We utilize these digital trackers for the following purposes:

Strictly Necessary trackers are needed for our websites or applications to function. They enable core functions like carrying out network transmissions and enabling you to log in to our systems. They also enable us to maintain your privacy choices by preventing advertising-related or other optional digital trackers from being placed on your browser or device. Strictly necessary cookies cannot be switched off through our services.
Functional trackers allow us to provide personalization and convenience features, such as remembering your login information or preferred location. For example, we use Bing maps to display mapped locations on our website and to geolocate addresses provided via our service.
Performance trackers allow us to count visits and traffic sources so we can measure and improve the performance of our Services. We currently utilize Google analytics to understand traffic trends and patterns in our web application. This includes general, anonymized data that we use to improve our service to all Passport members. You also may be able to opt out of use of your information for advertising by interacting directly with Google Analytics by visiting: https://policies.google.com/technologies/partner-sites/
Commission trackers are used so that we may earn a small commission on purchases you make when accessing other websites via Passport that results in a purchase. This commission is managed through Commission Junction. We have included a cookie in our domain that links back to the Passport URL that originates the purchase; it does not contain any personally identifying information.

How to manage digital trackers. In most cases, you can disable trackers through your browser or device settings. If you choose to disable these trackers, it will affect how our services function and may prevent you from using certain features.

eCommerce partners. Some of our ecommerce partners utilize a tracking pixel in their checkout page to track how many Passport members complete the checkout process. Tracking pixel data is anonymized and aggregated and cannot be used to identify individuals. You can manage the cookies and trackers that are set by the merchant’s website through the cookie and tracker management tools they provide on their website. You can also manage cookies and trackers through your browser’s settings.

Your Choices & Rights

You have the following rights to your personal information:

Right to information/know. You can request whether we have collected your personal information, and in certain cases, the following information about how we have collected and used your personal information during the past 12 months:
- The categories of personal information we have collected.
- The categories of sources from which we collected personal information.
- The business or commercial purpose for collecting, sharing, and/or selling personal information.
- The categories of personal information that we sold or disclosed for a business purpose.
- The categories of third parties to whom personal information was sold, shared, or disclosed for a business purpose.
Right to access. You can request a copy of the personal information that we have collected about you during the past 12 months. You are entitled to receive any personal information you have provided to us in a structured, commonly used, and machine-readable format. We will provide your personal information electronically in an easily readable and transferable format appropriate to the data (such as a comma separated file, a spreadsheet, or similar).
Right to correction. You can correct your personal information by signing into your member profile and updating your personal information. In some cases, your member data may only be changed by contacting your employer or the sponsoring entity who has provided you with the membership.
Right to deletion. You can ask us to delete the personal information that we have collected from you. We will delete your personal information upon your request unless there is a legal obligation to retain it. If there is a legal obligation, we will notify you. Any personal information stored in backups will be restricted upon your request, such that it is never recovered and will be deleted following the backup retention period (not to exceed one year).
Right to opt-out of tracking for targeted advertising purposes. While we do not sell personal information, we, or your sponsoring entity, may deliver targeted ads (also known as interest-based ads) to you, as we have described in the "How We Use the Information We Collect and "Personal Information We Share & Why" sections above. If we ever use tracking cookies for targeted advertising, you will have the right to opt-out of those cookies.
Right to nondiscrimination. You are entitled to exercise the rights described above free from discrimination.
Right to object to our processing of your personal information. You may contact us if you wish to no longer participate in the Passport program and we will remove your data from our systems.

How to exercise your rights.

Right to information/know, access, and deletion. You can exercise any of these rights by emailing privacy@passportunlimited.com.
Right to opt-out of tracking for targeted advertising purposes. We do not use your personal information for targeted advertising. You can enquire about our practices by emailing privacy@passportunlimited.com.

We will respond to any request we receive via email under this section within 30 days.

Verification of identity. We will need to verify your identity to process your information/know, access, correction, and deletion requests. To verify your identity, we may require you to provide government identification, give a declaration as to your identity under penalty of perjury, and/or provide additional information.

Authorized agents. Your authorized agent may make a request on your behalf upon our verification of the agent's identity and our receipt of a copy of the valid power of attorney given to your authorized agent. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your rights on your behalf, provide the information we request to verify your identity and provide us with written confirmation that you have given the authorized agent permission to submit the request.

This section does not apply to:

information exempted from the scope of state-specific data privacy laws;
activities governed by a different privacy notice, such as notices we give to personnel or job candidates; or
Personal Information we collect, use, and share on behalf of our customers as a "service provider" under state-specific data privacy laws.

We reserve the right to partially comply or fully deny any of the above rights to:

meet our obligations under federal, state, and local laws;
comply with any civil, criminal, or regulatory inquiry, investigation, subpoena, or summons;
cooperate with law enforcement;
cooperate with a government agency; and/or
exercise or defend legal claims.

Your rights to your personal information do not extend to personal information that we have de-identified or aggregated with other information.

To stop receiving our email marketing you can change your email preferences within your member profile, follow the unsubscribe instructions in any of the emails we send to you, or contact us and we will do it for you.
To opt out of sharing your device geolocation or receiving push notifications, you may update the location or notification permission settings on your device.

Revoking your consent. Passport Unlimited will request your consent for processing sensitive personal information. You may revoke your consent at any time. For example, you may revoke your consent to the use of device precise location information through our app by turning off the location permission for our app on your device.

California-Specific Rights

Do Not Track signals. Some web browsers may transmit "do not track" signals to websites with which the web browser communicates. Our websites do not respond to Do Not Track (DNT) signals or browser settings.

Selling personal information. We do not "sell" personal information as defined by the CCPA and have not sold Personal Information in the preceding 12 months.

Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.

Shine the Light. California Civil Code Section 1798.83 permits consumers that are California residents to request certain information regarding our disclosures of personal information to third parties for such third parties' direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at privacy@passportunlimited.com.

Consumer rights notice. Under California Civil Code Section 1789.3, we are required to provide California residents with the following specific consumer rights information:

This website is owned and operated by Passport Unlimited, Inc.
Unless otherwise expressly stated, this website is provided without charge.
To file a complaint regarding this website or to receive further information regarding use of this website, please send a letter to or contact us via email at support@passportunlimited.com. You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California’s Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at (916) 445-1254 or (800) 952-5210.

Security & Retention of Your Personal Information

We work hard to protect your information from unauthorized access, alteration, disclosure, or destruction. We do this by employing safeguards like firewalls, data encryption, physical access controls to our servers, and other access controls. No safeguards, including the highest levels of data encryption, can ensure perfect security. As such, we cannot expressly warrant the security of any information that you transmit to us, you do so at your own risk.

We will retain your personal information for three years following the expiration of your membership or last activity, whichever occurs last. For members in our Passport Dining Programs, we retain your personal information for 10 years following the expiration date of your membership or for 10 years following the expiration of your gift purchaser’s membership (in cases where your membership was provided as a gift), whichever occurs last. For members with unassigned gift cards, we retain your personal data until all your gift inventory has been assigned. When we no longer need your information, we dispose of it in a secure manner according to our data retention and deletion policies.

Personal Information of Children

Our websites and mobile apps are not intended for use by anyone under 18 years of age. We do not knowingly collect information from children under 18. If you are under 18, please do not use our websites or mobile apps or submit any personal information to us. If we become aware that we have collected personal data from someone under the age of 18, we will delete that information promptly. If you are a parent or legal guardian of a child under 18 and believe that a child has provided us with their personal data, please contact us at privacy@passportunlimited.com.

Changes To This Notice

We may change this Privacy Statement from time to time. We will not reduce your rights under this Privacy Statement without your explicit consent. We always indicate the date the last changes were published for your review. Changes will become effective immediately upon publication but will not apply retroactively. If changes are significant, we will provide a more prominent notice (such as a website banner or email notification) for your awareness.

How To Contact Us

If you have a question about this statement, you believe your account has been misused, or want to know about our approach to privacy, you may email us at privacy@passportunlimited.com. Alternately, you may reach us using the following methods:

Email:

support@passportunlimited.com

Phone:

(425) 827-2447

Toll-Free:

(800) 410-4211

Mail:

Passport Unlimited, Inc.
PO Box 727
Kirkland, WA 98083-9944