Privacy policy

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: