Passageways Privacy Policy

 

Passageways Privacy Policy 

Effective October 3, 2025 

This update includes several enhancements to provide greater transparency and better protect your privacy. A summary of the changes include:  

Enhanced Privacy Controls & Rights • Improved cookie consent management with granular control options • Clearer opt-out mechanisms for marketing communications • Information about your rights under various privacy laws (GDPR, CCPA, Colorado, Virginia and other state privacy laws) 

Expanded Data Collection Disclosures • More detailed information about data collection • Enhanced descriptions of third-party analytics tools and advertising practices  

Updated Contact & Process Information • New dedicated privacy email address, [email protected], and toll-free number• Enhanced procedures for exercising privacy rights and submitting requests • Updated authorized agent processes for privacy requests  

Strengthened International Compliance • Enhanced Data Privacy Framework compliance details • More comprehensive international data transfer safeguards • Updated dispute resolution mechanisms for international users  

 

Passageways, Inc (“Passageways,” “we” or “our”), the provider of OnBoard and other services, values the privacy of individuals who visit the Passageways public-facing website at www.onboardmeetings.com and the Passageways Help Center website at help.onboardmeetings.com (together, the “Passageways Websites”) or utilize the OnBoard web application located at app.onboardmeetings.com or its mobile applications (together, the “Platform”) (collectively, with the Passageways Websites, the “Services”). 

Please read the following Privacy Policy (“Privacy Policy”) to understand how we collect and use the information you (or the entity with which you are associated) may provide to us. This Privacy Policy may be revised from time to time, so please revisit this page often to remain fully informed of our policies. 

By using our Services, or voluntarily providing your information to us, you agree to the collection and use of your information as set forth in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not provide us with any information.  

APPLICABILITY OF THIS PRIVACY POLICY 

This Privacy Policy applies to any personally identifiable information Passageways collects or receives about a person. This Privacy Policy does not apply to information about you collected by third party services, applications, or website or advertisements associated with, linked to or otherwise accessible from the Services. The information collected or received by such third parties, is subject to their own privacy policies or practices and under no circumstances is Passageways responsible or liable for the third party’s compliance therewith. 

Please note that our processing of information uploaded to the Platform on behalf of our enterprise customers is governed by the terms of our agreement with the enterprise customer, rather than by this Privacy Policy.  If you would like to understand how your data may be handled by one of our enterprise customers, please contact that customer directly. 

HOW DO WE COLLECT INFORMATION FROM YOU? 

We collect ”Personal Information” through your use of the Services in various ways, including: (i) when you register for Services, (ii) when you use the Services, and (iii) when you elect to contact us electronically to request a trial, ask a question or for other reasons. “Personal information” is information that identifies you as an individual or relates to an identifiable individual. 

We also automatically collect certain information, including through the use of cookies and similar tracking technologies, whenever users access or interact with Passageways Websites. Passageways Websites use common automated information gathering tools such as log files that record page activity, “one-pixel gifs,” “clear gifs,” or “web beacons” which are small bits of code embedded to gather certain information, and/or cookies. When you visit Passageways Websites, whether or not you are a registered user of the Services (as “Registered User”), Passageways’ servers send a cookie to your computer. These technologies are used for purposes that may include analytics, improving functionality, and remembering user preferences. You can review and adjust your cookie settings at any time using our Cookie Manager. To the extent Passageways Websites contain any third party-provided features or functions, such features or functions may also send cookies from such companies to your browser (known as “third party cookies”). You can control cookie preferences via your browser settings. However, note that rejecting cookies may prevent you from taking advantage of certain portions of Passageways Websites. 

Our Services use third-party analytics tools such as Google Analytics, which utilize cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. These analytics tools may also collect information regarding the use of other websites, apps and online resources. You can learn about Google Analytics by visiting www.google.com/policies/privacy/partners/ and you can exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. 

We incorporate “pixels” provided by Meta Platforms, Inc. on Passageways Websites. This enables us to track user behavior after a user clicks on a Facebook ad and is redirected to our Websites. By doing so, we can assess the effectiveness of Facebook ads for statistical and market research purposes and sometimes retarget certain users. Facebook stores and processes this data. It is important to be aware that Facebook may associate this information with your Facebook account and utilize it for its own promotional activities, in accordance with Facebook’s own policies.  

WHAT INFORMATION DOES THE COMPANY COLLECT FROM YOU? 

Whether or not you are a Registered User, when you visit the Services, various types of information are collected automatically and passively, including through cookies, log files and other tools as noted above under the caption “How Do We Collect Information From You,” including, but not limited to the following: 

• the domain name and browser you use to access the Internet 

• the date and time of your visit 

• the pages you visited, and how many “hits” a particular item is receiving and links “clicked” 

• the address of the web site you visited immediately prior to visiting Passageways Websites 

• your IP address (a number assigned to your computer when you use the Internet) 

• your operating system 

• non precise geolocation 

• name of your internet service provider 

• non sensitive demographic data  

• data relating to malfunctions or problems occurring when you use your computer with the Services and other customer service information 

• information about your use of the Services, and particular features thereof, and how frequently you use them. This may include, for example, activities collected with session replay technology, such as your clicks, mouse movements, scrolls, keystrokes, and information about your device. 

Contact With Us: The Services allow you to contact us electronically through email, to request a demo or other information. Whenever you make such contact, you will be providing us with some or all of the following information: your name, email address, phone number and any information you choose to include in the text of your message. If you send an email message to Passageways, initiate a chat session, or complete a questionnaire, form, or other online survey found on the Services, Passageways may maintain the information in its databases.  

Registered Users: If you are a Registered User of the Platform, you (or someone on your behalf) will be providing us with some or all of the following registration-related information about you: name, address, phone numbers, email address.  

In addition, when you or other Registered Users use the Platform, certain data associated with your use of the services will be collected in addition to the general visitor data described above such as user log-in data, board role, other board service, feature usage, product settings, configuration, activity records, and associated log and metadata. Registered Users may also choose to submit additional information to the Platform, such as uploading photos or other images, or providing information about themselves in their profiles, including optional diversity-related data (e.g., how they identify with respect to gender, race, sexual orientation, or similar characteristics, if they wish to self-identify). Professional or Employment-Related Information: We collect professional or employment-related information, such as job history and employer information, during our sales process and store it securely in our CRM. Users of the OnBoard application may voluntarily choose to provide additional information to their application profile, such as photos, images, or optional diversity-related data (e.g., how they identify with respect to gender, race/ethnicity, sexual orientation, veteran or disability status or similar characteristics). We may use this data to improve the Services and, where allowed, generate anonymized or aggregated reports. You control whether or not to provide this information; if you don’t wish for us to process this information, please do not provide it. 

HOW IS YOUR INFORMATION USED? 

We may use the information we receive for the following purposes based on our legitimate interests to manage and develop our services: 

• to provide and improve our Services; 

• to help identify you as a Registered User; 

• to help keep the Services safe and secure, and protect users’ rights or property; 

• to assess overall activity on the Services, including tracking interest in particular features of the Services; 

• for internal operations, including troubleshooting, diagnosing problems with servers, data analysis, testing, research and service improvement. We use such information for statistical/analytical purposes and for evaluating our Services to make them more useful to customers and to track and aggregate information. For example, we use IP addresses to monitor the regions from which Registered Users and visitors navigate the Services. We also collect IP addresses from Registered Users when they log into the Services as part of Passageways’ “Identity Confirmation” and “IP Range Restrictions” security features; 

• to monitor your use of the Services, including to enforce our Terms of Use;  

• to analyze platform usage for product development, training, security, and marketing purposes; and 

• to correspond with you regarding our Services or matters relating to use or potential use of the Services. 

We may use the information we receive about you for the following purposes based on our legal obligations:  

• to store and process Personal Information for compliance with legal obligations; and 

• manage any requests to exercise data protection rights. 

We may use the information we receive about you for the following purposes based on our legitimate interests, or based on your consent where required by applicable law: 

• to inform you of developments in our company or with our Services that we believe may be of interest to you. For example, if you fill out a “Contact Me” form, we will use the information provided to contact you about your interest in the Services; and  

• for products and event information purposes. 

We use cookies and other automated and passive tools (such as log files) to track and personalize your use of the Services to improve your user experience. 

When our processing activity is based on your consent, you may withdraw your consent at any time by contacting us in accordance with the “Contact Us” section below. The revocation of your consent will not affect the lawfulness of any processing based on your consent before its withdrawal. 

We may disclose your Personal Information based on our legitimate interests to manage and develop our business: 

• with our affiliates (such as our subsidiaries) for the purposes described in this Privacy Policy; 

• with our service providers contracted to provide services to us or on our behalf, such as providers of services such as website hosting, data analysis, order fulfillment, fraud prevention, information technology, customer service, and marketing delivery, among other services; 

• in the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, where Personal Information may be sold or transferred as part of such a transaction, as permitted by law and/or contract;  

• in connection with the enforcement of terms which may govern the Services; and  

• to provide aggregate statistical information with respect to “traffic” patterns and usage of the Services to our partners or affiliates, provided that such information has been rendered non-Personal Information.  

We may disclose your Personal Information to appropriate authorities for compliance with a legal obligation or legitimate interests, such as: 

• when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities (such as for potential fraud or infringement); and 

• when required to do so by law or regulation, or in response to legal process (for example, a court order, search warrant or subpoena) or a request from a law enforcement or governmental agency or authority, and in other circumstances in which we have a good faith belief that a crime has been or is being committed by you or another user or that an emergency exists that poses a threat to the safety of you or another person. 

We may also disclose your information in order to protect the vital interests of individuals or to comply with our legal obligations to protect and defend our rights, property, or safety or those of our Registered Users, or others. 

Selling and sharing of personal information 

We do not sell Personal Information in the traditional sense of exchanging information for monetary payment, but we do disclose information to certain types of advertising partners in a manner that may be considered a “sale” or “sharing” under certain privacy laws, and we allow you to opt out of such “sale” or sharing” as described in “Your Privacy Choices.” 

Requests to Opt-Out of Sale or Sharing:  You opt out of the “sale” or “sharing” of your Personal Information by visiting Do Not Sell or Share (https://www.onboardmeetings.com/opt-out). 

THIRD-PARTY ADVERTISING ON Passageways WEbsites 

We use third-party advertising companies to deliver advertisements for goods and services that may be of interest to visitors to the Passageways Websites. These companies may deliver advertisements based on information relating to your access to and use of the Passageways Websites, and other websites or online services across your devices, as well as information received from third parties.  

These advertising companies may place or recognize a unique cookie, pixel tag, or similar tracking technology on your browser. We and/or our partners may use cookies for delivering personalized advertising emails, including identifying visitors to our advertisers’ websites and sending personalized emails based on the visitors’ browsing experience. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, which may be shared with a data provider solely in hashed, non-human readable form. Users can also express their choices for display advertising, through the following platforms: Digital Advertising Alliance opt-out platform (http://www.aboutads.info/choices) or the Network Advertising Initiative opt-out platform (http://www.networkadvertising.org/choices/). If you would like more information about this practice, and to learn about your choices in connection with it, please visit http://www.networkadvertising.org/choices/ and http://www.aboutads.info/choices. 

We and/or these advertising companies also use technologies like cookies and web beacon technology to associate certain Internet-related information about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. They may use this information to provide you with interest-based (personalized) advertising or other targeted content. We do not control how these third parties collect or use your information. However, these third parties may provide you with choices over this type of collection or use of your information.   

Your Privacy choices 

Depending on the jurisdiction in which you reside, you may have the right to update, access, correct, rectify, delete Personal Information; receive a copy of your Personal Information for purposes of transmitting it to another company; and/or restrict, object to or opt out of certain processing of Personal Information.  To exercise such a right, please send us your request in accordance with the “Contact Us” section below. We will handle any such requests consistent with applicable law. 

Our marketing emails contain links allowing you to opt-out of receiving future marketing communications. You also may opt out of receiving marketing emails from us by contacting us in accordance with the “Contact Us” section below.  

Jurisdiction-specific rights are listed below.  

Privacy Rights for European Union and UK Residents 

ADDITIONAL INFORMATION REGARDING THE EUROPEAN UNION AND UK: Under the EU and UK GDPR, you may have the following rights regarding your Personal Information:  

• Access – You have the right to ask us for copies of your Personal Information. 

• Rectification – You have the right to ask us to rectify Personal Information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 

• Erasure – You have the right to ask us to erase your Personal Information in certain circumstances. 

• Restriction of processing – You have the right to ask us to restrict the processing of your Personal Information in certain circumstances. 

• Objecting to processing – You have the right to object to the processing of your Personal Information in certain circumstances. 

• Data portability – You have the right to ask that we transfer the Personal Information you gave us to another organization, or to you, in certain circumstances. 

You are not required to pay a fee for exercising these rights. To make a request, please contact us in accordance with the “Contact Us” section below. We will respond to you in the time period required by law.  

Privacy Rights for U.S. Residents 

A number of U.S. states have comprehensive data privacy laws which provide (now or in the future) their state residents with rights to: 

• Know – You have the right to confirm whether we process their Personal Information. 

• Access – You have the right to access certain Personal Information. 

• Delete – You have the right to request deletion of certain Personal Information. 

• Correction – You have the right to request to correct inaccuracies in their Personal Information,  

• Data portability – You have the right to ask that we transfer the Personal Information you gave us to another organization, or to you, in certain circumstances.  

• Opt-out – You have the right to opt out of Personal Information processing for: 

• targeted advertising; 

• sales; or  

• profiling in furtherance of decisions that produce legal or similarly significant effects. 
• Sensitive Data Limitations – Either limit (opt-out of) or require consent to process sensitive Personal Information. Please note we limit our use of Sensitive Personal Information that we have collected about you to that which is necessary to perform the Services that we provide to you or as is otherwise legally permissible. 

Nevada provides its residents with a limited right to opt-out of certain Personal Information sales. However, please know we do not currently sell data triggering that statute’s opt-out requirements. 

To exercise these rights, please email [email protected] or 1-844-416-6976.  

We may need to request additional Personal Information from you, such as email address, state of residency, or mailing address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information.  

Authorized Agents 

To make a request as an authorized agent on behalf of a U.S. resident covered by an applicable privacy law, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, and we may also require the resident to verify their own identity directly with us; or directly confirm with us that they provided you permission to submit the request. 

Nondiscrimination  

You have the right to be free from unlawful discriminatory treatment for exercising any of your rights under this section. 

CHILDREN 

This website is not for children and Passageways does not knowingly collect Personal Information from anyone under the age of 18 or direct services of the Services to anyone under the age of 18. If you are under 18, please do not use the Services or send any information about yourself to us. 

RETENTION PERIOD 

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.  

The criteria used to determine our retention periods include: 

 

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); 

• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or 

• Whether retention is necessary in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

PROTECTING YOUR PERSONAL INFORMATION 

We use our best commercial efforts to ensure the security of our systems and to prevent any disclosure of information inconsistent with this Privacy Policy (for example, as a result of unauthorized acts by third parties). However, no data transmission can be absolutely guaranteed as secure in every instance. If you suspect unauthorized access to your information, please contact Passageways immediately. 

INTERNATIONAL VISITORS 

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, including the U.S., which may have data protection rules that differ from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.  

If you choose to use Services from the European Union, United Kingdom, or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the U.S. for storage and processing.  

ADDITIONAL INFORMATION REGARDING THE EU/UK: Your information may be transferred to a country outside of the EU/UK that is not recognized by the Secretary of State as providing an adequate level of data protection according to EU/UK standards (the full list of countries is available here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers/#Q1). For transfers from the EU/UK to countries not considered adequate by the applicable regulatory authority, we have put in place adequate measures, to protect your Personal Information.  

Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services, which also may have data protection rules that differ from those of your country.  

POLICY MODIFICATIONS 

We reserve the right, at any time, to modify, alter, or update this policy, and any such modifications, alterations, or updates will be effective upon posting.  

CONTACT US 

Passageways, Inc., located at 333 N. Alabama Street, Suite 300, Indianapolis, IN 46204, is the controller responsible for the collection, use, and disclosure of information under this Privacy Policy. If you have any questions, comments, requests, or concerns about our processing activities, please email us at [email protected].  

ADDITIONAL INFORMATION REGARDING THE UK: You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues (www.ico.org.uk). 

DATA PRIVACY FRAMEWORK 

Passageways complies with the EU-U.S. Data Privacy Framework (EU-US DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-US DPF Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Passageways has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Policy and the EU-US DPF Principles or Swiss-U.S. DPF Principles (collectively, the Principles), the Principles will take precedence. To learn more about the Data Privacy Framework, please visit https://www.dataprivacyframework.gov. You may view our self-certification on the Data Privacy Framework List. 

Passageways is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. We also may be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requests. 

Individuals in applicable jurisdictions, may request to access their user data and HR Data, and to limit use and disclosure of this information, in accordance with the DPF Principles. To make such a request, please contact us at [email protected]. If your request involves personal information contained in user data that we process on behalf of an enterprise customer, please direct your request to that enterprise customer. 

Passageways is responsible for personal information that it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. Passageways complies with the DPF Principles for all such onward transfers of personal information, including the onward transfer liability provisions. 

Individuals with inquiries or complaints regarding our compliance with the DPF Principles should first contact us at [email protected]. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit our U.S.-based third-party dispute resolution provider at https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. JAMS’ services are provided at no cost to you. 

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Passageways also commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (“DPAs”) and the ICO and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to any unresolved complaints concerning our handling of human resources data in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship. 

For complaints regarding DPF compliance that are not resolved by any of the other DPF mechanisms, you may have the possibility, under certain conditions, to invoke binding arbitration before a Data Privacy Framework Panel.