Privacy Policy

Updated: 29 January, 2021

We at Facere Technologies Pvt. Ltd. (henceforth referred to as "Company"); respect your privacy and value the relationship we have with you. Our Privacy Policy is designed to inform you regarding the information that we collect from you when you use our Services ("FTpass User App, FTpass Client App"). Some of your personally identifiable information is collected by our 'Services' in order to operate. For the sake of clarity and transparency of our company’s privacy policy to our customers ("you", "Users"), this section has been divided into different modules so as to give our customers a clear insight about our Policies.

Our prime focus is laced to the belief that we value our customers and the information that is provided by them. We do our best to keep that information safe and intact in our secure database to ensure a sense of safety to our customers that their personal information will not be shared to advertisers, spammers or any other third parties.

In course of your interaction with our Services, we may collect some general information as described below:

1. Information We Collect About You

The Service enables you and other individuals who install the FTpass User App or FTpass Client App or other variants of the FTpass Client App that we may make available to ("Users", "You") to aggregate your professional and social credentials at a single location, use the "Site" to create a "FTpass Network", send badges for such FTpass Network ("FTpass Badges") to members of your professional and social organizations ("Organizations"), to allow other Users within a shared FTpass Network to confirm your credentials for the same by using the FTpass User App or FTpass Client App, including by scanning the QR code associated with your User account or by inputting into the FTpass User App or FTpass Client App the characters of the "FTpass Code" associated with your User account, to use the "FTpass Keys" feature to gain secure, physical or logical access to locations or items associated with a FTpass Badge, such as computer workstations and websites or servers, to discover other Users in your FTpass Network when such Users are in your contact directory ("Contact Discovery") and to allow such other Users to use the Contact Discovery feature to discover you. In order to facilitate these processes, the Service may collect your personally identifiable information in various ways:

  • Information about you when you create a new FTpass Network, when you are invited to join a FTpass Network or when you accept a FTpass Badge for a FTpass Network you are invited to join ("FTpass Account Information")
  • In the Administrator option, by connecting a FTpass Network to your Organization’s existing account with certain third–‐party sites, such as apple.com or google.com ("Third Party Sites")
  • Collecting your User Data, by recording when and where you use certain features of the Service, such as the FTpass Keys features and in other ways as described by this Privacy Policy.
  • 2. FTpass Account Information

    As a User, if you choose to create a new FTpass Network using the Site, you will be the administrator for such FTpass Network ("Administrator"). If you choose to establish a new FTpass Network as an Administrator or if you are invited via email by an Administrator to join a new FTpass Network, the FTpass Account Information that we will collect may include, without limitation:

  • your name
  • your organization
  • your title
  • your email address
  • your phone number
  • your photo
  • 3. Third Party Site Information

    If you are Administrator of a FTpass Network, you may integrate the FTpass Badges for such FTpass Network with an existing Third Party Site account, thereby enabling you and other Users in your FTpass Network to log into such Third Party Site using FTpass Badge. As an Administrator, if you choose to integrate your FTpass Network with a Third Party Site, you may be asked to provide certain personal information, including your name, the specific URL associated with your Organization’s Third Party Site account, and your username or email address associated with such Third Party Site (collectively hereinafter referred to as "Third Party Site Information"). As an Administrator, if you choose to integrate your FTpass Network with a Third Party Site, you may use your Organization’s existing address book, directory or other list of contacts located on such Third Party Site to invite other members of your Organization to join your FTpass Network, thereby allowing such other members of your Organization to log into such Third Party Site using applicable FTpass Badges. If an Administrator uses a Third Party Site to send you a FTpass Badge, thereby inviting you to join a FTpass Network, in addition to your FTpass Account Information, we may collect your username for such Third Party Site. Your use of Third Party Sites in general and your relationship with such Third Party Sites are subject to such Third Party Sites’ own privacy policies and other terms and policies, which we strongly recommend that you review before you start using the Service or integrate any of your FTpass Badges with such Third Party Sites. We do not control and are not responsible for the processing of your information by Third Party Sites.

    4Usage Information

    In addition to the FTpass Account Information and Third Party Site Information, we may automatically collect information about you based upon your use of our Service, including your User Data (as defined below), when and where you use the FTpass Keys feature, when and where you use the Service to unlock doors or log into your computer, Third Party Site or other system, your requests for customer support, when you use the Service’s Peer Discovery feature, your user feedback and other communications you direct to us, how often you log into the Service and what functions of the Service you frequently use (collectively the "Usage Information").

    5. Login Information

    We may also collect your login information for the websites or servers of participating Organizations, which we will use to verify your credentials for each applicable Organization. As referenced above, if your FTpass Badge is integrated with a Third Party Site, we may also collect your username from such Third Party Site (together with the login information of participating Organizations, collectively referred to as "Login Information").

    6. Credentialing Information

    When you choose to create or accept a FTpass Badge for an Organization, we collect certain information about you ("Credentialing Information") which will be visible in the FTpass User App or FTpass Client App for other Users affiliated with such Organization to view or in the FTpass User App or FTpass Client App for FTpass Mobile Users (as defined below) to view, in each case, as part of the verification process or Contact Discovery feature. Credentialing Information may include, for example, your name, organization, title, photo, email address, and phone number.

    7License Information

    In certain cases, you may have the opportunity to verify your identity by using the FTpass User App or FTpass Client App to scan your Aadhar, driver’s license or other government issued form of identification. If you choose to use this identity verification function, we will collect certain of your personal information directly from your Aadhar or other form of identification, such as your first and last name, date of birth, picture and zip code ("License Information").

    8Biometric Information

    We may collect, with your consent, your finger print, voice print or facial profile which are considered biometric data (the "Biometric Information"). This Biometric Information may be used to validate your Credentialing Information when logging into the Service on a new device and to provide Administrators, FTpass Mobile Users and other Users with a biometric means of confirming Credentialing Information.

    9. Cookies

    9.1 When you visit the Site, we may collect certain information by automated means, such as cookies. A cookie is a token that a server gives to your browser when you access a website. Cookies are capable of storing many types of data. Cookies help provide additional functionality to the site or to help us analyze site usage more accurately. For instance, it can "remember" your email address to save your time. We also use cookies to track responses to our marketing materials, such as emails and online advertisements. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies.

    9.2 The Site may also feature cookies associated with certain unaffiliated companies. For example, we partner with other companies to provide you with connections to certain social networks, such as Facebook, Twitter, LinkedIn, etc. The use of these cookies is subject to such companies’ own cookie policies, which we strongly recommend for you to review before you use the Site.

    10. Web Analytics

    We may use web analytics services on the Site and Apps, such as those of Google Analytics. The service providers that administer these services use technologies such as cookies to help us analyse how visitors use the Site. The information collected through these means (including IP address) is disclosed to or collected directly by these service providers, who use the information to evaluate use of the website. To disable Google Analytics, please download the browser add–‐on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout.

    11. Information We Collect When You Access the Service on a Mobile Device

    When you have installed the FTpass User App or FTpass Client App on your mobile device, we collect a unique identification number that we assign to you, your IP address, phone model and operating system. In connection with the Applications, with your permission, we may collect your precise location information from your mobile device, including when you are not using the FTpass User App. In addition, even if you have not enabled location services for the Applications on your mobile device, we may derive your general location information from your use of the Applications, including from your Bluetooth signal when another User discovers you through the Service’s Peer Discovery feature, or in connection with your use of FTpass Badges or the FTpass Keys feature to gain physical or logical access to locations or items associated with your FTpass Badges (the precise and general location information are collectively referred to as the "Location Data" and together with the other information obtained from your mobile device, the "Mobile Information"). "Mobile Information" together with FTpass Account Information, Third Party Information, Usage Information, Login Information, Credentialing Information, License Information and Biometric Information, are collectively referred to as "User Data".

    12How We Use Your Information (User Data)

    12.1 The Company will use User Data for purposes of providing the Service and, in particular:

  • to enable you to use the Service to organize your professional and social credentials.
  • to contact you when Administrators invite you to join their FTpass Network by sending you a FTpass Badge
  • to validate your identity by using your mobile OTP, Aadhar or any other government–issued form of identification
  • to integrate your FTpass Badge with an existing Third Party Site account
  • to log into a Third Party Site using a FTpass Badge
  • to use the FTpass Keys feature to gain secure physical or logical access to locations or items associated with a FTpass Badge, including printers, computer workstations, Third Party Sites and other websites or servers of participating Organizations
  • to validate your Credentialing Information to other Users
  • to validate your Credentialing Information on new or additional mobile devices
  • to enable you to use the Service’s Peer Discovery feature to discover other Users in your FTpass Network when such Users are in close proximity to your current location, and to allow you to save the Credentialing Information of such Users to the contact list on your mobile device
  • to allow other Users in your FTpass Network to use the Service’s Peer Discovery feature to discover you when such Users are in close proximity to your current location, and to enable such Users to save your Credentialing Information to the contact list on their mobile device
  • to send you emails regarding your use of the Service
  • to provide technical support and to respond to your inquiries
  • to create and issue reports which may include reporting on your activity patterns, preferences and Location Data
  • to enable Administrators to generate reports on Users within the FTpass Network for which they are the Administrators, including reports related to such User’s activity patterns, preferences and Location Data
  • to enable FTpass Mobile Users to view information of other Users within the FTpass Networks(s) for which they are a FTpass Mobile User, including information related to User’s activity patterns, preferences and Location Data.
  • to enable FTpass Mobile Users to use the Service’s Peer Discovery feature to discover Users in the FTpass Networks for which they are FTpass Mobile Users when such Users are in a specified range(set by the Administrator) from the FTpass Mobile User’s current location, and to enable the FTpass Mobile User to save the date, time, location or event where such Users were discovered as well as the Credentialing Information of such Users to the FTpass User App or FTpass Client App on their mobile device or to the FTpass server
  • to enable FTpass Mobile Users to make calls, send text messages or send emails to other Users in such FTpass Mobile User’s FTpass Network via the FTpass User App or FTpass Client App
  • 12.2 In addition, the Company may use User Data for the following purposes:

  • to communicate with you about new features or promotions of the Company or Service
  • to prevent fraud or potentially illegal activities
  • to enforce our Terms of Use
  • to solicit your feedback to improve the Service and your experience using it
  • to administer and improve the Service, including by creating test reports on the User Data we collect, and
  • to keep track of your activity patterns, preferences and Location Data in order to improve the level of service you receive from the Service and to provide reporting to Administrators and FTpass Mobile Users.
  • 13How We Share Your Information (User Data)

    We may share User Data in the following cases:

  • With Affiliates and Our Third Party Service Providers: We may share your User Data with our affiliates and third party service providers. To receive a full list of all service providers, please contact us at the address specified in the "How to Contact Us" section below. Except as otherwise set forth in this section, we will only share your User Data with any such parties in connection with the administration of the Service or for the purpose of improving your experience with the Service. Third party service providers are not authorized by us to use or disclose your User Data except as necessary to perform services on our behalf or comply with legal requirements. If you have shared your Third Party Site Information with us, we will only disclose it to the extent permitted by such Third Party Site.
  • With Third Party Sites: If your FTpass Badge is integrated with a Third Party Site, we may share your User Data with the applicable Third Party Sites.
  • With Administrators: We may share some specific User Data with the Administrator of a FTpass Network that you are a member of. Such User Data may include your Usage Information, your Credentialing Information, and your Mobile Information (including your Location Data).
  • With FTpass Mobile Users: The Service allows the Administrator of any FTpass Network to provide other Users in such FTpass Networks (each "FTpass Mobile User") access to your Usage Information, Credentialing Information and your Mobile Information (including your Location Data) through the FTpass User App or FTpass Client App. We may share, with your consent, your Credentialing Information with other FTpass Mobile Users in your FTpass Network who are within a specified distance (set by the Administrator) from the FTpass Mobile User’s location. FTpass Mobile Users will have the option to save your Credentialing Information to the FTpass User App or FTpass Client App on their mobile device or to the FTpass server.
  • With Other Users: If you do not deactivate the Service’s Bluetooth–‐enabled Contact Discovery feature, we may share your Credentialing Information with other Users in your FTpass Network who are in close proximity to your current location (approximately 100 feet) using the Bluetooth signal on your mobile device. Such Users of the FTpass User App or FTpass Client App will have the option to save your Credentialing Information to the contact list on their mobile device. This functionality can be disabled by turning off the FTpass User App or FTpass Client App Bluetooth sharing functionality in the Settings of your mobile device. In that case, you will still be able to use your phone’s Bluetooth signal for other purposes.
  • As required by Law: We may disclose any User Data when we believe, in our sole discretion, disclosure is necessary or appropriate to comply with any applicable law, regulation, legal process or governmental request.
  • To Protect Our Legitimate Business Interests: We may disclose User Data when we believe, in our sole discretion, disclosure is necessary to protect the Company’s legitimate business interests.
  • In Connection with a Sale of Our Business: We also reserve the right to transfer User Data in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use the User Data in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred the User Data with any inquiries concerning the processing of that information.
  • 14. How We Protect Your User Data

    We work hard to ensure safety of User Data using teams of engineers, automated systems and advanced technology such as encryption, digital certificates and machine learning. Additionally, We maintain strict administrative, technical and physical safeguards to protect the User Data that we collect about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

    15. Transfers of User Data to Other Countries

    The Company uses databases located in different jurisdictions. We may transfer User Data we collect about you to our databases located in countries other than your country of residence, including countries which have laws requiring a different level of data protection compared to your country of residence. We will take all the necessary steps to ensure that such transfers of User Data comply with applicable data protection laws, in particular, the legal requirements on adequate protection for data transfers to countries outside of the European Economic Area.

    16Your Privacy Rights and Choices

    To stop the Service from collecting your Usage Information at any time, uninstall the FTpass User App or FTpass Client App from all of your devices. However, since FTpass is a cross platform Identity Management System, significant information would be stored and distributed as deemed necessary. If applicable law requires, we will provide you with access to the User Data we have retained about you and the ability to review, correct, update, block or delete the information where it is inaccurate. Subject to applicable law, we may limit or deny access to your User Data where providing such access is unreasonably burdensome or expensive under the circumstances. Please submit your request to the address specified in the "How to Contact Us" section below.

    17. Updates to This Privacy Policy

    This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information processing practices or for any other purpose. We will post a notice on the Site to notify you of any significant changes to the Privacy Policy and indicate there and at the top of the Privacy Policy when it was most recently updated.

    How to Contact Us

    If you have any questions or comments about this Privacy Policy, please contact us by email at [contact@ftpass.com] or call us at +91 8368381197.

    You may also write to us at:

    Facere Technologies Pvt Ltd,

    Sector 63, Noida

    India 201301