Pangiam Mobile Enrollment Privacy Policy 

Last updated May 14, 2025

1. Introduction

At PANGIAM, we are committed to protecting the privacy and security of all of your Personal Data. Our Members who sign up to a part of the Pangiam Mobile Enrollment Program (“Members”) trust us to keep their Personal Data safe and to protect their privacy, and we’re focused on delivering on that promise. Importantly, PANGIAM does not sell your Personal Data. We are transparent about the information we have, how we protect and use it, and how Members engage with PANGIAM from the very beginning — starting with our Privacy Policy below.

2. Policy

This Privacy Policy describes how Pangiam Inc., and its corporate subsidiaries and affiliates (collectively, “PANGIAM”, “we”, and “us”) use your Personal Data when you access or use any of our products and services, directly or through our partners, including identity verification, faster access to partner services and fraud prevention (collectively, “PANGIAM Services” or “Services”), visit our Member websites, or communicate with us. This Privacy Policy does not apply to Personal Data we collect or process when you are a PANGIAM employee or contractor or when you apply for employment at PANGIAM. Additionally, this Privacy Policy does not apply to activities that PANGIAM undertakes as a service provider or processor to a third party, including a PANGIAM partner.

3. What Personal Data Do We Have?

Personal Data is any information that identifies you or that PANGIAM can use to identify you. Personal Data does not include information that is anonymous or that has been de-identified so that it cannot identify you. When you interact with and use PANGIAM Services, we may use, collect or process the following kinds of Personal Data, including information derived from this Personal Data, depending on the Services you use, your jurisdiction, and what is permitted or required by the laws that apply:

  • Personal Data includes face data;
  • Account and Membership information, including your name, Membership and service level, renewal information, account credentials, and account settings;
  • Contact information, including your name, address, email address, phone number, and information about individuals you may ask us to contact;
  • Business information, including your job title, email address and phone number, professional or employment information, and your employer’s name, address, and contact information, including when you request information via email about use of PANGIAM’s services;
  • Government-issued ID information, including passport or national ID number, social security number, copies of your government-issued identification documents (e.g., driver’s license, passport, and alien registration card);
  • Identifiers, including internet protocol (IP) address, and identifiers for the devices you use to access our products, services, or websites;
  • Demographic and physical information, including information from your government-issued ID, such as your age, date and place of birth, connected travelers including family Members, citizenship, employment and education status (e.g., for discount eligibility), gender, height, and weight;
  • Biometric data, including faceprints, fingerprints, iris scans, and digital images and video of your fingers, eyes, and face;
  • Payment and financial information, including your payment card details, billing address, and financial account information;
  • Transaction and background data, including information about past transactions with PANGIAM or our partners, failure to pay or return status with prior merchants, and other information we receive from partners and service providers to provide our identity verification and fraud and safety services;
  • Travel information, including flight details and itineraries, travel preferences, PANGIAM lane wait times, frequent flyer and other customer loyalty numbers, and Known Traveler Number;
  • Communications with PANGIAM, including customer support interactions, chatbot conversations, any correspondence that you send to us by postal mail, email, telephone, or webform, survey responses, and any other information you choose to send to us;
  • Location information, including precise geolocation as derived from your IP address and GPS information from your device; and
  • Usage and Device information, including information about how and when you interact with or navigate our Services and Member websites, language preference, and internet or similar network activity on the devices you use to access our Services, websites or survey responses.

Depending on where you live and the Services you use or access, some of the Personal Data we use may be considered “sensitive” or “special category” Personal Data under the laws that apply to your information, including biometric data, precise location data and health information. Where legally required, we will obtain your consent before collecting or processing your sensitive Personal Data. PANGIAM uses, collects and processes sensitive Personal Data only as needed to provide and develop our Services.

4. How Do We Receive Your Personal Data?

PANGIAM may receive Personal Data from the following sources:

  • Directly from you, including when you create an account, upload Personal Data to our Services, communicate with us, or otherwise provide us with your Personal Data;
  • Automatically through our Services, including from your device when you use or interact with our Services or visit our Member websites, and through the use of cookies and similar technologies;
  • From our partners or other third parties, including partners where you use PANGIAM, our partners who help us provide our verification and fraud prevention services, and advertising and analytics business partners; and
  • From our service providers, including when we engage them to enable certain technology and when they collect, use or process your Personal Data on our behalf.

5. Why Do We Ask for Personal Data?

Depending on what Services you use or access, we may use your Personal Data for the following purposes:

  • To provide our Services, including to create your account, manage our application and enrollment process, operate our Services, verify your identity, and to authenticate and verify your eligibility for and use of our Services;
  • To provide customer support, including by communicating with you about and addressing support issues and to ensure that customer support issues are being handled appropriately;
  • Location data is used to detect where your enrollment occurred;
  • To evaluate, improve and update our Services, including by analyzing how our Services are used, for debugging and troubleshooting purposes, improving our Services, and developing new Services;
  • For advertising and marketing purposes, including understanding which of our Services are relevant to you including through online behavior, serving you with advertising material, and sending you marketing communications. Where applicable, we limit how our third-party advertising partners use data collected via cookies and other tracking. You can also choose whether we have this information through the use of browser settings and other third-party tools, and by implementing Global Privacy Control on your browser;
  • To detect and prevent fraud and malicious activity, including making sure that you are you when you use PANGIAM, detecting and preventing fraudulent uses of PANGIAM Services, fraud against us or our partners, or other malicious activity or harassment, and to investigate and report deceptive or illegal activities;
  • To protect our systems, including detecting, preventing, and responding to security threats and incidents, and securing our systems and facilities;
  • To communicate with you, including in response to communications you send us by postal mail, email, telephone, or webform;
  • To enforce our rights and policies, including ensuring compliance with our Member Terms, and as necessary for us to preserve, exercise, or defend legal claims; and
  • For legal compliance purposes, including to investigate or respond to government or regulator inquiries, investigate or respond to court orders, subpoenas, or other legal process, for legal and financial reporting, to respond to privacy rights requests.

PANGIAM uses your Personal Data (including face data) only where we have a lawful basis to do so. Depending on the Services you use or access, PANGIAM uses, collects and processes your Personal Data to:

  • Fulfill contractual obligations, for example when we use your Personal Data to provide you with the Services you request in accordance with our Member Terms;
  • Comply with legal requirements, for example when we respond to court orders, or subpoenas;
  • Achieve our or a third party’s legitimate interests, for example to detect and prevent fraud;
  • With your consent, for example when consent is required to generate biometric data or to send you marketing communications; and
  • Public Interest/Vital Interests, for example providing verification services in airports or other security experiences.

6. Who Do We Share Personal Data With?

PANGIAM does not sell your Personal Data including face data. Depending on how you interact with PANGIAM or our Services and websites, we may securely share your Personal Data as explained below.

  • With Your Consent. We may share Personal Data with third parties with your consent, including when you choose to use a Service or participate in a program we offer with our partners. We may also share Personal Data to third parties for advertising and marketing purposes. For Personal Data collected through cookies.
  • To our Partners. We may share Personal Data with our partners in order to verify your identity, detect and prevent fraud or malicious activity, and provide information about your enrollment and verification status, account and use of PANGIAM Services.
  • To our Service Providers. We may engage service providers to help power our technologies or perform services on our behalf, including processing, storing, or deidentifying Personal Data, conducting identity and security verification checks, performing advertising and marketing services, conducting analytics, payment processing, and other services to provide our Services and manage our business. Service providers are bound by contractual terms to process your Personal Data in accordance with this Privacy Policy or required by applicable law.
  • Safety. We may share Personal Data when we determine disclosure is appropriate or necessary to prevent physical harm to our customers, employees, partners or Members of the public.
  • As Legally Required. We may share your Personal Data if required by law or legal process, including to governmental or regulatory bodies. We also may share your Personal Data in response to a lawful court order, subpoena, or investigatory demand from a competent court or regulator or where we determine disclosure is appropriate or necessary in the context of investigating actual or suspected unlawful or malicious conduct.
  • Corporate Restructuring. We may share your Personal Data as part of our assets during an actual or proposed merger, acquisition, or other corporate restructuring or transaction, including receiverships, bankruptcies, or joint ventures.

PANGIAM or its service providers may deidentify or anonymize your Personal Data and share this deidentified or anonymous information to others as permitted by applicable law.

7. Transferring Personal Data Internationally

PANGIAM may store, process, and transfer your Personal Data in a country other than that where you live, including the United States. PANGIAM engages in international transfers only as permitted by applicable law and enters into appropriate data protection terms designed to ensure an adequate level of protection, including the EU Standard Contractual Clauses and UK Addendum.

8. How We Protect Personal Data

We use appropriate technical, organizational, and physical controls to protect your Personal Data from unauthorized access, modification, disclosure, or destruction. You can help keep your Personal Data secure by taking precautions including never sharing your account password with anyone. If you have reason to believe that your PANGIAM account or your Personal Data has been compromised or no longer is secure, please contact us at privacy@pangiam.com.

9. Retention of Personal Data

We retain your Personal Data for as long as is required to provide you with our Services and to fulfill the purposes described in this Privacy Policy or as otherwise required or permitted by applicable law. We carefully consider several factors when determining how long to retain your Personal Data, including:

  • The time period necessary to fulfill the purposes for which we collected the Personal Data;
  • Your history of using our Services, including the duration and status of your relationship with us or our partners;
  • The time period necessary for us to comply with our legal obligations, including any statute of limitations or other period during which legal or regulatory claims may be brought by or against us or to continue ongoing legal proceedings;
  • Our internal obligations, including contractual commitments with partners; and
  • Face data will not be retained longer than 12 months after it was last accessed through the Mobile Enrollment App.

In order to avoid fraudulent activity against us, our Services, or our partners, PANGIAM may retain certain of your Personal Data even after you terminate your PANGIAM account for as long as may be necessary solely for fraud detection and prevention purposes, as permitted by applicable law. In order to allow you continued access to the Services, we will not delete your PANGIAM account unless you have asked us to do so, as described below.

For more information about how to exercise your privacy rights and to make choices regarding your Personal Data, please see the “Your Privacy Rights and Choices” section of this Privacy Policy.

10. Children’s Personal Data

PANGIAM does not direct its products, services, or websites at children under the age of majority as defined in local law. If we learn that we have collected Personal Data from a child under the age of majority without the permission of the child’s parent or legal guardian, we will promptly delete it.

11. Your Privacy Rights and Choices

At PANGIAM, we respect your privacy rights and offer you the ability to exercise your privacy rights and to make choices regarding your Personal Data. We honor these rights for all our Members, regardless of where they live. Depending on where you live, and subject to exceptions and limitations provided by local law, you or your authorized agent may exercise the following rights:

  • Right to Access / Know: Access your Personal Data and receive confirmation whether we process your Personal Data and the categories of Personal Data we process.
  • Right to Portability: Receive your Personal Data in a portable, machine-readable format.
  • Correction / Rectification: Correct, rectify, or update inaccurate Personal Data about you.
  • Deletion / Erasure: Request that we delete your Personal Data. PANGIAM might need to keep certain of your Personal Data for purposes such as legal compliance and fraud prevention.
  • Withdraw Consent: Where we rely on your consent to process your Personal Data, withdraw that consent at any time.
  • Object / Restrict / Opt-Out: Opt-out of or restrict certain processing of your Personal Data, including processing for the purposes of advertising and our sharing of your Personal Data for advertising purposes, and object to processing of your Personal Data that we undertake on the basis of our legitimate interests.
  • Appeal: Appeal our decisions about your privacy rights requests.
  • Non-Discrimination: PANGIAM will not discriminate against you for exercising any of your privacy rights. To exercise your privacy rights, you may contact us at privacy@pangiam.com.

We may need to verify your identity and your right to receive the information requested before responding to your privacy rights request. We may contact you and request additional information as necessary. PANGIAM will respond to your privacy request in the time period specified by local law.

12. Privacy Policy Updates

We may update or make changes to this Privacy Policy from time to time to account for changes to how we collect, use, process, or share your Personal Data. We will indicate the date of our latest update by changing the “Last Updated” date at the top of this Privacy Policy, and any changes will apply to the collection and processing of Personal Data after that date.

If we update this Privacy Policy in a way that requires notice to you or your consent under the law, we will provide you with such notice or obtain your consent.

13. How to Contact Us

PANGIAM is the controller of your personal information covered by this Privacy Policy. If you have any questions about this Privacy Policy or about how we collect, use, process, share, or otherwise handle your Personal Data, please contact us through our data protection officer at privacy@pangiam.com.

14. Notice to Users in Canada

PANGIAM and our third-party service providers may maintain and process your Personal Data outside your jurisdiction of residence (including outside the Province of Quebec), such as in the United States. Personal information transferred to the U.S. will be subject to U.S. laws.

To establish and verify your identity, we collect a selfie as well as a photo of your government-issued ID. We extract information about your facial features from the photos and use this to match your selfie with the photo on your ID card. For users in Canada, PANGIAM will retain biometric data and other personal information only until the occurrence of the first of the following: (a) the initial purpose for collecting or obtaining such data has been satisfied or (b) three years following your last interaction with PANGIAM (unless you request to close your account and discontinue all use of PANGIAM Services earlier).