Privacy Policy

1. Introduction

PassExam, developed and operated by PassExam Trading Co., Ltd. (Jiujiang Liantongkao Shangmao Youxian Gongsi), a company duly organized and existing under the laws of the Peoples Republic of China with its registered office at 114-3, Building 4, Helonglong Resettlement Area Phase I, Hetang Xincun Community, Wuli Street, Lianxi District, Jiujiang 332000, China, is committed to protecting the privacy and personal data of every individual who interacts with our website, products, and services. This Privacy Policy explains in clear and thorough terms how we collect, use, store, share, and safeguard your information when you visit https://www.passexam.mom or engage with our computer integrated systems design and related professional services.

We recognize that privacy is a fundamental right and we take our responsibility to protect your data with the utmost seriousness. By using our website or services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, you should discontinue use of our website and services immediately. We may update this policy from time to time, and we encourage you to review it periodically to stay informed about how we are protecting the information we collect. Your continued use of the PassExam website after any modifications to this policy constitutes your acceptance of the updated terms.

PassExam provides professional computer integrated systems design, information technology consulting, technical architecture planning, system integration, managed IT operations, cybersecurity compliance, and related technical services to enterprises and organizations worldwide. The nature of our business requires us to handle certain categories of information with diligence and care. This policy applies to all information collected through our website, email communications, telephone calls, contact forms, client onboarding processes, and any other interaction with PassExam where personal or business data is exchanged. It also applies to data collected from prospective clients, current clients, former clients, vendors, partners, and visitors to our website.

2. Information We Collect

We collect several categories of information to provide our services effectively and to improve your experience with PassExam. The information we gather can be broadly divided into information you provide to us directly, information collected automatically through technology, and information we obtain from third-party sources. Each category is described in detail below.

Personal Identification Information. When you fill out a contact form on our website, request a consultation, subscribe to our newsletter, register for an account, or otherwise communicate with us, you may voluntarily provide personal identification information. This includes but is not limited to your full name, email address, telephone number, company name, job title, industry sector, physical address, postal code, country of residence, and any other details you choose to include in your message. We collect this information solely to respond to your inquiry, deliver the services you have requested, and maintain our professional relationship with you or your organization.

Business and Project Information. In the course of delivering our computer integrated systems design and consulting services, we may receive detailed information about your business operations, technical infrastructure, existing system architecture, software and hardware inventories, network configurations, security protocols, data flow diagrams, operational workflows, business requirements documentation, project specifications, budgets, timelines, and strategic goals. This information is essential for us to perform accurate assessments, design appropriate solutions, and deliver high-quality professional services tailored to your unique needs.

Automatically Collected Information. When you access our website at https://www.passexam.mom, our servers and third-party analytics tools automatically record certain technical information. This includes your Internet Protocol (IP) address, browser type and version, operating system, device type and model, screen resolution, referring and exit pages, date and time stamps, clickstream data, pages viewed and time spent on each page, search queries, and other diagnostic and usage data. We also collect information through cookies, web beacons, tags, and similar tracking technologies as described in our Cookies and Tracking section below.

Communication Records. When you contact us via email at team@passexam.mom, by telephone at +15092868650, through our website contact forms, or through any other communication channel, we may retain records of those communications including the content of your messages, attachments, metadata, and our responses. This helps us provide consistent and efficient customer support, maintain an accurate history of our interactions, and continuously improve the quality of our services.

3. How We Use Your Information

PassExam uses the information we collect for a range of legitimate business purposes that are essential to the delivery and improvement of our services. We are committed to using your data only for the purposes for which it was collected, unless we reasonably determine that we need to use it for another compatible purpose. The following is a detailed description of how we use each category of information.

We use personal identification and contact information to respond to your inquiries, schedule consultations, prepare proposals, deliver our computer integrated systems design and consulting services, process service agreements, manage billing and payments, send you important administrative updates regarding your projects, provide technical support, and communicate with you about your account or our ongoing professional relationship. We may also use your contact information to send you relevant newsletters, industry insights, service updates, and promotional materials, but only if you have given your explicit consent to receive such communications. You may opt out of marketing communications at any time by clicking the unsubscribe link included in every email or by contacting us directly.

We use business and project information exclusively to analyze your technical environment and requirements, design tailored systems architecture solutions, plan integration strategies, perform gap analyses, develop project roadmaps, estimate resource requirements, prepare deliverables, coordinate with our technical teams, track project milestones, and ensure the successful delivery of our professional services. This information is treated as confidential and is accessed only by authorized PassExam personnel and contractors who have a legitimate need to know it for the execution of their duties.

Automatically collected technical and usage data is used to monitor and analyze trends in website traffic and user behavior, administer and improve our website, diagnose server and performance issues, protect against fraud and unauthorized access, ensure the security and integrity of our systems, gather demographic information about our user base, measure the effectiveness of our marketing campaigns, and enhance the overall user experience. Aggregated and anonymized data derived from this information may also be used for internal research, reporting, and business intelligence purposes.

Communication records are retained and used to maintain a comprehensive history of our interactions with you, resolve disputes, enforce our terms of service, train our staff, improve our customer support processes, and comply with any applicable legal or regulatory obligations. We do not use communication content for any purpose unrelated to the management of our professional relationship with you.

4. Legal Bases for Processing

Under applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR) of the European Union and the Personal Information Protection Law (PIPL) of the Peoples Republic of China, PassExam relies on one or more specific legal bases to process your personal data depending on the nature of the processing activity, the type of data involved, and the jurisdiction in which you are located. We have carefully assessed each of our processing activities and identified the appropriate lawful grounds.

Contractual Necessity. The primary legal basis for much of our data processing is the performance of a contract or the taking of steps prior to entering into a contract. When you engage PassExam to provide computer integrated systems design, consulting, or other professional technical services, we process the personal and business information that is necessary to fulfill our contractual obligations to you or your organization. This includes processing required for service delivery, project management, billing, and ongoing account administration.

Legitimate Interests. We process certain categories of personal data based on our legitimate business interests, provided those interests are not overridden by your data protection rights and freedoms. Our legitimate interests include improving our website and services based on aggregated usage analytics, protecting the security and integrity of our networks and systems against cyber threats, detecting and preventing fraudulent or unauthorized activity, managing our business operations efficiently, developing new service offerings that address client needs, and conducting reasonable direct marketing to existing clients regarding similar services, in compliance with applicable laws.

Consent. Where required by applicable law, we obtain your explicit, informed, and freely given consent before processing your personal data for specific purposes, such as sending electronic marketing communications, placing non-essential cookies on your device, or processing sensitive categories of personal data. You have the right to withdraw your consent at any time without affecting the lawfulness of processing conducted prior to the withdrawal. To withdraw consent, please contact us using the information provided in the Contact Information section of this policy.

Legal Obligation. In certain circumstances, we may be required to process your personal data to comply with applicable laws, regulations, court orders, governmental requests, or other legal processes to which PassExam is subject. This may include retaining records for tax, accounting, and corporate compliance purposes, responding to valid legal requests from law enforcement or regulatory authorities, or meeting obligations under international trade and data protection laws.

5. Data Sharing and Disclosure

PassExam does not sell, rent, lease, or trade your personal information to third parties for their own commercial or marketing purposes. We consider your data to be a trust you have placed in us, and we handle it with corresponding care. There are, however, certain limited and necessary circumstances under which we may share your information with third parties, as described below.

Service Providers and Subprocessors. We may engage trusted third-party service providers and subprocessors to perform functions and provide services on our behalf that are essential to our business operations. These may include cloud hosting and infrastructure providers, email delivery and communication platform services, customer relationship management software, project management and collaboration tools, analytics and performance monitoring services, payment processors, accounting and invoicing platforms, and professional advisors such as legal counsel and auditors. All service providers are contractually obligated to process your data only in accordance with our documented instructions, to implement appropriate technical and organizational security measures, and to comply with all applicable data protection laws. We conduct due diligence on all third-party providers before engagement and periodically review their compliance.

Business Transfers. In the event that PassExam Trading Co., Ltd. is involved in a merger, acquisition, reorganization, sale of assets, joint venture, assignment, transfer, or other disposition of all or any portion of its business, assets, or equity, your personal data may be among the assets transferred or disclosed as part of that transaction. We will notify you via prominent notice on our website and via email if applicable before your personal data becomes subject to a different privacy policy as a result of such a transaction.

Legal Compliance and Protection. We may disclose your information to courts, law enforcement agencies, governmental authorities, regulators, or other authorized third parties if we believe in good faith that such disclosure is reasonably necessary to comply with applicable laws, regulations, legal process, or enforceable governmental requests; to investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, or violations of our Terms of Service; to protect the rights, property, or personal safety of PassExam, our employees, our clients, or the general public; or to enforce our contractual rights and agreements.

Aggregated and De-Identified Data. We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you with third parties for research, marketing, analytics, industry benchmarking, and other lawful purposes. Such data does not constitute personal data under applicable law and is not subject to the restrictions in this Privacy Policy.

6. Cookies and Tracking Technologies

PassExam uses cookies, web beacons, pixel tags, local storage objects, and similar tracking technologies on our website to collect and store certain information about your browsing activities and to enhance your user experience. Cookies are small text files that are placed on your device when you visit a website and that can be read by the website on subsequent visits. They serve a variety of functions including enabling core website functionality, remembering your preferences, analyzing site performance, and delivering relevant content.

Essential Cookies. These cookies are strictly necessary for the operation of our website. They enable core functions such as page navigation, secure access to restricted areas, session management, and load balancing. The website cannot function properly without these cookies, and they are set automatically when you visit our site. Essential cookies do not require your consent under most applicable data protection laws, as they are necessary for the provision of the service you have explicitly requested.

Analytics and Performance Cookies. These cookies collect aggregated and pseudonymized information about how visitors use our website, including which pages are visited most frequently, how long visitors spend on each page, the sequence of pages viewed, and any error messages encountered. We use this information to improve the performance, design, and content of our website. The data collected by these cookies does not identify you personally. We use third-party analytics services, such as Google Analytics, which set their own cookies for this purpose. You can learn more about how these services handle your data by reviewing their respective privacy policies.

Functional and Preference Cookies. These cookies allow our website to remember choices you make, such as your preferred language, region, or the types of services you are interested in, and to provide enhanced and more personalized features. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

Managing Your Cookie Preferences. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies, delete existing cookies, or alert you when a cookie is being sent. You can manage your cookie preferences through the settings menu of your browser. Please note that if you choose to disable cookies, some parts of our website may not function properly and your user experience may be diminished. For more detailed information about cookies and how to manage them, you may visit https://www.allaboutcookies.org. We do not currently respond to Do Not Track signals from browsers.

7. Data Retention

PassExam retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, tax, or reporting requirements. When determining the appropriate retention period for each category of personal data, we consider the nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, whether those purposes can be achieved through other means, and the applicable legal and regulatory requirements.

Personal identification and contact information related to client accounts and active projects is retained for the duration of the business relationship and for a period of up to seven (7) years following the termination of the relationship, to comply with applicable tax and commercial record-keeping obligations and to respond to any post-termination legal claims. Business and project information provided in the context of professional services engagements is retained for the duration of the project and for a reasonable period thereafter as necessary to resolve disputes, enforce our agreements, and comply with professional standards. Automatically collected technical and usage data is typically retained in identifiable form for a period of twenty-six (26) months, after which it is either deleted or permanently anonymized and aggregated. Communication records are retained for a period consistent with the retention of the associated account or project data.

When personal data is no longer needed for the purposes for which it was collected and there is no overriding legal or regulatory requirement to retain it, we will securely delete, destroy, or irreversibly anonymize it using industry-standard methods. If you wish to request the deletion of your personal data before the expiration of our standard retention periods, you may do so by contacting us as described in the Contact Information section. We will assess your request and respond in accordance with applicable data protection laws.

8. Data Security

Protecting the confidentiality, integrity, and availability of your personal data is a top priority for PassExam. We have implemented and maintain a comprehensive information security program that includes administrative, technical, and physical safeguards designed to protect your information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Our security measures include but are not limited to: encryption of data in transit using Transport Layer Security (TLS) protocols; encryption of data at rest on our servers and backup systems; network firewalls, intrusion detection, and intrusion prevention systems; regular vulnerability scanning and penetration testing conducted by independent security professionals; strict access controls based on the principle of least privilege and role-based access management; multi-factor authentication for access to systems containing personal data; comprehensive logging and continuous monitoring of system access and activity; regular security awareness training for all employees and contractors; secure software development lifecycle practices including code reviews and security testing; business continuity and disaster recovery plans that are tested periodically; and physical security controls at all facilities where personal data is stored or processed.

While we strive to use commercially acceptable means to protect your personal data, no method of transmission over the Internet or method of electronic storage is one hundred percent secure. We cannot guarantee absolute security, and we cannot be responsible for unauthorized access beyond our reasonable control. In the unlikely event of a data breach affecting your personal data, we will notify you and the relevant supervisory authorities without undue delay and in accordance with the requirements of applicable data protection laws. We encourage you to also take steps to protect your own data, including using strong passwords, keeping your login credentials confidential, and ensuring that your devices and software are kept up to date.

9. International Data Transfers

PassExam is a global business with operations, technical infrastructure, service providers, and clients located in multiple countries around the world. As a result, your personal data may be transferred to, stored on servers located in, and processed in countries other than the country in which you reside, including China, the United States, member states of the European Union, and other jurisdictions where our service providers and subprocessors operate. These countries may have data protection laws that differ from, and in some cases may be less protective than, the laws of your home country.

When we transfer personal data across international borders, we take appropriate measures to ensure that your data receives an adequate level of protection in accordance with applicable data protection laws. For transfers of personal data originating from the European Economic Area (EEA), the United Kingdom, or Switzerland, we rely on one or more of the following legal mechanisms: Standard Contractual Clauses (SCCs) approved by the European Commission or the relevant authority; an adequacy decision issued by the European Commission recognizing that a particular country provides an adequate level of data protection; binding corporate rules, where applicable; or your explicit consent after being informed of the possible risks of such transfers. For transfers subject to the Personal Information Protection Law of China, we comply with the requirements for cross-border transfers established thereunder, including conducting personal information protection impact assessments and obtaining necessary certifications. You may request additional information about the specific safeguards we have in place for cross-border data transfers by contacting us using the details provided in the Contact Information section.

10. Privacy for Children

The PassExam website and our professional computer integrated systems design services are directed at businesses, enterprises, and professional adults. Our website and services are not intended for use by children under the age of sixteen (16), and we do not knowingly collect, solicit, use, or disclose personal data from anyone under the age of sixteen without verified parental or guardian consent in accordance with applicable laws, including the Childrens Online Privacy Protection Act (COPPA) in the United States, the General Data Protection Regulation (GDPR) in the European Union, and the Personal Information Protection Law (PIPL) in China.

If we become aware that we have inadvertently collected or received personal data from a child under sixteen without verified parental consent, we will take prompt and reasonable steps to delete that information from our records as quickly as possible. If you are a parent or legal guardian and you believe that your child has provided us with personal data without your consent, please contact us immediately using the information in the Contact Information section of this policy. We are committed to protecting the privacy of children and we encourage parents and guardians to monitor and supervise the online activities of minors in their care.

We also recommend that parents and guardians educate their children about the importance of protecting their personal information online and about the potential risks associated with sharing information on the Internet. If we make any changes to how we handle information from children in the future, we will update this policy and provide appropriate notice.

11. Your Rights and Choices

Depending on your jurisdiction, you may have specific legal rights regarding the personal data we hold about you. PassExam respects all applicable data protection rights and is committed to facilitating their exercise in a timely and transparent manner. The rights described below represent those most commonly provided under data protection laws globally, though the availability and scope of each right may vary based on your location and the applicable legal framework.

Right of Access. You have the right to request access to the personal data we hold about you and to obtain a copy of that data, along with certain information about how we process it. This includes the categories of personal data concerned, the purposes of the processing, the recipients or categories of recipients to whom the data has been or will be disclosed, the envisaged retention period or the criteria used to determine it, and the source of the data if it was not collected directly from you.

Right to Rectification. You have the right to request that we correct any inaccurate or incomplete personal data we hold about you. We will make the requested corrections without undue delay and will notify any third parties to whom we have disclosed the relevant data, where feasible and appropriate.

Right to Erasure. You have the right to request the deletion or removal of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, when you withdraw your consent and there is no other legal basis for processing, when you object to processing and there are no overriding legitimate grounds, or when the data has been processed unlawfully. This right is subject to certain exceptions where retention is required by law or necessary for the establishment, exercise, or defense of legal claims.

Right to Restrict Processing. You have the right to request that we restrict or suspend the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data, when the processing is unlawful and you oppose erasure, or when we no longer need the data but you require it for legal claims. Where processing is restricted, we may continue to store your data but we will not otherwise process it without your consent or for legal reasons.

Right to Data Portability. You have the right, in certain circumstances, to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and to transmit that data to another controller without hindrance from us. Where technically feasible, you may request that we transmit the data directly to another organization on your behalf.

Right to Object. You have the right to object to the processing of your personal data on grounds relating to your particular situation, where the processing is based on our legitimate interests or the performance of a task carried out in the public interest. You also have an absolute right to object to the processing of your personal data for direct marketing purposes at any time.

Right to Withdraw Consent. Where we rely on your consent as the legal basis for processing your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Right to Lodge a Complaint. If you believe that our processing of your personal data violates applicable data protection laws, you have the right to lodge a complaint with the competent supervisory authority in your country of residence, place of work, or place of the alleged infringement. While you are not required to do so, we would appreciate the opportunity to address your concerns directly before you approach a supervisory authority, and we encourage you to contact us first so that we may attempt to resolve any issues.

To exercise any of the rights described above, please submit your request to us by email at team@passexam.mom or by mail to our registered office address. We may need to verify your identity before processing your request, which may require you to provide additional information. We will respond to your request within the timeframes established by applicable law, typically within thirty (30) calendar days. If we require an extension, we will notify you of the reason for the delay within the initial response period. We do not charge a fee for exercising your data protection rights unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable fee based on administrative costs or we may refuse to act on the request.

12. Third-Party Links and Services

Our website may contain hyperlinks to third-party websites, plugins, applications, and online services that are not owned, operated, or controlled by PassExam Trading Co., Ltd. These links are provided for your convenience and informational purposes only. When you click on a third-party link, you will be directed to that third partys website or service, which operates under its own privacy policy and terms of use. We encourage you to review the privacy policy of every website and service you visit.

We do not endorse, control, or assume any responsibility for the content, privacy practices, security measures, or data handling policies of any third-party site or service. This Privacy Policy applies exclusively to information collected by PassExam through our website and services. It does not apply to information collected by any third party, even if you access that third partys site by clicking a link from our website. We are not liable for any loss or damage arising from your use of linked third-party sites or your reliance on the privacy policies or practices of those sites. If you have concerns about a third-party website linked from our pages, we recommend that you contact the site operator directly.

Additionally, our website may include embedded content, social media features, and interactive widgets hosted by third-party platforms such as video hosting services, map services, and social networking platforms. These features may collect your IP address, track which page you are visiting, and set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing them.

13. Changes to This Privacy Policy

PassExam reserves the right to update, modify, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, to incorporate new legal or regulatory requirements, to address changes in the services we offer, or for other operational, legal, or business reasons. When we make changes, we will post the revised policy on this page and update the Effective Date at the top of the policy to indicate when the changes become effective.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your data. If we make material changes that significantly affect your rights or the way we process your personal data, we will provide a more prominent notice, which may include sending an email notification to registered users who have provided us with their email address and for whom we have ongoing business communications. We may also display a notice on our website homepage for a reasonable period. Continued use of our website or services after the effective date of any revised policy constitutes your acknowledgment and acceptance of the updated terms, to the extent permitted by applicable law. If you do not agree with the revised policy, you should discontinue use of the PassExam website and services and, where applicable, request deletion of your data.

14. Contact Information

If you have any questions, comments, concerns, or complaints about this Privacy Policy, our data processing practices, or your rights regarding your personal data, or if you wish to exercise any of the rights described in the Your Rights and Choices section above, please do not hesitate to contact us. We have appointed a data protection contact who is responsible for overseeing questions and handling requests related to this Privacy Policy.

You may reach PassExam through any of the following channels:

Email: team@passexam.mom
Phone: +15092868650
Website: https://www.passexam.mom
Registered Office Address:
PassExam Trading Co., Ltd.
114-3, Building 4, Helonglong Resettlement Area Phase I
Hetang Xincun Community, Wuli Street
Lianxi District, Jiujiang 332000
China

We are committed to resolving any concerns you may have about our handling of your personal data. We will acknowledge receipt of your inquiry within five (5) business days and will make every effort to address and resolve your concern promptly and satisfactorily. If you are not satisfied with our response, you have the right to escalate your concern to the data protection supervisory authority in your jurisdiction as described in the Your Rights and Choices section.