Privacy Policy

Modified on Thu, 31 Oct, 2024 at 12:59 PM

Platform Privacy Policy



1. Introduction


1.1. This Privacy Policy outlines how Learner Pass Pty Ltd ("LearnerPass", "we", "our", or "us") collects, uses, discloses, and manages personal information.


1.2. We are committed to protecting your privacy and handling your personal information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) ("Privacy Act").


1.3. This policy applies to all personal information collected by LearnerPass through:


1.3.1. Our website at LearnerPass.com.au

1.3.2. Any other digital platforms or services we operate



2. Personal Information We Collect


2.1. We collect personal information that is reasonably necessary for our business functions and activities. This may include:


2.2. For Learner Drivers:


2.2.1. Full name

2.2.2. Date of birth

2.2.3. Gender

2.2.4. Contact details (phone number, email address, residential address)

2.2.5. Emergency contact details

2.2.6. Driver's licence details

2.2.7. Payment information

2.2.8. Driving lesson history and progress


2.3. For Driving Instructors:


2.3.1. Full name

2.3.2. Date of birth

2.3.3. Contact details

2.3.4. Driver's licence and instructor accreditation details

2.3.5. Police clearance information

2.3.6. Working with Children Check information

2.3.7. Vehicle details

2.3.8. Banking and payment information

2.3.9. Lesson history and student feedback


2.4. For all users:


2.4.1. Information provided through customer support channels

2.4.2. Device information (IP address, browser type, operating system)

2.4.3. Usage data and analytics

2.4.4. Apple account information (for users who choose to sign in with Apple)

2.5.5. Apple Calendar data (for instructors who connect their Apple Calendar) 

2.6.6. Google account information (for users who choose to sign in with Google) 

2.7.7. Google Calendar data (for instructors who connect their Google Calendar)



3. How We Collect Personal Information


3.1. We collect personal information through:


3.1.1. Direct interactions with our website, app, or customer service

3.1.2. Automated technologies such as cookies and tracking pixels

3.1.3. Third-party sources, including Google and Apple platforms and credit reporting agencies 


3.2. We will only collect personal information by lawful and fair means.



4. Purpose of Collection and Use


4.1. We collect and use personal information for purposes including:


4.1.1. Providing and improving our services

4.1.2. Processing payments and maintaining accounts

4.1.3. Communicating with users about our services

4.1.4. Conducting marketing and promotional activities

4.1.5. Complying with legal and regulatory obligations

4.1.6. Resolving disputes and troubleshooting problems

4.1.7. Authenticating users and managing account connections

4.1.8. Syncing and managing calendar data for scheduling purposes


4.2. We will not use your personal information for purposes other than those for which it was collected, unless:


4.2.1. You have consented to the additional use

4.2.2. The additional use is directly related to the original purpose

4.2.3. The use is required or authorised by law



5. Disclosure of Personal Information


5.1. We may disclose personal information to:


5.1.1. Driving instructors (for learner drivers' information)

5.1.2. Learner drivers (for driving instructors' information)

5.1.3. Service providers assisting with our business operations

5.1.4. Payment processors and financial institutions

5.1.5. Government agencies and regulatory bodies as required by law


5.2. We will take reasonable steps to ensure that third parties who receive personal information from us protect it in a manner consistent with this policy.


5.3. We do not sell personal information to third parties for marketing purposes.



6. Overseas Disclosure


6.1. We may disclose personal information to overseas recipients in the course of our business operations and payment verifications.


6.2. We will take reasonable steps to ensure that overseas recipients handle personal information in accordance with the APPs.



7. Data Security


7.1. We implement reasonable security measures to protect personal information from:


7.1.1. Misuse, interference, and loss

7.1.2. Unauthorised access, modification, or disclosure


7.2. Our security measures include:


7.2.1. Encryption of data in transit and at rest

7.2.2. Regular security audits and penetration testing

7.2.3. Access controls and authentication procedures

7.2.4. Staff training on data protection and privacy


7.3. No data transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.



8. Access and Correction


8.1. You have the right to access and correct your personal information held by us.


8.2. To request access or correction:


8.2.1. Log into your account and update your information directly

8.2.2. Contact our team using the details provided in Section 12


8.3. We will respond to access and correction requests within a reasonable timeframe.


8.4. If we refuse an access or correction request, we will provide written reasons for the refusal and information about how you can complain about the refusal.



9. Retention and Disposal


9.1. We will retain personal information only for as long as it is required for our business purposes or as required by law.


9.2. When personal information is no longer needed, we will take reasonable steps to destroy or de-identify it securely.



10. Cookies and Analytics


10.1. We use cookies and similar technologies to:


10.1.1. Improve user experience

10.1.2. Analyse website and app usage

10.1.3. Personalise content and advertisements


10.2. You can manage cookie preferences through your browser settings.


10.3. We use third-party analytics services, which may collect information about your use of our digital platforms.



11. Google API Services


11.1. We use Apple and Google Sign-In and Calendar APIs to provide authentication and scheduling services for our users.


11.2. The information we receive from these APIs is used solely for the following purposes:


11.2.1. To authenticate users and create or link their LearnerPass accounts

11.2.2. To display and manage booking availability for driving instructors

11.2.3. To schedule and manage driving lessons    


11.3. We do not use Apple or Google user data for any advertising purposes.


11.4. We do not sell or share Apple or Google user data with third parties, except as necessary to provide and improve our services, comply with applicable laws, or as otherwise specified in this privacy policy.


11.5. We do not allow anyone to read Apple and Google user data unless:


11.5.1. We have obtained the user's express and written authorisation

11.5.2. Ut us necessary for security purposes or to comply with applicable laws

11.5.3. Our use is limited to internal operations and the data has been aggregated and anonymised


11.6. LearnerPass's use and transfer to any other app or information received from Google or Apple APIs will adhere to the Apple and Google API Services User Data Policies, including the Limited use requirements.



12. Contact Us


12.1. If you have any questions, concerns, or complaints about this Privacy Policy or our handling of your personal information, please contact us through our Support Centre.


12.2. We will acknowledge and investigate any complaint promptly and will respond to you in writing within a reasonable time.


12.3. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.


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