1. Introduction
Pocket Labs Pty Ltd (ABN 93695191621, ACN 695191621, "Pocket", "we", "us", or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our wallet pass membership management platform and services.
This policy complies with the Australian Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), and the European Union's General Data Protection Regulation (GDPR) where applicable.
2. Information We Collect
2.1 Information You Provide
We collect information you provide directly to us:
- Account Information: Name, email address, business name, phone number, billing address
- Payment Information: Credit card details, billing information (processed securely through Stripe)
- Business Information: Company details, industry type, location information
- Customer Data: Information about your members/customers that you upload to our platform
- Communications: Messages, feedback, and support requests you send us
2.2 Automatically Collected Information
When you use our services, we automatically collect:
- Usage Data: Pages viewed, features used, actions taken, time spent on platform
- Device Information: IP address, browser type, operating system, device identifiers
- Wallet Pass Data: Installation status, pass updates, notification delivery status
- Location Data: Approximate location based on IP address (for geo-push features if enabled)
2.3 Information from Third Parties
- Authentication providers (Google, Microsoft) if you use social login
- Payment processors (Stripe) for transaction verification
- Integration partners (Lightspeed, Shopify, etc.) with your authorization
3. How We Use Your Information
We use collected information for:
- Service Delivery: Provide, maintain, and improve our platform
- Wallet Pass Management: Generate, update, and deliver wallet passes to end users
- Communications: Send service updates, notifications, and marketing (with consent)
- Payment Processing: Process subscriptions and handle billing
- Analytics: Understand usage patterns and improve our services
- Security: Detect fraud, prevent abuse, and protect user accounts
- Legal Compliance: Meet legal obligations and enforce our terms
- Support: Respond to inquiries and provide customer support
4. Information Sharing and Disclosure
We share your information only in the following circumstances:
4.1 Service Providers
- Supabase: Database and authentication infrastructure
- Stripe: Payment processing
- Apple & Google: Wallet pass delivery infrastructure
- Email providers: Transactional and marketing email delivery
- Analytics services: Usage analytics and performance monitoring
4.2 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred. We will provide notice before your information is transferred and becomes subject to a different privacy policy.
4.3 Legal Requirements
We may disclose your information if required by law, court order, or government request, or to protect our rights, property, or safety.
4.4 With Your Consent
We may share your information with third parties when you explicitly consent to such sharing.
5. Data Security
We implement industry-standard security measures to protect your information:
- Encryption in transit (TLS/SSL) and at rest
- Regular security audits and monitoring
- Access controls and authentication requirements
- Secure data centers with physical security measures
- Employee training on data protection
However, no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.
6. Data Retention
We retain your information for as long as your account is active or as needed to provide services. We will also retain and use your information as necessary to comply with legal obligations, resolve disputes, and enforce agreements.
When you delete your account, we will delete or anonymize your personal information within 90 days, except where retention is required by law.
7. Your Rights
7.1 Australian Users (Privacy Act 1988)
Under the Australian Privacy Act, you have the right to:
- Access your personal information we hold
- Correct inaccurate or incomplete information
- Request deletion of your information (subject to legal requirements)
- Opt-out of marketing communications
- Complain to the Office of the Australian Information Commissioner (OAIC)
7.2 European Users (GDPR)
Under GDPR, you have additional rights:
- Right to data portability
- Right to restrict processing
- Right to object to processing
- Right to withdraw consent
- Right to lodge a complaint with a supervisory authority
7.3 Exercising Your Rights
To exercise any of these rights, contact us at privacy@getpocketpass.com. We will respond within 30 days.
8. International Data Transfers
Your information may be transferred to and processed in countries other than Australia, including the United States and European Union. We ensure appropriate safeguards are in place, including:
- Standard contractual clauses approved by relevant authorities
- Adequacy decisions by the European Commission
- Binding corporate rules where applicable
9. Children's Privacy
Our services are not directed to individuals under 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.
10. Cookies and Tracking
We use cookies and similar tracking technologies. For detailed information, see our Cookie Usage Policy.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by email or through our platform. Your continued use of our services after changes constitutes acceptance of the updated policy.
12. Contact Us
If you have questions about this Privacy Policy or our data practices:
Pocket Labs Pty Ltd
ABN: 93695191621
ACN: 695191621
Address: 1/84 View St, Gymea, Sydney, NSW 2227, Australia
Email: privacy@getpocketpass.com
Support: hello@getpocketpass.com
OAIC Complaints: If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au