Privacy Policy

1. Information we may collect

The information collected depends on how you use PassCLLT.

Purchase and Full Access information

When Full Access is purchased or restored, PassCLLT may process and store information such as:

• purchase or access reference;
• email address and name associated with the verified purchase, where provided;
• purchase date and time;
• access expiry date and access status;
• information required to restore legitimate access;
• a device identifier used to apply the permitted device limit;
• device slot, first-seen and last-seen information; and
• browser or device user-agent information where required for access administration and troubleshooting.

These records are used to verify purchases, provide access, support Restore Access, enforce the applicable device limit, prevent misuse and provide customer support.

Payment information

Payments on the PassCLLT website are processed through Paystack. PassCLLT does not require users to provide full payment-card details directly to PassCLLT. Payment information is processed through the payment provider. PassCLLT may receive and retain information necessary to verify a transaction and activate access, including transaction references, payment status and customer information returned as part of the payment-verification process.

The Google Play version of PassCLLT may use Google Play payment services where required by Google Play policy. This policy will be updated before public Android release if the final Android payment implementation changes the information processed.

2. Email and communication information

PassCLLT may collect an email address when it is required or voluntarily provided for purposes such as:

• sending a purchase confirmation or access reference;
• helping a customer restore access;
• responding to support requests;
• sending a requested test result; or
• sending marketing communications where the user has expressly opted in.

Transactional messages required to provide a requested service do not depend on marketing consent. Marketing communications are optional.

Where WhatsApp marketing is offered, a WhatsApp number is collected only when the user chooses that option and provides the required consent. Users may withdraw marketing consent at any time by contacting PassCLLT.

3. Test-result email information

If a learner chooses to have a test or preview result emailed, PassCLLT may temporarily store:

• email address;
• selected vehicle category;
• result and percentage;
• section scores;
• date and time of the request;
• source of the request; and
• the relevant consent record.

Transactional result-request records are scheduled for deletion after approximately 90 days, unless retention is reasonably required for a legal, security or dispute-related reason.

Test results remain available on screen regardless of whether the learner chooses to provide an email address where this functionality applies.

4. Usage analytics

PassCLLT uses privacy-minimised analytics to understand how the service is used, improve the learning experience and measure the effectiveness of marketing campaigns.

Analytics may include information such as:

• the hour of an event;
• type of action or event;
• free or Full Access tier;
• selected vehicle category;
• learning or test type;
• pass/fail result;
• percentage or section scores;
• traffic-source and campaign tags;
• landing path and attribution method; and
• aggregated purchase or revenue indicators used for business reporting.

The current analytics system is designed not to include names, email addresses, payment references, Restore Access references, persistent visitor identifiers, session identifiers or device fingerprinting.

Raw analytics records are currently retained for approximately 180 days and may then be removed or retained only in aggregated reporting where individual identification is not intended.

Paystack and the PassCLLT access register remain the authoritative records for purchases and customer access. Analytics data is used for directional product and marketing reporting and is not treated as the financial source of truth.

5. Local device storage

PassCLLT may use browser or device storage, including local storage and session storage, to support app functionality. This may include information needed to remember or resume:

• selected vehicle;
• learning progress;
• test progress and answers;
• paid-access state;
• a stable device identifier used for access/device-limit administration;
• campaign attribution for the current browser/session where applicable;
• language selection where applicable; and
• other preferences required for the app to function correctly.

Some of this information may remain on the user's device until it expires, is overwritten, the browser or app data is cleared, or the application is removed.

6. Why we use information

PassCLLT processes information only where reasonably necessary to:

• provide the learning service;
• verify purchases and activate Full Access;
• restore legitimate access;
• enforce access and device rules;
• send requested transactional emails;
• provide customer support;
• maintain security and prevent misuse;
• understand and improve app performance and usage;
• measure marketing effectiveness;
• communicate with users who have opted into marketing; and
• comply with applicable legal, tax, accounting and regulatory requirements.

7. Third-party service providers

PassCLLT uses third-party services where reasonably necessary to operate the service.

Paystack

Used for payment processing and transaction verification for purchases made through the PassCLLT website.

Google services

PassCLLT uses Google services for certain operational functions, which may include Google Workspace, Google Apps Script, controlled business records, Google Play services and other Google tools introduced as part of Android distribution.

Netlify

Used to host and deliver the PassCLLT website and web application.

Third-party providers process information according to their own terms and privacy practices as well as the instructions and configuration used by PassCLLT.

The final Google Play Android architecture and any additional Android SDKs will be reviewed before public release. This Privacy Policy and the Google Play Data Safety declaration will be updated where required so that they accurately reflect the released Android version.

8. Information sharing

PassCLLT does not sell personal information.

Information may be shared only where reasonably necessary:

• with service providers that help operate PassCLLT;
• to process or verify a payment;
• to deliver a requested service;
• to protect PassCLLT, its users or its systems;
• to investigate suspected fraud, misuse or security incidents;
• where required by law, regulation, court order or a competent authority; or
• where the user has provided appropriate consent.

9. Data security

PassCLLT uses reasonable technical and organisational safeguards appropriate to the information being processed. These measures include limiting access to private operational records, keeping sensitive service credentials out of the public application, using secure HTTPS connections for online services and restricting the information collected to what is reasonably needed for the relevant purpose.

No internet-based service can guarantee absolute security. PassCLLT will respond to suspected security incidents in accordance with applicable legal obligations.

10. Data retention

PassCLLT does not intend to keep personal information indefinitely. Different records are kept for different periods depending on their purpose.

• transactional test-result email requests are normally deleted after approximately 90 days;
• raw privacy-minimised analytics records are currently retained for approximately 180 days;
• marketing contact information may be retained while consent remains active and may be removed or suppressed when consent is withdrawn;
• purchase, payment-verification, access, device and Restore Access records may be retained for as long as reasonably required to provide the purchased entitlement, support legitimate restores, resolve disputes, prevent misuse and meet legal, tax or accounting obligations.

Where information is no longer reasonably required, PassCLLT may delete, anonymise or securely archive it as appropriate.

11. Access, correction and deletion requests

Users may contact PassCLLT to request access to, correction of, or deletion of personal information held about them, subject to applicable legal requirements and legitimate record-retention obligations.

PassCLLT may need to verify the identity of the person making the request before releasing, changing or deleting information.

A deletion request does not necessarily require PassCLLT to delete records that must lawfully be retained, for example records required for transaction, tax, fraud-prevention, legal or dispute-resolution purposes.

To make a privacy request, email hello@passcllt.co.za.

12. Marketing choices

Marketing is optional. Where PassCLLT asks for consent to receive email or WhatsApp marketing, the learner or customer may decline without losing access to functionality that does not require marketing consent.

Marketing consent may be withdrawn at any time by contacting PassCLLT or using any unsubscribe method provided in the communication.

13. Children and younger learners

PassCLLT is a learner's licence preparation service intended for learner drivers, including older teenagers and adults. PassCLLT is not designed as an app specifically for young children.

Where a learner is under 18, a parent or legal guardian should complete purchases and provide contact or marketing consent where required by the PassCLLT journey. A learner can view an eligible free test result on screen without submitting contact details.

14. No government affiliation

PassCLLT is an independent learner's licence preparation product. It is not a government department, licensing authority or official government application, and it is not represented as being produced or endorsed by the South African government.

15. Changes to this Privacy Policy

PassCLLT may update this Privacy Policy when the service, technology, legal requirements or third-party services change. The current version will be published on the PassCLLT website with its effective or last-updated date.

Material changes affecting how personal information is handled will be reflected in the policy before or when the relevant functionality is released.