Privacy Policy

Pocket Labs Pty Ltd (ABN 93 695 191 621, ACN 695 191 621, "PocketPass", "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 player 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.

2.1 Information You Provide

• Account information: name, email address, business name, phone number, billing address
• Payment information: billing details (processed securely through our payment provider)
• Business information: company details, industry type, location
• Customer data: information about your players/customers that you upload or sync
• Communications: messages, feedback, and support requests you send us

2.2 Automatically Collected Information

• Usage data: pages viewed, features used, actions taken, time 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 (for geo-push features if enabled)

2.3 Information from Third Parties

• Authentication providers if you use social login
• Payment processors for transaction verification
• Integration partners (Lightspeed, etc.) with your authorization

• 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 accounts
• Legal compliance: meet legal obligations and enforce our terms
• Support: respond to inquiries and provide customer support

4.1 Service Providers

• Supabase: database and authentication infrastructure
• Apple & Google: wallet pass delivery infrastructure
• Lightspeed: the integration you connect
• Email and hosting providers (AWS): transactional email and hosting

4.2 Business Transfers

In a merger, acquisition, or sale of assets, your information may be transferred. We will provide notice before it 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.

• Encryption in transit (TLS/SSL) and at rest
• Regular security monitoring
• Access controls and authentication requirements
• Least-privilege service credentials

No method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

We retain your information for as long as your account is active or as needed to provide services and comply with legal obligations. When you delete your account, we delete or anonymize your personal information within 90 days, except where retention is required by law.

7.1 Australian Users (Privacy Act 1988)

• Access the personal information we hold about you
• Correct inaccurate or incomplete information
• Request deletion (subject to legal requirements)
• Opt out of marketing communications
• Complain to the Office of the Australian Information Commissioner (OAIC)

7.2 European Users (GDPR)

• 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 these rights, contact us at privacy@getpocketpass.com. We will respond within 30 days.

Your information may be processed in countries other than Australia. We ensure appropriate safeguards are in place, including standard contractual clauses and adequacy decisions where applicable.

Our services are not directed to individuals under 18, and we do not knowingly collect their personal information. If you believe we have, contact us immediately.

We may update this Privacy Policy from time to time and will notify you of material changes. Continued use after changes constitutes acceptance.

OAIC complaints: if you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner at oaic.gov.au.

See also our Terms and Conditions.