PASSFAN Privacy Policy

Full PASSFAN Privacy Policy

Operator: PASSFAN HUB LTD Company number: 17438949 Registered office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ Privacy contact: privacy@passfanhub.co.uk Support contact: support@passfanhub.co.uk Effective date: 8 September 2026

This policy explains how PASSFAN HUB LTD ("PASSFAN", "we", "us" or "our") uses personal information in PASSFAN and PASSFAN Hub. It applies to our Instructor service, Learner service, websites and associated support services.

Our guiding principle is: your data is yours. We use customer data to provide, secure, maintain and support PASSFAN, to meet legal obligations and for the other limited purposes described here. We do not use customer data for unrelated purposes, advertising or cross-company tracking.

1. Who is responsible for personal information?

Responsibility depends on the information and why it is used.

• PASSFAN operates account, authentication, security, platform communication and service administration systems.
• Instructors enter and manage pupil, teaching and business records within their own account. These include contact details, lessons, progress, homework, messages and payment records.
• Learners access records shared through their linked account and provide their own account, messaging and learning information.

This describes the way the service currently operates. The legal role can depend on the information and purpose: an Instructor is responsible for the pupil and teaching records they choose to enter, while PASSFAN is responsible for its own account, security and platform administration. Learners can contact their Instructor about pupil records or PASSFAN using privacy@passfanhub.co.uk.

2. Information we process

Depending on the features used, we may process:

Instructor and business information

• name, business name, email address, telephone number, postal address and other contact details;
• Firebase user ID, Instructor ID, tenant ID and PASSFAN account or reference number;
• account, subscription, plan, cancellation and deletion status;
• trusted-device identifiers, trusted-session and device-verification records, authentication events and security logs;
• push-notification tokens and notification preferences;
• learner and waiting-list records entered or managed by the Instructor;
• lessons, lesson summaries, progress, homework, resources, reflections and messages;
• income, expenses, mileage, accounting periods, payments, credits and related business records;
• receipts and receipt images, vehicle details, business logo and branding files;
• account export archives, internal service backup archives, and records of secure export generation, download or redemption;
• diagnostic information, error information and limited usage or app-open events needed to operate and improve reliability.

Learner information

• name, email address, telephone number where applicable and profile or contact details;
• Firebase user ID and the link between that ID and the Instructor's pupil record;
• lesson details, summaries, progress, homework, learning activity, resources and reflections;
• messages and notification preferences or state;
• invitation, onboarding, email-verification and terms-acceptance records;
• authentication, security, diagnostic and limited app-open information.

Information from devices and services

We may receive device and app identifiers, operating-system and app-version information, push tokens, App Check or App Attest integrity signals, IP address and technical request logs. We do not use these for advertising or cross-company tracking.

PASSFAN does not intentionally collect precise background location. If a user chooses an external map or directions link, the external provider may process location or destination information under its own policy.

3. How information is obtained

Information may be supplied by an Instructor or Learner, created through use of PASSFAN, generated by security and authentication systems, or received from service providers used to deliver PASSFAN. An Instructor may provide a Learner's information when creating a pupil record or invitation.

4. Why we process information and our legal bases

We use personal information only where there is an applicable legal basis. Which basis applies depends on the information and purpose and may include:

• contract: to create and operate an account, provide subscribed features, deliver requested communications, exports and support, and administer cancellation;
• legitimate interests: to secure PASSFAN, prevent misuse, maintain service reliability, diagnose faults, improve existing features, keep proportionate audit records and manage our business, balanced against users' rights;
• legal obligation: for tax, accounting, company, consumer, data-protection, law-enforcement or other legal duties;
• consent: where the law requires consent, for example for optional device permissions or communications. Consent may be withdrawn, although this does not affect earlier lawful processing;
• vital interests or legal claims: in exceptional circumstances where necessary to protect a person or establish, exercise or defend legal claims.

Where PASSFAN acts as a processor for an Instructor, we process learner records on that Instructor's documented instructions, subject to legal obligations.

We do not currently use personal information for automated decisions that produce legal or similarly significant effects.

5. Who can see information?

Instructors can see the learner and business records available within their own tenant. Learners can see information made available through their own linked pupil account. Role, tenant and pupil-ownership controls are designed to prevent access to another customer's records.

Normal PASSFAN platform administration does not provide unrestricted browsing of an Instructor's learner or financial records. PASSFAN systems and authorised backend services process data where required to deliver, secure and maintain the service. Privileged infrastructure access is technically possible where operationally or legally required, including security investigation, support, recovery, legal compliance and incident response. Such access must be limited to authorised people and purposes.

We may disclose information where required by law, court order or a competent authority, or where reasonably necessary to protect rights, safety and security.

6. Service providers and external services

We use trusted service providers (sometimes called subprocessors) to help us operate PASSFAN. Our service providers describes the categories used for current production services. It is versioned separately so provider changes can be recorded without duplicating the list here.

Providers process information for the relevant service under their applicable contractual, privacy and security arrangements. Depending on the service, a provider may process information on our behalf or for its own independent purposes.

Receipt processing and AI-assisted features

Receipt preparation such as cropping and resizing occurs in the app. When receipt text extraction is requested, the receipt image is sent through our backend to an external OCR service; OCR is not performed solely on your device. Extracted fields can include supplier, invoice number, date, amounts and payment method.

OCR diagnostics record processing status and limited operational metadata. They are designed not to include the receipt image, raw receipt text or extracted receipt contents.

AI-assisted features may process selected content through an external service only where that feature is enabled and used. Production activation of the currently developed lesson-assistance integration has not been established, so users should not assume that ordinary lesson notes are routinely sent to an AI provider. Any production activation requires the processing record and public information to be reviewed and updated.

7. International transfers

The location of a PASSFAN backend Function does not establish where every provider processes information. Details of applicable processing locations and transfer arrangements can be requested from privacy@passfanhub.co.uk. No particular transfer mechanism is asserted by this technical description.

8. Security

PASSFAN uses proportionate technical and organisational safeguards. These include Firebase Authentication, App Check and native App Attest where applicable, trusted-device and session protection for Instructor accounts, role and ownership controls, encrypted network transport, restricted backend access and security or audit controls.

No online service can guarantee absolute security. Users must protect passwords and devices and tell us promptly if they suspect unauthorised access.

9. Retention, subscription cancellation and record keeping

We keep personal information while it is needed to provide, secure and administer the service. Some records may be retained where reasonably needed for accounting, tax, legal, security, fraud-prevention, dispute or audit purposes.

Account cancellation and account deletion are different processes. Supported account-closure workflows include an export period and staged cleanup. Timing can depend on the account state, incomplete exports, retryable failures and a recorded hold. We do not promise that all data is erased immediately or within a single fixed period.

Financial records and linked receipts may be retained where needed for tax, accounting, legal or audit purposes. Backup copies may remain for a limited operational period where technically necessary and are not promised to disappear immediately. We delete or anonymise information when it is no longer reasonably required, subject to those obligations and technical constraints. Keep your own copies of records you need.

Service storage is not a statutory record-keeping guarantee. Instructors remain responsible for keeping tax and business records for the period required by HMRC and other authorities. PASSFAN is not the customer's permanent statutory archive.

Security, transaction, accounting, complaint and legal-claim records may be retained for a proportionate period where required by law or reasonably necessary. Retained data will be restricted to the relevant purpose and deleted or anonymised when that purpose ends.

10. Cancellation and Delete account are different

Cancelling a subscription normally takes effect at the end of the paid period and does not itself request immediate account deletion.

Delete account is a deliberate, separate and potentially irreversible process. It requires confirmation and reauthentication. Access is restricted during deletion. Deletion and export preparation may happen asynchronously. Account and associated data will be deleted or anonymised where PASSFAN has no lawful reason to retain it. Once irreversible purge begins, the account cannot normally be restored.

Deleting a Learner account removes the Learner's sign-in, learner-owned profile, preferences, notifications and learner-owned activity, and removes the learner account link from the Instructor's pupil record. It does not automatically delete Instructor-owned lesson, payment or business records where the Instructor has an independent lawful purpose for them. Such records should be minimised where appropriate.

11. Your rights

Subject to applicable law and exemptions, individuals may have rights to:

• be informed about processing;
• access personal information;
• correct inaccurate or incomplete information;
• request deletion;
• restrict processing;
• object to processing based on legitimate interests;
• receive or transfer certain information in a portable form;
• withdraw consent where processing relies on consent;
• complain to the Information Commissioner's Office (ICO).

Rights do not apply identically to every purpose. For example, deletion may not apply where information must be retained by law or for legal claims. We may need to verify identity. Contact privacy@passfanhub.co.uk. The ICO can be contacted through ico.org.uk.

12. Children and young Learners

PASSFAN Learner may be used by people under 18. Instructors may store learner contact, lesson, progress, homework and message information. The Instructor is responsible for the pupil and teaching records they choose to create. PASSFAN provides the platform and processes account and platform information to provide and protect the Learner service.

A young Learner may ask what information is held, request correction, or ask for deletion. Depending on age, understanding and circumstances, a parent or person with parental responsibility may be able to act on the Learner's behalf. We will consider the Learner's rights and best interests when responding.

See the Learner-friendly privacy summary at the beginning of this Privacy Policy for a shorter explanation.

13. Notifications and permissions

Push notifications are optional. Device permission can be refused or changed in device settings. If notifications are enabled, Apple and Firebase process device tokens and delivery information. Camera or photo access is used only when the user chooses a feature such as capturing or selecting a receipt or image.

14. Cookies and local storage

PASSFAN uses browser or app storage required for authentication, trusted-session security, preferences and operation. Any non-essential analytics or similar technology must not be enabled without an appropriate legal basis and notice. The application source does not enable advertising analytics. Some learning resources use embedded YouTube players, and selected map or external resource links contact their providers. These services can receive technical request information; see the service-provider information.

15. Changes to this policy

We may update this policy when the service, providers or law changes. Material changes will be identified by a new version or effective date and, where required, notified or presented for renewed acceptance.

16. Contact and complaints

Contact PASSFAN HUB LTD at privacy@passfanhub.co.uk or 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ. You may also complain to the ICO. We would appreciate the opportunity to address the issue first, but this does not affect the right to contact the ICO.