First Pass Privacy Policy
This policy explains how FIRST PASS PTY LTD, trading as FIRST PASS, collects, uses, stores, and discloses personal information through the First Pass website and platform for learners, instructors, bookings, payments, support, and compliance management.
1. What We Collect
Depending on how you use First Pass, we may collect:
- account and identity information such as name, preferred name, email address, phone number, gender, date of birth, login details, password reset records, and account-security records
- booking and service information such as lesson type, transmission type, pickup location, suburb, appointment history, instructor selection, calendar information, and notes provided through the website
- payment and transaction information relating to purchases, Stripe payment intent references, payment responses, booking records, refunds, disputes, chargebacks, and platform wallet, ledger, settlement, commission, payout, or earnings records where used by the website
- organisation-funded support information such as funding organisation details, authorised contacts, ABN, learner details supplied by an organisation, participant or client references, purchase-order references, funding source, funded allocation, consent, attendance, service usage, remaining support, evidence-link access, and driving test outcome consent
- instructor profile, payout, and compliance information such as public profile details, vehicle details, service regions, accreditation information, connected payment account status, driving licence records, instructor licence records, WWCC information, uploaded compliance documents, document review outcomes, and expiry dates
- review, rating, notification, and support information generated through the platform
- contact, support, and application information, including contact enquiries, instructor applications, messages you send to us, support notifications, submitter confirmations, and any anti-spam, email, phone, or verification records used to protect the platform
- technical and website usage information such as IP address, browser type, cookies, device information, and general usage data
2. How We Collect Information
- directly from you when you register, apply to instruct, search, book, pay, contact us, request a password reset, upload documents, update your profile, or otherwise use the website
- from your interaction with the platform, including dashboard use, bookings, cancellations, rescheduling, reviews, and notification activity
- from instructors, learners, funding organisations and their authorised contacts, payment providers, connected account providers, vehicle lookup or compliance providers, notification providers, service providers, and support interactions where needed to operate the platform
3. How We Use Information
We may use personal information to:
- create and manage learner and instructor accounts
- display instructor profiles, support instructor search and filters, and facilitate lesson or driving test package bookings
- process Stripe checkout, payment confirmations, refunds, payment webhooks, booking records, settlement records, admin commission records, wallet or earnings records, connected-account or payout records, and other platform transaction records
- manage cancellations, rescheduling, switch-instructor requests, no show records, completion records, payment-waived records, refund records, notifications, and support activity
- receive and administer organisation funding requests, verify payment, invite learners, record consent, allocate and track funded credits, provide funded services, and generate secure evidence statements
- verify instructor identity, vehicle, connected payment account, and compliance information and manage uploaded documents
- communicate with users about bookings, changes, reminders, password resets, support matters, instructor applications, service updates, and compliance issues
- detect, investigate, and reduce fraud, duplicate bookings, payment errors, chargebacks, unauthorised account access, and platform misuse
- improve the website, protect the platform, and comply with legal obligations
4. Disclosure of Information
We may disclose personal information to:
- learners and instructors where needed to facilitate bookings, lesson delivery, and related service coordination
- a funding organisation and its authorised contact, but only for the funded service and only to the extent permitted by the learner's consent or otherwise required or permitted by law
- Stripe and other payment or connected-account providers that support checkout, payment confirmation, refunds, disputes, instructor payout setup, payout status, and platform financial operations
- vehicle lookup, document review, identity, compliance, or verification providers where used to support instructor onboarding, vehicle records, compliance checks, or platform safety
- technology, hosting, email, SMS, storage, notification, and support providers acting on our behalf
- regulators, courts, law enforcement, insurers, or professional advisers where required or permitted by law
We do not sell personal information as part of the ordinary operation of the site.
5. Storage and Security
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. However, no internet-based service can guarantee absolute security.
Payment details may be handled through third-party payment providers rather than stored directly by FIRST PASS PTY LTD in full card form. We may store payment references, status records, refund records, ledger records, payout records, and reconciliation records needed to operate the platform. Uploaded instructor documents and related compliance records may be stored and reviewed as part of instructor verification, administration, reporting, and support.
If we suspect a data breach, we may take steps to contain it, investigate what happened, assess the risk of harm, and improve our controls. We will notify affected individuals, the Office of the Australian Information Commissioner, or another authority where notification is required by applicable law.
6. Cookies and Website Analytics
We may use cookies and similar technologies to remember preferences, improve site performance, understand usage patterns, support login or session functionality, protect checkout and account flows, and keep booking or cart details available while you move through the website. You can manage cookies through your browser settings, although some site functions may not work properly if cookies are disabled.
7. Access and Correction
You may request access to personal information we hold about you, or request correction of inaccurate information, by contacting us. We may need to verify your identity before responding. You can also update some account information directly through your First Pass dashboard.
8. Service Messages and Marketing Choices
We may send operational messages needed to administer an account or booking, including payment confirmations, booking changes, reminders, security notices, compliance notices, and support responses. Where we send optional promotional email or SMS communications, you may use the unsubscribe facility provided or contact us to opt out. Opting out of promotional communications does not prevent essential service messages connected with an active account, transaction, booking, safety matter, or legal obligation.
9. Retention
We keep personal information for as long as reasonably necessary for platform operation, booking management, payment reconciliation, instructor settlement, refund handling, support, compliance, legal, record-keeping, audit, tax, fraud prevention, and dispute-management purposes, unless a longer retention period is required or permitted by law.
10. Overseas Providers
First Pass is an Australian platform for Australian learners and instructors. Some providers that support First Pass, including payment, hosting, email, SMS, analytics, support, or compliance providers, may store or process information outside Australia, including in Australia and the United States. A provider may also process information in another country where its infrastructure, personnel, or subcontractors operate. The countries involved may change when our providers change. Where practicable, you may contact First Pass for current information about the countries relevant to a particular provider. Where overseas processing occurs, we take reasonable steps to use providers that handle information consistently with applicable privacy and security obligations.
11. Questions and Complaints
If you have a question or complaint about privacy, please contact support@firstpass.com.au first so we can investigate. Please describe the concern and provide enough information for us to identify the relevant account or interaction. We may verify your identity, acknowledge the complaint, investigate relevant records and providers, and provide an outcome or progress update within a reasonable time. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.