This is a draft and is not yet in force.

WheelPass privacy policy

Last updated: [date]

In short: we collect what we need to connect learners with instructors, book and record lessons, and keep people safe. We do not sell your data. We do not show learners an instructor's home postcode, or instructors a learner's full address before they approve a lesson. You can download your data or delete your account in the app at any time.

[A shorter version for 16 and 17 year olds is at the end.]

1. Who we are

[Business name], [company number], [address] is the controller of your personal data. We are registered with the ICO: [registration number]. Contact: [privacy email].

2. What we collect, and why

What Why Our legal reason
Your name, email address, and that you are a learner or an instructor To run your account and sign you in We need it to provide WheelPass to you (contract)
Learners: date of birth, learning stage, transmission, the district (the first part) of the postcode you search To check you are 16 or over, tell instructors if you are under 18, and show relevant instructors. We do not keep the full postcode you search with Contract; protecting children
Learners: pickup address for each lesson So your instructor knows where to collect you. Your instructor sees only the district until they approve the lesson Contract
Learners: practical test date and centre To remind you. Only your instructor can see it, and only if you choose Your consent
Learners: theory practice answers, mock test results, saved questions To show your progress and practise Contract. Shared with an instructor only if you choose
Instructors: profile (photo, bio, languages, rate), the districts you cover, your availability, your car (registration, make, model; MOT and tax status), your base postcode (never shown to learners) To list and run your business Contract
Instructors: ADI number, badge type, expiry and a photo of your badge To check you are on the DVSA register. The photo is deleted soon after we decide; we keep the decision, the ADI number and the expiry Safety and protecting children; legal duties
Instructors: bank account details So learners can pay you. Encrypted. Only learners connected to you can see them, and we log every time they are shown Contract
Lessons, requests, payments you say you made and that were confirmed, refunds The record of what was booked and paid. We never hold money Contract; keeping records
Messages in the app So you and your instructor or learner can talk. We do not read them. A small number of trained staff can read a conversation that has been reported, and we log it Contract; safety
Reviews and replies Help others choose Legitimate interests
Reports, blocks and suspensions Safety Legitimate interests; protecting children
Which version of our terms, this policy and the guidelines you accepted, and when To show what you agreed to and to ask you again when they change Legitimate interests; legal duty
Notifications and your notification settings; your phone's push token To tell you things (lesson reminders, requests, payments) and respect what you choose Contract; your consent for optional ones
How often features are used (counts only, for example "searches today") To understand how WheelPass is used. These counts are not linked to you Legitimate interests
Technical errors (from Sentry) To fix faults. We try not to send personal details Legitimate interests

We never collect your driving licence number.

3. Who we share it with

Some of these providers are outside the UK. [Describe the safeguards, for example the UK addendum or adequacy decision, for each.]

4. How long we keep it

Data How long
Your account details While you have an account. When you delete your account your name and email are replaced and your sign-in record is deleted
Chat messages 12 months after your connection ends
Records of lessons and payments 6 years (the other person needs the record). After you delete your account they stay without your name
Badge photos Deleted shortly after the decision
Notifications 90 days
The record of which version of our terms and policies you accepted Kept after you delete your account, without your name, as evidence of what was agreed
Theory answers While you have an account
Admin audit logs 2 years
Reports and safety records As long as needed for safety; if someone is suspended or banned we keep what we need to stop them returning

If something is under a legal hold, we keep it until the hold ends.

5. Your rights

You can ask us to give you a copy of your data, correct it, delete it, restrict or object to how we use it, and you can complain to the ICO (ico.org.uk). In the app: Home (learners) or Profile (instructors) → Privacy and your data lets you download your data and delete your account. For anything else, write to [privacy email]. We answer within one month. Your date of birth can only be changed by us, because it decides what you can do.

6. Safety and security

Bank details are encrypted. Staff only see what they need, and what they look at is logged. Requests to our servers must come from our apps. We have a written procedure for data breaches and will tell you and the ICO if one affects you.

7. Cookies

The WheelPass apps do not use cookies. Our website uses only what it needs to work and does not use advertising or tracking cookies.

8. Changes

We will tell you in the app before important changes. The latest version is always at [website]/privacy.


The short version for 16 and 17 year olds

You are old enough to use WheelPass, and your privacy matters just as much.