Privacy Policy

Effective Date: 6 January 2026 · Version 1.0

1. Purpose of This Privacy Policy

This Privacy Policy explains how Passpoint, a product of Godse TechFx Solutions Limited, collects, uses, and protects your personal data when you use our theory test preparation platform. Specifically, it informs you of:

• The personal data we collect;
• How we use that data;
• Who has access to the data collected;
• Your rights as a user; and
• Our cookie policy.

This Privacy Policy applies in addition to the Terms of Service of Passpoint.

2. Legal Framework (GDPR)

For users in the European Union, we adhere to the Regulation (EU) 2016/679 (General Data Protection Regulation). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint one under Article 37 of the GDPR.

3. Consent

By using Passpoint, you agree to the conditions set out in this Privacy Policy. Where the legal basis for processing your personal data is your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.

To withdraw your consent:

• Update your privacy preferences within the app,
• Use the unsubscribe link in our communications,
• Adjust your device settings, or
• Contact us at support.passpoint@techfxsolutions.co.uk.

4. Legal Basis for Processing

We collect and process personal data only when we have a legal basis under Article 6 of the GDPR:

• Consent: You have provided consent for one or more specific purposes.
• Legitimate Interests: Processing is necessary to maintain platform security, prevent fraud, and improve Passpoint.
• Contract Performance: Processing is necessary for the performance of a contract with you.
• Legal Obligation: Processing is necessary to comply with a legal obligation.

5. Personal Data We Collect

5.1 Data Collected Automatically

• IP address
• General location
• Device hardware and software details
• Clicked links and content viewed within the app
• Session monitoring, performance metrics
• Crash and troubleshooting data

5.2 Data Collected When You Use the App

• Account Registration: Name, email, phone number, password, date of birth, and profile photo
• Subscription & Payment: Payment details when subscribing
• Language & Personalisation Settings: Preferred languages, voiceover preferences, and test settings
• In-App Communication: Questions submitted to the Help Centre
• Test Activity: Practice test progress, scores, and session data

6. How We Use Personal Data

6.1 Automatically Collected Data

• Statistics & Analytics: Understand usage patterns and improve user experience
• Fraud Detection & Security: Detect suspicious behaviour and secure accounts
• Service Improvement: Optimise app performance and fix bugs
• Marketing & Personalisation (with consent): Tailor content and promotions
• Technical Support: Troubleshoot errors and improve stability

6.2 Data You Provide to Us

• Service Fulfilment: Manage your subscription and provide access to content
• Payment Processing: Process subscription payments and refunds
• Verification & Compliance: Anti-fraud measures and UK regulatory compliance
• Customer Support: Answer questions and resolve disputes
• Marketing & Communication (Consent Required): Email notifications and promotions

7. Who We Share Personal Data With

We may share user data with the following categories of third parties:

• Payment Processors (e.g. Stripe, PayPal)
• Cloud & Hosting Providers (e.g. AWS, Google Cloud)
• Analytics Providers (e.g. Google Analytics, Mixpanel)
• Email & Notification Services (e.g. SendGrid, Mailtrap)
• Legal / Regulatory Authorities where required by law

We will not sell or share your data with other third parties, except if required by law, to protect our legal rights, or to buyers in the event of a business sale.

8. International Data Transfers

Personal data may be transferred to countries outside the UK where our trusted service providers operate. We ensure all such transfers comply with applicable data protection laws, and that appropriate safeguards — including encryption and Standard Contractual Clauses — are in place to protect your data.

9. How Long We Store Personal Data

• User account data: Retained while the account is active or until a deletion request is received
• Subscription and payment data: 7 years
• Communication logs and support requests: 3–5 years
• Anonymised or aggregated analytics data: Retained indefinitely

10. How We Protect Your Personal Data

We implement appropriate technical, administrative, and physical measures to protect your data, including:

• Encryption of data in transit and at rest
• Secure authentication and role-based access controls
• Monitoring for suspicious activity
• Regular backups and secure storage
• Payment information processed only through PCI-DSS compliant services

11. Your Rights as a User

Under the UK GDPR and Data Protection Act 2018, you have the following rights:

• Right to be informed
• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to data portability
• Right to object

To exercise any of these rights, please contact our Privacy Officer at: privacy@techfxsolutions.co.uk

12. Children

The minimum age to use Passpoint is 17 years of age, in line with the minimum age to apply for a provisional driving licence in the United Kingdom. We do not knowingly collect personal data from children under 16. If we learn that we have collected such data, it will be deleted as soon as possible.

13. How to Access, Modify, Delete, or Challenge Your Data

If you would like to know whether we hold your personal data, how it has been used, or if you wish to have your data deleted or modified, please contact our Privacy Officer: privacy@techfxsolutions.co.uk

14. Do Not Track

We respond to browser-initiated Do Not Track (DNT) signals. If we receive a DNT signal, we will not track that user.

15. How to Opt Out

• Marketing communications: via unsubscribe links or in-app settings
• Analytics or tracking cookies: via cookie banner, browser settings, or in-app privacy settings
• Third-party sharing: via consent settings or by disabling marketing cookies

16. Cookie Policy

We use the following types of cookies:

• Functional Cookies: Remember your selections and preferences
• Analytical Cookies: Improve design and functionality by collecting usage data
• Targeting Cookies: Personalise the content you see
• Third-Party Cookies: Track anonymised interactions, manage sessions, and measure performance

17. Changes to This Privacy Policy

This Privacy Policy may be amended from time to time. When we amend this policy, we will update the Effective Date at the top. Users will be notified of material updates via the app, website, or email.

18. Complaints

If you have any complaints about how we process your personal data, please contact us. If you feel we have not addressed your concern satisfactorily, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk.

19. Contact Information

Last updated: 6 January 2026 · Version 1.0