Privacy Policy

Last updated: 14 March 2026

1. Introduction

HallPass (Pty) Ltd (“HallPass”, “we”, “us”, “our”) is committed to protecting your personal information in accordance with the Protection of Personal Information Act, 2013 (POPIA) and other applicable South African legislation.

This Privacy Policy explains how we collect, use, store, and protect the personal information of schools, parents/guardians, staff, and children who use our platform.

2. Information We Collect

2.1 Account Information

  • Full name
  • Email address
  • Phone number
  • Hashed password and PIN
  • User role (parent, staff, administrator)

2.2 Child Information

  • Full name
  • Date of birth (if provided)
  • Class/group assignment
  • Medical notes and allergies (if provided by parent)
  • Photograph (if uploaded by parent or school)

2.3 Attendance Data

  • Check-in and check-out timestamps
  • Method of verification (QR code, PIN, manual)
  • Identity of the person who performed the check-in/out
  • Absence and late notices

2.4 Authorized Persons

  • Name, phone number, and relationship to child
  • ID number (if provided)
  • QR token for gate verification

2.5 School Information

  • School name, address, and contact details
  • Operating hours
  • Class structure and staff assignments

3. What We Do NOT Collect

We never collect:

  • Location or GPS data
  • Biometric data (fingerprints, facial recognition)
  • Browsing history or cookies for advertising
  • Financial information (payments are handled by third-party processors)

Your data is never sold to anyone. Ever.

4. How We Use Your Information

We use your personal information to:

  • Operate the check-in/check-out system and verify identities at the gate
  • Send real-time notifications about your child’s attendance
  • Generate attendance reports for schools
  • Manage authorized persons for child pickup
  • Communicate service updates and important notices
  • Improve the Platform’s functionality and user experience
  • Comply with legal obligations

5. Legal Basis for Processing (POPIA)

We process your personal information under the following lawful grounds as defined by POPIA:

  • Consent (Section 11(1)(a)): You provide consent when you register and accept our Terms of Service
  • Contractual necessity (Section 11(1)(b)): Processing is necessary to provide the attendance management service
  • Legal obligation (Section 11(1)(c)): Where we are required by law to retain certain records
  • Legitimate interest (Section 11(1)(f)): To improve and secure our Platform, provided your rights are not overridden

6. Data Hosting and International Transfers

Where Your Data Is Stored

HallPass uses secure cloud infrastructure provided by reputable third-party providers. These services may store and process your data on servers located outside of South Africa, including in the United States and the European Union.

In accordance with Section 72 of POPIA, we ensure that international transfers are protected by:

  • Adequate protection: Our cloud providers maintain security certifications (SOC 2 Type II, ISO 27001) that meet or exceed POPIA requirements
  • Contractual safeguards: Data processing agreements are in place with all providers, binding them to protect your information
  • Consent: You provide explicit consent to international data transfers when you accept our Terms of Service
  • Technical measures: All data is encrypted in transit (TLS 1.3) and at rest (AES-256)

Our current infrastructure providers include Vercel (application hosting), Neon (database), and Railway (background services).

7. Data Sharing

We share your personal information only with:

  • Your school: School administrators and authorized staff can view attendance data, parent contact details, and child information for their school only
  • Infrastructure providers: Cloud hosting, database, and email service providers who process data on our behalf under strict data processing agreements
  • Legal authorities: When required by law, court order, or to protect the safety of children

We do not share your data with advertisers, data brokers, or any unrelated third parties.

8. Data Security

We protect your information through:

  • Encryption in transit (TLS 1.3) and at rest (AES-256)
  • Cryptographically unique 64-character QR tokens
  • Bcrypt-hashed passwords and PINs (never stored in plain text)
  • Role-based access controls ensuring multi-tenant data isolation
  • Automated database backups
  • Regular security monitoring and updates

9. Children’s Privacy

We take the privacy of children very seriously. Child data is:

  • Only accessible to the child’s school and linked parents/guardians
  • Never used for marketing or advertising purposes
  • Protected by the same security measures as all other data
  • Only collected to the extent necessary for attendance management

Parents/guardians may request to view, correct, or delete their child’s information at any time.

10. Data Retention

We retain your personal information as follows:

  • Active accounts: Data is retained for as long as your account is active and the school subscription is current
  • Attendance records: Retained for the duration required by South African education regulations, or a minimum of 3 years
  • Deleted accounts: Personal data is deleted within 90 days of account deletion, except where retention is required by law

11. Your Rights Under POPIA

You have the right to:

  • Access: Request a copy of the personal information we hold about you
  • Correction: Request correction of inaccurate or incomplete information
  • Deletion: Request deletion of your personal information, subject to legal retention requirements
  • Object: Object to the processing of your personal information on reasonable grounds
  • Withdraw consent: Withdraw your consent to processing at any time (this may affect your ability to use the Platform)
  • Complain: Lodge a complaint with the Information Regulator of South Africa

To exercise any of these rights, please contact us at hello@hallpass.co.za.

12. Cookies and Analytics

HallPass uses only essential cookies required for the Platform to function (such as authentication session cookies). We do not use tracking cookies, advertising cookies, or third-party analytics that track individual users.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered users of material changes via email or in-app notification. The “Last updated” date at the top of this page indicates when the policy was last revised.

14. Information Regulator

If you believe your personal information has been mishandled, you may lodge a complaint with:

The Information Regulator (South Africa)

15. Contact Us

For any questions or requests regarding this Privacy Policy or your personal information, please contact:

HallPass (Pty) Ltd

See also our Terms of Service and Trust & Safety page.