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Draft template — pending review

Privacy Policy

This is an unfinished template, not a final policy or legal advice. It requires legal and operational review before publication or reliance. Placeholders below must be completed and checked against how SquarePass actually operates.

Effective date: [To be confirmed after review]

Who is responsible

SquarePass is a product of SquarePass Limited. [Review: confirm the data controller, registered address and privacy contact details.]

Information we collect

[Review: list account details, referral information, uploaded documents, communications and technical information actually collected, including information about other people.]

How and why information is used

[Review: describe each purpose and applicable lawful basis, including assessing referrals, making suitable introductions, account administration and communications. Confirm how third-party information is handled.]

Sharing and international transfers

[Review: identify recipient categories, service providers, any specialist-sharing process and any international transfers and safeguards. Do not assume all information is confidential or shared only by consent.]

Retention and security

[Review: specify retention periods or criteria and accurately describe implemented security measures without guaranteeing absolute security.]

Your rights and concerns

[Review: explain applicable rights, identity checks, how to make a request and the relevant supervisory authority. Insert verified privacy contact details.]

Cookies and updates

[Review: align with the Cookie Policy and document how material policy changes will be communicated.]