Privacy Policy

# Privacy Policy — Drivers Log SA

**Effective date:** 12 September 2026

**Last updated:** 12 September 2026

Drivers Log SA ("**the App**", "**we**", "**us**") is an electronic driving logbook for South Australian learner drivers, published by **1st Learn Pty Ltd** ("**the Publisher**"). This policy explains what personal information the App collects, why, how it is stored, and the choices you have. It is written to meet both the Google Play Data Safety and Apple App Store Privacy "Nutrition Label" disclosure requirements, and the Australian Privacy Principles (APPs) under the *Privacy Act 1988* (Cth).

If you do not agree with this policy, do not use the App.

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## 1. Who this policy covers

- **Drivers** — the learner permit holder who creates an account and uses the App.

- **Supervisors** — the licensed driver who accompanies a learner on a trip. Supervisors do not install the App or hold an account. A driver enters a supervisor's permit number and phone number to start a trip, and the supervisor receives a one-time SMS code to confirm they are present. By entering a supervisor's details, the driver confirms they have that supervisor's consent to share this information with us for this purpose.

## 2. Information we collect

### 2.1 Account information (collected at sign-up)

| Data | Purpose |

|---|---|

| Full name | Displayed in-app; printed on your driving log report |

| Phone number (+61) | Account identifier; used to send you SMS one-time codes (sign-up and login) |

| Driver's licence / learner permit number | Unique account identifier (required to be unique — no duplicate accounts per permit); printed on your driving log report |

We use **Firebase Phone Authentication** (a Google service) to verify your phone number by SMS. Firebase/Google may process your phone number and device signals (such as an app integrity/attestation token) solely to send the code and to prevent SMS abuse. See [§5](#5-third-party-services-we-use).

### 2.2 Trip data (collected while you use the logging features)

| Data | Purpose |

|---|---|

| GPS location, recorded continuously during a trip (including while the App is backgrounded or the screen is locked) | Draw your route, calculate distance and duration, and record start/end addresses for your logbook |

| Trip start/end time, duration, pause time | Populate your logbook and printed report |

| Road type, weather, traffic density, day/night flag | Trip conditions you select, included in your logbook |

| Supervisor's permit number and phone number | Recorded against the trip as required by the SA Government logbook format; used to send the supervisor a one-time SMS code to confirm supervision |

Location is only collected while a trip is actively running. You can deny location permission, but the App cannot record a trip without it.

### 2.3 Information we do NOT collect

We do not collect: precise location outside an active trip, contacts, photos/camera, microphone, advertising identifiers, browsing history, or payment information. The App contains no advertising and no analytics/tracking SDKs.

### 2.4 Information generated on your device

Your session/login state is stored locally on your device (not shared with us) so you stay signed in between app opens.

## 3. How we use your information

We use the data above only to:

- create and secure your account and verify you are a genuine learner driver;

- record, display, and let you export your supervised driving hours in the format required by mylicence.sa.gov.au;

- verify that a licensed supervisor was present for each trip (anti-fraud / legal compliance);

- provide customer support if you contact us.

We do not sell your personal information, and we do not use it for advertising or profiling.

## 4. Where your data is stored

Account and trip data is stored in **Cloud Firestore** (Google Cloud), a database maintained by Google as our data processor, in the **australia-southeast1** (Sydney) region. Data may transit through Google's global infrastructure for backup and service delivery. Google's own privacy and security practices are described at https://cloud.google.com/security/privacy.

## 5. Third-party services we use

|---|---|---|---|

We do not share your data with any other third party, and we do not permit these providers to use your data for their own purposes.

## 6. Data retention and deletion

We retain your account and trip data for as long as your account is active, since it forms part of the official record of your supervised driving hours. You may request deletion of your account and all associated data at any time by contacting admin@1stlearn.com.au. We will delete your data within [30] days of a verified request, except where retention is required to comply with a legal obligation or resolve a dispute.

## 7. Your rights

Subject to the Australian Privacy Principles, you may request to:

- access the personal information we hold about you;

- correct inaccurate information (note: name, phone number and permit number are fixed at sign-up by design to preserve logbook integrity — contact support to correct an error);

- delete your account and data (see §6);

- ask how your information has been used or disclosed.

To exercise any of these rights, contact admin@1stlearn.com.au.

## 8. Children and minors

South Australian learner permits can be held from age 16. If you are under 18, you (or your parent/guardian) confirm that you are permitted to use this App under applicable law. We collect no more information from a minor than from an adult user, as described above.

## 9. Security

We rely on Firebase's security infrastructure, including encryption in transit (TLS) and at rest, and Firestore Security Rules restricting each driver's data to that driver's own account. No method of electronic storage is 100% secure; we cannot guarantee absolute security.

## 10. Account deletion

You can delete your account directly from the App: **Profile → Delete account**. This permanently removes your account and trip data as described in §6. [Confirm this control exists before publishing — required by Apple App Store Guideline 5.1.1(v) for any app that supports account creation.]

## 11. Changes to this policy

We may update this policy from time to time. Material changes will be notified in-app or by SMS to your registered number. Continued use of the App after a change constitutes acceptance of the updated policy.

## 12. Contact us

1st Learn Pty Ltd

17 Tigress Dr, Hallett Cove, SA 5158, Australia

admin@1stlearn.com.au

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## Appendix — Data Safety / App Privacy mapping

For whoever completes the Google Play **Data Safety** form and Apple **App Privacy** questionnaire at submission time:

|---|---|---|---|---|---|

| Name | Yes | No | Account, app functionality | Yes | No |

| Phone number | Yes | Yes (Google, for OTP delivery only) | Account, verification | Yes | No |

| Driver licence/permit number | Yes | No | Account (unique ID), reporting | Yes | No |

| Precise location in background | Yes, during an active trip only | No | App functionality | Yes | No |

| Advertising ID / analytics / crash logs | No | — | — | — | — |

| Payment info | No | — | — | — | — |

**Data is encrypted in transit:** Yes (TLS, via Firebase). **Users can request data deletion:** Yes (§6, §10). **Data collection is required for the app to function:** Yes — location and supervisor details are core to the logbook feature and cannot be made optional.

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