Privacy Policy

Wiseclutch Ltd, trading as ActivePass, is the data controller of your personal data for the purposes of the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. This policy explains what we collect, why, and what rights you have.

1. Who We Are

Wiseclutch Ltd t/a ActivePass, registered in Ireland. Contact hello@activepass.ie for any data protection query, including to exercise any of the rights listed in Section 7 below.

2. What Personal Data We Collect

• Order data: name, email address, and payment confirmation (we never see or store your full card details — this is handled entirely by Stripe).
• Gifting data: where you buy a Pack as a gift, the recipient's name and email address, provided by you.
• Communications: any emails or messages you send us, including support requests.
• Technical data: IP address, browser type, device information, and pages visited, collected automatically via cookies (see our Cookie Policy).
• Marketing preferences: whether you've opted in or out of marketing emails.

3. Why We Process It, and Our Legal Basis

• To fulfil your order (performance of a contract) — issuing your Voucher, processing payment, handling support requests.
• To comply with the law (legal obligation) — tax records, consumer protection record-keeping under the Gift Vouchers Act 2019.
• To send marketing communications (consent) — only where you have opted in; you can withdraw this consent at any time.
• To improve the site (legitimate interest) — aggregated, anonymised analytics; we balance this against your right to privacy and do not use it to build individual profiles for purposes beyond running the business.

4. Who We Share It With

• Partners — we share only your first name and Voucher code, solely to allow the Partner to verify a booking. We do not share your email address, phone number, or payment details with Partners.
• Stripe — processes your payment as an independent data controller under its own privacy policy; we never see or store your card details.
• Email and hosting providers — process data on our behalf as data processors, under contract, solely to deliver our service (e.g. sending your Voucher email, hosting the website).
• Nobody else. We do not sell personal data, and we do not share it with any other third party for their own marketing purposes.

5. International Data Transfers

Where a processor (such as Stripe) transfers data outside the European Economic Area, this is done under an approved safeguard such as the EU Standard Contractual Clauses.

6. How Long We Keep Your Data

Order and transaction data is kept for as long as your Voucher remains valid (a minimum of 5 years, per the Gift Vouchers Act 2019), plus any additional period required for tax and accounting records under Irish law. Marketing data is kept until you withdraw consent.

7. Your Rights Under GDPR

You have the right to:

• Request access to the personal data we hold about you.
• Request correction of inaccurate data.
• Request erasure of your data, where it is no longer needed or you withdraw consent (subject to our legal obligation to retain certain transaction records).
• Object to or restrict certain processing, including marketing.
• Request a portable copy of your data.
• Withdraw marketing consent at any time by emailing hello@activepass.ie or clicking unsubscribe.
• Lodge a complaint with the Data Protection Commission (dataprotection.ie), Ireland's independent supervisory authority.

8. Children's Data

Our Little Ones-suitable Activities are booked and paid for by an adult. We do not knowingly collect personal data directly from children; any child's name provided as part of a family booking is provided by the purchasing adult and used solely to facilitate that booking.

9. Security

We use industry-standard technical and organisational measures (encrypted connections, access controls, and a PCI-compliant payment processor) to protect your data against unauthorised access, loss, or misuse.

10. Changes to This Policy

We may update this policy from time to time; material changes will be posted here with an updated date.

Wiseclutch Ltd t/a ActivePass · Registered in Ireland · hello@activepass.ie