Toronto Coffee Pass
Privacy Policy

Effective Date: August 30, 2026

Locale 32 ("Locale 32," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use the Toronto Coffee Pass mobile application (the "App") and related services (collectively, the "Services").

This Policy is intended to comply with Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy law in Ontario.

By using the App, you agree to the collection and use of information in accordance with this Policy.

1. Information We Collect

1.1 Personal Information You Provide

  • Account Information: First name, last name, email address, and date of birth when you create an account.

  • Activation Information: The activation code you enter to activate your Pass.

  • Redemption Activity: Records of which participating cafés you've redeemed an offer at, and when.

  • Reviews: Ratings, written reviews, and related details you choose to submit about a café (e.g., whether staff were aware, extras purchased, whether you'd recommend the café). Some fields may be shared publicly within the App if you choose to make them visible; others (such as a private message to the café) are not shown to other users.

  • Communications: Any information you provide when contacting us for support.

1.2 Information Collected Automatically

  • Device Information: Device model, operating system, and app version, collected for troubleshooting and compatibility.

  • Usage Data: General information about how you interact with the App (e.g., screens visited), used to improve the Services.

1.3 Information We Do Not Collect

We do not process or store payment information within the App. Pass purchases are made through our website and handled by our third-party payment processor (via Squarespace); Locale 32 does not receive or store your full payment card details.

We do not collect precise GPS location data. Café locations are shown on a map using each café's fixed address, not your device's location.

2. How We Use Your Information

We use the information we collect to:

  • Create and manage your account and activated Pass;

  • Verify that you meet the minimum age requirement to use the Services;

  • Verify and process redemptions at participating cafés;

  • Display and moderate reviews within the App;

  • Send transactional communications (e.g., account confirmation, password reset, activation confirmation);

  • Respond to support requests;

  • Maintain the security and integrity of the Services, including detecting fraudulent or duplicate activation attempts;

  • Improve and troubleshoot the App.

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

3. Legal Basis and Consent

By creating an account and activating a Pass, you provide consent for us to collect and use your information as described in this Policy. Where required by law, we will seek your explicit consent before collecting sensitive information or using your information for a new purpose not described here. You may withdraw consent at any time by closing your account, subject to certain legal or contractual restrictions (see Section 7).

4. Sharing Your Information

We do not sell, rent, or trade your personal information. We may share information in limited circumstances:

  • With Participating Cafés: A café can see that a redemption has occurred and any review you've submitted about that café, but does not receive your account email or password.

  • With Service Providers: Third parties who help us operate the Services, such as our database/hosting provider (Supabase) and our transactional email provider (Resend). These providers are contractually restricted from using your information for any purpose other than providing services to us.

  • For Legal Reasons: If required to comply with a legal obligation, court order, or valid governmental request, or to protect the rights, property, or safety of Locale 32, our users, or the public.

  • Business Transfers: If Locale 32 is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, subject to this Policy (or a policy providing at least equivalent protection).

5. Data Retention

We retain your personal information for as long as your account remains active, and for a reasonable period afterward to comply with legal obligations, resolve disputes, and enforce our agreements. You may request deletion of your account and associated personal information at any time, as described in Section 7.

6. Data Security

We take reasonable administrative, technical, and physical measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction, including access controls and encryption in transit. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

If we become aware of a data breach that creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as required by law.

7. Your Rights and Choices

Under PIPEDA, you have the right to:

  • Access the personal information we hold about you;

  • Correct inaccurate or incomplete information;

  • Withdraw consent for our continued collection or use of your information, subject to legal or contractual limitations;

  • Request deletion of your account and associated personal information.

You can update your account information directly within the App, or contact us at cheers@locale32.ca to make an access, correction, or deletion request. We will respond within a reasonable time and in accordance with applicable law.

You may also file a complaint with the Office of the Privacy Commissioner of Canada if you believe we have not handled your personal information in accordance with this Policy or applicable law.

8. Children's Privacy

The App is not intended for use by children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected personal information from a child under 13, we will take steps to delete it promptly. If you believe a child has provided us with personal information, please contact us at cheers@locale32.ca.

9. Third-Party Links

The App may contain links to third-party websites (such as café websites or social media pages). We are not responsible for the privacy practices of these third parties, and we encourage you to review their privacy policies separately.

10. International Data Transfers

Your information may be stored and processed outside your province of residence, including in the United States, where our service providers (such as our hosting and email providers) operate their infrastructure. This means your information may be subject to the laws of those jurisdictions, including potential access by their government authorities.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the "Effective Date" above and, where appropriate, providing notice within the App. Your continued use of the Services after changes take effect constitutes your acceptance of the updated Policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact:

Locale 32
Email: cheers@locale32.ca
Website: locale32.ca/torontocoffeepass