Privacy policy

Pass Around the Smile Website Privacy Policy Last updated: 20 October 2026

We care about your privacy as much as your peace of mind. This policy explains what personal information we collect through passaroundthesmile.com, why, who helps us look after it, and the choices you have.

1. Who we are

passaroundthesmile.com (the website) is run by Pass Around the Smile Enterprises Pty Ltd (ACN 644 249 954) as trustee for the Massey Family Trust (ABN 98 249 525 387), of PO Box 218, Nobby Beach QLD 4218, Australia (we, us, our). Our privacy officer is Cleo Massey. Privacy questions and requests: hello@passaroundthesmile.com.

This policy covers the website, our online shop, our 1:1 readings, our online courses, our email newsletter and the forms on our website. The Pass Around the Smile app has its own privacy policy at app.passaroundthesmile.com/privacy.

We handle personal information in line with the Australian Privacy Principles. Where they apply to you, we also follow the UK GDPR and EU GDPR, New Zealand's Privacy Act 2020 and Canada's privacy laws.

2. Information we collect

Sensitive information. Readings are personal, and you might choose to tell us about your health, relationships, wellbeing or other sensitive matters. You never have to. If you do, you consent to us using it only to give you your reading. We don't use it for marketing, we don't share it with anyone outside our small team, and we never mention it publicly.

How we collect it. We collect information directly from you, automatically when you use the website, and from our service providers (for example, Shopify when you check out, or our booking app when you book a reading). You can browse the website without giving us your name. We need your contact and delivery details to fulfil an order.

What we don't do. We never sell or rent your personal information. We don't record readings. We don't use what you share in a reading or in a form to build an advertising profile of you.

3. How we use your information

We use your information to sell and deliver products, give readings and courses, provide customer support, send the emails you choose, keep the website secure, improve what we offer, advertise our products (see section 5) and meet our legal obligations. We don't make decisions about you by automated means that significantly affect you.

If you are in the UK or EU, our legal bases are: performing our contract with you (orders, readings, courses and support); our legitimate interests in running, securing and improving our business, and in handling complaints or legal claims; your consent (marketing emails, non-essential cookies, and any sensitive information you share in a reading); and legal obligations (tax and business records). You can object at any time to our use of your information based on legitimate interests.

4. Marketing emails

We only send newsletters and offers if you sign up or tick the marketing box at checkout. Buying from us is not agreeing to marketing. If you opt in, we add your email address to our list in Klaviyo, our email provider. Every email has an unsubscribe link, and we act on it within 5 working days. We keep unsubscribed email addresses on a do-not-send list so we can honour your choice.

5. Cookies, analytics and advertising

The website uses cookies, pixels and similar technology. Some are essential, such as those that keep your cart and run checkout. We also use them for:

• Analytics: Shopify analytics, Google Analytics and Microsoft Clarity help us see how people use the website. Clarity records how visitors scroll, click and move around our pages (session recordings and heatmaps) so we can improve the site. It is set to mask what you type into form fields.
• Advertising: pixels from Meta (Facebook and Instagram), Google and YouTube, Pinterest and TikTok measure our ads and help show them to people likely to be interested. Some of these also receive visit and purchase information directly from Shopify's servers, not only from your browser.
• Email: Klaviyo connects your visits with the emails you've signed up for, so we can send relevant emails, such as a reminder about items left in your cart.
• Reviews and video: Judge.me shows and collects product reviews, and Tolstoy shows our shoppable videos and counts views.
• Creator partnerships: Shopify Collabs tracks purchases made through our creators' affiliate links so we can pay them commission.

This means these providers may receive information about your visit, such as pages viewed, products added to cart, purchases, your device and your IP address, and use it under their own privacy policies. You can choose which cookies to allow through our cookie banner where it's shown, change your ad settings on each platform, or block or delete cookies in your browser. Blocking essential cookies may stop the shop working properly.

6. Who helps us run the website

We use trusted service providers who handle your information on our behalf, under terms that limit how they can use it and require them to protect it.

We may also disclose information to our professional advisers (such as our accountant), if we sell or restructure the business (under confidentiality), or where the law requires it.

7. Information stored overseas

Some providers store or process data in the United States, Canada and other countries where they have facilities. We choose providers that protect personal information to a high standard and take reasonable steps to make sure they handle it in line with the Australian Privacy Principles. For UK and EU customers, transfers are covered by standard contractual clauses, the UK International Data Transfer Addendum, adequacy decisions (Canada) or, where the provider is certified, the EU-US Data Privacy Framework and its UK Extension. You can ask us for a copy of the safeguards we use.

8. Children

Many of our products are made for families, but our shop, courses and readings are for adults. If you are under 18, please ask a parent or guardian to buy for you. Readings, podcast guest applications and Ask Cleo submissions are for people 18 and over. We don't knowingly collect personal information from children under 13. If you believe a child has given us personal information, please email us and we will delete it.

9. How long we keep your information

10. Keeping your information safe

We use encrypted connections on our website, two-step login on our business accounts, access limited to the people who need it, and providers with strong security programs. Payment details are encrypted and handled by our payment providers. No system is perfectly secure. If a data breach is likely to cause you serious harm, we will tell you and any regulator we need to.

11. Your rights

You can ask to access or correct your personal information, or to delete it (unless we must keep it, for example for tax records). Email hello@passaroundthesmile.com and we'll reply within 20 working days (and always within one month), free of charge. We may need to confirm your identity first. If you are in the UK or EU, you can also object to or restrict our use of your information, receive a copy in a portable format, and withdraw consent at any time. If you are in the US, we don't sell your personal information for money. Our advertising pixels may count as sharing for targeted advertising under some US state laws. You can opt out through our cookie banner, your ad settings on each platform, or by emailing us.

12. Complaints

Please email hello@passaroundthesmile.com first. We will acknowledge your complaint promptly (and always within 30 days) and aim to resolve it within 30 days. If you're not satisfied, you may be able to contact the privacy regulator where you live: Australia: the Office of the Australian Information Commissioner, oaic.gov.au; UK: the Information Commissioner's Office, ico.org.uk; EU: your local data protection authority; New Zealand: the Office of the Privacy Commissioner, privacy.org.nz; Canada: the Office of the Privacy Commissioner of Canada, priv.gc.ca.

13. Changes to this policy

We may update this policy when our business or the law changes. We'll post the new version here with a new date, and if a change is important, we'll tell you by email or on the website before it takes effect.

14. Contact us

Pass Around the Smile Enterprises Pty Ltd, PO Box 218, Nobby Beach QLD 4218, Australia. Email: hello@passaroundthesmile.com.