Privacy Policy

DRAFT FOR REVIEW. This document has not been legally reviewed and is not final. It describes how the service is intended to work when online ordering opens. Highlighted items are placeholders still to be completed.

1. Who we are

YEKLENS Ltd, Accra, Ghana. Contact: info@yeklens.com.

Company registration number and registered address: [TO BE SUPPLIED]

Data Protection Commission registration number: [DPC REGISTRATION NUMBER, pending]

2. What we collect

• From schools: for each child, their first and last name, class and school, and the school's own pupil number.
• Photographs of children taken on photo day.
• From parents and guardians who order: an email address or phone number, order details, and a payment reference. Payments are processed by Paystack. We never see or store card or mobile money details.
• Security records: when a Photo ID and Key are entered, we record the attempt, including failed attempts and the IP address, to protect against guessing.
• Messages you send us by email or the contact form.

3. How we use it

To photograph children, link each photo to the right child's private gallery, let parents and guardians view and order photos, take payment, deliver orders and send receipts, report sales to the school, keep the service secure, and reply to your messages. We do not sell personal information [confirm: and do not use it for advertising].

4. How photographs are protected

• Previews carry a visible watermark. Full-quality originals stay in private storage and are released only through a paid order.
• Photos can be opened only by someone who enters a child's Photo ID and Photo Key from the printed card.
• We do not use facial recognition or biometric matching. Photos are linked to children using the child's card.
• [PROPOSED, to be confirmed: we do not use photographs of children on our website, social media or marketing without the written permission of the child's parent or guardian]

5. Who we share information with

The school receives sales reports [confirm exactly what the school can see]. We use service providers to run the service: Supabase (database and private file storage), Render and Vercel (hosting) and Paystack (payments). [LEGAL REVIEW: where these providers store data, and any transfer outside Ghana]

6. How long we keep it

Photographs, class-list information and order records are kept for [RETENTION PERIOD, to be confirmed] and then deleted or anonymised. Security records are kept for [PERIOD, to be confirmed].

7. Your rights and removal requests

A parent or guardian can ask to see, correct or delete the information we hold about their child, ask us to remove a photograph, or ask us to stop using it. Email info@yeklens.com with the child's Photo ID (printed on the card; never send the Key) and your contact details. We may need to check that you are the parent or guardian. We will respond within [RESPONSE TIME, to be confirmed].

8. Cookies

This website does not use advertising or tracking cookies [confirm before launch]. When online ordering opens, your browser may keep a temporary session so your child's photos stay open while you shop. This is needed for the service to work.

9. Complaints

Please contact us first. You may also complain to the Data Protection Commission of Ghana.

10. Legal basis and changes

This policy is intended to comply with the Data Protection Act, 2012 (Act 843) of Ghana [LEGAL REVIEW REQUIRED]. Version: draft. Last updated: [DATE]