1Who we are
Vinenux is operated by Tercel Nova Ltd (company registration no. CS060270424, TIN C0063982722), Madina, registered with the Data Protection Commission of Ghana under the Data Protection Act, 2012 (Act 843), registration no. PROV2609477 (registered 13 September 2026, valid until 12 September 2028). Contact: info@tercelnova.com. Data Protection Supervisor: Felix Adu Asare, info@tercelnova.com.
2What this policy covers
The Vinenux mobile app (iOS and Android) and Vinenux Web, which includes emergency lookup, the organisation portal and platform administration. It covers data about children, parents and guardians, family members, organisation staff and emergency responders.
3The data we hold
| Category | Examples | Who provides it |
|---|---|---|
| Account data | Name, email address, phone number, password (stored by our authentication provider, never in readable form), Google sign-in details, language and app settings | You |
| Child profile | Names, date of birth, gender, photo, home address, insurance policy and expiry, emergency notes | Parent or permitted family member |
| Health data | Blood group, allergies and reactions, conditions, medications, vaccinations, height and weight | Parent, permitted family member, or approved organisation |
| Education and development | Schools, classes, grades, teacher notes, goals, achievements, strengths and areas to work on | Parent, family member, or approved organisation |
| Organisation records | Health visits, academic progress, attendance, behaviour notes, incident reports | Approved organisations |
| Documents | Birth certificates, passports, immunisation cards and other uploads | Parent or permitted family member |
| Memories | Moments, photos, videos, memory capsules, letters to the future (written or voice) | Parent or permitted family member |
| Finance | Expenses, receipts, savings deposits and sources | Parent or permitted family member |
| Private parent data | Parent journal, reminders | Parent only |
| Access and activity data | Who was invited, permissions granted, access requests and decisions, emergency code use, family and staff activity logs | Generated by Vinenux |
| Technical data | Device type, app version, crash reports, usage analytics, hashed network addresses for rate limiting | Generated by Vinenux and our service providers |
| Feedback | Suggestions, bug reports and complaints you send us | You |
Health data and data about children are special personal data. We handle them with extra care, as Act 843 requires [counsel to confirm the exact provisions].
4Why we use it and on what basis
- To provide Vinenux: storing and organising your child’s record, showing reminders and calendars, generating exports. Basis: our contract with you, and your consent on your child’s behalf.
- To share what you choose to share: with family members, organisations and emergency responders you approve. Basis: your consent, given each time you invite someone or approve a request.
- To protect children and the service: rate limiting, fraud and misuse detection, security logs. Basis: our legitimate interest in keeping records safe, and legal obligations.
- To fix and improve Vinenux: crash reports and usage analytics. Basis: our legitimate interest. [Decision: whether analytics can be switched off by users.]
- To contact you: account emails, text messages, verification, invitations and service notices. Basis: our contract with you.
We do not sell personal data. We do not use it for advertising. We do not use children’s records to train AI models.
5Who can see your child’s record
Only the people you allow, and only the parts you allow.
- Family Circle members see what their role and your chosen permissions allow, limited to the children you select. Photos and videos are off by default except for co-parents.
- Organisations (schools, clinics, hospitals) see only the record categories you approve. They are never given finance, documents, the journal or letters. Their access continues until you revoke it.
- Emergency responders see identity, allergies, conditions, medications and emergency contacts for 12 hours after you approve their request.
- Tercel Nova Ltd staff can access records only to provide support you ask for, investigate misuse or security incidents, or comply with the law. Every privileged action is logged.
- Service providers process data on our behalf under contract (see clause 8).
- Authorities only when the law requires it (see our Third-Party and Government Data Request Policy).
Your parent journal, reminders and letters to the future are visible only to you. No permission exists that could share them.
6Records organisations add
When an approved organisation adds a record (for example attendance or a school clinic visit), that organisation is responsible for its accuracy and is a joint controller of it with Tercel Nova Ltd. You can see these records in the app but cannot edit them. To correct one, contact the organisation or us.
7Revoking access
You can remove a family member, revoke an organisation’s access, or revoke an emergency code at any time, and it takes effect immediately. Revoking stops future access. It cannot undo what someone has already seen, noted or copied into their own records.
8Where data is stored and who processes it
Vinenux runs on Google Firebase (Google Cloud). Data is stored in Google Cloud’s us-central1 region (Iowa, United States), outside Ghana. Crash reports and usage analytics are also processed by Google in the United States. Our main service providers are Google (authentication, database, file storage, notifications, analytics and crash reporting), Zoho (email), [SMS provider ●] (text messages), and the Apple and Google app stores for app distribution. We transfer data outside Ghana only with the safeguards Act 843 requires [counsel to specify].
9Document scanning
When you scan a document, text is read on your phone using on-device text recognition. The image is not sent to us for reading. It is uploaded only if you choose to save it to the record.
10How we protect data
Access rules are enforced on our servers, not only in the app. Data is encrypted in transit and at rest. Emergency codes are stored only as keyed hashes. Code lookups are rate-limited. The app can be locked with a PIN, Face ID or fingerprint. No system is perfectly secure; if a breach affects your data, we will tell you and the Data Protection Commission as the law requires.
11How long we keep data
While your account is active. If you delete a child’s record or your account, we delete it from live systems within [30 days] and from backups within [90 days]. We keep access and consent logs for [6 years] to show that sharing was lawful. Records organisations added may also be kept by those organisations under their own obligations.
12Your rights
You may ask to access, correct or delete your data or your child’s, object to processing, or withdraw consent. Most of this can be done in the app (export, edit, delete, revoke). Otherwise, email info@tercelnova.com. We respond within [30 days] [confirm Act 843 timeline]. If you are unhappy with our response, you can complain to the Data Protection Commission of Ghana.
13Your child’s rights
The record is about your child, and your child has rights in it too. We encourage parents to involve children in decisions about sharing as they grow. When a child turns 18, [control of the record passes to them / the parent can hand over a life book of the record] [decision required: the system currently offers only the life book export].
14Children using Vinenux
Vinenux accounts are for adults aged 18 or over. Children do not have their own accounts.
15Parents’ own data and other people’s data
Your journal, reminders and letters may mention other people. You are responsible for what you write about others. Photos may show other children; share them with care.
16Changes to this policy
We will notify you in the app and by email at least [30 days] before a material change takes effect.
17Contact
Tercel Nova Ltd, 0200101018. Email: info@tercelnova.com.