Privacy Notice

This notice explains what information Jojo Bloom by ZION collects, why, who can see it, how long we keep it, and what your rights are under the Protection of Personal Information Act (POPIA). It is a draft: the parts in [square brackets] still have to be completed and the whole notice reviewed by a South African privacy lawyer before real families use the app.

Who is responsible

[Legal name of the responsible party] is the responsible party. Our Information Officer can be reached at [Information Officer email address]. If a school or therapy practice uses the app for its children, [explain who is responsible for what].

What we collect

• Your account: your name, email address, the role you chose, the country and time zone you chose, and when you accepted these documents. We use your time zone to show every time in your local time, and your country to give you the right notices. You choose both yourself and can change them on your account page; we do not work them out from your location.
• Information about a child, entered only by a parent or guardian: a preferred name, age or birth date, an optional photo, allergies, medicine and emergency notes, emergency contacts, and optional details about how the child communicates, eats, sleeps and plays. Some of this is health information, which the law treats as special personal information.
• Records written by people a parent invited: daily updates, therapy session records, goals and progress, notes, comments and messages. These may describe a child's development and support needs.
• Care handovers: the details a parent chooses to share with a temporary caregiver for a set time.
• Who looked and when: a log of invitations, changes to access, and when someone opened a child's details, including the emergency view.
• Feedback you send us: what you tried to do, what got in the way, and an optional screenshot. Please do not include a child's name or face in a screenshot.

We do not track your location, read your contacts, or collect advertising identifiers, and the app uses no analytics or advertising tools.

Why we use it, and our lawful basis

To let you sign in, and to let the people a parent or guardian chooses care for a child safely and keep each other informed. We do not sell personal information or use it for advertising. [Lawyer to confirm the lawful ground for each use, and the basis for processing children's and health information, including parental or guardian consent.]

Who can see it

A child's information is private to their parents or guardians. A teacher, therapist or caregiver sees it only if a parent or guardian invites them, and only the parts the parent allows, for as long as the parent allows. Having a particular role in the app never gives someone access to a child. A parent can remove anyone at any time and it takes effect at once. Parents can read the conversations and records about their own child. Our team can see feedback you send us, and the people who run the service can reach the database to keep it running.

Who else handles it

We use service providers to run the app: Supabase (database, sign-in and file storage) and [hosting provider]. They handle information only on our instructions, under a written agreement. [Operator agreements to be signed and reviewed.]

Where it is stored

Information is stored in [region, confirm before launch], which is outside South Africa. [Legal review: basis for transferring information across borders.]

How long we keep it

We keep a child's information until a parent or guardian deletes it or deletes their account. Some housekeeping data is removed automatically after a set time: read notifications, ended care handovers, withdrawn message text, finished feedback, finished requests and the access log. [Periods to be decided and reviewed by a lawyer.] Backups can keep deleted information until they expire, which is [period].

Your rights

• See it: you can download your information from "My account" at any time, or ask for a fuller copy that includes messages.
• Correct it: parents can change their children's details at any time, and every change is kept in a history. Professionals can correct or withdraw their own records; the earlier wording is kept for the record.
• Delete it: you can ask for your account to be deleted from "My account". We check who you are first. A child whose only guardian you are is deleted with all their records. A child with another guardian stays with them. Things you wrote in shared places, such as updates, messages and shared notes, stay so other families keep their record, and show as "Former member".
• Object to how your information is used.
• Complain to the Information Regulator (South Africa) if you are unhappy with how we handle your information. [Add the Regulator's current contact details.]

Keeping it safe

Sign-in sessions are protected, access to information is enforced in the database itself, we limit repeated sign-in attempts, and our logs hold error codes, not names or messages. No system is perfectly secure. If there is a breach that affects you, we will tell you and the Information Regulator as the law requires, as soon as reasonably possible.

Children

Children do not use the app and cannot have accounts. Only an adult with parental responsibility should add a child.