Privacy Policy

G3N, operated by Merolav Technologies.
Effective date: 10 August 2026  ·  Last updated: 17 August 2026

This policy explains, in plain language, what personal information G3N collects, why we collect it, how we protect it, and the choices you have. It applies to the G3N mobile and web applications and covers learners of all ages, including children.

We designed our data practices to meet the Ghana Data Protection Act, 2012 (Act 843), and to generalise to stricter regimes such as the EU/UK GDPR and the US COPPA children's-privacy standard, so that the same protections travel with your data wherever you are.

1. Who we are

G3N is an educational application built by Merolav Technologies. For the purposes of data protection law, Merolav Technologies is the data controller for the personal data described in this policy. You can reach us using the details in the Contact section.

2. What we collect and why

We collect as little as possible, and we organise data into tiers by sensitivity. Most of the app works with data that is not tied to your real-world identity.

Learning & usage data (not personally identifying)

What	Why
A random, pseudonymous ID for your device/profile	To connect your activity together without using your name
Which topics you practise, how long you spend, retries, hint usage, crash/error logs	To improve teaching quality, personalise your review, and keep the app reliable
Quiz and assessment scores, mastery/progress state	To show your progress and adapt what we teach you next

We do not record the free-text content of your answers or your tutor conversations in our analytics. Tutor session transcripts stay on your device unless you explicitly choose to share them.

Voice and image data (AI features)

Some features work by sending audio or images to our cloud AI provider (Google Cloud). Live captioning and the G3N Early spoken reading, writing and counting lessons send microphone audio for speech-to-text; the G3N Early writing lessons and image scanning send a photo for the AI model to read or describe. In G3N Early this means a child's spoken answers and photos of their handwriting are sent to the cloud. This audio and these photos are sent without your name or identifying details, are used only to provide the feature (never for advertising), are processed under a data-processing agreement, and are not stored on our servers after the request. For children, these features run only after a parent or guardian has consented.

Account data (only if you create an account)

What	Why
Phone number or email (stored hashed)	To sync your progress across devices and recover your account
For guardian accounts: phone number + PIN, and a record of parental consent	To let a parent/guardian set up and consent for a child

Sensitive data (only if you opt in for specific features)

What	Why
Exam registration number and final exam grades	Only if you choose features such as an outcome/university-match report — never required to use the app
School name, region, home language	Optional personalisation and cohort analysis

Sensitive data is stored separately, under stricter access controls, and is only used for the specific purpose you consented to.

3. Our legal basis for processing

• Legitimate interest for non-identifying usage and reliability data that is necessary to provide and improve the service.
• Consent for saving learning progress, creating an account, and for any sensitive data. We ask at the moment the feature would help you, and you can decline and still use the core app.

4. Children's data and parental consent

• Generative-AI features are gated for children. If a user is under the age threshold, AI-generated content is blocked until a parent or guardian provides consent.
• Guardian accounts and verifiable consent. A parent/guardian can create an account and consent on a child's behalf. For the G3N Early track (voice- and handwriting-based lessons for ages 5–8), the parent verifies they are an adult by completing a mobile-money or card payment, which serves as verifiable parental consent under COPPA's monetary-transaction method. We record that consent in an append-only ledger. A parent can withdraw consent at any time, which stops the AI voice lessons and lets them delete the child's data.
• School-mediated consent. Where a school enrols students, consent may be provided by the school under a signed data-processing agreement, acting in loco parentis, instead of an individual parental checkbox.
• Minimal collection. For children we avoid collecting real-world identifiers wherever possible and keep most learning data pseudonymous.

If you believe a child has provided us personal data without appropriate consent, contact us and we will delete it.

5. Data stored only on your device

Some information — such as chat history, journal entries, and story progress — is kept on your device and not on our servers. On-device data is encrypted at rest. You can erase it at any time from Settings → Delete My Data.

6. Who we share data with

We do not sell your personal data or use it for third-party advertising. We share data only with service providers who help us run G3N, under data-processing agreements:

Provider	Purpose
Google Cloud (Vertex AI, Cloud Run, Cloud SQL)	AI processing and secure hosting. AI requests do not include your name or identifying information — only the lesson context and structured prompt.
One-time-passcode / SMS provider	Sending login and verification codes (if you use an account)
Payment processor (Paystack)	Processing payments, if you make one

7. Where your data is processed

Your data is processed and stored in a defined cloud region, and identified outcome data collected in Ghana stays within that region. We do not route identified data across jurisdictions unnecessarily. This posture is designed to satisfy the cross-border transfer rules of the Ghana Data Protection Act and equivalent GDPR expectations.

8. How long we keep data

• Pseudonymous learning/usage data: retained to improve the service; it is not linked to your identity.
• Account data: kept while your account is active; deleted within 30 days of your deletion request.
• Sensitive data: kept while your consent is in force; deleted within 30 days of you withdrawing consent.
• Consent records: kept as an append-only audit trail (withdrawals are recorded, not erased).

9. How we protect your data

• Encryption in transit (TLS) on all connections; cleartext traffic is disabled.
• Encryption at rest, both on the device and in our cloud database.
• A strict separation between analytics data and identity data, enforced so that engineers working on learning models cannot access phone numbers or emails.
• We request only the permissions we need — we do not access your contacts or location.

10. Your rights

Depending on your jurisdiction, you have the right to access, correct, delete, or export your personal data, to withdraw consent, and to object to certain processing. You can:

• Delete on-device data any time via Settings → Delete My Data.
• Request deletion of account and sensitive data by contacting us — completed within 30 days.
• Lodge a complaint with the Ghana Data Protection Commission (or your local data-protection authority).

11. Changes to this policy

We may update this policy as the app evolves or as the law requires. We will change the "Last updated" date above and, for material changes, provide notice in the app.

12. Contact us

For any privacy question or request, contact:

Merolav Technologies
Email: george.nyarko@merolavtechnologies.site