Creare Concepts, trading as Ladybug Portal ("we", "our", or "us"), is committed to protecting the privacy and security of all users of the Ladybug Portal platform. This Privacy Policy explains how we collect, use, store, share, and protect your personal data, and sets out your rights as a user or data subject.

 

This policy applies to all users of the Platform, including school administrators, teachers, students, parents, and guardians. Where users are minors, special provisions apply as set out in Section 8 below.

 

Creare Concepts is in the process of registering with Ghana's Data Protection Commission as required under the Data Protection Act, 2012 (Act 843). Until registration is confirmed, we operate in accordance with the Act's requirements. We recommend schools also confirm their own compliance obligations with the Commission.

 

1. Our Legal Framework

Our primary data protection obligations are governed by:

• Ghana's Data Protection Act, 2012 (Act 843)
• Ghana's Electronic Communications Act, 2008 (Act 775)
• Any applicable sector-specific regulations issued by the Ghana Education Service

Where Creare Concepts processes data on behalf of a School, the School acts as the data controller and Creare Concepts acts as the data processor. This means the School determines the purposes for which data is processed, and Creare Concepts processes that data only on the School's instructions and in accordance with this policy.

 

Our practices are aligned with international data protection standards. However, we do not claim formal compliance with the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), as these apply to entities operating within those jurisdictions.

 

2. Data We Collect

1. Personal Information

   • Full name, gender, nationality, date and place of birth
   • Contact details — email address, phone number, residential address
   • Identification and affiliation details

2. Financial Information

   • Fee payment records, outstanding balances, and payment history
   • Payment transaction data processed through Paystack (our third-party payment processor)
   • Note: Creare Concepts does not store full card or bank account details. These are handled exclusively by Paystack.

3. School and Academic Data

   • Student enrolment records, class assignments, and academic year data
   • Attendance records and disciplinary data
   • Curriculum plans, assessment results, lesson plans, and academic progress
   • Report cards and generated academic reports

4. Technical and Usage Data

   • IP address, device type, browser type, and operating system
   • Login timestamps, session duration, and usage patterns
   • System interaction logs for security and performance monitoring

5. Communication Data

   • Messages or correspondence sent through or to the Platform
   • Support requests and responses

6. Sensitive Data

   • Health-related information about students (e.g. allergies, medical conditions) where provided by the School for safeguarding purposes
   • This category of data is collected only where necessary and with explicit consent from the parent or guardian

 

3. How We Use Your Data

• Administration — enrolment management, attendance tracking, and student record management
• Academic delivery — lesson planning, curriculum management, and assessment tracking
• Financial management — fee processing, invoice generation, and financial reporting for schools
• Communication — account notifications, service updates, and system alerts
• Security — fraud detection, access control, and protection against unauthorised use
• Service improvement — anonymised and aggregated usage analytics to improve Platform performance
• Legal compliance — retention and processing of records as required by Ghanaian law

 

4. Data Storage and Security

Creare Concepts takes the security of your data seriously. Key measures include:

• Each school's data is stored on a dedicated server environment, physically and logically isolated from other schools' data. This means a security incident affecting one school cannot spread to another.
• Sensitive data is encrypted in transit and at rest.
• Access to data is controlled through role-based permissions. Users can only access data relevant to their role.
• Regular security reviews and backup procedures are in place.
• In the event of a data breach, affected schools and users will be notified promptly and remediation steps will be taken immediately.

 

5. Third-Party Data Sharing

We share data with third parties only where necessary and under strict conditions:

• Paystack — for secure processing of fee payments. Paystack operates under its own privacy policy and is PCI-DSS compliant.
• Server and infrastructure providers — for hosting and maintenance of the Platform.
• Legal authorities — where required by Ghanaian law, court order, or regulatory authority.
• Creare Concepts does not sell personal data to any third party. We do not share data for advertising or marketing purposes.
• All third-party service providers are contractually bound to process data only for the purposes for which it was shared and to maintain appropriate security standards.

 

6. Data Retention

We retain different categories of data for different periods:

• Active user data — retained for the duration of the School's subscription and for 90 days following termination.
• Financial transaction records — retained for a minimum of 7 years in accordance with Ghanaian financial regulations.
• Student academic records — retained for the duration of the School's subscription. Schools may export all records before termination.
• Security and access logs — retained for 12 months.
• After applicable retention periods, data is securely and permanently deleted.

 

7. Your Rights

As a data subject under Ghana's Data Protection Act, you have the following rights:

• Access — the right to request a copy of the personal data we hold about you.
• Correction — the right to request correction of inaccurate or incomplete data.
• Deletion — the right to request deletion of your data, subject to legal retention obligations.
• Restriction — the right to request that we limit processing of your data in certain circumstances.
• Objection — the right to object to processing of your data for analytics or other non-essential purposes.
• Portability — the right to receive your data in a structured, machine-readable format.

 

To exercise any of these rights, please contact us at privacy@ladybugportal.com. We will respond within 21 days. Where a request relates to a student's data, it should be made by the School Administrator or the student's parent or guardian.

 

8. Children's Privacy

Creare Concepts recognises the particular sensitivity of data relating to minors and takes the following steps:

• Student data is collected and processed only for the educational and administrative purposes described in this policy.
• Schools are responsible for obtaining parental or guardian consent before enrolling students under 13 on the Platform.
• Sensitive data relating to minors — including health information — is collected only with explicit parental or guardian consent and is treated with the highest level of protection.
• Student accounts are accessible only to the student, their designated teachers, school administrators, and their registered parent or guardian.
• Creare Concepts does not use student data for advertising, profiling, or any commercial purpose beyond the delivery of the Platform.

 

9. Cookies and Tracking

The Platform uses cookies and similar tracking technologies. Full details are provided in our separate Cookies Policy available at www.ladybugportal.com/cookies-policy. In summary:

• Essential cookies — required for the Platform to function. These cannot be disabled.
• Performance cookies — used to monitor Platform performance and identify technical issues.
• Analytics cookies — used to understand how users interact with the Platform, in order to improve it.
• Users can manage non-essential cookies through their browser settings or the cookie preference centre on the Platform.

 

10. Changes to This Policy

• We may update this Privacy Policy periodically to reflect changes in our practices or applicable law.
• Schools will be notified of material changes via email at least 30 days before they take effect.
• The current version of this policy is always available at www.ladybugportal.com/privacy-policy.

 

11. Contact and Complaints

For any questions, requests, or complaints regarding this Privacy Policy or our data practices, please contact:

 

Data Protection Contact — Creare Concepts

Email: privacy@ladybugportal.com

Address: Accra, Ghana

Website: www.ladybugportal.com

 

If you are not satisfied with our response, you have the right to lodge a complaint with Ghana's Data Protection Commission: www.dataprotection.org.gh