TovCare
Privacy Policy
1. Who we are
TovCare (“TovCare”, “we”, “us”) is operated by TODO legal entity name, company registration number, registered address, Kigali, Rwanda. We provide a childcare management platform made of native Android and iOS apps, a web administration dashboard at admin.tovcare.app and an API, used by daycare centers and preschools (“Centers”) and by the parents and guardians of enrolled children (“Parents”).
Questions and requests about personal data: contact@tovcare.app. TODO: replace with a dedicated privacy address and name a data protection contact person if required.
2. Our role: controller and processor
For information about children, parents and staff that a Center enters into TovCare, the Center decides why and how that information is used. The Center is the data controller and TovCare is the data processor acting on the Center's instructions under a data processing agreement.
For account credentials, security logs, billing of Centers and communications with us, TovCare is the data controller.
If you are a Parent and want to know how your Center uses your family's information, contact the Center first. We will help the Center answer you.
3. The governing law
We process personal data in accordance with Rwanda's Law No. 058/2021 of 13 October 2021 relating to the protection of personal data and privacy and its implementing regulations. The supervisory authority is the National Cyber Security Authority (NCSA). Where Centers operate in other countries of East Africa, local data protection law may also apply.
4. What we collect
| Category | Examples | Who provides it |
|---|---|---|
| Account data | Name, phone number, email address, Google account identifier (when using Google Sign-In), role at the Center, profile photo. | You, or the Center that invites you |
| Child profile | Name, date of birth, gender, room and program, enrollment dates, photo, allergies and medical notes, emergency contacts, people authorized to pick up the child. | The Center and the Parent |
| Attendance | Check-in and check-out times, who dropped off and picked up, late-pickup records. | Center staff |
| Daily updates and photos | Meals, naps, mood, activities, incident notes and photos or short videos of the child during the day. | Center staff |
| Messages | Messages and announcements exchanged between Center staff and Parents inside TovCare. | Staff and Parents |
| Payment data | Invoices, amounts in RWF or USD, payment method, MTN Mobile Money phone number and transaction reference, payment status, receipts. We do not collect card numbers; card payments are disabled. | The Center, the Parent and MTN |
| Device and technical data | Push notification token, app version, operating system, device identifiers needed for security, IP address, time zone, crash and error logs. | Your device |
| One-time passcodes | The phone number and 6-digit code used to sign in; codes expire after 5 minutes. | You |
We do not collect data directly from children. We do not use advertising trackers, and the apps and this website contain no third-party analytics.
5. Children's data and parental consent
TovCare exists to help adults care for children. All children's data is entered by a Center or by the child's Parent or legal guardian. Before a Center enrolls a child in TovCare, the Center must obtain the consent of a parent or guardian to process the child's personal data for the purposes in this policy, including photos. Parents can withdraw consent by contacting the Center; the Center can then stop photos or close the child's profile.
Parents cannot self-register into a Center. A Center creates the child's profile and issues an invite code, and only a person with that code can be linked to the child.
6. Why we use personal data
- Running the Center's service to families: enrollment, attendance, daily updates, photos and messaging (performance of the Center's agreement with the Parent and consent for photos).
- Collecting fees: issuing invoices, processing MTN Mobile Money payments, recording receipts and reconciling payments (performance of a contract).
- Security and account protection: sign-in, one-time passcodes, session tokens, fraud and abuse prevention, audit logs (legitimate interest and legal obligation).
- Notifications: push notifications, SMS and email about your child, your account or your invoices (performance of a contract). Marketing messages are sent only with your consent and you can opt out at any time.
- Improving the service: aggregated usage statistics and crash reports that do not identify individuals (legitimate interest).
- Legal obligations: tax, accounting and responding to lawful requests from authorities.
7. Who we share data with
We share personal data only with providers that help us run TovCare, under contracts that restrict what they can do with it:
| Provider | What for | Data involved |
|---|---|---|
| MTN Rwanda (MTN Mobile Money) | Collecting fee payments requested by the Center | Payer phone number, amount, currency, transaction reference |
| Google (Firebase Cloud Messaging) | Delivering push notifications to Android and iOS devices | Device push token, notification content |
| Google (Google Sign-In) | Optional sign-in on Android and the web admin | Google account identifier, name, email |
| Apple (Apple Push Notification service) | Delivering push notifications to iOS devices | Device push token, notification content |
| Cloudflare (R2 object storage, DNS, Pages) | Storing photos and documents; serving this website | Photos, attachments, IP addresses in edge logs |
| Twilio and Africa's Talking | Sending one-time passcodes and SMS notifications | Phone number, message content |
| Fly.io | Hosting the API, database and background workers (region: Johannesburg, South Africa) | All application data |
| Email delivery provider | Sending invoices, receipts and account emails | Email address, message content TODO: name the provider |
We do not sell personal data. We do not share children's data with advertisers. We may disclose data if required by law or to protect the safety of a child.
8. Where data is stored and international transfers
Application data is hosted in South Africa (Fly.io, Johannesburg region) with encrypted backups, and photos are stored with Cloudflare R2. This means personal data is stored outside Rwanda. TODO: state the legal basis for the transfer (NCSA authorisation reference or applicable exemption) or the date by which hosting moves to Rwanda.
9. How long we keep data
| Data | Retention |
|---|---|
| Child profile, attendance, daily updates, photos, messages | While the child is enrolled, then TODO 12 months after withdrawal, unless the Center or Parent asks for earlier deletion |
| Invoices, payments and receipts | TODO 10 years after the transaction, as required for accounting and tax |
| Account data | While the account is active, then TODO 90 days after closure |
| Security and access logs | TODO 90 days |
| One-time passcodes | 5 minutes |
| Encrypted backups | TODO 35 days rolling |
10. How we protect data
All traffic is encrypted in transit (TLS). Each Center's data is isolated at the database level so that no Center can see another Center's families. Photos and documents are never public: they are accessible only through time-limited links issued to signed-in users. Backups are encrypted. Access by TovCare staff is limited to what is needed to operate and support the service and is logged. If a breach affects your personal data we will notify the Center, the affected people and the NCSA as required by law.
11. Your rights
Under Rwandan law you have the right to:
- access the personal data we hold about you or your child and receive a copy;
- correct inaccurate or incomplete data;
- ask for deletion of data that is no longer needed;
- object to or restrict certain processing, and withdraw consent (for example for photos) at any time;
- receive your data in a portable format;
- not be subject to decisions based solely on automated processing;
- lodge a complaint with the National Cyber Security Authority.
To exercise these rights, contact your Center or write to contact@tovcare.app. We will respond within TODO 30 days. We may need to verify your identity first.
12. Cookies and this website
This website sets no cookies and uses no analytics. The admin dashboard at admin.tovcare.app stores a session token in your browser so you stay signed in; it is strictly necessary for the service.
13. Changes to this policy
We will post changes on this page and update the effective date. For significant changes we will notify Centers and Parents through the app or by email before they take effect.
14. Contact
TovCare, TODO registered address, Kigali, Rwanda. Email: contact@tovcare.app.