Privacy notice template for apps built with Crew

DRAFT — not legal advice. Must be reviewed by a qualified Ghanaian lawyer before use with real customers or payments, and by a US lawyer before the planned Wyoming company takes over.

• Document: end-user-privacy-template
• Version: 1.0
• Effective date: 2026-11-13

Summary in plain language

This is a starting point for the privacy notice your own app shows its users. Crew fills it in from what your app really collects and where your users are, and you check it. You are responsible for the final notice, because you are in charge of your users' data.

How Crew uses this template

• Crew fills each {{placeholder}} from your app's actual data use: the fields in its database, its sign-in method, its payment setup, and the messages it sends. Crew does not guess. A section for something your app does not do is left out.
• Crew shows you the filled notice before you publish. You must read it, correct it and approve it.
• When you change your app, Crew checks whether the notice needs to change, and asks you to approve the update.
• The notice is linked from every page footer and the sign-up screen, as a real page with headings, readable by screen readers.

• Crew asks where your users are, and adds the matching "If you live in…" parts below. Your own country's part is always included.

Planned: this filling step comes with hosted apps (ADR-0053) and is not built yet. Today's live sites collect no personal data; their footer links Crew's own notice about how it counts visits.

The template

The text below is what your users see. Lines that start with Instruction: are for Crew and for you, and are removed.

Privacy notice for {{app_name}}

Last updated: {{last_updated}}

Who we are

{{app_name}} is run by {{owner_legal_name}}, {{owner_address}}. We are responsible for your personal data. Contact us at {{owner_contact_email}}{{owner_contact_phone_optional}}.

What we collect

Instruction: Crew lists only what the app really collects, one line each. Examples:

• Your account: {{account_fields}}, for example your name, email address and phone number.
• Your password: stored only in a scrambled form that cannot be reversed.
• Your orders or bookings: {{order_fields}}.
• Messages you send us: {{message_fields}}.
• Files you upload: {{upload_kinds}}.
• Payments: handled by Paystack. We do not see your full card number or mobile money PIN. We receive the amount, date and a reference.

We do not use advertising trackers. {{cookie_statement}}

Instruction: Crew sets cookie_statement from the app: for example "We use one cookie to keep you signed in, and nothing else."

Why we use it

• To provide the service you asked for: {{core_purpose}}.
• To take payment, and keep accounts the law requires.
• To keep the app secure and prevent fraud.
• {{optional_marketing_line}}

Instruction: Include marketing only if the app has an opt-in. Example: "To send you offers, only if you ask us to. You can stop at any time."

Who helps us

We use {{platform_name}} to build and host this app. It stores your data for us and may not use it for anything else. Other services we use:

• {{processor_list}}

Instruction: Crew lists each service the app really uses, with what it does and where. Example: "Paystack, payments, Ghana and Nigeria." GitHub and AI providers hold the app's code, not your data, and are not listed.

Where your data is stored

Your data is stored in {{storage_region}}. Our providers must protect it as the law where you live requires. {{transfer_statement}}

Instruction: Crew sets transfer_statement from the regions below. Example for EU users: "When your data leaves Europe, it is protected by the European Commission's Standard Contractual Clauses."

How long we keep it

• Your account: while it is open, then {{account_retention}} after you close it.
• Orders and payments: {{payment_retention}}, for tax and accounting.
• {{other_retention}}

Your rights

Wherever you live, you can ask us to:

• show you the data we hold about you, and give you a copy;
• correct it;
• delete it;
• stop using it for a purpose you object to;
• give it to you in a common format, to take elsewhere.

Contact {{owner_contact_email}}. We will answer within {{response_days}} days.

You can also complain to {{home_regulator}}.

If you live in…

Instruction: Crew includes only the parts for where the app's users are, one short paragraph each, and leaves the rest out. Each part names the law and the regulator, for example:

• Ghana: the Data Protection Act, 2012 (Act 843); the Data Protection Commission (dataprotection.org.gh).
• The EU, the EEA or the UK: the GDPR or the UK GDPR, with restriction and portability; your local data protection authority, or the ICO in the UK. {{eu_representative_optional}}
• California: we do not sell or share your personal information; you can know, delete and correct it.
• Nigeria: the Nigeria Data Protection Act, 2023; the Nigeria Data Protection Commission.
• Kenya: the Data Protection Act, 2019; the Office of the Data Protection Commissioner.
• South Africa: POPIA; the Information Regulator.

Children

{{children_statement}}

Instruction: Default: "This app is not meant for children under 18, and we do not knowingly collect their data." Change it only if the owner has checked the law and Crew has agreed the app is set up for children.

Changes

We will update this notice when we change how we use your data, and tell you in the app or by email for important changes.

Placeholders Crew must fill

If a placeholder cannot be filled from real facts, Crew asks the owner, and does not publish until it is filled.