Crew Privacy Policy

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: privacy-policy
• Version: 1.0
• Effective date: 2026-11-13

Summary in plain language

We collect what we need to build and run your apps: your account, your projects, and what you say to Crew. Voice notes become text, then the recording is deleted. We record what you do in Crew, never what you say, to improve it. We do not sell your data, use ad trackers or cookies, or train AI on your content. The companies that help us are listed here, with where they are: mostly the EU and the US. You can see, correct, download or delete your data. Crew is run from Ghana, and you also keep the rights the law where you live gives you.

1. Who is responsible

The person or company that runs Crew ("Crew", "we") is the data controller for the personal data in this policy. That means we decide why and how it is used.

• Today: [OWNER FULL LEGAL NAME], an individual operating Crew from Ghana, [ADDRESS IN GHANA].
• Planned: around the end of December 2026, [CREW LLC], a Wyoming limited liability company, is to take over Crew. Planned: it does not exist yet. We will tell you in the app at least 30 days before, and publish a new version of this policy that names it.

This policy covers people who use Crew to build apps ("you"). It does not cover the people who use the apps you build. For their data, you are the controller and Crew is your processor. See the Data Processing Agreement.

The privacy laws that protect you depend on where you live. Section 9 explains the main ones.

2. What we collect

2.1 Your account

• Your name, email address and profile picture from your sign-in provider (Google, through Firebase).
• An account identifier we create.
• Your settings, such as notification choices, quiet hours and time zone.

2.2 Your projects and what Crew remembers

• What you ask Crew to build, typed or spoken, and every revision of it.
• Your answers to Crew's questions, and the decisions and plan made from them, with your own words as their source.
• Crew's replies to you, including spoken replies.
• The code, files, pictures and text that Crew generates, and the versions it publishes.
• Planned: a few facts about how you like to work, such as your name, language or whether you use a screen reader, each with the words you said. They apply across your projects, and you can see and delete them.

When you ask Crew to forget something, we replace its words with a note that it was erased, and rebuild anything made from it.

2.3 Voice

• Voice notes: we send the recording to ElevenLabs to turn it into text. We do not store the recording. It is held in memory for that one request, then discarded. We keep the text and a fingerprint (a SHA-256 hash) of the audio, so a repeated upload is not charged twice.
• Spoken replies: when Crew answers a voice note aloud, ElevenLabs turns Crew's reply text into speech. We keep that audio with the project.
• Device voice: by default your phone reads replies aloud itself. That speech does not leave your phone.
• Natural voice calls (optional): ElevenLabs runs the call. It is set to keep no recording and to delete transcripts within one day.

2.4 Your code in GitHub

Planned: being built. Each project's code is kept in its own private repository on GitHub, in Crew's organisation crewapps-projects. The repository also holds the project's plan and decisions, which can quote your words. It never holds your sign-in, payment details or secrets.

2.5 Your device

• A push-notification token for each phone you sign in on, its platform (Android or iOS) and its time zone. We use it only to send you Crew's notifications.
• The app's version number.
• If you test early versions of the app, Firebase App Distribution receives your email address and your device's model and system version.

2.6 Payments

Planned: buying credits is being built.

• Paystack processes payments. We never receive your card number.
• We send Paystack your verified email address so it can send your receipt. We do not store it with the payment.
• We receive payment details: the amount, currency, date, a reference, whether it succeeded, and any refund or dispute.
• We keep your credit balance and the record of what each credit was spent on.

2.7 Feedback

Planned: being built. If you send feedback in the app, we keep what you wrote, its kind, and the app version and platform, and email it to our team through Resend.

2.8 Records of agreement and security

• When you accept these documents, we record which version, a fingerprint of its exact text, when, the app version, and a keyed hash of your IP address. We do not store your IP address with the acceptance.
• Our servers keep short technical logs, such as errors and request times. We design logs to leave out the content of your requests and any secrets.

2.9 Sites made with Crew

• Visitors: when someone visits a live site, we count visits for its owner. The visitor's IP address and browser details are used for a moment to count unique visitors with a key that changes daily, and are never stored. We keep only daily totals, such as page views, country and phone or computer. Live sites set no cookies and run no tracking scripts.
• Reports: if you report a site, we keep your report and any contact details you give, to handle it and any appeal.

2.10 Analytics about Crew

What you do in Crew (product events). Our servers record the actions you take, so we can see where Crew helps and where people get stuck, run our accounts, and help you when you ask. Each record holds your account identifier, the project's identifier, what happened (for example: signed up, sent a message, answered a question, started a build, went live, bought credits), when, and a few small details such as a build's outcome or a credit pack's size. It never holds what you said or wrote. We keep these records for 13 months, then delete them. They are included when you download your data, and deleted when you delete your account.

Firebase Analytics in the app. The app uses Google's Firebase Analytics to understand how the app itself is used: which screens are opened, how long sessions last, and which app version, phone model, operating system and country they come from. It identifies you only by a scrambled code made from your account identifier (a one-way hash), never by your name, email or what you say.

• We turn off advertising identifiers, ad personalisation and Google signals. Google acts as our processor.
• Google Analytics keeps this data for 2 months, the shortest period it offers.
• If we copy it into our Google BigQuery storage to study it, the copy is kept for up to 60 days.
• If you live in the European Union, the EEA or the United Kingdom, the app asks for your agreement before it collects any of this.
• Anyone can turn it off in the app: Account, then Privacy, "Share usage analytics". Turning it off does not affect the product events above, which we need to run the service.

We also count builds, failures, timings and costs to keep Crew working. When Crew emails its own team about the service, such as a new number of users or a monthly finance summary, the email holds counts and totals, not your details. We do not use cookies, advertising IDs or third-party advertising trackers.

3. Why we use it, and our legal basis

Lawyer question: confirm the basis for each purpose under each law in section 9.

We do not sell your data. We do not use it for advertising. We do not use your content to train AI models, and our AI providers do not either under their commercial terms.

4. Who processes it for us

These companies process personal data for us, under contracts that limit what they may do. Regions are our understanding of each provider's setup and must be confirmed against signed terms before launch.

Paystack, Google Play and the Apple App Store also use data for their own purposes, such as fraud checks and store rules, under their own privacy policies.

Planned, not used yet. We will add each of these here, and tell you in the app, before it receives your personal data:

• OpenAI (Codex models) as a second engineer;
• an SMS provider in Ghana (Arkesel or Hubtel) and an email service, for apps with sign-in;
• an error-tracking service.

5. Sending data across borders

Crew is run from Ghana, and most of our providers store data in the European Union or the United States. Wherever your data goes, we send it only to providers bound by contract to protect it to a standard at least as high as this policy. Section 9 says what each law requires.

Lawyer question: what do Act 843 and the Data Protection Commission require for transfers abroad? Should we offer an Africa data region when one exists?

6. How long we keep it

Assumption: the 35-day backup period depends on our providers' settings. Confirm before launch.

7. How we protect it

• All traffic is encrypted (HTTPS). Our providers encrypt stored data.
• Each account and project is walled off in the database by row-level security, checked on every row.
• Short-lived, signed access tokens. Secrets are kept out of code, logs and screenshots.
• AI agents work in a sandbox, without access to GitHub, payments or other people's projects.
• Built apps are checked by automatic security tests before they are published, and each project's previews run on their own web address.
• Admin access is limited to the owner, read only, and every access is recorded.
• If a security breach puts your data at risk, we will tell you and the regulators the law requires, within the time it sets. Lawyer question: confirm the deadlines in each market.

No system is perfectly secure, but we work to protect your data.

8. Your rights

Wherever you live, you can ask us to:

• access: tell you what personal data we hold about you and give you a copy;
• download: give you your data in a common, machine-readable format;
• correct data that is wrong, out of date or incomplete;
• delete your data, or your whole account;
• forget something you told Crew;
• object to a use of your data, such as analytics, and stop it;
• restrict a use of your data while a complaint is checked;
• withdraw consent where we rely on it.

You can also complain to the regulator where you live (section 9).

To use a right, contact us (section 11). We may ask you to prove who you are. We answer within 21 days, or sooner if your law requires it. It is free, unless a request is clearly unfounded or excessive. Some data we must keep by law, such as payment records. We tell you if we cannot delete something, and why.

Crew does not make decisions about you with legal or similarly serious effects by automated means alone. Payments, refunds and suspensions are decided by fixed rules we publish, or by a person.

We do not send marketing without your agreement.

9. If you live in…

Each part below is a draft for the lawyers to check.

9.1 The European Union, the EEA or the United Kingdom

• The GDPR, or the UK GDPR, applies to how we handle your data, because we offer Crew to you.
• Legal bases: contract (Article 6(1)(b)), legal duty (Article 6(1)(c)), legitimate interests (Article 6(1)(f)) and consent (Article 6(1)(a)), as in section 3. You may object to any use based on legitimate interests.
• Your rights: all of section 8, including portability and restriction.
• Complaints: to the data protection authority where you live, work, or where you think the law was broken; in the UK, the Information Commissioner's Office (ico.org.uk).
• Transfers: Crew is run from Ghana, and your data goes to Ghana and the United States, which the EU and UK do not treat as giving equal protection in general. We rely on the European Commission's Standard Contractual Clauses, the UK's International Data Transfer Addendum, or a provider's certification under the EU-US Data Privacy Framework and its UK extension. You may ask us for a copy of the safeguards.
• Representative: [EU REPRESENTATIVE] and [UK REPRESENTATIVE]. Lawyer question: must Crew appoint an EU representative under Article 27 GDPR, and a UK one under the UK GDPR, or does the exception for occasional, low-risk processing apply? Which Standard Contractual Clauses module covers Crew itself as a controller outside the EU?

9.2 California and other US states

• We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We have not done so in the last 12 months, so there is nothing to opt out of.
• What we collect (section 2): identifiers (name, email, account and device identifiers), commercial information (credit purchases), internet or other electronic network activity (how you use Crew, section 2.10), audio (voice notes, deleted once transcribed), the content of your messages and projects, and technical logs. We do not use sensitive personal information to infer things about you.
• Your rights: to know what we collect, use and disclose; to delete; to correct; to opt out of sale or sharing; to limit the use of sensitive personal information; and not to be treated differently for using these rights. An agent you authorise may ask for you.
• Lawyer question: Crew is likely below the CCPA's thresholds today. We give these rights to everyone in California anyway. Confirm, and which other state laws apply.

9.3 Nigeria

• The Nigeria Data Protection Act, 2023 gives you the rights in section 8, including not to be subject to a decision made only by automated means.
• You can complain to the Nigeria Data Protection Commission.
• Lawyer question: does Crew need to register as a data controller of major importance, and which basis covers transfers out of Nigeria?

9.4 Kenya

• The Data Protection Act, 2019 gives you the rights to be informed, access, object, correct, delete and port your data.
• You can complain to the Office of the Data Protection Commissioner.
• Lawyer question: must Crew register with the Commissioner as a controller outside Kenya, and what do sections 48 to 50 require for transfers?

9.5 South Africa

• The Protection of Personal Information Act, 2013 (POPIA) gives you the rights to know, access, correct, delete and object, including to direct marketing.
• You can complain to the Information Regulator.
• Lawyer question: does POPIA apply to Crew as a business outside South Africa, must we register an information officer, and does section 72 allow our transfers?

9.6 Ghana

• Crew is run from Ghana. The Data Protection Act, 2012 (Act 843) applies to all our processing, and gives you the rights in section 8.
• You can complain to the Data Protection Commission, Ghana (dataprotection.org.gh). Confirm the current contact details before launch.
• Registration: Act 843 requires data controllers to register with the Commission. Flag: Crew must register before launch and show its number here: [DPC REGISTRATION NUMBER].

10. Children

Crew is for people aged 18 or over. A child aged 13 or over may use Crew only with a parent or guardian who accepts the terms, and no one under 13, or under the higher age the law sets where they live, may use it. We do not knowingly collect children's data without a guardian's agreement. If you think a child's data reached us without that, contact us and we will delete it.

Apps you build must not target children or collect their data unless you have checked the law and Crew has agreed the app is set up for it. See the Acceptable Use Policy.

11. Contact

• Data protection contact: [NAME OR ROLE], [privacy@crew domain]
• Post: [ADDRESS IN GHANA]
• In the app: Account, then Legal and help.

Tell us first if something is wrong, and we will try to fix it. You can always complain to your regulator (section 9).

12. Changes

We may update this policy. For a material change, such as a new provider or a new use of your data, we tell you in the app before it takes effect and ask you to accept again. Each version has a number and an effective date.