Privacy Policy

Complete Scholar is operated by Zero Miles Per Hour Ventures, and provides a cloud-based school management platform used by schools and educational organisations.

Address: Accra, Ghana
Email: support@completescholar.com

Depending on how the Service is used, we may process different categories of information.

Account information may include:

• name, email address, and phone number;
• username and password credentials;
• role and school affiliation.

Student information entered by schools may include:

• name, date of birth, and gender;
• admission number and class;
• academic records, attendance, and examination results;
• disciplinary information and photographs;
• guardian and enrollment information; and
• boarding and transport information.

Parent/guardian information may include:

• name, phone number, email, and address;
• relationship to student;
• communication preferences and payment information.

Teacher and staff information may include:

• name and contact information;
• employment information and assigned subjects or classes;
• attendance and payroll-related information where supported; and
• qualifications and other information entered by the school.

Financial information may include invoices, fee records, payment status, transaction references, payment history, and scholarship information. We generally do not need to store complete payment-card details where payment processing is handled by a third-party payment provider.

School systems may contain information that is more sensitive than ordinary account information, such as medical information, disability-related information, disciplinary records, biometric information (if supported), emergency contact information, and information concerning minors.

Schools should only provide information necessary for legitimate educational or administrative purposes. Complete Scholar will apply appropriate safeguards to information processed through the platform.

We may receive information directly from you — for example, when you create an account, contact support, subscribe, submit a form, or communicate with us.

We may also receive information from your school about its students, parents, teachers, staff, and administrators.

We may automatically collect technical information when you use the platform, such as:

• IP address, browser type, device type, and operating system;
• login information and timestamps;
• pages or features accessed; and
• error logs and security events.

We may use personal information to provide Complete Scholar; create and manage accounts; authenticate users; manage subscriptions and process payments; provide customer support; send system, SMS, and email notifications; maintain security and detect fraud or abuse; troubleshoot technical problems; improve our services and generate reports; maintain backups; comply with legal obligations; and communicate important information about the Service.

We will not use personal information for purposes incompatible with the purposes for which it was collected, except where permitted or required by law.

When a school uses Complete Scholar to manage information about its students, parents, teachers, and staff, the school generally determines the purposes for which the information is collected and used, while Complete Scholar provides the technology and processes the information to provide the Service.

The school is therefore responsible for determining the appropriate lawful basis for collecting and using its users' information. Complete Scholar processes that information according to the school's instructions, our agreement with the school, applicable law, and our legitimate operational requirements. Where appropriate, these responsibilities will be further defined in a Data Processing Agreement.

Depending on the circumstances, personal information may be processed on the basis of consent; performance of a contract; compliance with a legal obligation; protection of vital interests; legitimate interests; or another lawful basis permitted under applicable law. The exact legal basis may depend on whether Complete Scholar or the school is responsible for the relevant processing activity.

Complete Scholar is designed for use by educational institutions and may process information relating to children and students. Because children may be particularly vulnerable data subjects, schools are responsible for ensuring that appropriate notices, permissions, lawful bases, and safeguards are in place when collecting and processing student information.

Complete Scholar will process student information only for legitimate purposes connected with providing the Service and according to the applicable agreement with the school.

We may share personal information with carefully selected service providers that help us operate Complete Scholar, including cloud hosting providers, SMS/USSD and email delivery providers, payment providers, and customer support or backup providers. Service providers may only receive information necessary to provide the relevant service.

We may also disclose information where required by law or pursuant to a valid legal process; to protect the rights, safety, or security of users; to investigate fraud or abuse; or during a corporate transaction such as a merger, acquisition, or sale of assets.

We do not sell student personal information.

When payments are made through Complete Scholar, transactions may be processed by third-party payment providers, subject to their own privacy policies and terms. We may receive information such as transaction ID, amount, payment status, payer information, payment method, and reference information. Where possible, sensitive payment credentials such as complete card numbers remain with the payment provider rather than Complete Scholar.

If a school uses Complete Scholar to send SMS or email communications — including campaign and automated messages — information necessary to deliver them, such as recipient name, phone number, email address, message content, and delivery information, may be shared with the relevant messaging provider. A guardian may opt out of a school's marketing-style communications; account, billing, and security communications cannot necessarily be opted out of while the account remains active. The school is responsible for ensuring that its communications comply with applicable laws and its obligations to recipients.

Where a guardian interacts with Complete Scholar through a USSD session (for example, to register or check information via a short code), the USSD network operator and our USSD service provider receive the guardian's phone number and the information exchanged during that session in order to route and process it. This is a separate channel from SMS/email and is subject to the operator's and provider's own technical handling of that session.

Complete Scholar may use cookies and similar technologies to keep users logged in, remember preferences, maintain security, understand platform usage, and improve performance. Where required, users will be provided with appropriate choices regarding non-essential cookies.

We implement reasonable technical and organisational measures designed to protect personal information against unauthorised access, unauthorised disclosure, loss, alteration, destruction, or misuse — including encryption, access controls, authentication, logging, backups, monitoring, security updates, and restricted administrative access. However, no internet-based system can guarantee absolute security.

We retain personal information for as long as an account remains active, and afterward for as long as reasonably necessary for fulfilling contractual obligations, complying with legal obligations, resolving disputes, maintaining security, enforcing agreements, or other legitimate purposes. We do not automatically delete a school's information when its subscription ends — a school (or an individual, where the school is unable to act) may request deletion at any time by contacting us, and we will action a genuine request within a reasonable time subject to the exceptions above. The specific retention period may otherwise depend on the type of information, the purpose for which it was collected, legal requirements, the school's instructions, and operational requirements.

Complete Scholar may use cloud infrastructure or third-party providers located outside Ghana. Where personal information is transferred across borders, we will take appropriate steps to ensure that the transfer and processing comply with applicable data protection requirements.

Depending on applicable law and the circumstances, individuals may have rights relating to their personal information, including rights to access personal information; request correction of inaccurate information; request deletion where applicable; object to or request restriction of certain processing; withdraw consent where processing is based on consent; request information about how their data is processed; and seek redress where their rights have been violated.

Where Complete Scholar processes information on behalf of a school, requests relating to student or staff records may need to be directed to the relevant school.

Privacy requests can be sent to support@completescholar.com. Please include enough information for us to understand and respond to your request. Where the request concerns information controlled by a school, we may direct the request to the relevant school.

Where applicable, our Data Protection / Privacy Contact is [NAME OR TITLE], reachable at support@completescholar.com or [PHONE]. The Ghana Data Protection Commission provides compliance guidance for organisations processing personal data, including registration, data protection principles, and DPIA considerations.

Where we become aware of a personal-data security incident affecting information processed through the Service, we will take appropriate steps to:

1. investigate the incident;
2. contain and remediate the issue;
3. assess the potential impact;
4. notify affected parties and/or the relevant authority where required by law; and
5. implement measures to reduce the likelihood of recurrence.

Complete Scholar may contain links or integrations to third-party websites and services. We are not responsible for the privacy practices of third-party services, and users should review the privacy policies of those services before providing personal information.

We may send service-related communications such as account notifications, security alerts, billing notices, maintenance notices, and important product updates. Where legally permitted, we may also send marketing communications, which users may unsubscribe from where applicable. Service and security communications cannot necessarily be opted out of while maintaining an active account.

We may update this Privacy Policy from time to time. When material changes are made, we may notify users through the platform, email, or another appropriate method, and the updated policy will include a revised "Last Updated" date.

Complete Scholar
Operated by: Zero Miles Per Hour Ventures
Address: Accra, Ghana
Privacy Email: support@completescholar.com
Support Email: support@completescholar.com
Phone: [PHONE NUMBER]