Privacy notice
DRAFT for Oluremi O. Balogun (consent and safeguarding) to review before testing with learners. It follows the Nigeria Data Protection Act 2023 (NDPA) and describes what the Magana app, server and portal do today. When they change, this notice changes in the same commit. Points marked [check] need a decision or a legal check.
Last updated: 26 October 2026 · Contact: maganasupport@gmail.com
The short version
- Photos and PDFs of your papers are read and then deleted. They are never saved on the server or kept on your phone.
- What Magana reads for you stays on your phone, unless you save it to your library (30 days) or share it.
- No tracking. The app and website have no analytics, no trackers and no crash reporting.
- Magana never asks for your bank PIN or any account password. The one password it may ask for is a locked PDF's own, to open that one file. It is never saved.
- On WhatsApp (adults only), your photos pass through Meta's servers before Magana reads them.
- You can see, correct or delete what we hold about you, and complain to the Nigeria Data Protection Commission.
Who we are
Magana is a reading companion for blind and low-vision people in Nigeria, built and run by the Magana team. For this notice, "we" means the Magana team. We decide how Magana handles personal data, so under the NDPA we are the data controller.
When a school uses the teacher portal, the school decides what it records about its learners, and we hold it for the school. [check] The school is then the controller for its learner records and Magana is its processor; a short agreement with each school should say so.
What we collect, why, and our legal basis
The NDPA lets us use personal data only for a clear purpose and on a lawful basis. Health information is sensitive personal data, so we use it only with your explicit consent (you choose to read a health paper or take the quick check), or to protect someone's life in an emergency.
| What | Why | Legal basis | Kept |
|---|---|---|---|
| A photo or PDF of a page | To read it to you | Your consent: you choose to send it | Not kept. Read in memory on our server, then deleted. The phone deletes its copy once it is sent |
| A locked PDF's password | To open that one file | Your consent | Not kept. Used once, never saved or logged, never sent back |
| The text Magana read | So you can hear it again | Your consent | On your phone only. In your library only if you save it: 30 days |
| Your speech (answers, commands, questions) | To understand what you say | Your consent | Not kept. See "Speech recognition" |
| Quick health check answers | To set how soon a nurse calls you back | Explicit consent; vital interests for danger signs | Not kept. Never logged or stored |
| A call-back request: reason, phone number, language, priority | So a nurse or pharmacist can call you | Explicit consent | 30 days, then deleted. You can cancel it |
| Your age group and language | To show only what your age group may use, in your language | Legitimate interests; a guardian's consent for 13 to 17 | On your phone. Every request tells our server your age group |
| Reminders, saved questions, your Independence Score | For you | Your consent | On your phone only, until you delete them (score: last 90 days) |
| School, teacher and class records | To run the teacher portal | Contract with the school; legitimate interests | See "Teachers and schools" |
| Server logs: time, internet address, which page of our service was asked for, errors | To keep the service working and safe | Legitimate interests | Rotated: the oldest goes when 3 files of 10 MB are full (usually a few weeks) |
Server logs never contain photos, page text, recordings or health-check answers.
Speech recognition
When you speak an answer, a command or a question, Magana tries these in order:
- Your phone's own recogniser, where Android can recognise speech on the phone (usually Android 12 or later with an offline model). The audio never leaves your phone.
- Magana's own speech server (NCAIR1's Hausa, Yorùbá, Igbo and Nigerian-English models). The short recording is sent securely, recognised in memory and deleted at once.
- Adults only: the phone's usual recogniser, which may send the audio to Google or the phone maker.
- Otherwise, tap your answer. Everything works by tapping.
Learners under 18 never use step 3.
Children and age groups
- 18 and over: everything, including health and money papers.
- 13 to 17: school subjects only, after a parent or guardian agrees. No health or money papers, no WhatsApp, no open questions, no descriptions of people.
- Under 13: only in a session a teacher starts. Nothing from it is saved.
Under the NDPA, a child's data needs a parent's or guardian's consent. The class teacher records that consent in the teacher portal: how and when the guardian agreed (signed form, in person or by phone). We keep no guardian name or phone number. Until consent is recorded, a learner aged 13 to 17 can read schoolwork pages and nothing else. [check, DRAFT] Reading while waiting for consent is new.
Magana on WhatsApp is for adults only. If someone says they are under 18, Magana replies once, pointing them to the app with a teacher or guardian, and then reads nothing more from that number. It keeps only "under 18".
- Your photos pass through Meta's servers. Messages to a business on WhatsApp are delivered by Meta's WhatsApp Cloud API. Meta decides how long it keeps them to deliver them; its documentation says up to 30 days. If you don't want that, use the app, which sends photos straight to our server.
- On our server:
- your photo is read in memory and never written down;
- the text read is kept for 30 minutes, for "Read again";
- your language and age group are kept under a coded form of your number, not the number itself, until you ask us to delete them;
- quick-check answers are never written down;
- a call-back request is kept for 30 days.
- Our logs never show message text or phone numbers.
PDFs
"Read a PDF" sends a PDF to our server the same way as a photo. It is read in memory and deleted. If a bank locked the PDF, Magana asks for that PDF's password and says it is used only to open the file. It is never your bank PIN, app password or one-time code. The password is shown as you type it, so TalkBack can say it, so type it where no one can see or hear.
Health and money papers
Health papers, bank statements and letters are never sent to an AI model. Magana reads them exactly as printed, numbers included, and translates only with phrases a pharmacist has approved. Magana gives no diagnosis and no financial advice. Health questions go to a nurse or pharmacist, and danger signs to a clinic or 112.
Handwriting
Magana marks lines that look handwritten. It reads their numbers only when two separate readings agree, and never reads handwritten numbers on a health paper. Two optional readers for handwritten schoolwork exist:
- TrOCR runs on our own server.
- Azure AI Vision Read sends a crop of each handwritten line to Microsoft.
Both are switched off. Azure would be used only if we switch it on, for adults' schoolwork only, and this notice would say so first.
Teachers and schools
| What | Kept |
|---|---|
| The school's name, state and local government area | While the school uses Magana |
| The principal's name, role, email and phone (the phone only so we can confirm the school) | While the school uses Magana |
| Teachers' names, emails, roles and classes | While they work at the school. When removed, they are signed out at once; their name stays in the audit log |
| Sign-in codes | 10 minutes, in a form that can't be read back |
| Sign-in sessions | Until sign-out, 30 minutes without activity, or 12 hours |
| Classes and class codes | While the class exists. Codes are stored in a form that can't be read back, plus an encrypted copy for the class's teacher and the school's admins |
| A learner's class link: the name the teacher gives, formats, language, under 18 or not, consent status | While they are in the class. "Remove from class" unlinks the phone at once |
| The linked phone | A random token on the phone; we store only a coded form of it. No phone number |
| Attendance, and figures a learner chooses to share | This term |
| Teachers’ uploads (worksheets, notes) | Only the text Magana read, never the file. While the school uses Magana; email us to delete one |
| The audit log (who invited, removed or changed whom, and when) | While the school uses Magana. A deleted learner is blanked in it |
A teacher sees only their own classes; a school's admins see the whole school. The Magana team sees school registrations, to confirm them, but not learners. Teachers never see the pages learners photograph or the questions they ask.
Who else handles your data
We use a few service providers. They handle data only to provide their service to us:
| Provider | What for | What they see |
|---|---|---|
| Amazon Web Services (London, UK) | Our server | Everything our server handles, encrypted on the way |
| Amazon SES | Sending teachers' sign-in codes and invitations | Teachers' email addresses |
| Cloudflare | Our domain names, and hosting the website and web app | Visitors' internet addresses |
| Meta (WhatsApp) | Delivering WhatsApp messages | WhatsApp messages and photos |
| The Ibà service | Working out call-back priority from the quick check | The answers, never stored |
| Google or the phone maker | Speech recognition, adults only, as a last resort | That short recording |
| Microsoft (Azure) | Handwriting, only if we switch it on | Crops of handwritten schoolwork lines |
During development the team also runs the explanation model on temporary Kaggle notebooks, with the team's own test pages only, never users' papers.
Data stored outside Nigeria
Our server is in London, United Kingdom. Sending personal data outside Nigeria is allowed under the NDPA when it stays adequately protected. The UK has its own data protection law, and we protect the data the same way wherever it is: encrypted connections, no photos kept, little data held. [check] Confirm the basis for this transfer with the NDPC's guidance (adequacy, or the safeguards the NDPA accepts).
How we keep data safe
- Every connection is encrypted (HTTPS).
- The app proves it is Magana with a key. Requests are limited per device and per address.
- We keep as little as we can. Photos, PDFs, recordings and health-check answers are never stored.
- Codes and phone links are stored in forms that can't be read back. Only the teachers who need class codes can see them.
- Teachers sign in with a one-time code by email: no passwords to steal.
- The server is updated by an automatic process with checks. Only the team's own computer can log in to it directly.
If a breach puts people's data at risk, we will tell the NDPC within 72 hours of finding out, as the NDPA requires, and tell the people affected as soon as we can when the risk to them is high.
Requests from the police or government
We share personal data with the police, a court or a government body only when Nigerian law requires it, and only what the request lawfully asks for. Where the law allows, we tell the person first. Because we keep so little, there is often nothing to give: no photos, page text, recordings or health-check answers exist.
Your rights
Under the NDPA you can:
- see the personal data we hold about you, and get a copy;
- correct it if it's wrong;
- delete it ("erasure");
- object to how we use it, or ask us to use it less;
- withdraw your consent at any time; this doesn't undo what was done before;
- complain to the Nigeria Data Protection Commission (NDPC), at ndpc.gov.ng.
How:
- Email maganasupport@gmail.com. We answer within 30 days.
- Most of what Magana keeps is on your phone: uninstalling the app deletes it.
- For a learner in a class, the teacher or school admin can remove the learner and, when a guardian asks, delete everything about them. A school admin confirms, and it is all deleted within 7 days.
Changes to this notice
When Magana changes what it does with personal data, we update this notice and the date at the top. Big changes are announced in the app, on WhatsApp and to schools before they take effect.
Contact
maganasupport@gmail.com · Magana team, Nigeria