1. Who we are and what this covers

The CWL School app is operated by the administration of Creativity Without Limits School, Gaza, Palestine (“we”, “us”). The school is the data controller.

The app is intended exclusively for enrolled students of the school and their parents or guardians. Accounts are issued only to people listed in school records; there is no open public sign-up.

2. Target audience and children's privacy

The app's target audience is the school's students and their parents. Some students are minors under 18, and some are under 13.

Legal basis for processing minors' data

Student data is processed by us as a licensed educational institution, under authority explicitly granted by the parent or guardian at enrolment, and solely for the educational and administrative purposes described here. Student accounts are created only by the administration with parental consent.

Our commitments regarding minors

• No advertising of any kind — no personalised ads, no contextual ads, no ad networks.
• No behavioural analytics or marketing trackers, and no advertising profiles.
• We never sell or share student data with data brokers, advertisers, or any commercial party.
• No open student-to-student messaging and no user-generated content visible to other users.
• No in-app purchases and no paid digital content.

Parents may access, correct, or request deletion of their child's data at any time (section 12).

3. Data we collect

We collect only what the app's features require. Tags match Google Play Data safety categories.

4. Data stored on your device

• Access token and basic student/parent details (name, grade, national ID).
• Preferences: language, dark mode, onboarding completion.
• If “Remember me” is enabled: your national ID.
• If biometric sign-in is enabled: your password is kept in the OS secure storage (Android Keystore / iOS Keychain).

Signing out or uninstalling the app removes this locally stored data.

5. Data sharing and storage locations

School servers (Oracle ORDS)

The primary destination for academic, financial and request data, transmitted over HTTPS/TLS. Access is limited to authorised administration staff under role-based permissions.

Google Firebase — two services only

• Firebase Cloud Messaging: notification delivery. Receives only the push token and device identifier.
• Cloud Firestore: storing “Contact us” messages until reviewed by the administration.

See the Firebase Privacy Policy.

AI assistant provider

⚠ [Provider name to be filled in] — see section 6.

International transfers

Firebase servers and the AI provider's servers are located outside Palestine. By using the app you consent to the transfer of the data described above to those servers, which are subject to contractual and technical safeguards.

6. AI assistant (generative AI)

The app includes an AI assistant that answers questions about a student's academic or financial standing.

How it works

• When you send a question, your question text and only the fields needed to answer it (such as grades or wallet balance) are sent to a language-model provider: ⚠ [provider name].
• Your national ID, password, profile photo, and bank receipts are never sent to the provider.
• The provider does not use your data to train its models, under our commercial terms with them.
• The assistant is scoped to your own account and cannot reach any other student's data.

Limitations

Generated answers may be inaccurate. The authoritative record is what appears in the app's screens and in the school's own system, not the assistant's answer. The assistant is never used to make an educational or financial decision automatically.

Reporting inappropriate output

If the assistant produces inappropriate, offensive, or incorrect content, report it immediately using the “Report this answer” button beneath every answer in the app, or email privacy@cwl.ps. Reports are reviewed within 72 working hours.

Safeguards

Filters are in place to prevent the assistant from generating content unsuitable for minors or straying outside school-related enquiries. The feature is optional and a parent may request that it be disabled for their child's account.

7. Permissions

You may revoke any optional permission at any time in your device settings; the app keeps working with only the related feature disabled.

8. Retention

• Academic and financial records: kept while the student is enrolled, then for ⚠ [number] years after graduation or withdrawal, under applicable Palestinian educational regulations.
• Push tokens (FCM): deleted on sign-out or uninstall.
• Support messages: deleted 12 months after the enquiry is closed.
• AI assistant conversations: deleted after 90 days.
• Transfer receipt images: deleted 24 months after the payment is approved, absent an accounting obligation to the contrary.
• On-device data: cleared immediately on sign-out or uninstall.

9. Account and data deletion

In the app

Profile → Edit Profile → Delete account. On confirmation, local data is erased immediately and sign-in is disabled.

What is deleted and what is kept

• Deleted within 30 days: sign-in credentials, profile photo, mobile number, address, push token, support messages, AI conversations, receipt images.
• Retained: the official academic and financial record, which the school is legally obliged to keep as an educational institution. This record is held in the school's administrative system, not in the app.

For full erasure including the official record, email privacy@cwl.ps and we will explain what can lawfully be deleted.

10. Security

• All communication is encrypted with HTTPS/TLS.
• Passwords are stored server-side as hashes, never in plain text.
• Tokens and (when biometrics are enabled) your password are kept in the OS secure storage on your device.
• Access is limited to your authorised account; staff access is governed by role-based permissions.
• If a breach affects your data, we will notify you in-app and by email or SMS within 72 hours of discovering it.

No method of electronic transmission or storage is 100% secure. Please never share your password.

11. Your rights

• Access — request a copy of the data we hold about you.
• Correction — via “Edit Profile” or by contacting the administration.
• Deletion — see section 9.
• Objection and restriction — request that specific processing stop, such as disabling the AI assistant.
• Withdrawing consent — by revoking optional permissions or deleting your account.

We respond to rights requests within 30 days. A parent may exercise these rights on behalf of their minor child.

12. Contact

13. Changes to this policy

We may update this policy from time to time. The “Last updated” date and version number above will change. For any material change — such as collecting a new category of data or adding a third party — we will notify you in the app and ask for your consent before the change takes effect. Continued use after an update constitutes acceptance.