Privacy & Security

Privacy Policy

Learn how Adenat Solutions collects, uses, and protects your personal data as a student, teacher, or school administrator.

SECURE AND TRANSPARENT

PASSCO360 PRIVACY POLICY

Passco360 is committed to protecting the privacy and personal information of students, parents, guardians, tutors, schools, school staff, Platform Staff, and other Users.

This Privacy Policy explains how Adenat Solutions & Enterprise, the operator of Passco360, collects, uses, stores, shares, protects, and retains personal information.

It also explains the choices and rights available to Users.

Effective Date: 1st Jan 2026

Last Updated: 29 July 2026

Applies to: Passco360 websites, applications, dashboards, school portals, Tutor tools, parent portals, virtual classrooms, assessment tools, payment services, communication tools, and related Services.

This Policy is intended to support compliance with the Ghana Data Protection Act, 2012 (Act 843) and other data-protection laws that may apply to particular Users or processing activities.

1. DATA CONTROLLER

Passco360 is a digital educational platform operated by:

Adenat Solutions & Enterprise

Registered Address: Accra, Ghana

Privacy Email: passco360official@gmail.com

Telephone: +233 545 138 148

Adenat Solutions & Enterprise generally acts as the Data Controller for personal information processed for:

Passco360 account registration;
Platform administration;
Tutor onboarding;
Parent and learner linking;
Platform security;
Payments and payouts;
Customer support;
Service communications;
Platform analytics;
Fraud prevention; and
The general operation of Passco360.

1.1 Schools and Institutional Data

A school may act as an independent or joint Data Controller for personal information that the school:

Uploads to its school portal;
Collects from students, parents, or staff;
Uses for school administration;
Uses to determine academic decisions;
Uses to manage school fees; or
Instructs Passco360 to process on its behalf.

Depending on the applicable agreement, Passco360 may act as a Data Processor for some school-controlled information.

The respective responsibilities of Passco360 and the school should be stated in the applicable School Service Agreement or Data Processing Agreement.

Personal information is not simply “owned” by a school. Students, parents, staff members, and other individuals retain applicable rights over personal information concerning them.

2. SCOPE OF THIS POLICY

This Privacy Policy applies to personal information processed in connection with:

Account registration;
Exam preparation;
Past-question practice;
Mock examinations;
Live and recorded classes;
Group tutoring;
One-on-one private tutoring;
School portals;
Parent portals;
Tutor Dashboards;
Assignments and submissions;
Attendance;
Assessments and grading;
Messaging;
Payments and payouts;
Support requests;
Platform administration; and
Other Passco360 Services.

This Policy applies whether the information is collected through:

A website;
A mobile or desktop device;
A school;
A parent or guardian;
A Tutor;
A payment provider;
A support interaction;
A live classroom; or
Another authorised source.

3. PERSONAL INFORMATION WE COLLECT

The information we collect depends on the User’s role, the Services used, and the information required to provide those Services.

3.1 Account and Identity Information

We may collect:

Full name;
Email address;
Telephone number;
Country;
Region, state, district, or city;
Residential or contact address;
Date of birth or age range;
Profile photograph;
Gender where voluntarily provided or lawfully required;
Account role;
Login and authentication information;
Verification status;
Preferred language;
Communication preferences; and
Account creation and activity dates.

3.2 Student and Learner Information

We may collect:

Student name;
Student identification number;
School name;
Class, form, level, or programme;
Subjects;
Parent or guardian information;
Enrolment records;
Attendance;
Learning progress;
Assignment submissions;
Quiz and examination results;
Tutor feedback;
Study activity;
Questions attempted;
Study streaks;
Performance analytics;
Certificates or completion records where applicable; and
School or Tutor comments.

3.3 Parent and Guardian Information

We may collect:

Name;
Email address;
Telephone number;
Relationship to the learner;
Identity-verification information;
Linked learner information;
Invitations and approvals;
Payment records; and
Parent-account activity.

3.4 Tutor Information

We may collect:

Identity documents;
Academic qualifications;
Professional qualifications;
Teaching licences;
Employment or teaching experience;
Subject specialisations;
References;
Interview and assessment results;
Teaching-demonstration records;
Background or safeguarding verification information;
Class listings;
Availability;
Tutor performance information;
Attendance and completion records;
Complaints and reviews;
Payment and payout information; and
Tax or compliance information where required.

3.5 School and Institutional Information

We may collect:

School name;
School code;
Registration or accreditation details;
Address and location;
Contact information;
School administrator information;
Staff roles and permissions;
Student and staff lists;
School subscription information;
Fee settings;
Institutional verification records;
Join requests;
School portal activity; and
Records uploaded or generated by the school.

3.6 Classroom and Enrolment Information

We may collect:

Class enrolments;
Class schedules;
Student–Tutor relationships;
Attendance records;
Session duration;
Participant activity;
Homework and assignments;
Quiz activity;
Assessment records;
Grading and feedback;
Classroom chat;
Whiteboard interactions;
Shared resources;
Screen-sharing activity; and
Class completion information.

3.7 Audio, Video and Recording Information

Where a Live Class or meeting is recorded, we may process:

Audio;
Video;
Display names;
Profile images;
Classroom chat;
Screen sharing;
Whiteboard activity;
Participant lists;
Session timestamps; and
Other activity captured during the session.

Participants should be notified when recording is enabled.

We do not use audio or video for facial recognition, voice identification, or biometric identification unless that purpose is separately disclosed and legally authorised.

3.8 Payment and Transaction Information

We may collect:

Payer name;
Payment amount;
Currency;
Transaction reference;
Payment date;
Payment status;
Service purchased;
Mobile Money network;
Masked account or card details;
Refund records;
Chargebacks;
Tutor Wallet activity;
Tutor payout details; and
Bank or Mobile Money account information.

Full payment-card information is ordinarily processed by authorised payment providers and is not stored directly by Passco360.

3.9 Device, Technical and Usage Information

We may collect:

IP address;
Device type;
Browser type;
Operating system;
Device identifiers;
Login timestamps;
Pages or features accessed;
Referring pages;
Session activity;
Error logs;
Performance information;
Approximate location derived from an IP address;
Security events; and
Cookie or local-storage identifiers.

3.10 Communication and Support Information

We may collect:

In-app messages;
Support requests;
Emails;
Feedback;
Complaints;
Appeal submissions;
Survey responses;
Reports of misconduct;
Safeguarding reports; and
Communications with Platform Staff.

3.11 Special Personal Information

Some information may be treated as sensitive or special personal information, including information relating to:

Children;
Health or disability;
Religious beliefs;
Ethnic origin;
Criminal allegations or convictions;
Safeguarding concerns;
And other legally protected information.

We will process this information only where it is necessary, legally authorised, appropriately protected, and supported by a valid legal basis.

4. HOW WE COLLECT INFORMATION

We may collect information:

Directly from the User;
From a parent or guardian;
From an authorised school;
From a Tutor;
From an authorised school administrator;
Through the User’s activity on Passco360;
From payment providers;
From identity-verification providers;
From publicly available professional records;
From references supplied during Tutor onboarding;
From support and complaint processes; or
From another source where collection is lawful and appropriate.

Where information is collected from another person or institution, we will take reasonable steps to inform the affected individual where required.

5. PURPOSES FOR WHICH WE USE INFORMATION

We may use personal information to:

5.1 Operate Accounts

Create and manage User accounts;
Verify email addresses and telephone numbers;
Assign and verify roles;
Authenticate Users;
Process onboarding;
Manage account settings; and
Provide dashboard access.

5.2 Provide Educational Services

Deliver past questions and practice exercises;
Deliver mock examinations;
Recommend learning activities;
Manage classes and bookings;
Provide Tutor feedback;
Support assignments and grading;
Record attendance;
Generate learning analytics;
Provide parent progress information; and
Support school academic management.

5.3 Provide Live and Recorded Classes

Enable audio and video communication;
Operate the virtual classroom;
Support whiteboards and screen sharing;
Record authorised sessions;
Provide class recordings;
Verify Tutor attendance and class completion;
Investigate classroom complaints; and
Protect learner safety.

5.4 Process Payments

Process subscriptions and purchases;
Verify transactions;
Calculate commissions;
Maintain Tutor Wallet records;
Process payouts;
Handle refunds;
Investigate chargebacks;
Prevent fraudulent transactions; and
Maintain legally required financial records.

5.5 Communicate With Users

Send account-verification messages;
Send class reminders;
Send payment receipts;
Provide school notifications;
Notify Users of join requests;
Provide support responses;
Send security alerts;
Communicate legal or policy changes; and
Send marketing communications where permitted.

5.6 Protect the Platform

Detect fraud;
Investigate misconduct;
Prevent unauthorised access;
Enforce role permissions;
Protect children;
Monitor security;
Maintain audit records;
Resolve disputes; and
Enforce Passco360’s agreements and policies.

5.7 Improve Passco360

Diagnose technical problems;
Improve performance;
Optimise the Platform for low-bandwidth connections;
Understand feature usage;
Develop new services;
Conduct statistical analysis;
Test Platform improvements; and
Improve accessibility and usability.

Where reasonably possible, information used for analytics and research will be aggregated, anonymised, or pseudonymised.

6. LEGAL AND AUTHORISED BASES FOR PROCESSING

Depending on the circumstances, Passco360 may process personal information because:

The individual has given consent;
Processing is necessary to provide a requested service or perform a contract;
Processing is authorised or required by law;
Processing is necessary to protect the individual’s legitimate interests;
Processing is necessary for Passco360’s legitimate interests or those of another authorised party;
Processing is necessary to protect a person’s vital interests;
Processing is necessary for fraud prevention, security, or safeguarding; or
Processing is necessary to perform another lawful duty.

Where processing is based on consent, the individual may withdraw consent.

Withdrawing consent does not make earlier lawful processing unlawful. It may, however, prevent Passco360 from continuing to provide a feature that requires the relevant information.

7. CHILDREN’S AND LEARNERS’ PRIVACY

Passco360 provides educational services that may be used by children and young learners.

Under Ghana’s Data Protection Act, information relating to a child under parental control is treated as special personal data and requires appropriate protection and legal justification.

7.1 Direct Student Registration

Where a learner cannot legally provide valid consent independently, Passco360 may require:

Parent or guardian consent;
Parent or guardian verification;
School authorisation;
An invitation from an authorised adult; or
Another legally recognised basis.

7.2 Registration Through a School

Passco360 does not automatically assume that every learner registered by a school has parental consent.

A school that provides learner information must confirm that it has:

Lawful authority to provide the information;
Given appropriate notices;
Obtained consent where required;
Implemented suitable safeguarding procedures; and
Limited the information to what is necessary.

7.3 Parent Linking

A parent or guardian may access a learner’s information only after appropriate verification.

Verification may include:

Learner approval;
Parent identity verification;
School confirmation;
An invitation;
Matching account information; or
Another suitable verification process.

7.4 Use of Student Data

Passco360 does not:

Sell student personal information;
Use student information for third-party targeted advertising;
Allow unrelated parents to access student information; or
Permit Tutors to use student contact details for unrelated marketing.

7.5 Safeguarding

Passco360 may process and disclose information where reasonably necessary to:

Protect a child;
Investigate suspected abuse;
Respond to a safeguarding concern;
Comply with a legal obligation;
Preserve relevant evidence; or
Report a matter to an appropriate authority.

8. SMART FEATURES AND AUTOMATED PROCESSING

Passco360 may use Smart or automated tools to:

Recommend questions;
Generate study plans;
Provide draft explanations;
Produce performance summaries;
Identify learning gaps;
Detect suspicious assessment activity;
Assist with Content moderation; or
Support Platform operations.

Information processed by these tools may include:

Question attempts;
Scores;
Subject performance;
Study history;
Learning preferences;
Tutor feedback; and
Platform activity.

Smart-generated feedback may contain errors and should not be treated as the sole basis for an important academic, disciplinary, admission, employment, safeguarding, or financial decision.

Where a decision significantly affects a User and is based solely on automated processing, the User may request information about the reasoning and ask for appropriate human review, subject to applicable law.

9. HOW INFORMATION IS SHARED

We may share information only where reasonably necessary and legally authorised.

9.1 With Schools

A verified school may access information relating to its authorised students and staff, including:

Identity information;
Attendance;
Assignments;
Assessment performance;
Enrolment;
School fees where enabled; and
School-portal activity.

School access is limited by roles and permissions.

9.2 With Tutors

A Tutor may access information reasonably required to teach authorised learners, including:

Learner name;
Enrolment;
Attendance;
Assignments;
Submissions;
Assessment performance; and
Class communications.

Tutors must not use this information outside their authorised duties.

9.3 With Parents and Guardians

A verified parent or guardian may access information concerning a properly linked learner.

The available information may include:

Attendance;
Enrolled classes;
Assignments;
Performance;
Tutor feedback;
Payments; and
School updates.

9.4 With Other Class Participants

Depending on classroom settings, other participants may see:

Display name;
Profile image;
Camera feed;
Microphone activity;
Chat messages;
Shared screen;
Whiteboard contributions; and
Other classroom participation.

9.5 With Service Providers

We may use service providers for:

Hosting and databases;
Authentication;
Payments;
Email;
Messaging;
Live video and audio;
Storage;
Smart-feedback features;
Analytics;
Security;
Error monitoring; and
Customer support.

Current providers may include Supabase, Paystack, Resend, live-class providers, and other technical service providers.

The provider list may change as Passco360’s Services develop.

Where required, providers must process personal information under appropriate confidentiality, security, and data-processing terms.

9.6 For Legal and Safety Purposes

We may disclose information where reasonably necessary to:

Comply with law;
Respond to a valid court order;
Respond to a lawful regulatory request;
Protect a child;
Prevent fraud;
Protect the rights and safety of Users;
Investigate criminal activity;
Establish or defend legal claims; or
Protect Passco360’s systems and property.

9.7 Business Transfers

If Passco360 or Adenat Solutions & Enterprise is involved in a merger, restructuring, financing, acquisition, or sale of assets, personal information may be transferred as part of that transaction.

Where reasonably possible, affected Users will be notified before their information becomes subject to a materially different privacy policy.

9.8 No Sale of Personal Information

Passco360 does not sell, rent, or trade personal information to data brokers or third-party advertisers.

10. INTERNATIONAL DATA PROCESSING AND TRANSFERS

Some service providers may process or store information outside Ghana.

Where personal information is transferred internationally, Passco360 will take reasonable steps to:

Identify the countries or regions involved;
Use service providers with appropriate security measures;
Enter into suitable data-processing agreements;
Limit transfers to information needed for the relevant service;
Apply contractual or organisational safeguards; and
Comply with applicable Ghanaian and foreign data-protection requirements.

Information about material international processing arrangements may be provided on request or through a published service-provider list.

11. PAYMENT INFORMATION

Payments may be processed by authorised third-party payment providers.

Passco360 may receive and retain transaction information such as:

Payer name;
Payment amount;
Currency;
Payment status;
Transaction reference;
Mobile Money network;
Masked account information;
Refund information; and
Service purchased.

Passco360 does not ordinarily receive or store complete card information.

Payment providers process payment information under their own privacy and security terms.

12. DATA RETENTION

Passco360 retains personal information only for as long as reasonably necessary for the purpose for which it was collected, unless longer retention is:

Required by law;
Required by a contract;
Necessary to resolve a dispute;
Necessary for financial or tax records;
Necessary for safeguarding;
Necessary for fraud prevention;
Necessary to protect purchased learner access;
Necessary for security; or
Authorised by the individual.

Retention may vary by category.

12.1 Account Information

Account information may be retained while the account is active and for a reasonable period after closure to manage disputes, security, legal obligations, and account restoration.

12.2 Academic and School Records

Academic and school records may be retained according to:

The applicable school agreement;
The school’s lawful instructions;
Educational record requirements;
Learner access requirements; and
Applicable law.

12.3 Class Recordings

Recordings may be retained:

For the class-access period;
While a learner is entitled to access the recording;
While a complaint or safeguarding investigation remains open;
For quality-assurance purposes where properly disclosed; or
For another authorised retention period.

12.4 Payment Records

Transaction, commission, refund, payout, and tax records may be retained for the period required by applicable financial, tax, contractual, and legal obligations.

12.5 Security and Audit Records

Security events, access logs, and audit records may be retained for fraud prevention, investigation, legal compliance, and system protection.

12.6 Deletion and De-identification

At the end of the applicable retention period, information will be:

Securely deleted;
Destroyed;
Anonymised; or
De-identified,

unless continued retention is lawfully permitted.

Backup copies may remain temporarily until they are removed through normal secure backup-rotation processes.

13. DATA SECURITY

Passco360 uses reasonable technical and organisational measures intended to protect personal information.

These measures may include:

Encryption in transit;
Encryption at rest where supported;
Role-based access controls;
Authentication controls;
Database access policies;
Logging and monitoring;
Account-verification procedures;
Secure development practices;
Data backups;
Staff access restrictions;
Confidentiality requirements;
Incident-response procedures; and
Periodic security reviews.

Core Platform data may be hosted using providers such as Supabase. Service-provider certifications form only one part of Passco360’s security programme and do not remove Passco360’s responsibility to configure and operate its systems securely.

No internet-based service can guarantee absolute security. Users are also responsible for protecting their passwords, devices, verification codes, and account access.

14. DATA SECURITY INCIDENTS

Where Passco360 has reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, Passco360 will investigate and take reasonable corrective action.

Where required, Passco360 will notify:

The Ghana Data Protection Commission;
Affected individuals;
Relevant schools;
Parents or guardians;
Service providers; or
Other competent authorities.

Notifications will be made as soon as reasonably practicable where required and will include information that can help affected individuals take protective measures.

Notification may be delayed where an authorised security agency or the Data Protection Commission lawfully determines that immediate notice would interfere with an investigation.

15. COOKIES AND SIMILAR TECHNOLOGIES

Passco360 may use cookies, browser storage, and similar technologies.

15.1 Essential Technologies

Essential cookies or local storage may be used to:

Keep Users signed in;
Maintain secure sessions;
Prevent fraud;
Remember account settings;
Support authentication;
Maintain shopping or enrolment activity; and
Provide essential Platform functions.

Disabling essential technologies may prevent parts of Passco360 from working.

15.2 Preference Technologies

Preference technologies may remember:

Appearance settings;
Language;
Dashboard preferences;
Accessibility settings; and
Other User choices.

15.3 Analytics Technologies

Analytics technologies may collect information about how Users interact with Passco360.

Analytics information may include device information, feature usage, page visits, error events, and approximate location.

Where reasonably possible, analytics information will be aggregated or pseudonymised.

Passco360 should obtain appropriate consent before using non-essential cookies where consent is legally required.

15.4 Advertising Technologies

Passco360 does not currently use third-party behavioural advertising cookies to target students with advertisements.

If this practice changes, this Policy and the applicable cookie controls will be updated before such technologies are introduced.

16. DATA-SUBJECT RIGHTS

Subject to applicable law, an individual may have the right to:

16.1 Be Informed

Receive information about:

The information collected;
Why it is collected;
Whether providing it is mandatory;
The consequences of not providing it;
Who may receive it; and
The individual’s rights.

16.2 Access Personal Information

Request confirmation of whether Passco360 holds personal information about the individual and request an understandable copy or description of that information.

16.3 Correct Personal Information

Request correction of inaccurate, incomplete, outdated, excessive, or misleading information.

16.4 Request Deletion

Request deletion of information that:

Is no longer needed;
Was obtained unlawfully;
Is inaccurate or excessive;
Is no longer authorised for retention; or
Must otherwise be deleted under applicable law.

Deletion is not absolute. Passco360 may retain information where legally or contractually required or where it is necessary for safeguarding, disputes, security, financial records, or another lawful purpose.

16.5 Object to Processing

Object to processing that causes or is likely to cause unwarranted damage or distress, subject to lawful exceptions.

16.6 Request Restriction

Request that Passco360 limit particular processing while an issue concerning accuracy, lawfulness, or authority is reviewed.

16.7 Withdraw Consent

Withdraw consent where consent is the basis for processing.

16.8 Object to Direct Marketing

Require Passco360 to stop using personal information for direct marketing.

16.9 Request Human Review

Request appropriate human review of a decision that significantly affects the individual and is based solely on automated processing.

16.10 Request an Export

Request an export of relevant account information in a commonly used electronic format where technically feasible and legally appropriate.

16.11 Complain

Submit a complaint to:

Passco360;
The Ghana Data Protection Commission; or
Another competent authority.

16.12 Exercising a Right

Requests may be sent to:

passco360official@gmail.com

A request should include:

The requester’s name;
Registered account information;
The right being exercised;
Relevant details; and
Proof of identity where reasonably required.

Passco360 may request additional information to verify identity and protect personal information from unauthorised disclosure.

Passco360 will respond promptly. Access requests governed by the Ghana Data Protection Act should be completed within the legally applicable period, which is generally no later than 40 days after receipt of a valid request.

A request may be limited or refused where complying would unlawfully disclose another person’s information, interfere with safeguarding, compromise security, violate a legal obligation, or fall within another lawful exception.

17. SCHOOL DATA REQUESTS

An authorised school administrator may request:

Access to school-controlled records;
An export of relevant institutional information;
Correction of school records;
Changes to staff permissions;
Closure of the school portal; or
Deletion of eligible school-controlled information.

Before acting, Passco360 may verify:

The requester’s identity;
The requester’s school authority;
The rights of affected students or staff;
Contractual obligations;
Learner access rights;
Financial obligations;
Safeguarding requirements; and
Legal retention requirements.

Closing a school account does not automatically permit deletion of all student, staff, payment, assessment, or safeguarding records.

18. DIRECT MARKETING

Passco360 may send information about:

New classes;
Subscription plans;
Tutor opportunities;
School Services;
Promotions; and
Other Passco360 offerings

where the User has consented or where another lawful basis applies.

Users may opt out of marketing messages at any time.

Opting out of marketing does not stop essential communications such as:

Security notices;
Payment receipts;
Class reminders;
School notifications;
Account notices;
Safeguarding messages; or
Legal updates.

Student personal information will not be sold or provided to third parties for their independent direct-marketing activities.

19. CHANGES TO THIS PRIVACY POLICY

Passco360 may update this Privacy Policy to reflect:

Changes in law;
New Platform features;
New categories of information;
New service providers;
Security developments;
Changes to processing activities; or
Operational changes.

When material changes are made, Passco360 may:

Update the “Last Updated” date;
Provide an in-app notification;
Send an email;
Request renewed consent where required; or
Provide another appropriate notice.

A Privacy Policy is primarily a notice explaining data practices. Continued use of the Platform does not replace consent where applicable law requires specific consent for a new processing activity.

20. CONTACT AND COMPLAINTS

Questions, concerns, privacy requests, or complaints may be submitted to:

Adenat Solutions & Enterprise

Platform: Passco360

Privacy Email: passco360official@gmail.com

Telephone: +233 545 138 148

Registered Address: Accra, Ghana

Users may also submit a complaint to the Ghana Data Protection Commission where they believe their personal information has been processed unlawfully or their data-protection rights have not been respected.