Privacy notice

1. WHO THIS NOTICE IS ABOUT NELLA Studios is a creative production facility in Accra, Ghana. When you send us a booking request, create an account, or ask us a question, NELLA Studios decides why and how your personal data is used, which makes it the data controller under Ghana's Data Protection Act, 2012 (Act 843). The controller is NELLA STUDIOS LTD, a company registered in Ghana under the Companies Act, 2019 (Act 992) with company number CS038370226. Its registered office is 28 Road Leading Community 20, Lashibi, Greater Accra, Ghana. That address is also the studio address and the address for support and general correspondence — for this company the three are the same place, which is not true of every company and is stated here so that no reader has to assume it. [NELLA TO CONFIRM: whether NELLA Studios is registered as a data controller with Ghana's Data Protection Commission, and the registration number if so. No number has been invented for this draft.] [NELLA TO CONFIRM: the name and contact details of the person accountable for data protection at NELLA Studios. No name is given here, because naming a person who has not agreed to the role would be worse than an obvious gap.] [NELLA TO CONFIRM: the email address and postal address a person should use to exercise the rights in section 10. The site has no monitored privacy mailbox today.] 2. WHAT WE COLLECT WHEN YOU SEND A BOOKING REQUEST Everything below is a field the booking request form actually has. Nothing on this list is aspirational. About the project: what you are creating; the date and start time you would like; how long you need; how often you need the studio; and any alternative dates or times you list. About you: whether you are booking as an individual or for an organisation; the country you are in; a budget range if you choose one; whether you need a formal quote; whether you are ready to pay a deposit; and how you heard about us. About the session: which space you would prefer; how many people are coming; how many vehicles you expect; the equipment, crew and styling you need, with your own notes on each; whether you need catering, how many meals, and whether alcohol is involved. About the work: a description of the project; your goals; the platforms it is for; the deliverables you expect; your deadline; any special requests; and up to ten reference links. Links only — the form does not accept file uploads from someone who is not signed in. How to reach you: your name; your email address, your phone number, or both; and whether you would prefer email, WhatsApp, SMS or a phone call. At least one contactable address is required, because a request we cannot answer helps nobody. Ghanaian phone numbers are converted to international format before they are stored, so 0244123456 is stored as +233244123456. Email addresses are stored in lower case. 3. THE FIVE ANSWERS WE TREAT AS MORE SENSITIVE THAN THE REST Accessibility needs, dietary notes, allergy notes, privacy needs and security needs are held in a separate place from the rest of your request. That has two consequences you can hold us to: They are readable only by staff who hold a specific named permission, not by every member of staff who can see your booking. They are deleted 180 days after they are written, independently of the request they belong to. The clock is a database default and a job runs every five minutes to enforce it. This is the only retention period in this notice that is a fact about the running system rather than a decision still to be made. 4. WHAT WE RECORD WHEN YOU TICK A CONSENT BOX Messaging and marketing permissions are separate from each other and separate from messages about your own request. Nothing is ever pre-ticked, and we never treat silence as agreement. When you tick one we record: which permission it was; which channel it applies to; the exact wording that was on your screen at that moment; which version of the relevant policy document that wording belonged to; the time; your IP address; your browser's user-agent string; and the language your browser asked for. That record exists so "what exactly did I agree to, and when" has an answer years later. It is kept as evidence and is never edited. Section 10 explains why it survives even a deletion request. 5. WHAT WE RECORD ABOUT HOW YOU ARRIVED If you reach the site from a campaign link, we record the campaign parameters in the address, the page you landed on, and the host of the site that referred you — the host only, never the full referring address. A referring address routinely carries a search query or a username in its path; the host answers the marketing question and drops the personal data. We also set a random, opaque identifier in one of our own cookies so we can tell that the same browser has been here before. It is not derived from your IP address, your device or your browser characteristics, so it is not a fingerprint. [NELLA TO CONFIRM: whether attribution of this kind requires consent in Ghana, and whether that cookie may be set before a visitor has agreed to it. The site currently sets it without asking. This is a live question, not a settled one.] 6. WHAT WE COLLECT IF YOU HAVE AN ACCOUNT Your name; optionally a creator or business name, your role and your industry; your email address; your phone number; your country; your timezone; and how you would prefer to be contacted. If you belong to an organisation account, we also hold that organisation's details and your role in it. Your sign-in address is held by our authentication provider and is separate from the contact email on your profile. Changing one does not change the other. 7. WHY WE ARE ALLOWED TO USE IT [NELLA TO CONFIRM: the lawful basis for each category above, confirmed by a Ghanaian-qualified lawyer. The engineering record proposes "steps taken at your request before entering a contract" for booking requests and "consent" for marketing, and marks every one of them as a proposal pending legal review. This draft does not promote a proposal into a statement.] 8. WHO ELSE SEES IT These are the service providers that process your data today. Each one is in the codebase. None has been added to make the list look complete. Supabase — our database, sign-in and file storage. It holds everything described above. The database runs on Amazon Web Services in London, United Kingdom. Vercel — hosts and delivers this website. It sees the metadata of your requests to the site. Resend — sends transactional email, meaning email about your own request. It sees the recipient address and the content of that message. The following are present in our configuration but switched off, so they receive nothing today: Paystack, because the site takes requests rather than payments; a WhatsApp provider, because none is selected; an SMS provider, because none is selected; and Sentry, our error monitor, because no reporting address is set. If any of them is switched on, this notice must be updated before it happens. Sentry is additionally configured never to attach IP addresses, cookies or request bodies to an error report, and session recording is fixed at zero and cannot be turned on from configuration alone. [NELLA TO CONFIRM: any other processor not visible in this codebase — an accountant, a CRM, a scheduling tool, a cloud drive holding client media. Anything you actually use has to appear here.] 9. YOUR DATA LEAVES GHANA Your personal data is stored and processed in the United Kingdom, not in Ghana. Act 843 places conditions on moving personal data outside Ghana. [NELLA TO CONFIRM: the transfer assessment for Supabase, Vercel and Resend. It does not exist. It is recorded in our engineering documentation as an open legal item and it has to be closed before this notice is published, because this section currently discloses a transfer without saying what makes it lawful.] [NELLA TO CONFIRM: whether the EU or UK GDPR applies to NELLA in respect of clients based in Europe or the United Kingdom, and whether a representative is required. If either applies, this notice needs additional disclosures that this draft does not contain.] 10. HOW LONG WE KEEP IT Sensitive session notes — accessibility, dietary, allergy, privacy and security — are deleted 180 days after they are written, automatically. That is stated in section 3 and is true today. [NELLA TO CONFIRM: the retention period for booking requests and the contact details on them. There is none. No period is set and no job deletes them.] [NELLA TO CONFIRM: the retention period for leads, message threads, notifications and provider webhook records. There is none.] [NELLA TO CONFIRM: the retention period for financial records. This is usually set by Ghanaian tax law rather than chosen. Please have your accountant state the period rather than estimating it.] [NELLA TO CONFIRM: the retention period for the audit log, which records staff actions and keeps a name after the account it belonged to is deleted.] No retention period has been invented for this draft. A plausible number here would look reviewed and would not be. 11. YOUR RIGHTS, AND WHAT ACTUALLY HAPPENS WHEN YOU USE THEM You can ask us for a copy of the personal data we hold about you, to correct it, to send it to you, to erase it, or to object to something we are doing with it. If you have an account you can raise the first four from the privacy page inside it. Asking costs nothing. Nothing is deleted the moment you ask. We have to confirm you are who you say you are first, because fulfilling somebody else's request against your account would itself be a breach. We aim to answer within 21 days. That is an operating commitment we have set ourselves. It is not a statement of the statutory period. [NELLA TO CONFIRM: the statutory period for responding to a data subject request under Act 843. If the statute says something other than 21 days, the statute wins, and both this paragraph and the system's own default have to change.] An erasure does not remove everything, and we would rather tell you now than surprise you afterwards. Four categories survive: The record of what you agreed to, and of anything you asked us to stop. Destroying the evidence that you asked not to be contacted would destroy the proof that we were ever told. Your entry on our do-not-contact list. An erasure adds to that list. It never removes from it. Financial records — invoices, payments, credits and refunds — for as long as Ghanaian tax law requires. The record of the request itself: that you made it, that we confirmed who you were, and what we did about it. If your erasure could not be completed in full, we will tell you which parts were kept and why. 12. COOKIES The site sets two cookies of its own, and your browser holds a session cookie while you are signed in. There is no analytics cookie, no advertising cookie and no third-party cookie. The cookie policy describes each one. 13. AUTOMATED DECISIONS Nothing on this site decides anything about you automatically. A booking request is read and answered by a person. 14. SECURITY Access to data is enforced by the database itself, row by row, rather than by the application asking nicely. Staff permissions that touch personal data require two-factor authentication. Application logs redact email addresses and phone numbers by field name before anything is written. Session recording is off. [NELLA TO CONFIRM: how a personal data breach is reported to you and to the Data Protection Commission, and within what period. We have an internal incident runbook; the commitment to you has not been written.] 15. CHILDREN [NELLA TO CONFIRM: whether NELLA accepts bookings from, or shoots involving, people under 18, and what consent is required from a parent or guardian. The booking form does not ask anyone's age, so this notice cannot currently say anything true about it.] 16. COMPLAINTS If you are not satisfied with how we have handled your personal data you can complain to us, using the contact details in section 1, and you can complain to Ghana's Data Protection Commission. 17. CHANGES Every version of this document is kept, with the date it took effect. When the wording changes, a new version is created rather than this one being edited, so a consent recorded against an earlier version still resolves to the words that were actually shown.