PRIVACY POLICY

Last Updated: March 2026

Effective Date: March 2026

Information We Collect
How We Use Information
How We Share Information
AI Processing & Your Data
Data Retention
Your Rights
Data Security
International Compliance
Changes to This Policy
Contact Us

1. INFORMATION WE COLLECT

1.1 Information You Provide

We collect information you directly provide to us:

Account Registration:

Name, username, email address
Phone number (optional)
Date of birth
Password (encrypted)
Profile photos and biography

Content & Activity:

Videos and photos you upload
Captions, descriptions, and metadata
Comments, likes, and interactions
Search queries and viewing history
Follower/following lists

Payment Information:

Payment method (credit card, mobile money)
Billing address
Tax identification (for monetization)
Banking details (for creator payments)

Note: Payment information is handled by Paystack. Aentury does not directly store full credit card details.

Communications:

Messages to other users
Customer support inquiries
Feedback and survey responses

Moderation & Account Status:

Content moderation decisions and outcomes
Warning records and violation history
Suspension and ban records
Appeal submissions and resolutions
Content reports filed by or against you

1.2 Automatically Collected Information

We automatically collect certain information:

Device Information:

Device type and model (iOS, Android, web browser)
Operating system and version
Device identifiers (IDFA, AAID, IP address)
Device settings and configuration

Location Information:

GPS coordinates (if you enable location services)
City, state, and country
Location metadata tagged in uploaded videos
IP-based location approximation

Usage & Analytics:

Features accessed and time spent on each
Content viewed and interaction patterns
Video watch time and completion rates
Links clicked and buttons pressed
Crash reports and error logs
Cookies and similar tracking technologies
Referral sources

1.3 Third-Party Information

We may receive information from:

Social media platforms (if you link accounts)
Payment processors (Paystack)
Analytics providers (Google Analytics)
Cloud storage providers (Supabase, Cloudinary)

2. HOW WE USE INFORMATION

We use collected information to:

2.1 Provide & Improve Services

Deliver core platform functionality (uploading, viewing, searching)
Optimize content discovery and recommendations
Improve search accuracy and relevance
Fix bugs and enhance user experience
A/B test features and UI improvements

2.2 AI Processing & Machine Learning

Analyze video content to extract metadata (place, category, tags)
Generate automated descriptions and summaries
Train AI models to improve search and recommendations
Detect inappropriate content for moderation
Create location intelligence and place insights

2.3 Content Moderation & Safety

Pre-publish text screening: Comments and captions are analyzed for profanity, hate speech, threats, and harassment before posting
Pre-publish media screening: Photos and videos are analyzed by AI for sexual content, AI-generated/synthetic content (deepfakes), and graphic violence before publishing
Automated enforcement: Content that violates policies is blocked from publication; repeat violations trigger progressive account restrictions (warnings, suspensions, bans)
Moderation records: We maintain records of warnings issued, suspensions applied, bans enforced, and appeals submitted for accountability and due process

2.4 Monetization & Payments

Calculate creator earnings and revenue shares
Process and facilitate payments via Paystack
Detect and prevent payment fraud
Generate tax reports and payment statements
Manage subscriptions and billing

2.5 Communication

Send service updates and announcements
Notify creators of earnings and payments
Respond to support inquiries
Send promotional content (with consent)
Alert you of policy changes

2.6 Security & Compliance

Detect, investigate, and prevent fraud
Enforce Terms of Service and Community Guidelines
Respond to legal requests and law enforcement
Protect against unauthorized access
Comply with applicable laws (Ghana, AU, international)

2.7 Analytics & Business Intelligence

Understand user trends and behavior
Monitor platform health and performance
Create aggregated, anonymized reports
Benchmark against industry standards

2.8 Personalization

Customize your feed and recommendations
Suggest creators and content relevant to interests
Show targeted ads based on viewing history
Recommend places in your location

3. HOW WE SHARE INFORMATION

3.1 Service Providers

We share information with vendors who perform services on our behalf:

Cloudinary: Video hosting and optimization
Supabase: Database and backend infrastructure
Paystack: Payment processing and financial transactions
Google Analytics: Usage analytics and insights
AWS/Vercel: Content delivery and server hosting
SendGrid: Email communications

These providers are contractually bound to protect your information and process it only for specified purposes.

3.2 Legal Requirements & Law Enforcement

We may disclose information:

In response to valid legal process (subpoenas, court orders)
To comply with applicable laws
To respond to government inquiries
To protect rights, property, and safety
To prevent fraud or illegal activity

3.3 Business Transfers

If Aentury is acquired, merged, or assets are sold, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.

3.4 Aggregated & Anonymized Data

We may share aggregated, anonymized data (where individuals cannot be identified):

Industry insights and trends
Platform usage statistics
Content popularity rankings
Location-based tourism insights

3.5 With Your Consent

We share information when you:

Explicitly consent to third-party sharing
Link social media accounts
Participate in partnerships or promotions

3.6 What We Don't Sell

We do NOT sell your personal information to third parties. We do not share personal data with advertisers or marketers for their direct use without explicit consent.

4. AI PROCESSING & YOUR DATA

4.1 How AI Uses Your Data

Your content and data are processed by AI systems to:

Generate metadata and location tags
Improve search and content discovery
Create automated content summaries
Screen text (comments, captions) for policy violations before publication
Screen media (photos, videos) for prohibited content before publication
Detect AI-generated or synthetic media (deepfakes, AI-rendered images)
Classify content for moderation
Personalize recommendations
Train machine learning models

4.2 AI Model Improvement

We use data (including your content) to train and improve Tern's AI models. You can opt-out by contacting legal@aentury.com, though this may limit feature personalization.

4.3 AI Accuracy & Disclaimers

AI-generated information is not guaranteed to be accurate
AI may make mistakes or errors
Do not rely on AI outputs for critical decisions
Aentury is not liable for AI errors or misclassifications

4.4 Your Rights Regarding AI

You have the right to:

Request what AI data has been used
Opt out of AI-based personalization
Request deletion of data used for AI training
Appeal AI-based content decisions

5. DATA RETENTION

5.1 Active Accounts

While your account is active, we retain:

Profile information indefinitely
Upload videos and content indefinitely
Interaction history and engagement metrics
Payment records (for 7 years for tax/legal compliance)

5.2 Account Deletion

Upon account deletion:

Profile and personal information are deleted within 30 days
Videos may remain searchable but are marked as deleted
Comments and interactions are preserved (for content integrity)
Payment records are retained for 7 years for legal/tax compliance
Usage analytics are anonymized

5.3 Moderation Records

Moderation-related data is retained as follows:

Warning records: Retained for the life of the account and 2 years after deletion (for accountability and repeat offender detection)
Suspension records: Retained for the life of the account and 2 years after deletion
Ban records: Retained permanently (for preventing re-registration)
Appeal records: Retained for the life of the account and 2 years after deletion
Content reports: Retained for 2 years
Moderation action logs: Retained for 3 years

5.4 Temporary Data

We retain certain data for limited periods:

Server logs: 90 days
IP addresses: 90 days
Cookies: As per your browser settings
Support tickets: 2 years

6. YOUR RIGHTS

Depending on your location, you may have certain rights:

6.1 Global Rights (All Users)

Access: Request a copy of personal data we hold about you
Correction: Request corrections to inaccurate information
Deletion (Right to be Forgotten): Request deletion of your personal information
Portability: Receive your data in a portable format
Withdraw Consent: Withdraw consent for data processing at any time

6.2 Ghana & African Union Compliance

Under the Ghana Data Protection Act, 2012 and AU regulations:

You have the right to know what data is collected
You have the right to access your personal information
You have the right to request correction or deletion
You have the right to lodge a complaint with authorities

6.3 EU GDPR Compliance (if applicable)

If you're in the EU:

Additional rights apply under GDPR
You have the right to restrict processing
You have the right to object to processing
You have the right to lodge a complaint with your national data protection authority

6.4 California CCPA (if applicable)

If you're in California:

You have the right to know what is collected
You have the right to delete your information
You have the right to opt-out of sales/sharing
You have the right to non-discrimination for exercising rights

6.5 How to Exercise Your Rights

To exercise any of these rights, contact: privacy@aentury.com

Include:

Your full name and account email
Specific request (access, deletion, correction, etc.)
Proof of identity
Specific details about your request

We will respond within 30 days or legally required timeframes.

7. DATA SECURITY

7.1 Security Measures

We implement industry-standard security safeguards:

TLS/SSL encryption for data in transit
AES-256 encryption for sensitive data at rest
Firewalls and intrusion detection systems
Regular security audits and penetration testing
Limited employee access to personal data
Two-factor authentication options

7.2 Security Limitations

No security system is 100% secure. While we use appropriate safeguards, we cannot guarantee absolute security against:

Hacking attempts
Data breaches
Malware
Insider threats
Advanced cyber attacks

7.3 Breach Notification

If a security breach affects your personal information, we will:

Notify you within 72 hours (or as legally required)
Provide details of the breach
Advise steps you can take
Report to relevant authorities

8. INTERNATIONAL COMPLIANCE

8.1 Ghana Jurisdiction

Aentury operates under Ghana Data Protection Act, 2012 and Electronic Transactions Act. Our headquarters is in Ghana.

8.2 Africa-Wide Expansion

As Tern expands across Africa, we comply with:

National data protection laws
Regional AU regulations
Local telecom and electronic transaction laws

8.3 International Data Transfers

Your data may be processed and stored in:

Ghana (primary)
European Union (backup, EU-US Data Privacy Framework compliant)
Cloud providers globally (Supabase, Vercel, AWS)

By using Tern, you consent to cross-border data transfer.

8.4 GDPR & International Compliance

We are committed to compliance with GDPR, CCPA, and other international privacy standards, even if not strictly required.

9. SPECIAL CATEGORIES OF DATA

9.1 Sensitive Information

We collect minimal sensitive data:

Location information (if enabled)
Biometric data (face detection for age verification, optional)

9.2 Children's Data

Tern does not knowingly collect data from users under 13
Users 13-17 may use view-only features
No monetization for users under 18
Parental consent may be required in some jurisdictions

10. CHANGES TO THIS POLICY

We may update this Privacy Policy at any time. Material changes will be:

Announced on the Platform
Sent via email to registered users
Posted with a new effective date

Your continued use of Tern after updates constitutes acceptance.

11. CONTACT US

For Privacy Questions: Email: privacy@aentury.com

For Legal Inquiries: Email: legal@aentury.com

Physical Address: Aentury Limited Ghana

Data Protection Officer: Available upon request at dpo@aentury.com

Governing Law: These Terms are governed by Ghanaian law and applicable AU regulations.

SUMMARY FOR USERS

? We Collect: Your profile, videos, location (if enabled), device info, and usage patterns

? We Use Data For: Improving the platform, personalizing recommendations, processing payments, AI content moderation (pre-publish screening), and AI model training

? We Don't Do: Sell your personal data to third parties, share with advertisers without permission, or retain data longer than necessary

?? You Have Rights: Access, correction, deletion, and to opt-out of certain processing

By using Tern, you acknowledge you have read, understood, and agree to this Privacy Policy.

Last Updated: March 2026 Version 2.0 � Updated with AI content moderation data processing, moderation records collection, and enforcement data retention policies