Privacy Policy

1. Introduction

HERO CONTROL SYSTEMS Ltd ("we", "us", or "our") operates O'Sense: the web dashboard at app.osense.io, the O'Sense mobile app on Google Play, and the WhatsApp services they send and receive messages through (together, the "Services"). This Privacy Policy explains what we collect, why, who can see it, and the rights you have over it under Zambia's Data Protection Act 2021.

Most information in O'Sense is recorded about you by your employer, school or the business you deal with, which uses O'Sense to run its operations. That organisation decides what is recorded and who may see it, and is the first place to ask about your records. We provide the software and process the information on that organisation's behalf.

2. Information We Collect

2.1 Account and business information

When an organisation sets up O'Sense, and when it adds its people, we hold:

• Name, phone number and email address; job title and department
• Company name, registration details and business address
• Login credentials
• Payroll details the employer records: salary, bank or mobile-money account, statutory deductions (PAYE, NAPSA, NHIMA), leave and attendance
• Business records the organisation creates: clients, prospects, quotations, invoices, receipts, delivery notes, stock, job cards, expenses and ledger entries
• Billing information for the subscription itself

2.2 Face recognition (biometric data)

If your employer uses attendance by face, the O'Sense app turns a photo of your face into a set of numbers called a template. That template is encrypted and never leaves your phone: it is not uploaded, not shared, and not used to identify you anywhere else. A photograph of your face taken at enrolment is stored by your employer so your enrolment can be rebuilt if the phone is lost or replaced.

Each clock-in records the time, who was recognised, how confident the match was, and where the phone was if a location was available. If you clock in when the day already has a record, or clock out early, you are asked why and your answer is kept with the record. A supervisor override is recorded with a photograph of the place.

2.3 Location

For attendance and receipts, location is taken only at the moment you record something — a clock-in, a clock-out, a receipt. The phone is not followed between those moments. School transport is different in two ways. While a bus run is active, the attendant's phone reports where the bus is, so guardians and the school can see it coming; this stops when the run ends. And when a child is scanned on or off the bus, the phone records where that happened, if it has a location fix — section 2.5 explains why and how long it is kept. The web dashboard does not track anyone's location.

2.4 Photographs

The Services keep photographs where a record needs one:

• Receipts you photograph and send, on the app or on WhatsApp, are read automatically and recorded as your organisation's spending. The picture is kept, and anything else visible in it is kept with it — do not use it for personal receipts
• Your enrolment photograph, if you use attendance by face
• A photograph taken when someone collects a child at the school gate instead of the bus (section 2.5). Only the most recent one is kept for each child: a new collection replaces the previous photograph
• Photographs supporting an attendance override

Photographs are stored on our servers and are visible only to authorised people in the organisation that recorded them.

2.5 School transport and children (Route43)

Where a school or transport operator uses Route43, it records, and we hold on its behalf:

• About each child: name, grade and gender as the school records them, the route and stop they use, a printed QR tag number, any notes the school adds, and each time they are scanned on or off the bus — the time, the stop, and whether the tag was scanned or the attendant recorded the child by hand (and why)
• About guardians: name, relationship to the child, phone numbers, and whether they want WhatsApp updates
• About people allowed to collect a child at the gate (a driver, a relative): name, phone number and NRC number, and for each collection the time, who collected the child, and a photograph
• Where a child was collected: the location of each scan, if the phone had one. The school uses these to suggest each child's usual pickup point, which a member of staff must confirm before it is used; nothing is taken as fact until a person accepts it
• Requests from guardians: a guardian can message the school's O'Sense number on WhatsApp to ask where the bus is, report that their child is absent, or ask for a one-off ride. The message is kept, in the guardian's own words, with the request

When a child boards, the guardian is sent a WhatsApp message with a tracking link. The link needs no login and opens a page showing the child's first name, the bus registration, the route, the attendant's name, the destination, whether the child is on the bus or has been dropped off and when, an estimated arrival time, and the bus's current position on a map. It does not show the bus's earlier path, other children, or anyone's address. A link works for that ride only and stops working within 24 hours of pickup.

Route43 does not use face recognition on children.

2.6 Messages on WhatsApp

Some things in O'Sense happen over WhatsApp. When you send a receipt or a leave request to your organisation's O'Sense number, we receive that message and process it to create the record. When O'Sense sends you something — a payslip, a service reminder, an invoice, a morning brief, a bus tracking link — it goes to the number your organisation has recorded for you. WhatsApp is operated by Meta under its own terms; we see only the messages sent to and from the O'Sense numbers, never your other conversations. The app never reads your messages, contacts, photos or files.

2.7 Usage data

We automatically collect information about how the Services are used: device type, operating system and browser, IP address and approximate location, features used, and error and performance logs.

3. How We Use Your Information

We use the information to:

• Provide the Services your organisation has subscribed to, and keep its records
• Run payroll, produce payslips, and record attendance and leave
• Read receipts and post them as expenses; keep the ledger and produce statements
• Send the messages described in section 2.6 to the numbers your organisation provides
• Show a guardian where the bus is during an active run
• Let anyone holding a document O'Sense produced check it against the record (section 4)
• Bill the subscription
• Keep the Services secure, detect misuse, and improve them
• Comply with legal obligations

4. Data Sharing and Disclosure

We do not sell personal information. We share it only as follows:

• Within your organisation: managers and administrators can see the records that organisation keeps about you — attendance, payroll, leave, receipts you submitted — according to the roles it sets
• Document verification: payslips, invoices, quotations, receipts, delivery notes, certificates and sealed accounts carry a code that opens a public page confirming the document against the record. That page shows only what is already printed on the document in the holder's hand — never line items, notes, or anything else about you or the organisation — and needs no login
• Guardians: for their own child only — pickup and drop-off confirmations, the tracking page described in section 2.5, and, when someone collects the child at the gate, that collection's photograph
• Service providers: the cloud hosting and messaging providers that run the Services on our behalf, including Meta's WhatsApp Business Platform for messages
• Legal requirements: when required by law or to protect our rights
• Business transfers: in connection with a merger, acquisition or sale of assets

5. Data Security

We implement industry-standard security measures to protect your data:

• SSL/TLS encryption for data in transit
• Encrypted storage for sensitive information
• Regular security audits and updates
• Access controls and authentication
• Secure data centers with physical security

While we strive to protect your information, no method of transmission over the internet is 100% secure.

6. Data Retention

Your organisation's records are kept for as long as its account is active. Specifically:

• Account and business records: until the organisation deletes them or ends its subscription, after which they are held for a hand-over period and then deleted, unless the law requires them to be kept
• Attendance records, including the location taken at clock-in: kept with the organisation's payroll records
• Face templates: on your phone only, removed when your enrolment is removed or the app is uninstalled
• Guardians' tracking links: stop working within 24 hours of pickup, and are deleted 7 days after that
• Where a child was scanned on or off the bus: the location is erased after 90 days; the record that the child was picked up or dropped off is kept with the school's transport records
• The bus's position during runs, and pickup points confirmed by staff: kept with the school's transport records, visible only to its authorised staff, until the school deletes them or ends its subscription
• Gate collection photographs: the most recent one for each child, replaced by the next
• Photographs and documents: until deleted by the organisation
• Billing records: 7 years, for legal compliance

7. Your Rights

You have the right to:

• Access: Request a copy of your personal data
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your data (subject to legal obligations)
• Portability: Receive your data in a machine-readable format
• Withdraw Consent: Opt out of marketing communications
• Restrict Processing: Limit how we use your data

Because your organisation decides what it records about you, the quickest route is usually to ask it first; we will help it respond. A parent or guardian can exercise these rights for their child, starting with the child's school. You can also contact us directly using the information below, and you may complain to the Data Protection Commissioner under the Data Protection Act 2021.

8. Cookies and Tracking

On the web dashboard we use cookies and similar technologies to keep you logged in, remember your preferences, understand how the Services are used and improve them.

Advertising measurement on osense.io: our public website uses the Meta Pixel to measure the results of our advertising on Facebook and Instagram — for example, that a visit to the site came from an advert, or that a visitor tapped the WhatsApp button. This sends Meta a record of the page visited and your browser information, which Meta may match to a Facebook or Instagram account. The Pixel is used on the marketing website only, not inside the O'Sense dashboard or the mobile app. You can limit this through your browser's cookie settings and Meta's ad settings.

You can control cookies through your browser settings. Disabling them may affect functionality.

9. Children's Privacy

O'Sense accounts are for organisations and their adult staff; we do not knowingly create accounts for anyone under 18. The one place the Services hold information about children is Route43, the school transport module, where a school or transport operator records the children on a route, their guardians and each pickup and drop-off so that guardians can be told their child is safely on and off the bus. That information is held on the school's or operator's behalf and used only for transporting the child: running each trip, telling the guardian, answering a guardian's question about a past trip, and helping the school plan its routes. It is never used for advertising and never sold. The school or operator is responsible for obtaining the parents' agreement (section 2.5). Staff may not copy, photograph or share it outside their work.

10. International Data Transfers

Your data may be transferred to and processed in countries other than Zambia. We ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Last updated" date. Continued use of our Services after changes constitutes acceptance of the updated policy.