Privacy policy

This Privacy Policy explains how Neni ('Neni', 'we', 'us', 'our') collects, uses, stores, and protects personal data when you use the Neni mobile applications and web admin panel (together, the 'Service').

Neni is a platform that allows kindergartens in Uzbekistan to share daily photo, video, audio, and text updates about children with their parents or legal guardians.

The Service is designed for three categories of users:

• Parents and legal guardians of children attending a kindergarten that uses Neni
• Nannies and teachers employed by such kindergartens
• Administrators of such kindergartens

We take privacy especially seriously because the Service involves data about children, including their photos, videos, voices, and biometric features.

The data controller for personal data processed through Neni is:

• Operator: Neni
• Address: Tashkent, Uzbekistan
• Tax ID (STIR/INN): to be confirmed
• Email: support@neni.uz
• Phone: +998 90 123 45 67

For data of children and their parents, the kindergarten that uses Neni acts as a joint controller together with us. The kindergarten is responsible for obtaining consent from parents and for the accuracy of the data it uploads.

If you have questions about this Policy or about how your data is processed, you can contact us at support@neni.uz.

Data about parents and legal guardians

• Full name
• Phone number
• Email address (optional)
• Preferred language
• Account password (stored as a cryptographic hash, never in plain text)
• App usage data (login times, device type, app version)
• Push notification token

Data about children

Provided by the kindergarten and/or parent:

• Full name
• Date of birth
• Group or class
• Emergency contact
• Reference photo (used for AI face recognition — see Section 5)
• Status (active or inactive)

Generated during use of the Service:

• Photos and videos taken by nannies during the day
• Audio recordings made by nannies (optional, see Section 6)
• Text updates about the child
• Tags linking media to the child

Data about nannies and teachers

• Full name
• Phone number
• Assigned group or class
• Account credentials
• Content authored (photos, videos, audio, text) and timestamps

Data about administrators

• Full name
• Phone number
• Email address
• Account credentials
• Administrative actions log

Technical data

• Device model and operating system
• App version
• IP address
• Crash and error logs
• Approximate location (only if required for security checks)

We do not collect precise GPS location, contacts, SMS, or browsing history.

A parent may refuse consent to face recognition while still using the rest of the Service. In that case, the child will be tagged manually by the nanny only.

Neni uses AI face recognition to help nannies tag the correct child in photos and videos. This involves processing biometric data, which is treated as sensitive personal data.

What we do

• We generate a mathematical representation (a 'faceprint') from the child's reference photo.
• When a nanny uploads new media, the system compares detected faces in that media against the faceprints of children in the same group only.
• The system suggests matches to the nanny, who must confirm them before publication.
• The system never publishes content automatically.

What we do not do

• We do not use children's faceprints for any purpose other than tagging within their own kindergarten.
• We do not sell or share faceprints with third parties for advertising, profiling, surveillance, or law-enforcement purposes outside of binding legal requests.
• We do not use a child's faceprint to identify them outside of the Service.
• We do not match faceprints of children across different kindergartens.

Your rights

• You may withdraw consent for face recognition at any time. The child's faceprint will be deleted within 30 days.
• You may request manual tagging only as the default for your child.

Nannies may record short voice notes about a child's day. These recordings are processed in two ways:

• A speech-to-text engine converts the audio to text in Uzbek, Russian, or English.
• The nanny reviews and edits the text, then publishes the text version to the parent feed.

The original audio file is:

• Stored only if the kindergarten enables this option
• Stored for no longer than 30 days by default
• Never published to the parent feed unless the kindergarten and parent explicitly opt in

Voice transcription may be performed by a trusted third-party AI provider acting as our processor (see Section 8). Audio is transmitted over encrypted channels and is not used by the provider to train their models.

We use personal data only for the purposes listed in Section 4. In particular:

• We use a child's data only within the kindergarten where the child is enrolled.
• We show updates about a child only to that child's confirmed parents or legal guardians.
• We do not use children's photos, videos, or voices for advertising, marketing, or training third-party AI models.
• We do not sell personal data to anyone, ever.

We share data only with parties who help us operate the Service. These are our 'processors', and they are bound by written agreements to protect the data.

A current list of our processors is available on request from support@neni.uz.

We may also disclose data:

• To law enforcement or courts if required by a valid legal order under the laws of the Republic of Uzbekistan.
• To protect the safety of a child or another person in an emergency.
• To a successor entity in case of a merger or acquisition, subject to the same protections.

In accordance with Article 27¹ of the Law of the Republic of Uzbekistan on Personal Data, personal data of citizens of Uzbekistan is stored on servers located within the Republic of Uzbekistan.

Some processing (for example, AI transcription) may involve temporary transfer of data to processors located abroad. Where this occurs:

• We use providers that offer adequate safeguards.
• Transfers are made over encrypted connections.
• Only the minimum necessary data is transferred.
• Data is not retained by the foreign processor beyond the time needed for the processing.

We protect personal data using technical and organisational measures, including:

• Encrypted transport (HTTPS/TLS) for all network traffic
• Encryption at rest for media files and backups
• Cryptographically hashed passwords
• Role-based access control: parents see only their own child; nannies see only their assigned group; admins see only their kindergarten
• No public or unsigned URLs for media
• Logging of administrative actions
• Regular security reviews and access audits
• Staff confidentiality obligations
• Incident response procedures

No system is perfectly secure. In the event of a data breach affecting personal data, we will notify the relevant authority and affected users in accordance with applicable law.

As a parent or user of Neni, you have the right to:

• Access the personal data we hold about you and your child.
• Correct inaccurate data.
• Delete your account and your child's data (the right to be forgotten).
• Withdraw consent for face recognition, voice recording, notifications, or any other consent-based processing, at any time.
• Object to processing based on legitimate interest.
• Restrict processing in certain situations.
• Receive a copy of your data in a structured format.
• Lodge a complaint with the State Personalisation Agency under the Ministry of Digital Technologies of the Republic of Uzbekistan, or with another competent authority.

To exercise any of these rights, contact us at support@neni.uz. We will respond within 30 days.

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

Because the Service is built around children, we apply extra safeguards:

• A child's data is uploaded and processed only with parental or guardian consent obtained by the kindergarten.
• Children themselves do not have user accounts.
• Children's data is never used for advertising, profiling, or any commercial purpose unrelated to the Service.
• A parent may at any time request that all data about their child — including photos, videos, audio, and faceprints — be deleted.
• When a child leaves the kindergarten, their data is moved to a restricted archive and then deleted in line with Section 10.

The Neni web admin panel uses a small number of cookies and similar technologies, strictly for:

• Keeping you logged in (session cookies)
• Remembering your language preference
• Detecting security issues such as unauthorised logins

We do not use advertising, tracking, or third-party analytics cookies in the admin panel.

We may update this Policy from time to time. When we do:

• We will update the 'Last updated' date at the top.
• For significant changes, we will notify users in the app and by email or SMS.
• For changes that require new consent (for example, a new AI feature), we will ask for that consent before the change takes effect for you.

The current version is always available inside the app and at https://neni.uz/privacy.

If you have any questions, concerns, or requests about your privacy, contact the Neni Privacy Team:

• Email: support@neni.uz
• Phone: +998 90 123 45 67
• Address: Tashkent, Uzbekistan

This Privacy Policy is available in Uzbek, Russian, and English. In the event of any discrepancy between language versions, the Uzbek version prevails.