Privacy Policy | Churchera

1. Introduction

At Churchera, we prioritize the privacy and protection of personal data. This Privacy Policy explains how we collect, use, store, disclose, and safeguard personal data in accordance with the Nigeria Data Protection Act 2023 (NDPA) and other applicable laws. This Policy applies to all users of our platform, including website visitors, mobile application users, and other individuals who interact with our services. By accessing or using our platform, you agree to the terms of this Privacy Policy. If you do not agree, you must not use our services.

PLEASE ENSURE THAT YOU HAVE READ AND FULLY UNDERSTOOD THIS PRIVACY POLICY BEFORE REGISTERING ON CHURCHERA OR USING CHURCHERA’S SERVICES. WE STRONGLY RECOMMEND THAT YOU CONSULT YOUR LEGAL PERSONNEL OR REPRESENTATIVES FOR PROPER UNDERSTANDING.

2. Definitions

2.1 The term “Churchera”, “Company”, “us”, “we”, or “our” refers to Churchera Innovation Limited - a Private Limited Liability Company incorporated and registered with the Corporate Affairs Commission (CAC) under the laws of the Federal Republic of Nigeria; with registration number RC9227676 and registered address at 2 D. C. Chukwu Lane, Enugu State, Nigeria. It includes Churchera’s affiliated services or corporate partners where Churchera Innovation Limited does not directly provide the services.

2.2 “User”, “Giver”, “Member”, “Donor”, or "Customer" refers to eligible person or entity using Churchera to transact, make, or receive payment. The User must agree to these Terms of Service to use Churchera's services. For reference, “You” may be used in some sentences or phrases to refer to the same person or entity described herein.

2.3 "Services" refers to services provided or facilitated by Churchera or our partners.

2.4 "Account" refers to a User's registered account on Churchera, which is required to access and use our services.

2.5 “Payment Service Provider” means licensed third-party financial institutions regulated by the Central Bank of Nigeria that process payments on the platform and may act as independent data controllers.

2.6 “Payment” refers to any form of legitimate transaction carried out on our platform.

3. Lawful Basis for Processing Personal Data

We process personal data based on one or more of the following lawful bases:

Consent provided by the user
Performance of a contract
Compliance with legal obligations
Legitimate interests, provided such interests do not override user rights

Where processing is based on consent, users have the right to withdraw such consent at any time with notice.

4. Types of User Data Collected

We collect various types of data, including:

4.1 Personal Data: Name, email address, phone number, and other contact information.

4.2 Sensitive Personal Data: This may include financial information, identity documents (such as government-issued ID), and biometric data where required for identity verification. Such data is collected only where necessary and processed with enhanced security measures in compliance with applicable laws.

4.3 Usage Data: Information about your use of our platform, including search history, activities on the platform, payment and transaction history, and other interactions.

4.4 Device Data: Information about your device, including IP address, device type, location and operating system.

5. Purpose of Data Collection

We collect data for the following purposes:

5.1 Account Management: To create, maintain and manage your account and wallet, provide customer support, and authenticate your identity.

5.2 Service Provision: To provide our services, including wallet, and other features.

5.3 Marketing and Analytics: To personalize your experience, improve our services, and target marketing efforts.

5.4 Security and Compliance: To ensure the security and integrity of our platform, comply with laws and regulations, and prevent fraud or other illegal activities.

We do not process personal data in a manner incompatible with the purposes for which it was collected, except as required or permitted by law.

6. Data Storage and Security

We implement appropriate technical and organizational measures to safeguard personal data, including:

Encryption of sensitive data in transit and at rest
Access controls and role-based data access restrictions
Regular system monitoring and vulnerability assessments
Staff confidentiality obligations and data protection training

While we take reasonable steps to protect personal data, no system is completely secure. However, we remain responsible for complying with applicable data protection laws.

7. Data Breach Notification

In the event of a personal data breach, Churchera will take appropriate steps to contain and investigate the breach. Where required by law, we will notify affected users and the Nigeria Data Protection Commission (NDPC) within the timeframes prescribed by applicable regulations.

8. Data Sharing

We share personal data with:

Payment Service Providers: To facilitate secure payment processing
Service Providers: For identity verification, analytics, hosting, and customer support
Regulatory Authorities: Where required by law or to comply with legal obligations

All third parties are required to process personal data in accordance with applicable data protection laws and appropriate contractual safeguards.

9. Cross-Border Data Transfers

Where personal data is transferred outside Nigeria, we ensure that such transfers are subject to appropriate safeguards in accordance with the Nigeria Data Protection Act 2023.

10. User Rights

Under applicable data protection laws, users have the right to:

Request access to their personal data
Request correction of inaccurate or incomplete data
Request deletion of personal data
Restrict or object to certain types of processing
Withdraw consent where processing is based on consent
Request transfer of their data (data portability)
Lodge a complaint with the Nigeria Data Protection Commission (NDPC)

Requests may be made through our designated contact channels.

11. Specific Considerations for Different User Categories

11.1 Members: We collect data to provide our services, including payment processing, wallet and account management.

11.2 Churches: We collect data to manage church accounts, provide services, and ensure compliance.

Data is collected only to the extent necessary for the specific services provided to each category of user.

12. Compliance

We comply with the Nigeria Data Protection Act 2023 (NDPA) and applicable regulations. Where applicable, we also align with international data protection standards such as the General Data Protection Regulation (GDPR).

13. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including:

For the duration of an active account
For a reasonable period after account closure for legal, regulatory, and audit purposes
As required by applicable laws or regulatory authorities

14. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance user experience, analyze usage, and improve our services. Users may control cookie preferences through their browser settings. Disabling cookies may affect certain functionalities of the platform.

15. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or personal data, please contact us at support@churchera.com. For data protection-specific inquiries, you may also contact our designated data protection contact through the same channel.

16. Changes to Policy

We may update this Privacy Policy to reflect changes in our practices or applicable laws. We will notify users of any material changes via email, in-app notifications, push notifications, Churchera app or website updates. Continued use of the platform after such changes constitutes acceptance of the updated Privacy Policy, to the extent permitted by law.

17. Agreement and Liability

By registering on Churchera, you acknowledge that you have read and understood this Privacy Policy and you represent and warrant that the information we have about you or the entity you represent is true and correct. Hence, you agree to indemnify us of any loss or damages from incorrect or misleading data. While users are responsible for ensuring that the information they provide is accurate, nothing in this Privacy Policy excludes or limits Churchera’s responsibility to comply with applicable data protection laws. To the extent permitted by law, liability arising from data-related claims shall be limited to reasonable and proportionate damages.

18. Age Requirement

You represent and warrant that you are at least 18 years old or of the age of maturity as defined by applicable jurisdiction to use our services. You represent and warrant that you are eligible to receive or use our services according to the laws of applicable jurisdiction. We do not knowingly collect or process personal data of individuals under the age of 18 or individuals prohibited from receiving or using our services according to the laws of applicable jurisdiction. Where such data is identified, we will take steps to delete it promptly. This is to ensure that users are legally capable of being bound by this Privacy Policy.

19. Severability

If any of the provisions of our Privacy Policy shall be invalid or unenforceable, such invalidity or unenforceability shall not invalidate or render unenforceable the entire Privacy Policy but rather the entire Privacy Policy shall be construed as if not containing the particular invalid or unenforceable provision or provisions, and you agree that the rights of Churchera shall be construed and enforced accordingly, to effectuate the essential intent and purposes of our Privacy Policy.

20. Dispute Resolution

Any dispute arising from this Privacy Policy shall first be resolved through amicable negotiation. Where unresolved, disputes shall be referred to mediation or arbitration in accordance with the Arbitration and Mediation Act 2023, with the seat of arbitration in Abuja, Nigeria.

21. Governing Jurisdiction

The Federal High Court, Abuja, Nigeria shall have jurisdiction over matters arising from this Privacy Policy, subject to applicable dispute resolution provisions.

22. Governing Law

This Privacy Policy shall be governed by, construed and enforced in accordance with the laws of the Federal Republic of Nigeria.