Privacy Policy

1. Introduction

Speiro (Pty) Ltd ("Speiro", "we", "us") operates the Speiro CMS church management platform, including the mobile application (iOS and Android), web application, and associated backend services (collectively, the "Platform").

This Privacy Policy explains how we collect, use, store, and protect your personal information when you use the Platform. We are committed to complying with the Protection of Personal Information Act 4 of 2013 (POPIA) and other applicable data protection laws.

2. Who Is Responsible for Your Data

Your church is the Responsible Party under POPIA. Your church decides what data to collect, why, and how it is used within the Platform. Speiro acts as the Operator, processing data on behalf of your church in accordance with our service agreement.

For questions about how your church uses your data, contact your church administrator directly. For questions about how Speiro handles data as a platform provider, contact us at the details below.

3. What Information We Collect

3.1 Information You Provide

• Account information: Name, email address, password (stored as a secure hash, never in plain text)
• Profile information: Phone number (optional), profile photo (optional)
• Church activity: Group membership, volunteer roles, service attendance, schedule assignments
• User-generated content: Prayer requests, announcements, messages, meeting notes
• Giving information: Donation amounts, dates, and payment method references (no card numbers or bank details are stored by Speiro - see Section 7)

3.2 Information Collected Automatically

• Device information: Device type, operating system version, app version
• Push notification tokens: Firebase Cloud Messaging tokens for delivering notifications
• Usage data: Login timestamps, feature usage patterns (aggregated, not individual tracking)

3.3 Information We Do NOT Collect

• Location data
• Contacts or address book
• Browsing history
• Health or fitness data
• Financial account details (card numbers, bank accounts, CVVs)
• Advertising identifiers

4. How We Use Your Information

We use your information solely to provide and improve the Platform:

• Authenticate your identity and manage your account
• Display your church's content (services, groups, announcements, songs)
• Send push notifications for schedule reminders, announcements, and prayer updates
• Enable communication between church members and leaders
• Generate reports for church administrators (attendance, giving summaries, group health)
• Provide offline access to cached church data
• Improve Platform performance and fix issues

We do not use your data for advertising, profiling, or selling to third parties.

5. Special Categories of Personal Information

The Platform processes information related to religious affiliation (church membership is inherently religious data). Under POPIA Section 27(d), this processing is permitted as it is carried out by a religious institution in the course of its legitimate activities, provided the information is not disclosed to third parties without your consent.

If children's information is recorded (e.g., children's check-in), your church is responsible for obtaining consent from a parent or legal guardian as required by POPIA Section 34.

6. Data Sharing and Third Parties

We share your data only with the following categories of service providers, solely to operate the Platform:

Service Provider	Purpose	Data Location
Amazon Web Services (AWS)	Cloud hosting	Cape Town, South Africa
Google Firebase (FCM)	Push notifications	Global (transient only)
Netcash (Pty) Ltd	Payment processing	South Africa
SendGrid (Twilio)	Email delivery	Global (transient only)

We do not sell, rent, or trade your personal information to any third party.

7. Payment Information

All financial transactions (tithes, offerings, donations) are processed by Netcash (Pty) Ltd, a PCI DSS Level 1 certified payment processor. Speiro does not store, process, or have access to your payment card numbers, bank account details, or CVV codes. Only transaction references (amount, date, method) are stored in the Platform for reporting purposes.

8. Data Security

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

• Encryption in transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher
• Encryption at rest: All stored data is encrypted using AES-256
• Password security: Passwords are hashed using bcrypt and never stored in plain text
• Tenant isolation: Each church's data is completely isolated using PostgreSQL Row-Level Security - it is architecturally impossible for one church to access another church's data
• Access control: Role-based permissions ensure users only see data appropriate to their role
• Infrastructure security: All servers run in private subnets with no direct internet exposure, protected by AWS Web Application Firewall
• Audit logging: Sensitive operations are logged for accountability

9. Data Hosting and Residency

All data is hosted on Amazon Web Services in the Africa (Cape Town) region (af-south-1), ensuring your data remains within South Africa. No personal data is transferred outside of South Africa unless you explicitly activate a third-party integration (e.g., Google Calendar sync).

10. Your Rights Under POPIA

You have the following rights regarding your personal information:

• Right of access: View your personal data through the app's "My Details" screen
• Right to correction: Request corrections to inaccurate data via your church administrator
• Right to deletion: Delete your account via "Privacy & Data" → "Delete My Account" in the app. Your data will be anonymised within 30 days in compliance with POPIA
• Right to object: Opt out of communications via notification preferences or unsubscribe links
• Right to data portability: Request an export of your data from your church administrator

To exercise any of these rights, contact your church administrator or email us at the address below.

11. Data Retention

• Your data is retained for as long as your church maintains an active subscription
• If you delete your account, your personal data is anonymised within 30 days
• If your church terminates their subscription, all church data is permanently deleted within 90 days
• Audit logs are retained for 2 years for compliance purposes

12. Cookies and Tracking

The mobile app does not use cookies or advertising trackers. The web application uses only essential session cookies for authentication. We do not use analytics tracking, advertising pixels, or fingerprinting technologies.

13. Children's Privacy

The Platform is not directed at children under 18. Children's data (e.g., check-in records) may be processed by the church with parental consent. We do not knowingly collect personal information from children without appropriate consent.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes through the app or via email. The "Last updated" date at the top of this page indicates when the policy was last revised.

15. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights: