Privacy Policy

1. Introduction

Zion App ("we," "our," or "us") is committed to protecting your privacy and the privacy of children. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our church management platform, in compliance with the Children's Online Privacy Protection Act (COPPA), the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable privacy laws.

2. Information We Collect

2.1 Personal Information (Adults)

We collect the following categories of personal information from adult users:

• Identifiers: Name, email address, phone number
• Account Information: Credentials, role, church affiliation
• Guardian Information: Relationship to children, pickup authorization, guardian codes
• Profile Information: Ministry assignments, volunteer status

2.2 Children's Information (Under 13)

For Kids Ministry services, with verifiable parental consent, we collect only the minimum information necessary:

• Child's first and last name
• Date of birth (used solely for age group assignment)
• Allergies, medical conditions, and special needs (for child safety only)
• Guardian contact information and relationship
• Check-in/check-out records and room assignments
• Incident reports (if any occur during care)

2.3 Public Event Registration

When you register for a church event through a public registration link (without creating an account), we collect:

• Required: Full name, email address
• Optional: Phone number, notes/special requests

Retention: Public registration data is retained for 1 year after the event date, after which it is automatically deleted. You can request immediate deletion by contacting the church or emailing privacy@zionapp.org.

2.4 Automatically Collected Information

• IP address (used for security, rate limiting, and audit logging)
• Device information and browser type
• Usage patterns and access timestamps
• Session cookies (functional only, no tracking)

3. How We Use Your Information

3.1 Legal Bases for Processing (GDPR)

We process personal data under the following legal bases:

• Contract Performance: To provide the church management services you have subscribed to
• Consent: For SMS notifications, optional features, and children's data processing
• Legitimate Interest: For security monitoring, fraud prevention, and service improvement
• Legal Obligation: To comply with applicable laws and respond to lawful requests

3.2 Purposes of Processing

• Provide and maintain church management services
• Process Kids Ministry check-ins and check-outs safely
• Send notifications about children (check-in confirmations, incidents)
• Ensure the safety and security of children in care
• Communicate important updates and service announcements
• Maintain audit logs for compliance and security
• Respond to data subject requests and support inquiries

4. Artificial Intelligence & LLM Policy

Zion App does not currently use AI or machine learning to process any personal data. If we introduce AI-powered features in the future, we will:

• Never send children's PII to AI/LLM services under any circumstances
• Implement technical guardrails to prevent accidental transmission of child data to AI services
• Update this Privacy Policy and notify all users before introducing any AI features
• Obtain explicit consent before processing any personal data with AI systems

5. SMS Communications

If you opt in to receive SMS notifications, we will send text messages for:

• Check-in confirmations with security codes
• Check-out confirmations
• Incident reports and alerts
• Important ministry updates

6. Children's Privacy (COPPA Compliance)

6.1 Verifiable Parental Consent

We require verifiable parental consent before collecting any information from or about children under 13. Your church, as the Data Controller, is responsible for obtaining consent through one of the following methods:

• In-person signed consent form at the church
• Electronic consent through the platform (with identity verification)
• Written consent provided to church administration

All consent records are tracked and auditable through our consent management system.

6.2 Parental Rights Under COPPA

As a parent or legal guardian, you have the right to:

• Review: Request to see all personal information collected about your child
• Correct: Request corrections to inaccurate information about your child
• Delete: Request deletion of your child's personal information
• Refuse: Refuse to allow further collection of your child's information
• Withdraw Consent: Withdraw your consent at any time, at which point we will stop collecting your child's data and delete existing data upon request

To exercise these rights, you can submit a data request online, contact your church administrator, or email privacy@zionapp.org.

6.3 Church Responsibility for COPPA

Your church, as the Data Controller, is primarily responsible for:

• Obtaining verifiable parental consent before registering children
• Providing parents with clear notice about what information is collected
• Maintaining records of parental consent
• Responding to parental requests to review, modify, or delete their child's data
• Training staff on proper handling of children's information
• Limiting access to children's data to authorized personnel only

6.4 Retention of Children's Data

Children's data is retained only as long as necessary:

• Active child profiles: retained while the child is actively enrolled
• Check-in records: retained for 2 years for safety and compliance
• Incident reports involving children: retained for 7 years
• Inactive children (no check-in for 12+ months): guardian notified with option to re-activate or delete
• Inactive children (no check-in for 24+ months): auto-archived with PII anonymized

7. Your Rights Under GDPR (European Users)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have the following rights under the General Data Protection Regulation:

• Right of Access (Art. 15): Request a copy of all personal data we hold about you
• Right to Rectification (Art. 16): Request correction of inaccurate or incomplete data
• Right to Erasure (Art. 17): Request deletion of your personal data ("right to be forgotten")
• Right to Restriction (Art. 18): Request limitation on processing of your data
• Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format (JSON or CSV)
• Right to Object (Art. 21): Object to processing of your data based on legitimate interest
• Right to Withdraw Consent (Art. 7): Withdraw previously given consent at any time
• Right Not to Be Subject to Automated Decisions (Art. 22): We do not make automated decisions that produce legal effects

International Data Transfers

Zion App is based in the United States. If you are accessing our services from the EEA or UK, your data will be transferred to and processed in the United States. We rely on standard contractual clauses (SCCs) as the legal mechanism for such transfers, as detailed in our Data Processing Agreement.

Data Protection Officer

For GDPR-related inquiries, contact our Data Protection Officer at dpo@zionapp.org.

8. Your Rights Under CCPA (California Residents)

If you are a California resident, you have the following rights under the California Consumer Privacy Act:

8.1 Right to Know

You have the right to know what personal information we collect, the categories of sources, the business purpose for collection, and the categories of third parties with whom we share it.

8.2 Categories of Personal Information Collected

8.3 Right to Delete

You can request deletion of your personal information, subject to certain legal exceptions (e.g., retaining data necessary for legal compliance or completing a transaction).

8.4 Right to Opt-Out of Sale

8.5 Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. You will receive equal service and pricing regardless of whether you exercise your privacy rights.

9. Information Sharing

We do not sell your personal information. We may share information with:

• Your Church: Church administrators have access to member and children data within their organization only (strict multi-tenant isolation)
• Service Providers: Third-party services that help us operate (see Section 12)
• Legal Requirements: When required by law, court order, or to protect rights and safety

We never share data across church tenants. Each church's data is completely isolated.

10. Data Security

We implement appropriate technical and organizational security measures:

• Encryption of data in transit (TLS) and at rest
• Field-level encryption for sensitive medical data (allergies, medical notes)
• Secure password hashing (bcrypt)
• Multi-tenant data isolation with database-level row security
• Account lockout after failed login attempts
• Rate limiting on authentication endpoints
• Guardian code and security code verification for child pickup
• Role-based access controls
• Comprehensive audit logging of all data access and mutations
• Regular dependency security audits

11. Audit Logging

For compliance and security purposes, we maintain comprehensive audit logs that record:

• All create, update, and delete operations on personal data
• Login and authentication events
• Data access and export events
• IP addresses and timestamps for each action

Sensitive fields (passwords, security codes, tokens) are redacted in audit logs. Audit logs are retained for 2 years (7 years for security-related events). These logs are used exclusively for security monitoring, compliance verification, and investigating unauthorized access.

12. Third-Party Services

We use the following third-party services to provide our platform:

All sub-processors are bound by data processing agreements. We will notify you of any changes to sub-processors with at least 30 days notice.

13. Data Retention

We retain data for the minimum period necessary for each purpose:

14. Cookies

We use only essential cookies necessary for the functioning of the platform:

• Session cookies: To keep you signed in
• Security cookies: CSRF protection and session management

We do not use tracking cookies, advertising cookies, or any third-party analytics cookies.

15. How to Exercise Your Rights

You can exercise any of your privacy rights by:

• Submitting a data request online
• Contacting your church administrator
• Emailing privacy@zionapp.org

We will respond to verifiable requests within 30 days (or 45 days for complex requests, with notification of the extension). We may need to verify your identity before processing your request.

16. Changes to This Policy

We may update this Privacy Policy periodically. For material changes, we will notify church administrators via email at least 30 days before the changes take effect. We will also update the "Last updated" date at the top of this page.

17. Contact Us

If you have questions about this Privacy Policy or our data practices: