Privacy Policy

Introduction

This Data Processing/Protection Policy applies to "Deeper Life Enterprise Solutions" and "Deeper Life Bible Church" (referred to as "us," "we," "our," or "the organization").

Purpose and Scope

Purpose of the Policy

The policy ensures compliance with relevant legislation including the Nigerian Data Protection Regulation 2009 (NDPR), the Cybercrimes Act (2015), the 10 Data Security Standards, and the General Data Protection Regulation (2016). The organization recognizes data protection as a fundamental right.

Scope of the Policy

This applies to employees, contractors, third-party vendors, and anyone handling personal or sensitive data collected by the organization.

Data Collection

Data Collected

The organization collects data through product and service interactions. Users provide data directly (registration, event signup, newsletter subscription, support requests) and indirectly (usage patterns, device information).

Means of Data Collection

Data collection occurs through two methods: direct provision by users and automatic collection via cookies and usage tracking. Collected categories include:

• Bio-data (name, email, age, gender, spousal information)
• Church data (district, group, region, state, country, worker/leader status)
• Career data (job, employment status, work location)
• Device data (operating system, browser type, URLs)

Data Not Collected

The organization does not intentionally collect sensitive information revealing political opinions, philosophical beliefs, sexual orientation data, or personal monitoring information. Anyone asked for such data by claiming church affiliation should contact support@dclm.org.

Data Processing: How We Use Your Information

• Product/Service Access: Account creation, website identification, survey invitations, and communications via email.
• Administrative Purposes: New product development, identity verification, account communications, and legal compliance.
• Member Management: Communication between leaders and members, attendance tracking, statistics, program notifications.

Data Access and Storage

Secure Storage

Data is stored on secure cloud services (AWS and Microsoft Azure) with regular data sanitation by authorized personnel only.

Retention Period

Data is retained for the duration of the user's membership or as necessary to fulfill the purpose for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Data Access

Access is strictly limited by role (Zonal Pastor, National Overseer, State Overseer, Region/District Coordinator, Group Pastor, District Pastor). Only the Super Admin has unrestricted access. Users may request copies of their data.

Deletion of Data

Users may delete personal information through account settings. The organization will delete full profiles except where legally required. Non-identifiable data may remain after deletion.

Data Processing Principles

• Establish policies for controlled sharing with other agencies considering all relevant legislation and user consent.
• Obtain informed, explicit consent in clear, accessible language when required.
• Ensure compliance with NDPR, GDPR, and Cybercrimes Act.
• Uphold user rights including: right to be informed, right of access, right to rectification, right to erasure, right to restrict processing, and right to object.

Responsibilities

Data Security Lead (DSL)

The organization has appointed a staff member as DSL who reports to senior management.

DSL Duties

• Ensure individual rights regarding personal data are upheld.
• Define data protection policies and procedures.
• Monitor information handling for compliance.
• Oversee system and process changes.