The short version

Who is responsible for what

This is the most important part of this policy, and it decides who you go to about your own information.

For a church administrator’s own account — the name, email address and password used to sign in to Foldmetric — we are the controller. We decide what is collected and why, and you exercise the rights below against us.

For a congregation’s records — the members in a church’s directory and their attendance — the church is the controller and we are its processor. The church decides who goes in its directory, what it is for, and how long to keep it. We hold and process that information on the church’s written instructions and for no purpose of our own.

So if you are a member of a congregation and want to know what is held about you, corrected, or erased, ask your church. They can act on it themselves inside Foldmetric, immediately. If you cannot reach them, write to us at privacy@foldmetric.com and we will put you in touch and, where the law requires it, act ourselves.

What we hold

About a church and its administrators

About a congregation

We do not ask for and have no field for dates of birth, addresses, giving, family relationships, photographs, or any of the special categories of data the GDPR protects — including, deliberately, religious belief. Foldmetric records that somebody was in a building. A church may of course infer more from that, which is one reason the church and not Foldmetric is the controller of it.

Technical

Why we hold it, and on what legal basis

Who else touches it

These are our sub-processors. We do not add one without updating this list.

When card payments go live, the provider taking them — Paystack for churches in Africa and Stripe elsewhere — will receive the billing contact and payment details directly. We will update this policy before that happens, not after.

We have never sold personal information, and we do not share it for cross-context behavioural advertising. We would have to change this policy and tell you before that could change.

Where it goes

Foldmetric serves churches in about twenty countries, so data may be processed outside the country you are in, including outside the UK, the EEA and Nigeria. Where personal data covered by the UK GDPR or EU GDPR leaves those areas, we rely on the European Commission’s Standard Contractual Clauses, and the UK Addendum where the UK GDPR applies. [CONFIRM: SCCs executed with each sub-processor, and a transfer risk assessment on file.]

How long we keep it

Your rights under the GDPR

If you are in the UK or the EEA you have the right to be told what we hold, to get a copy of it, to have it corrected, to have it erased, to restrict or object to how we use it, and to have it handed to you in a portable format. Where we rely on legitimate interests you may object, and we will stop unless we have compelling grounds not to.

We do not make automated decisions with legal or similarly significant effects about anybody. The absence list is a list; a person decides what to do about it.

Write to privacy@foldmetric.com. We answer within one month. You can also complain to your supervisory authority — in the UK, the Information Commissioner’s Office — though we would rather you gave us the chance to fix it first.

[IF SELLING INTO THE EEA OR UK WITHOUT AN ESTABLISHMENT THERE: appoint an Article 27 representative and name them here.]

Your rights under the CCPA/CPRA

If you are a California resident you have the right to know what personal information we have collected and why, to a copy of it, to have it deleted, to have inaccuracies corrected, and to limit the use of sensitive personal information. You also have the right not to be discriminated against for exercising any of them — and you will not be: nothing on Foldmetric gets worse because you asked.

In the twelve months before this policy was last updated we collected the categories described under What we hold: identifiers (name, email address, phone number), commercial information (your plan and payments), and internet activity limited to the abuse counters and server logs described above. We collected them for the purposes in the table above, from you or from the church that entered them.

We do not sell personal information, and we do not share it for cross-context behavioural advertising. We have not done so in the preceding twelve months, including for anyone under 16. There is therefore no “Do Not Sell or Share My Personal Information” link on this site, because there is nothing for it to switch off.

To exercise any of these, write to privacy@foldmetric.com. We will verify that the request is really yours — usually by replying to the address already on the account — and answer within 45 days. An authorised agent may act for you with written proof.

Children

Foldmetric is sold to churches, not to children, and an administrator account is for an adult. A church may well have children in its directory. That is the church’s decision as controller, and its responsibility to have a lawful basis and, where the law requires it, parental consent. We do not knowingly collect information directly from a child.

Security

Everything travels over TLS. The directory is never readable from a browser — the public check-in page can confirm a number belongs to a member without being able to list the congregation, and failed lookups are throttled. Session cookies are signed and unreadable by JavaScript. Each church’s records are stored beneath that church, so no query exists that could return another congregation’s data.

If a breach affects your data we will tell the relevant supervisory authority within 72 hours where required, and tell you without undue delay where the risk to you is high.

Changes

If we change this in a way that matters, we will say so on this page and email account administrators before it takes effect.

Contact

[LEGAL ENTITY NAME], [REGISTERED ADDRESS].
privacy@foldmetric.com
[DATA PROTECTION OFFICER, if one is required or appointed]

Churches needing a data processing agreement for their own records can request one at the same address.