Privacy Policy

Introduction

Thanks for using Foldmetric. Our mission is to help a church notice who has stopped coming, before it becomes months.

Foldmetric is an attendance platform for churches. A congregation checks in from a page on the church’s own subdomain, and its administrators see the roster, the attendance history, and the list of members who have missed. It is important to know what Foldmetric is not: it is not a directory anyone can browse, and it does not publish a congregation. The check-in page can confirm that a phone number belongs to a member; it cannot be asked who the members are.

We are a company built on trust. A church hands us the phone numbers of the people who turn up on a Sunday, and a fundamental part of earning that trust means being clear about how we use your information and protecting your right to privacy.

Foldmetric is a platform and a brand owned and operated by Bashlabs Innovation (“Bashlabs”, “us”, “we”). This Privacy Policy explains how Bashlabs collects, uses, and discloses information about you. It applies when you use our website, our check-in pages, and other online products and services that link to this Privacy Policy (collectively, our “Services”), contact us for support, or otherwise interact with us.

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), 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 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 hello@foldmetric.com and we will put you in touch and, where the law requires it, act ourselves.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice, such as a statement on our website or an email to account administrators before it takes effect. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Contents

• Collection of Information
• Use of Information
• Sharing of Information
• Transfer of Information to Other Countries
• Your Choices
• Your California Privacy Rights
• Additional Disclosures for Individuals in Europe
• Other Important Information
• Contact Us

Collection of Information

Data you provide to us

• Account creation. To create an account you provide your name, an email address, a password, and the role you picked from a list. For the church itself: its name, the subdomain you chose, country, city, time zone, service times, and a logo if you upload one. Passwords are handled by Google Firebase Authentication; we never see or store one.
• Subscriptions. If you subscribe to a paid plan you provide billing details. Card details are never sent to us or stored by us; they go directly to the payment provider. We keep your plan, the currency you are quoted in, and a record of payments.
• Invitations. The email address and role of anyone you invite to help administer the church, until the invitation is accepted or revoked.
• Your congregation’s directory. Each member’s name, and a phone number or an email address (at least one, because that is how check-in recognises them), plus the date they were added and whether they were added by the office or registered themselves. This is the church’s data, held on its instructions, as described above.
• Attendance. That a named member checked in, on which date, to which service, and at what time.
• Messages to members. If a church turns on automatic follow-up, a record of each message sent to a member: when, on which channel, the words exactly as sent, and whether it went out or why it did not. It points to the member’s entry in the directory and holds no second copy of their contact details. The church sees it, so it can tell who has been contacted. If a member has not come back after three messages, or cannot be messaged at all, we email the church’s administrators that member’s name and phone number or email address, so somebody can call them. We also keep a count of how many messages the church has sent each month, which is how its plan’s monthly allowance is applied, and email its administrators when most or all of it is used. The count names nobody.

Information automatically collected by using Foldmetric

• Activity information. What an administrator does inside the dashboard, so that the roster and the attendance history reflect it.
• Transactional and payment information. When you buy a subscription we record the plan, the amount, the currency and the date.
• Device and usage information. Our hosting provider keeps ordinary request logs, which can include IP addresses, for a short period for security and reliability. We do not build profiles from them.
• Abuse counters. To stop somebody testing thousands of phone numbers against a check-in page, we count failed attempts per connection. The IP address is hashed and never stored: it goes through a keyed hash, salted with a server secret, and only the result is kept, so the counter cannot be turned back into an address or a person. The counters expire on their own within days.
• Cookies. There is one cookie, named fold_church, set only after an administrator signs in. It records which church the session belongs to, is signed so it cannot be forged, is unreadable by JavaScript, and expires after seven days. It is strictly necessary for signing in, so no consent banner asks you about it.

Information we collect from third parties

• Payment providers confirm to us that a payment succeeded, and tell us when a recurring charge is due to fire.
• Invitations. If you are invited to administer a church, that church submits your email address to us in order to send the invitation.

Use of Information

We use the information we collect to provide, maintain and improve our Services. We also use it to:

• Create and maintain your account;
• Run your church’s check-in page and produce its attendance reports and absence lists;
• Process transactions and send related information, such as confirmations and receipts;
• Send you technical notices, security alerts, and support and administrative messages;
• Respond to your questions and provide customer service;
• Detect, investigate and prevent security incidents, fraud, and other malicious or illegal activity, and protect the rights and property of Bashlabs and others;
• Debug, and identify and repair errors in our Services;
• Comply with our legal and financial obligations; and
• Carry out any other purpose described to you at the time the information was collected.

We do not use a congregation’s records for any purpose of our own. Not to train anything, not to sell to anyone, and not to market to the people in them. The church determined why that information was collected, and we are bound by it.

Sharing of Information

We share personal information in the following circumstances, or as otherwise described in this policy:

• Within your church. Administrators of a church see that church’s directory and its attendance history. Each church’s records are stored beneath that church, so no query exists that could return another congregation’s data. The public check-in page never lists a congregation.
• When the law requires it. We may disclose personal information if we believe disclosure is in accordance with, or required by, any applicable law or legal process. If we are going to disclose your information in response to legal process, we will give you notice so you can challenge it, unless we are prohibited by law or believe doing so may endanger others. We will object to requests we believe are improper.
• To enforce our terms. We may share personal information if we believe your actions are inconsistent with our user agreements or policies, or that it is necessary to protect the rights, property and safety of Bashlabs, our users, or the public.
• With our professional advisors (lawyers and accountants) where necessary to obtain advice or manage our business interests.
• Between our own companies. Bashlabs and its current and future parents, affiliates and subsidiaries under common control.
• In a corporate transaction. We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
• With your consent or at your direction.
• Aggregated or de-identified information that cannot reasonably be used to identify you.

We have never sold personal information, and we do not share it for cross-context behavioural advertising. There is no advertising on Foldmetric. We would have to change this policy and tell you before that could change.

Transfer of Information to Other Countries

Foldmetric serves churches in about twenty countries, and we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection equivalent to those of your home jurisdiction, 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. We take steps to ensure your personal information receives an adequate level of protection in the jurisdictions in which we process it.

Your Choices

• Account and church information. An administrator can access, correct, delete and export the church’s information at any time from the dashboard, on every plan, including the free one. Deleting a member removes that record immediately. Deleting your church deletes what is under it. Please note that if you close your church we may continue to retain certain records as required by law, which are invoices and nothing else.
• If you are a member of a congregation rather than an administrator, ask your church. They can act on your request themselves, immediately. See Who is responsible for what, above.
• Cookies. Most web browsers accept cookies by default, and you can usually adjust your browser settings to remove or reject them. Our one cookie is what keeps an administrator signed in, so rejecting it means you cannot sign in.
• Communications preferences. You may opt out of non-administrative email by following the instructions in the message or by writing to hello@foldmetric.com. If you opt out we may still send you administrative email, such as messages about your account, billing, or a security issue.

Your California Privacy Rights

The California Consumer Privacy Act (“CCPA”) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

In the preceding 12 months we have collected the following categories of personal information: identifiers (name, email address, phone number), commercial information (your plan and your payments), and internet or other electronic network activity information (limited to the server logs and hashed abuse counters described above). For the precise data points and the sources of collection, see Collection of Information. We collect it for the purposes described in Use of Information. In the preceding 12 months we have disclosed the following categories for business purposes to the following categories of recipients:

Bashlabs does not sell your personal information, and does 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.

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use and disclose about you, (2) request deletion of your personal information, (3) request correction of inaccurate personal information, (4) opt out of any sales of your personal information, if we ever engage in that activity, and (5) not be discriminated against for exercising these rights. You will not be: nothing on Foldmetric gets worse because you asked. Make a request by emailing hello@foldmetric.com. We may verify a request by asking you to provide identifying information, usually by replying to the address already on the account, and we answer within 45 days.

If we receive your request from an authorised agent, we may ask for evidence that you have provided that agent with a power of attorney, or that the agent otherwise has valid written authority to submit requests on your behalf. This may include requiring you to verify your identity.

Additional Disclosures for Individuals in Europe

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights and protections under applicable law regarding the processing of your personal data, and this section applies to you.

Legal basis for processing

Data retention

• While your church is on Foldmetric. The directory and the attendance record are kept until you delete them. Attendance is the product: a record that quietly deleted itself after a year would make the absence list wrong, so we do not expire it on our own initiative.
• Messages to members, the record of who was passed to the church to call, and the monthly count of messages sent are deleted automatically about thirteen months after they were made: long enough to compare a month with the same month a year earlier, and no longer.
• When you delete a member. Their record, and the record of messages sent to them, goes immediately.
• When you close your church. Everything under it is deleted within [30 days: confirm], except records we are required to keep for tax and accounting, which are invoices and nothing else.
• Abuse counters expire on their own within days.

Data subject requests

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive it in a portable format, the right to ask that it be corrected or erased, and the right to object to, or request that we restrict, certain processing. Where we rely on legitimate interests you may object, and we will stop unless we have compelling grounds not to.

To exercise your rights:

• An administrator can export a church’s roster and attendance from the dashboard at any time, and correct or delete records there.
• You may withdraw consent, or ask for your administrator account to be deleted, by writing to hello@foldmetric.com, except to the extent we are prevented by law from deleting something.
• If you are a member of a congregation, ask your church first, since it is the controller of that record and can act immediately.

We answer within one month. 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.

Questions or complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside, though we would rather you gave us the chance to fix it first. Contact details can be found using the links below:

• For individuals in the EEA: edpb.europa.eu
• For individuals in the UK: ico.org.uk
• For individuals in Switzerland: edoeb.admin.ch

Other Important Information

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. However, we cannot warrant the security of any information you send us, and there is no guarantee that data may not be accessed, disclosed, altered or destroyed by breach of any of our physical, technical or managerial safeguards. 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.

Our Services are dynamic, and we introduce new features which may require the collection of new information. If we collect materially different personal data, or materially change how we collect, use or share your data, we will notify you and modify this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us at hello@foldmetric.com.