Privacy Policy

1. Who we are and what this policy covers

AI Soft (Pty) Ltd (“we”, “us”, “GraceHub”), registration number 2025/881016/07, of 332 Boundary Road, North Riding, Johannesburg, Gauteng, 2169, South Africa, operates the GraceHub church administration platform: the website at https://grace-hub.co.za, the GraceHub member app for iOS and Android, and the APIs behind them.

This policy covers everything we do with personal information across all of those. It applies whether you are a church administrator, a staff member, a volunteer, a church member using the mobile app, or a visitor who filled in a form.

Two parties handle your information, and the difference matters. Your church decides what to record about its members and why. Under the Protection of Personal Information Act 4 of 2013 (POPIA) it is the responsible party, and under the GDPR it is the controller. We provide the software and process that information on the church's instructions, as its operator (POPIA) or processor (GDPR). Where we make our own decisions, such as securing the platform, billing a church or preventing abuse, we are the responsible party, and this policy is our notice to you under section 18 of POPIA.

If you want your information corrected or removed and you are a member of a church that uses GraceHub, the fastest route is your church's administrator. You can also come to us directly at privacy@grace-hub.co.za and we will act on it.

2. Information Officer and how to reach us

Our Information Officer, appointed under section 55 of POPIA and registered with the Information Regulator, is Ntokozo Shabalala.

Privacy and data requests

privacy@grace-hub.co.za

General support

info@aisoft.co.za

Child safety reports

safety@grace-hub.co.za

Postal address

332 Boundary Road, North Riding, Johannesburg, Gauteng, 2169, South Africa

We answer privacy requests within 30 days. We may ask you to confirm your identity first. This is not to delay you, but because handing someone else's church record to the wrong person is the exact harm this policy exists to prevent.

3. What we collect

We collect only what the platform needs to do its job. What follows is the complete list, by category. Not all of it applies to you, because most of it depends on which features your church has switched on and what you choose to enter.

Identity and contact information

Your name and surname, email address, mobile number, physical and postal address, date of birth, gender, marital status, preferred language, and a profile photo if you upload one.

Church membership information

Your membership status and join date, the branch or campus you belong to, your roles and permissions, the ministries and teams you serve on, the small groups you belong to, your attendance and event check-ins, and your household or family links to other members.

Religious information

The fact of your membership of, and participation in, a religious organisation, including baptism, confirmation and discipleship records where your church keeps them. POPIA classifies information about religious beliefs as SPECIAL personal information (section 26), and we treat it that way: see section 5 below.

Financial information

Your giving history, meaning amounts, funds, dates, payment method and status. Also the donation receipts issued to you, merchandise orders and event ticket purchases. We never see, receive or store your card number, CVV or bank credentials: those are entered into Paystack's own secure payment form and sent straight to Paystack, never to our app or servers.

Content you create

Messages and conversations you send through the app, care and prayer requests (including any photograph you attach to one), notes, form submissions, group content, and anything else you type or upload.

Health information

Allergies, dietary needs, medical conditions and medication a member or a parent records, most often on a child's check-in record, so the team looking after them knows. Health information is special personal information under POPIA section 26 and is treated as such: see section 5.

Care and pastoral information

Where your church runs pastoral care, counselling or benevolence programmes through the platform, the records those produce. This can include health-related and other sensitive details that you or your pastoral team choose to record. Access is restricted to the people your church has given the relevant permission.

Account and technical information

Your account identifier, a securely hashed password, authentication tokens, the church and branch your account belongs to, IP address, the pages and screens you use, and error and diagnostic logs.

Location information

Only when you are an assigned responder who has chosen to go to a care request, and only while the app is open and you are marked as on your way. The app then shares your device's location so the member waiting can see how far off you are. It is foreground-only (there is no background or always-on tracking), it stops the moment the request is resolved, cancelled or handed back, the position is not retained afterwards, and it is refusable — declining it leaves the rest of the app working normally.

Just as importantly, here is what we do NOT collect:

• We do not track your location in the background or follow your movements over time, and we use no location-broadcasting or advertising SDKs. The app uses location in one narrow case only — an assigned responder sharing how far away they are while on their way to a care request — described in section 4.
• We do not track you across other companies' apps or websites, and we do not use advertising identifiers. The mobile app contains no advertising SDK and no analytics SDK at all.
• We do not sell your personal information, and we never have.
• We do not use your information to train machine-learning models.
• We do not read your device's contacts, calendar, microphone, or files outside the specific photo you choose to attach.

4. Device permissions the mobile app asks for

The app asks for three device permissions, each only at the moment you use the feature that needs it, and each refusable. Declining any of them leaves every other part of the app working normally.

Camera

Only when you choose to photograph something to attach to a care request. The app never opens the camera in the background.

Photo library

Only when you choose an existing picture to attach to a care request or to set as your profile photo. We receive the single image you pick, not your library.

Location (while in use)

Only when you are an assigned care-request responder and have said you are on your way, so the member waiting can see how far away you are. It is asked for at that moment, used only while the app is open, and never used to track you in the background. See section 3.

4a. Cookies and analytics on the website

This section is about the website only. The mobile app sets no cookies, contains no analytics SDK, and is not covered by anything below.

Strictly necessary cookies

A session cookie that keeps you signed in, and a security token that prevents cross-site request forgery. The site does not work without these, so they are set without asking.

Analytics

Google Analytics, to count visits and see which pages are used. It records the pages you view, an approximate location from your IP address, and your device and browser type. It is not used to build an advertising profile and we do not run advertising.

You can block or delete cookies in your browser settings, and turn off analytics with your browser's Do Not Track setting or an ad blocker. Doing so does not affect your account.

5. Why we process it, and our lawful basis

To run the service you asked for

Creating and securing your account, showing you your church's events, sermons, groups and giving history, delivering your messages, recording your check-ins. Lawful basis: performance of a contract, and the legitimate interests of your church in administering its own membership.

To process giving and orders

Recording a donation, initiating a payment with Paystack, issuing receipts, fulfilling merchandise orders and event tickets. Lawful basis: contract, and compliance with tax and financial record-keeping law.

To communicate with you

Transactional email and in-app notices: password resets, receipts, event reminders, and announcements from your church. Lawful basis: contract and legitimate interest; consent where the law requires it for marketing.

To keep the platform safe

Detecting fraud and abuse, investigating reported content, enforcing our Terms, and maintaining audit logs. Lawful basis: legitimate interest and legal obligation.

To meet legal obligations

Retaining financial records, responding to lawful requests, and complying with POPIA, tax law and, where applicable, the GDPR.

Special personal information. Your religious affiliation, and any health or pastoral detail recorded about you, are special personal information under POPIA section 26. For religious information we rely on section 27(1)(a), your consent, and on section 28, which permits a religious organisation to process its own members' religious information where that is necessary to achieve its aims. For health information we rely on your consent under section 27(1)(a), and on section 32 where it is processed to protect your health or that of a child in the church's care. You may withdraw consent at any time by contacting your church or us, and we will stop, subject to records we must keep by law.

6. Who we share it with

We share personal information only with the service providers listed below, each bound by a written agreement that limits them to processing it on our instructions. We do not sell it and we do not share it with advertisers or data brokers.

Google Cloud and Firebase (Google LLC / Google Ireland Ltd)

Authentication, database, file storage and application hosting. This is where your church's data physically lives.

Paystack (Paystack Payments Ltd, a Stripe company)

Payment processing for donations, merchandise and tickets. You enter card details on Paystack's own page; we receive only the outcome, the amount and a reference.

Brevo (Sendinblue SAS)

Delivery of transactional and notification email on our behalf.

YouTube and Vimeo

Where your church publishes sermon video on those platforms, the app embeds their player. Playing a sermon means the video platform sees the request, subject to its own privacy policy.

We also disclose personal information in these limited circumstances:

• Within your church, to the people your church's own permission settings allow: an administrator, your group leader, your pastoral team.
• Where the law requires it, or in response to a valid legal request.
• To protect the rights, safety or property of a member, of your church, or of us, including reports of child sexual abuse and exploitation, which we report to the relevant authorities.
• To a successor entity if the business is sold or reorganised, on the same terms as this policy.

7. Where your information goes

Your information is processed in South Africa and in the following places: Google Cloud and Firebase regions in the European Union (europe-west1, Belgium) and the United States; Paystack in Nigeria and South Africa, with Stripe group infrastructure in the United States and Ireland; and Brevo in the European Union (France).

When personal information leaves South Africa we rely on section 72 of POPIA: each recipient is bound by an agreement that upholds principles substantially similar to POPIA's conditions for lawful processing, and none of them may process it for their own purposes. For transfers out of the European Economic Area we rely on the European Commission's Standard Contractual Clauses. We do not carry out any processing that requires the Information Regulator's prior authorisation under section 57.

8. How long we keep it

While your account is active

For as long as you are a member of a church that uses the platform.

After you delete your account

Personal information is deleted or irreversibly anonymised within 30 days, except for the categories below.

Financial and donation records

Retained for 5 years from the end of the relevant tax year, as South African tax and company law requires. These are anonymised so the amount and date survive for the church's audit while no longer being linked to you.

Safety and abuse records

Reports of abusive or unlawful content, and the action we took, are retained for as long as needed to keep the platform safe and to meet legal obligations.

Backups

Encrypted backups roll off within 90 days. Deleted information disappears from backups as they expire.

9. How we protect it

• Everything is encrypted in transit with TLS, and encrypted at rest by our cloud provider.
• Passwords are stored only as salted hashes; nobody at GraceHub can read yours.
• Access is role-based: church administrators decide who in the church can see what, and our own staff access is limited to what a named support task requires and is logged.
• Payment card data never reaches our servers. It is entered on Paystack's hosted page.
• We keep audit logs of administrative actions, and we monitor for unusual access.

No system is perfectly secure. If a breach affects your personal information we will notify you and the Information Regulator as section 22 of POPIA requires.

10. Your rights

Under POPIA, and under the GDPR if you are in the EEA or UK, you have the right to:

• Ask whether we hold personal information about you, and get a copy of it.
• Have inaccurate or incomplete information corrected.
• Have information deleted or destroyed when we no longer have grounds to keep it.
• Object to processing based on legitimate interests, and to direct marketing at any time.
• Withdraw consent you previously gave, without affecting what we did lawfully before you withdrew it.
• Receive your information in a portable, machine-readable format.
• Complain to the Information Regulator, or to your local supervisory authority.

To exercise any of these, edit your details in the app or on the website, ask your church administrator, or email privacy@grace-hub.co.za. You can delete your account and request deletion of your data at any time. See "Deleting your account" below.

Information Regulator (South Africa)

Complaints: POPIAComplaints@inforegulator.org.za · General: enquiries@inforegulator.org.za · https://inforegulator.org.za

11. Deleting your account

You can delete your account and your personal information from inside the mobile app: open Profile, then Settings, then Delete account. You will be asked to confirm, and told exactly what is removed and what must be kept.

You can also request deletion without installing anything, at https://grace-hub.co.za/delete-account, or by emailing privacy@grace-hub.co.za from the address on your account. Either route is honoured within 30 days.

12. Children and young people

Churches keep records about children, such as a youth group register or a child's attendance at a holiday club. Where a church records information about a person under 18, that information is processed on the authority of a competent person (a parent or guardian) as section 35 of POPIA requires, and the church is responsible for obtaining it.

The GraceHub mobile app is not directed at children and is not listed in the Kids category on either store. An account may be created either by a church administrator or by a person joining their church themselves, and our Terms require an account holder to be 18 or older unless a parent or guardian has consented and accepted the Terms on their behalf. A member's request to join is reviewed and approved by their church before the account becomes active, which is where that check happens.

If you believe we hold a child's information without proper authority, email privacy@grace-hub.co.za and we will remove it. If you are a parent and want to see, correct or delete what your church holds about your child, ask your church administrator or write to us and we will help.

13. Access to information (PAIA)

The Promotion of Access to Information Act 2 of 2000 requires every private body in South Africa to publish a manual describing the records it holds and how to request them. Ours covers both the records we hold as a business and the records we process on behalf of the churches that use the platform.

The PAIA manual is available on request from privacy@grace-hub.co.za, and requests under PAIA should be sent to the Information Officer at the same address. A request about your own personal information does not need PAIA. Use section 10 above, which is faster.

14. Changes to this policy

We update this policy when what we do changes. The date at the top of the page always reflects the current version. For material changes we email registered users and show a notice in the app before the change takes effect. Continuing to use the platform after that means you accept the updated policy.