1. Introduction
This policy explains how EZER handles personal information. It is written to meet the Nigeria Data Protection Act 2023 (NDPA) and the standards set by the Nigeria Data Protection Commission (NDPC).
We have kept it short and plain. If anything is unclear, ask us.
2. Who controls the information
There are two roles here, and the difference matters:
- Your ministry decides whose records go into EZER, what is recorded, and why. Your ministry is the data controller for those records.
- We hold and process those records on your ministry’s instructions, so that the service works. We are the data processor. Our Terms of Service set out the processing terms between us and each ministry.
- We are the controller for the ministry’s own sign-in and subscription details, and for demo requests made on our website.
If you are a member of a ministry and want to know why your details are held, please ask your own ministry first, because they decide that.
3. What we hold
| Category | What it covers |
|---|---|
| Sign-in and ministry details | Ministry name, city, contact person, email address, phone number, the plan chosen, and when the terms were agreed to |
| Member records | The names, phone numbers, area, birthdays (with or without the year), titles, departments served in, family and group membership, and notes that your ministry chooses to enter, or that members give at the welcome desk or in the member app |
| Attendance | Who attended which service, and the time they arrived when they checked in |
| Prayer requests | What a member or the ministry writes, and who may see it (the whole care team, the pastor only, or private) |
| Children and teens | Children’s and teens’ names, birthdays, parents or guardians, check-in and collection records, as entered by the ministry |
| Photos | A profile photo, if a member adds one or the ministry adds one for them |
| Stewardship records | Amounts received and expenses recorded, with categories and dates, as entered by your ministry |
| Team messages | Messages between the people with a login in the same ministry |
| Notifications | If you turn notifications on, the address your phone’s notification service gives us, so we can send to that phone |
| Subscription status | Whether a payment succeeded, and when the plan renews |
| Demo requests | The ministry name, your name, email and anything you tell us when you ask for a demo |
| Technical logs | The records needed to keep the service running and secure |
Passwords. We never see or store your password in readable form. It is held only as a secure one-way hash, which means we cannot read it, recover it, or tell anyone what it is. If you forget it, you reset it.
Card details. We never receive or store card numbers. Payment details go directly to our payment provider and never reach us.
4. Sensitive information
Being on a ministry’s register says something about a person’s religious belief, and a prayer request can say something about their health or family. The NDPA treats this as sensitive personal data, and so do we:
- A ministry keeps these records in the course of its own activities with its members and the people who come to it, and with their agreement. Every form that puts a new person on a register asks for that agreement.
- Only the people the ministry gives access to can see them, and each team sees only the parts of EZER its pastor has opened to it. The database itself enforces this.
- Prayer requests can be kept to the pastor alone, or private. Their words are never shown in a phone notification, and nor is the name on one that is not shared with the whole care team.
- We do not use any of it for anything but providing the service to that ministry.
5. Children and young people
Under the NDPA, anyone under 18 is a child, and their information needs the agreement of a parent or guardian.
- Children do not have logins. A ministry’s children’s team keeps their records, and confirms that a parent or guardian has agreed before adding them.
- A member account in the member app is for people who are 18 or older, or whose parent or guardian has agreed. Whoever creates one confirms this.
- At the welcome desk, someone signing themselves up confirms they are 18 or older or a parent or guardian, and an usher signing someone up confirms the same on their behalf.
- Accounts that run a ministry are for adults only: whoever creates one confirms they are 18 or older.
If you believe a child’s information is in EZER without a parent’s agreement, tell the ministry or us, and it will be removed.
6. Photos
A member may add a profile photo in the member app, or the ministry may add one for them, so the ministry can recognise and celebrate them, for example on their birthday.
- Photos are stored privately. Only the member and their ministry’s team can see them, through links that expire within an hour.
- We do not use photos for face recognition, identification or any other biometric processing, and we do not let anyone else do so.
- A member can remove their own photo at any time from the member app, and the ministry can remove it for them. Removing it deletes the file.
7. Why we use it, and our lawful basis
| Purpose | Lawful basis under the NDPA |
|---|---|
| Providing the service to your ministry | Performance of a contract |
| Keeping a ministry’s member, attendance, prayer and children’s records | The ministry’s own basis as controller: the agreement of the person (or their parent or guardian), and the ministry’s legitimate activities with its members |
| Sending notifications to a phone | Consent, given by turning them on; withdrawn by turning them off |
| Taking subscription payments | Performance of a contract; legal obligation |
| Keeping the service secure | Legitimate interest |
| Answering support and demo requests | Performance of a contract; legitimate interest |
| Meeting tax and regulatory duties | Legal obligation |
| Sending account notices, such as a trial ending or a policy change | Performance of a contract; legal obligation |
We do not sell personal data. We do not rent, trade or disclose it for anyone else’s marketing, advertising or profiling. We do not send marketing email. We make no decisions about anyone by automated means alone.
8. The providers that run the service
EZER depends on a small number of specialist providers. They act only on our instructions, are bound by contract to protect the data, and may not use it for their own purposes.
| Provider | What it does | Where |
|---|---|---|
| Supabase | The database, sign-in, photo storage, and sending notifications | United Kingdom (London) |
| Netlify | Hosts the website and the app | Worldwide network |
| Paystack | Takes subscription payments | Nigeria |
| Resend | Delivers account emails, such as trial reminders | United States |
| Google, Apple and Mozilla | Deliver notifications to phones that turned them on. The content is encrypted on its way and they cannot read it. | Worldwide |
Beyond those providers, we do not give your information to anyone.
Because some of these providers keep data outside Nigeria, information is transferred abroad. We rely on the safeguards the NDPA permits for transfers, including contractual protections requiring an adequate level of protection.
We may disclose information where the law requires it, or to establish or defend a legal claim. We will tell you if that happens, unless the law prevents us.
9. How long we keep it
- While your subscription is active: we keep your records so the service works, and you can export them at any time. A ministry can delete a person’s record or photo whenever it chooses.
- After cancellation: your records stay available for export for 30 days.
- After that: we begin deleting them. Deletion completes within 90 days of cancellation, unless the law requires us to keep something longer.
- A trial that is never activated: the records are deleted, after a warning email seven days before.
- Notifications: a phone is forgotten when it is turned off, when someone signs out, or when the phone’s service says it is gone. Undelivered notices are dropped after a day.
- Demo requests: kept while we are talking with you, and deleted on request.
- Financial records: kept for the period Nigerian law requires.
- Backups: may hold copies for a short further period before being overwritten on their normal cycle.
You can ask for earlier deletion at any time.
10. Your rights under the NDPA
If your personal information is held in EZER, you have the right to:
- Be informed about how it is used;
- Access a copy of it;
- Correct anything inaccurate or incomplete;
- Erasure, where there is no continuing lawful reason to keep it;
- Restrict or object to certain processing;
- Portability, to receive it in a commonly used format;
- Withdraw consent at any time, where it was relied on, such as for notifications;
- Not be subject to a decision made by automated means alone;
- Complain to the Nigeria Data Protection Commission.
To exercise a right, write to hello@ezerng.com. We respond within 30 days. If a ministry entered the information, we will normally refer you to that ministry, because they control those records, and we will help them respond.
11. How we protect it
- All traffic is encrypted in transit using HTTPS.
- Passwords are stored only as secure one-way hashes.
- Every ministry’s records are isolated from every other ministry’s at the database level.
- Permissions are enforced by the database itself, so a person cannot reach information outside their role.
- Photos are private, reached only through links that expire.
- Access to live systems is limited to the people who need it.
No system is perfectly secure. If a breach occurs that is likely to put people at risk, we will notify the NDPC within 72 hours of becoming aware of it, and tell the ministries and people affected without delay, as the NDPA requires.
13. Changes to this policy
We will update this policy as the service and the law develop. Material changes will be notified by email or in the app at least 30 days in advance. The date at the top always reflects the current version.
14. Contact and complaints
For any privacy question or request, contact us at hello@ezerng.com.
If you are not satisfied with our response, you may complain to the Nigeria Data Protection Commission (NDPC).