DRAFT, not yet legal advice. Have a Kenyan advocate review this before launch, and fill in the [bracketed] details.
Who we are: OneAltar, operated by [legal entity name, registration number, Nairobi address]. Contact: [privacy email]. We follow the Kenya Data Protection Act, 2019 (and the GDPR where it applies).
You join OneAltar with one click. There is no login and no form. When you click Subscribe:
| What | Where it comes from | Why |
|---|---|---|
A random device ID (for example 3f2b…-…) | Created by your browser and kept in its local storage | So the same device is counted once, and so you can unsubscribe |
| Date and time you subscribed | Our server | Counting subscribers over time |
| Country (two letters, for example KE) | Worked out by Cloudflare from your connection. We do not store your IP address. | Showing how many countries are worshipping, planning languages and times |
| Preferred language (for example sw-KE) | Your browser's language setting | Planning which languages to support |
We do not collect your name, phone number, email, contacts or precise location for Subscribe. The device ID is not linked to anything that identifies you. Lawful basis: legitimate interest in counting and running the service (and your choice to click Subscribe).
Unsubscribe or erase: open "Optional: save my account…" under the Subscribe button and choose Unsubscribe this device. This deletes your row from our database and removes the ID from your browser. Clearing your browser's site data also removes the ID from your device. If you do that without unsubscribing first, the anonymous row stays in our count but can no longer be linked to you.
When you give using Lipa na M-Pesa (Pay Bill 522533, Account 7674573), the payment happens entirely inside Safaricom M-Pesa. OneAltar's website never sees your PIN. As with any Paybill payment, the account holder receives the transaction details that M-Pesa and the bank provide (typically your name, phone number, amount and reference). We use them only to record and acknowledge gifts, and we keep them as long as Kenyan tax and financial-record laws require. OneAltar will never ask for your PIN.
Only if you choose to fill in the optional "Church leader or volunteer?" form, we store the email or phone number you enter, your role, the country you type and a record of your consent. We use this only to contact you about the launch and onboarding, and keep it until launch plus 6 months or until you ask us to delete it. Lawful basis: your consent.
Saving your account with Google or a phone number is not live yet. If we add it, it will be optional, used only to sync your follows and bookmarks across devices, and this notice will be updated before it goes live.
Last updated: [date].