Privacy Policy

Introduction

Quabynah Codelabs LLC ("Zoe", "we", "our", or "us") operates Zoe Community ("the App"), a multi-tenant platform that connects churches ("communities") and their members. Zoe is built Ghana-first and offers devotionals and reading plans, events and RSVPs, prayer, groups and chat, fasting challenges, podcasts and sermons, and live services. Giving is planned and is not yet available.

This Privacy Policy explains what personal data we collect, why, how we use and share it, and the rights you have over it. Quabynah Codelabs LLC is the data controller for the personal data processed through the App under the Republic of Ghana's Data Protection Act, 2012 (Act 843) and, where it applies to members in the European Union, the EU General Data Protection Regulation (GDPR). Each community's administrators decide who joins their community and what is published inside it; see "Church administrators".

This notice covers the Zoe Community mobile app and our website. Where we rely on your consent, we ask for it separately and you may withdraw it at any time.

This document is a draft prepared for legal review. It describes our intended data practices in plain language and is not a representation of certified legal compliance.

Information We Collect

• Account information. Your name, email address, and profile photo, provided by Google, Apple or, where offered, GitHub when you sign in. We never receive or store your password with those providers. If you add a passkey, we store its public key and credential identifier, never the private key, which stays on your device.
• Profile details you add. A handle, a bio, interests, and an optional date of birth. Your date of birth is used to send you birthday wishes and to protect younger members. The date itself is never shown to anyone else; other members can only see that you have a birthday today, and only inside communities that enable birthday wishes and while you keep that setting on.
• Community membership. The communities you belong to, your membership status, and your role in each (member, leader, pastor, or administrator). Because Zoe is a platform for churches, your membership reveals your religious affiliation. That is special personal data under Act 843; see "Special personal data".
• Content you create. Posts, comments, reactions, chat, group and direct messages, prayer requests including private pastoral-care requests and the photos and voice notes you send in them, event RSVPs, reading and streak history, and items you save.
• Engagement signals. Which posts, events, devotionals and reading plans you open, react to, share, or subscribe to. We use them only to order the rails on your home screen; see "Retention".
• Location. With your permission, your device's coordinates at the moment you search for communities or events near you. We do not store your location on your profile.
• Microphone. With your permission, we use your microphone only while you record a voice note in a pastoral-care conversation. We never listen at any other time.
• Device and diagnostics. Push notification tokens, device model and operating system version, app version, and crash and error reports.
• Usage data. Pseudonymised analytics events (which features you use, which content you view) tied to an account identifier, collected only after you consent in the App.

We do not collect payment-card or mobile-money credentials. When giving launches, it will be processed by a licensed payment provider and this notice will be updated first.

Special Personal Data

Two kinds of data in Zoe are special personal data under Act 843: your religious affiliation, which your community membership reveals, and the content of prayer and pastoral-care requests, which often concern health, family, or other private matters.

We process them on the basis of your explicit consent, which you give when you join a community and when you submit a prayer or pastoral-care request, and, for community data, the standing of each community as a religious organisation processing the data of its own members. A pastoral-care request is visible only to you, the pastoral staff member it is assigned to, and your community's pastoral administrators; that restriction is enforced in our database, and no other community can see it. Prayer requests you post to a prayer wall are visible to the audience you choose. You may withdraw consent at any time by deleting the content, leaving the community, or deleting your account.

Cookies and Tracking Technologies

We use a limited set of cookies and similar technologies across our website and within the App.

• Website. We use strictly necessary cookies to make the site function and may use limited analytics to understand aggregate traffic. We do not use third-party advertising or cross-site tracking cookies. Where required, we ask for your consent to non-essential cookies and let you manage your preferences.
• Mobile app. The App does not use browser cookies. It keeps sign-in tokens in your device's secure keystore and caches content in the App's private storage so it works offline. We do not operate advertising SDKs.

You can control cookies through your browser settings and notification permissions through your device settings. Disabling some technologies may affect how the site or App works.

Lawful Bases for Processing

Act 843 requires your prior consent unless processing is necessary for a contract with you, required by law, in your legitimate interest, or in our legitimate interest, and the GDPR applies similar bases to members in the EU. We rely on:

• Performance of a contract — to provide the App and the features you ask for: your account, community membership, content, notifications you have turned on.
• Consent — for special personal data, optional analytics, location, non-essential cookies and any marketing. You may withdraw consent at any time without affecting processing already carried out.
• Legitimate interests — to keep the App secure, prevent abuse, order your home rails by what you engage with, and improve the product through pseudonymised analytics, balanced against your rights and freedoms.
• Legal obligation — to comply with applicable laws, lawful requests from authorities, and record-keeping duties.

How We Use Your Data

We plan to send published community content (devotionals, podcast episodes, and posts, never prayer or pastoral-care requests) to AI providers for search indexing and content moderation. We will update this notice and our provider list before that feature launches.

How We Disclose Your Data

We do not sell your personal data. We share it only as described here.

Service providers. We use the following providers to operate the App. Each receives only the data needed for its purpose and is bound by contractual confidentiality and data-protection obligations.

Image resizing runs on our own servers and involves no third party. When giving launches it will be processed by Paystack; when AI search and moderation launch they will use Voyage AI and OpenAI for published content only. Both will be added here first.

Church administrators. Administrators and leaders of a community you join can see information relevant to their community: your name, profile photo, membership role, and your activity and content within that community, such as your event RSVPs and posts. They also see daily totals of how their community is growing and taking part, such as how many members were active, prayed for each other, read its devotionals or listened to its podcasts. These totals name no one, and any total under five is shown only as "Fewer than 5". Pastoral-care requests are visible only to the staff member assigned to them and your community's pastoral administrators. Administrators of one community cannot see your data in another community; that separation is enforced in our database. If a community's administrators close it, or ask us to, they can download a copy of it that includes your name, handle, role and join date, and the posts you shared there other than private ones; see "When a community closes".

Legal requirements. We may disclose personal data when required by law, court order, or a valid request from a public authority, or where disclosure is necessary to protect the rights, safety, or property of our users, the public, or Zoe.

In the event of a merger, acquisition, or asset sale, personal data may be transferred to the successor entity, subject to this notice and applicable law.

Aggregated / De-Identified Data

We may aggregate or de-identify personal data so it can no longer reasonably be linked to you, for example counts of attendees at an event or overall feature-usage statistics. We may retain and use aggregated or de-identified data indefinitely for analytics, reporting, and product improvement. We do not attempt to re-identify it.

Retention of Your Data

We keep personal data only for as long as we need it for the purposes described in this notice, then delete or de-identify it.

• Account, profile, memberships, and the content you create. Kept while your account exists, or until the community they belong to is deleted; see "When a community closes". You can delete individual content at any time.
• Engagement signals. Deleted after 90 days; only the last 30 days are used to order your home screen.
• Notification history. Deleted after 90 days.
• Sign-in sessions. A session expires after 30 days without use, and you can end any session from the Active sessions screen in the App.
• Device tokens. Kept while valid; removed when you sign out, uninstall, or revoke notification permission.
• Diagnostics and pseudonymised analytics. Kept only as long as needed to find problems and understand usage; aggregated statistics may be kept indefinitely.

Account deletion. You can delete your account from the account settings in the App after confirming with a passkey; if you have none, the App asks you to add one first. Deletion is immediate and permanent, and there is no grace period and no way to undo it. Your account, profile, community memberships, engagement signals, reading history, bookmarks and highlights, reactions, media, notifications, message read markers and block lists are deleted straight away. Content you shared with other people stays where they received it, with your name and profile removed so it can no longer be linked to you: posts and comments, prayer requests, announcements, messages in community channels, and direct messages you sent, which the other participant keeps. We keep only records we must retain by law, a deletion record that holds a hash of your email address and the date, and aggregated data that cannot be linked to you.

When a community closes. A community closes when one of its administrators asks and another agrees, when we agree to the request of a community's only administrator, or when we close it ourselves. It closes straight away: its members lose access, it leaves search and discovery, nobody can join it, and pending join requests and invitations are declined. Its members are told in the App, by push notification and by email, and its followers by an item in their inbox.

• For 30 days it can be reopened. Until then memberships are kept, frozen with their roles, and follows are kept; a reopen gives everyone their place back.
• After those 30 days we delete the community from every service: its profile and settings, memberships and follows, everything created in it, prayer requests and pastoral care with their messages, the comments, reactions, RSVPs and reading history in it, channel messages, notifications and reminders, and its files. Direct messages, reading streaks and scripture bookmarks belong to no community and are not affected.
• Your own posts in the community, other than reposts, are the exception. They stay on your profile, visible only to you and marked with the community's name, and their images and video move into your account. The comments, reactions and reshares on them are deleted. You can delete them at any time, which deletes their files too, and they are deleted with your account.
• The administrators' copy. When a community's administrators closed it, or asked us to, they can download a copy of it until it is deleted: each member's name, handle, role and join date, and the posts (other than private ones), events, announcements, devotionals, podcasts and library pages created in it, with their images, audio and video. It holds no one's email address, phone number or birthday, and no prayer requests, pastoral care or messages. We keep it in private storage; only a signed-in administrator can get its download link, which works for five minutes; and we delete it when the community is deleted or reopens. We make no copy when we close a community for any other reason. Once downloaded, the copy is held by the administrators, whom our Terms require to keep it secure.
• What we keep. A record that the community existed: its name and web address, when and why it closed, which account closed it (cleared when that account is deleted), and when it was deleted. Old links use it to say the community is gone, and its web address is never given to another community. Photos an administrator uploaded for the community's leaders page stay with that administrator's account until it is deleted.
• Analytics. Pseudonymised analytics events already sent to Firebase and PostHog are not deleted with the community; they expire on those providers' own schedules.

Backups. Our database keeps a short recovery history and we take a weekly backup copy for disaster recovery. Weekly backups are deleted after 90 days, are never edited, and are never used to bring a deleted account or community back; deleted data leaves them when they expire.

Security of Your Data

We apply technical and organisational measures designed to protect your personal data:

• Encryption in transit using TLS for all communication between the App and our servers.
• Sign-in without passwords, using Google, Apple or GitHub and optional passkeys, with a fresh passkey confirmation required for sensitive actions such as deleting your account.
• Community isolation using database row-level security, so each community's data is strictly separated from every other community's.
• On-device protection. Sign-in tokens are stored in your device's secure keystore (Android Keystore or iOS Keychain); cached content is stored in the App's private storage.
• Private storage for pastoral photos and voice notes. They are never publicly reachable. Only the people who can read the conversation receive them, through links that expire after an hour.
• Least-privilege access, so staff and systems can only access the data they need, and separation between our services on the network.

No method of electronic transmission or storage is completely secure. If we become aware of a personal-data breach that affects you, we will notify the Data Protection Commission and you as soon as reasonably practicable, with the information you need to protect yourself, as Act 843 requires.

Your Rights as a Data Subject

Under Act 843, and under the GDPR where it applies to you, you have the following rights over your personal data:

• Access — ask whether we hold personal data about you, what it is, and receive a copy in an understandable form. You can also view much of it directly in your profile.
• Correction and deletion — have inaccurate, incomplete, or out-of-date data corrected, and have data deleted that we are no longer entitled to keep. You can update most profile details in the App at any time.
• Objection — require us to stop processing that causes you unwarranted damage or distress, and object to processing based on our legitimate interests.
• No direct marketing without your written consent, and the right to stop it at any time.
• Automated decisions — require that no decision that significantly affects you rests solely on automated processing. Zoe does not make such decisions.
• Withdraw consent — withdraw any consent you have given, at any time, without affecting prior processing.
• Portability — where the GDPR applies to you, receive a copy of your data in a structured, machine-readable format.
• Compensation — claim compensation for damage or distress caused by a breach of Act 843.

To exercise any of these rights, contact us at privacy@qcodelabs.com. We answer access requests within 40 days and objections within 21 days, as Act 843 requires, and within one month for members to whom the GDPR applies. We may need to verify your identity first. Exercising your rights is free unless a request is manifestly unfounded or excessive.

Children's Privacy

Zoe is intended for churchgoers and is not directed at children. Under Ghanaian law a child is anyone under 18, and a child's personal data may be processed only with the consent of a parent or guardian. You must be at least 18 years old to use the App, or have the consent and involvement of a parent or guardian, where the law of your country permits. We do not knowingly collect personal data from a child without that consent.

If you are a parent or guardian and believe a child has provided us with personal data without your consent, please contact us at privacy@qcodelabs.com and we will delete that data promptly.

International Transfer of Data

Zoe primarily serves users in Ghana, but our servers and database are in the European Union (Germany), and the providers listed above process some data in the United States and other countries. Your personal data is therefore transferred outside Ghana.

For every transfer we rely on the protection of EU law for data held in the EU, contractual data-protection commitments with each provider, and recognised transfer mechanisms such as standard contractual clauses where they apply. Act 843 requires us to ensure that providers outside Ghana comply with Ghanaian data-protection law, and our contracts with them say so. The provider table above names each destination. If you have questions about a specific transfer or its safeguards, contact us at privacy@qcodelabs.com.

Marketing and Communications

We send two kinds of messages:

• Service messages that are part of using the App, for example notifications about your community's events, devotionals, prayer requests, and announcements, and account or security notices. These are necessary to provide the service and you control them in your notification settings.
• Marketing messages about new features, updates, or offers. We send these only with your prior written consent, as Act 843 requires, or where otherwise permitted by law.

You can control notifications in your device settings and within the App, and you can opt out of marketing communications at any time using the unsubscribe link or by contacting us. Opting out of marketing does not stop essential service messages.

Complaints

If you have a concern about how we handle your personal data, please contact us first at privacy@qcodelabs.com so we can try to resolve it.

You also have the right to lodge a complaint with a supervisory authority. In Ghana, the relevant authority is the Data Protection Commission (https://dpc.gov.gh). If you are in the European Union, you may complain to the supervisory authority in your country of residence, place of work, or where the issue occurred.

Changes to This Notice

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through an in-app notification and update the "Last updated" date at the top of this document. Where required by law, we will seek your consent before applying changes that affect how we process your data.

Your continued use of the App after an update takes effect indicates your acknowledgment of the revised notice.

Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us:

Quabynah Codelabs LLC (operator of Zoe Community) Data controller — Republic of Ghana

• Privacy and data rights: privacy@qcodelabs.com
• General support: support@qcodelabs.com

Supervisory authority: Data Protection Commission (Ghana) — https://dpc.gov.gh