Privacy Policy
Effective date: 23 February 2026
Last updated: 24 March 2026
1. Introduction
Fellowr is a church management platform developed and operated by Famverse Ltd., a company registered in Nigeria. This Privacy Policy explains how we collect, use, store, share, and protect personal data in connection with the Fellowr platform and website.
We are committed to protecting your privacy and handling your data transparently and responsibly, in compliance with the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation 2019 (NDPR).
Famverse Ltd.
Registered with the Nigeria Data Protection Commission
NDPC Registration No.: NDPC/DCP/10932 (valid 23/02/2026 – 23/02/2028)
Email: support@famverse.org
This registration is maintained under Section 44 of the Nigeria Data Protection Act 2023, covering Famverse Ltd.'s role as both a data controller (for admin user data) and a data processor (for church member data processed on behalf of churches).
2. Who This Policy Applies To
This policy applies to:
- Church administrators and team members who register and use Fellowr to manage their church (“Users”)
- Donors who give to a church via Fellowr's online giving page (whether or not they are church members)
- Event attendees who register for or purchase tickets to church events hosted on Fellowr
- Visitors to the Fellowr website
Note on church member data
Fellowr operates in a dual data role:
- Data Controller — for admin user data (the people who sign up and manage the platform)
- Data Processor — for church member data (collected and owned by the church; Fellowr processes it on their behalf)
In accordance with Section 27(2) of the Nigeria Data Protection Act 2023, churches using Fellowr as data controllers are required to proactively inform their members about how their personal data is collected, stored, and processed through the platform. This includes providing members with access to this Privacy Policy or the church's own privacy notice. It is the responsibility of each church to ensure that their members are made aware of and understand the use of their data — members should not have to seek out this information themselves.
3. Consent
Your consent is the foundation upon which we process your personal data. Famverse Ltd. bears the burden of demonstrating that valid consent has been obtained for all data processing activities.
3a. How We Obtain Consent
- Account creation: By creating a Fellowr account, you expressly consent to the collection and processing of your personal data as described in this Privacy Policy, and agree to our Terms of Service. This consent is recorded at the time of registration.
- Third-party sign-in: When you sign in via Google or Apple, you consent to Fellowr receiving the profile information you authorise through the respective provider's consent screen.
- Continued use: Your continued use of the Fellowr platform after any updates to this policy constitutes ongoing consent to the processing described herein.
- Donors and event attendees: By completing a donation or event registration on Fellowr, you consent to the processing of the personal data you provide for the purposes described in this policy.
- Website visitors: By accessing and using the Fellowr website, you consent to the use of strictly necessary session cookies and the collection of data described in this policy.
3b. Consent for Church Member Data
Where a church enters member data into Fellowr, the church — as the data controller — is responsible for obtaining appropriate consent from those members before their data is processed. Fellowr processes this data solely on the church's behalf and in accordance with the church's instructions.
3c. Withdrawing Consent
You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal. To withdraw consent, you may:
- Delete your account through the platform settings
- Contact us at support@famverse.org to request data deletion or restriction of processing
Please note that withdrawing consent may limit your ability to use certain features of the platform.
4. Data We Collect and Why
4a. Data You Provide Directly (Admin Users)
| Data | Purpose | Legal Basis |
|---|---|---|
| Name, email address, password | Account creation and authentication | Contract performance |
| Church name, denomination, address, phone, timezone | Church profile setup | Contract performance |
| Payment information (processed by Paystack) | Subscription billing | Contract performance |
| Church bank account details (bank name, account number, account name) | Giving settlement — verified via Paystack and used to create a subaccount for donation payouts | Contract performance |
4b. Data Churches Enter About Their Members (Processed on Behalf of the Church)
Fellowr processes the following member data as a data processor on behalf of the church (the data controller):
- Full name, email address, phone number
- Date of birth, wedding anniversary
- Physical address, gender, join date
- Notes and any custom fields configured by the church
- Visitor/newcomer form submissions
- Donation history (amounts, dates, funds, payment methods) and giving statements
Fellowr does not use this member data for any purpose other than providing the service to the church.
4c. Data Collected Automatically
| Data | Purpose | Legal Basis |
|---|---|---|
| IP address (at sign-up / pricing page load) | Detecting geographic region for appropriate pricing tier | Legitimate interest |
| Session tokens | Maintaining login sessions | Contract performance |
Cookies: Fellowr does not currently use tracking or advertising cookies. Only strictly necessary session cookies are used to maintain your login state.
4d. Donor Data (Online Giving)
When someone gives to a church through Fellowr's online giving page — whether or not they are a registered church member — the following data is collected:
| Data | Purpose | Legal Basis |
|---|---|---|
| Donor name, email address, phone number | Donation receipt and communication | Legitimate interest / consent |
| Donation amount, fund, date, payment method | Recording and reporting the gift | Contract performance |
| Recurring giving preferences (frequency, next charge date) | Managing subscription donations | Consent |
| Payment card or bank details (processed by Paystack) | Processing the transaction | Contract performance |
Important: Payment card and bank account details are tokenised and processed entirely by Paystack. Fellowr never stores raw card numbers, CVVs, or bank login credentials on its servers.
4e. Event Attendee Data
When someone registers for or purchases a ticket to a church event hosted on Fellowr, the following data is collected:
| Data | Purpose | Legal Basis |
|---|---|---|
| Attendee name, email address, phone number | Event registration, ticket delivery, and communication | Contract performance |
| Ticket type, quantity, and purchase amount | Ticket allocation and payment processing | Contract performance |
| Payment information (processed by Paystack) | Processing paid ticket purchases | Contract performance |
| Voucher/discount codes used | Applying ticket discounts | Contract performance |
| Check-in timestamps and QR code scans | Event attendance verification | Legitimate interest |
Important: Event registration data is processed by Fellowr on behalf of the hosting church (data controller). Payment details for paid tickets are tokenised and processed by Paystack — Fellowr never stores raw card numbers or bank credentials. Ticket holds for in-progress purchases expire automatically after 10 minutes.
4f. Data Collected via Third-Party Authentication
When you choose to sign in or create an account using a third-party authentication provider, we receive certain profile information from that provider:
| Provider | Data Received | Legal Basis |
|---|---|---|
| Name, email address, profile picture, Google account identifier | Consent | |
| Apple | Name (first authorisation only), email address, Apple user identifier | Consent |
Fellowr only receives the data you authorise through the provider's consent screen. We do not access your contacts, browsing history, or any data beyond what is listed above.
We may also collect other relevant information as it relates to the use of our service or platform. Additional information may be collected as required by law or regulatory authorities.
5. How We Use Your Data
We use your data to:
- Provide, operate, and maintain the Fellowr platform
- Send transactional emails (account verification, password reset, subscription alerts)
- Send automated church reminder emails (birthdays, anniversaries) — sent to admins only, never to church members directly, unless enabled by the church via the member email feature
- Process and record donations — both manual entries by church admins and online gifts via Paystack
- Send donation receipt emails to donors and giving statement emails to members
- Process donation refunds and send refund notification emails
- Track church expenses, budgets, and generate financial reports (income vs. expenses)
- Process event registrations, ticket purchases, and check-ins — including sending confirmation emails with QR codes, event reminders, and cancellation notices
- Generate event insights and analytics (registration trends, ticket sales, revenue breakdowns) for church administrators
- Detect your geographic region for pricing (IP-based, one-time at registration)
- Respond to support requests sent to support@famverse.org
- Comply with legal obligations under Nigerian law
- Protect and safeguard the rights, property, and safety of Famverse Ltd., its users, and the public
We do not:
- Sell your data to third parties
- Use your data for advertising
- Use church member data for any purpose beyond delivering the service
6. AI Features and Data Sent to Third Parties
Fellowr includes optional AI-powered features (Weekly Digest summaries, AI Assistant, AI Form Insights). When these features are used:
- We send aggregate statistics and member names and event dates only to OpenAI (our AI provider)
- We never send email addresses, phone numbers, physical addresses, or any other sensitive personal data to OpenAI
- AI features are clearly labelled within the platform
- Churches on the Free plan do not have access to AI features
7. Data Sharing and Sub-Processors
We share data only with the following trusted third-party service providers (“sub-processors”) who process data on our behalf under appropriate data protection agreements:
| Provider | Purpose | Location |
|---|---|---|
| Vercel Inc. | Platform hosting and infrastructure | USA |
| Supabase / Railway | Database hosting | USA |
| Resend / SendGrid | Transactional email delivery | USA |
| Paystack | Subscription billing, online donation processing (including recurring gifts, refunds, and church bank account verification) | Nigeria / USA |
| OpenAI | AI-generated content (aggregate data only — see Section 6) | USA |
| Cloudinary | Image storage and delivery | USA |
| MaxMind / geoip-lite | IP-based geographic region detection | USA |
| Single sign-on authentication (Sign in with Google) | USA | |
| Apple | Single sign-on authentication (Sign in with Apple) | USA |
All sub-processors are bound by contractual obligations to protect your data and process it only as instructed by Famverse Ltd.
We may also receive personal data from third-party authentication providers (Google and Apple) when you choose to sign in or register using their services. The data received is limited to what you authorise through the provider's consent screen (see Section 4f).
8. International Data Transfers
Famverse Ltd. is based in Nigeria. Some of our sub-processors (listed above) are based in the United States. By using Fellowr, you acknowledge that your data may be transferred to and processed in countries outside Nigeria.
We ensure such transfers are protected by appropriate safeguards, including standard contractual clauses and/or the data protection terms of each sub-processor, in compliance with the NDPA 2023.
9. Data Retention
| Data Type | Retention Period |
|---|---|
| Admin account data | Retained for the life of the account + 90 days after deletion |
| Church member data | Retained for the life of the church's account + 90 days after account deletion |
| Church subscription data | Retained for the life of the account; see subscription expiry policy below |
| Deleted/expired church data | Permanently purged 180 days after subscription expiry |
| Deletion audit log | Retained for 2 years after church data deletion (legal compliance) |
| IP address (region detection) | Not stored persistently beyond the session |
| Subscription payment records | Retained for 7 years in accordance with Nigerian financial record-keeping obligations |
| Donation records, refund records, and giving statements | Retained for 7 years (financial record-keeping obligations) |
| Expense records and budget data | Retained for 7 years (financial record-keeping obligations) |
| Event registrations, ticket purchases, and check-in records | Retained for the life of the church's account + 90 days after account deletion |
| Ticket hold records (in-progress purchases) | Automatically expired after 10 minutes; purged within 24 hours |
| Church bank account details | Retained for the life of the account + 90 days after account deletion |
Notwithstanding the above, we may retain personal data for longer periods where required to fulfil any legal, accounting, tax, or regulatory reporting obligations, or to establish, exercise, or defend legal claims.
10. Your Rights as a Data Subject
Under the Nigeria Data Protection Act 2023, you have the following rights regarding your personal data:
- Right of Access — You may request a copy of the personal data we hold about you
- Right to Rectification — You may request correction of inaccurate or incomplete data
- Right to Erasure — You may request deletion of your personal data (subject to legal obligations)
- Right to Data Portability — You may request your data in a structured, machine-readable format (CSV export available via Settings → Billing)
- Right to Restriction of Processing — You may request that we limit how we process your data in certain circumstances
- Right to Object — You may object to processing based on legitimate interests
- Right to Withdraw Consent — Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing
To exercise any of these rights, contact us at: support@famverse.org
We will respond within 30 days of receiving your request, in accordance with the NDPA 2023.
Note for church members: If your data was entered by your church administrator, please contact your church directly to exercise your rights. Your church is the data controller for your member profile. Churches are obligated to facilitate your rights under the NDPA 2023.
11. Right to Lodge a Complaint
If you believe your data rights have been violated, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC):
- Website: ndpc.gov.ng
- Email: info@ndpc.gov.ng
We encourage you to contact us first at support@famverse.org — we are committed to resolving concerns directly.
12. Data Security
Famverse Ltd. implements appropriate technical and organisational measures to protect your data, including:
- Passwords are hashed using bcrypt — never stored in plaintext
- All data is transmitted over HTTPS/TLS encryption
- Database access is restricted to authorised personnel and systems only
- Session tokens are rotated and expire after 7 days
- Church data is logically isolated by church ID — no church can access another church's data
- Access to production systems is restricted to core engineering staff
- Payment card and bank account details for online giving and event ticket purchases are tokenised and processed by Paystack — Fellowr never stores raw card numbers, CVVs, or bank login credentials
- Event check-in QR codes are unique per registration and verified server-side — they cannot be reused or forged
- All authorised personnel with access to personal data are bound by non-disclosure agreements (NDAs) and confidentiality obligations
- Staff with access to personal data undergo data protection and confidentiality training
- Access to personal data is granted on a need-to-know basis and regularly reviewed
Despite these measures, no system is 100% secure. In the event of a data breach, we will notify affected users and the NDPC within 72 hours of becoming aware of the breach, as required by the NDPA 2023.
13. Automated Decision-Making
Fellowr does not currently use automated decision-making or profiling that produces legal effects or similarly significant effects on data subjects.
The AI-powered features described in Section 6 (Weekly Digest, AI Assistant, AI Form Insights) generate summaries and insights for church administrators but do not make automated decisions about individuals. These features are advisory in nature — all decisions regarding church members, donations, events, and other matters remain with the church administrators.
If automated decision-making is introduced in the future, we will update this policy and notify affected users. You will have the right to:
- Be informed about the existence of such processing
- Receive meaningful information about the logic involved
- Request human intervention or review of automated decisions
- Express your point of view and contest the decision
14. Children's Data
In accordance with Section 31 of the Nigeria Data Protection Act 2023, Fellowr takes the protection of children's data seriously.
14a. Account Registration
Fellowr accounts may only be created by individuals who are 18 years of age or older. The account registration process requires acceptance of our Terms of Service and this Privacy Policy, which serves as an age verification mechanism. We do not knowingly allow minors to create Fellowr accounts.
14b. Church Member Data Involving Minors
Church member directories may include records of minors (e.g. children of church members). Where a church enters data about a child or a person lacking legal capacity to consent into Fellowr:
- The church, as data controller, must obtain verifiable consent from the child's parent or legal guardian before entering the child's data
- The same requirement applies to persons who lack the legal capacity to consent — consent must be obtained from their legal guardian or representative
- Fellowr processes this data solely on the church's instructions and relies on the church having obtained appropriate consent
14c. Age Verification
Fellowr deploys the following mechanisms to verify the age of data subjects and protect minors:
- Account creation requires acceptance of Terms of Service, which stipulate a minimum age of 18
- Event ticket purchases and online donations require providing an email address and are intended for adults or those acting under parental supervision
- Churches are instructed to verify parental consent before entering minor data
If you believe a child's data has been submitted without appropriate parental or guardian consent, please contact us at support@famverse.org and we will promptly investigate and, where appropriate, delete the data.
15. Whistleblowing
Famverse Ltd. encourages the reporting of any suspected data protection violations, unlawful data processing, security breaches, or any other conduct that may breach this Privacy Policy or applicable data protection laws.
If you become aware of any such conduct, you may report it to:
Email: support@famverse.org
We commit to the following:
- All reports will be treated in strict confidence and investigated promptly
- Whistleblowers will be protected from retaliation, discrimination, or any adverse action as a result of making a good-faith report
- Where a report reveals a data protection breach, we will take immediate corrective action and notify the NDPC and affected data subjects where required by law
- Anonymous reports are accepted and will be investigated to the extent possible
16. Changes to This Policy
We may update this Privacy Policy from time to time. When we do:
- The “Last Updated” date at the top of this page will be revised
- For material changes, we will notify Super Admins by email at least 14 days before the change takes effect
- Continued use of Fellowr after the effective date constitutes acceptance of the revised policy
17. Contact Us
For any privacy-related questions, requests, or concerns:
Famverse Ltd.
Email: support@famverse.org