Privacy notice

Draft version 1 · Effective date: to be confirmed after legal review

This is a working draft. A registered South African attorney must review and approve the final text before it is relied on. Updates will be posted here; material changes will be communicated directly to visitors whose contact details we hold.

Wellspring is the community outreach platform of the Panorama SDA Church and the Westrand English SDA Church. We use it to welcome and stay in touch with people who attend our health days, Daniel & Revelation seminars, cooking classes and other outreach events.

This notice explains what personal information we collect, why we collect it, how we look after it, and the rights you have under the Protection of Personal Information Act, 4 of 2013 (“POPIA”).

1. Who is responsible for your information

2. The personal information we collect

When you register at one of our events (usually on a tablet at the welcome table) we ask for:

• Contact details — your name, email, phone and address.
• Age and sex.
• Lifestyle information (optional — you may skip any field) — height, weight, exercise, sleep, breakfast, smoking, alcohol.
• Your interests — the topics you'd like us to contact you about.
• Whether you're already a member of one of our congregations.

Some of this is “special personal information” under POPIA: information about your religious beliefs, and information about your health and lifestyle. We only process it with your explicit consent, or (for members) under the religious-organisation exception in POPIA §27(1)(e).

3. Why we collect it, and the lawful basis

• To welcome you to the event and know who is present — your consent (§11(1)(a))
• To contact you after the event about topics you chose — your consent for direct marketing (§69)
• To give you personalised health / lifestyle information — your consent for health information (§27(1)(a))
• To keep records of event attendance for pastoral and administrative purposes — legitimate interest (§11(1)(f)) and, where applicable, §27(1)(e)
• To comply with South African law — legal obligation (§11(1)(c))

You can refuse any purpose without losing the others.

4. How we store it

• Private PostgreSQL database operated by Amazon Web Services in the Cape Town (af-south-1) region.
• Encrypted at rest and in transit (TLS 1.2+).
• Access is restricted by role and is logged.
• We do not sell or rent your information.
• Your information is not transferred outside South Africa.

5. Who we share it with

• Our own staff and volunteers with a defined role at your site.
• Operators acting on our instructions: AWS (hosting, South Africa), Xneelo (email & DNS), Weldforge SSO (login), Twilio (SMS, when used).
• Law enforcement or regulators only when compelled by a valid legal process.

6. How long we keep it

You can ask us to delete your information earlier at any time — see section 8.

7. Direct marketing and follow-up communications

Every marketing message we send includes a one-click unsubscribe link. You can also email privacy@wellspring.org.za and we will honour the request within one working day.

8. Your rights

Under POPIA you have the right to:

1. Know what personal information we hold about you (§23).
2. Ask for a copy (§23).
3. Correct anything that is wrong or out of date (§24(1)(a)).
4. Ask us to delete your information (§24(1)(b)).
5. Object to processing on legitimate-interest grounds (§11(3)).
6. Withdraw your consent at any time (§11(2)(b)).
7. Complain to the Information Regulator of South Africa: inforegulator.org.za · POPIAComplaints@inforegulator.org.za.

To exercise any of these rights, email privacy@wellspring.org.za. We aim to respond within 30 days and may ask for proof of identity first.

9. Children

If you are under 18, we ask for your parent or legal guardian's consent before registering you. We do not process health or lifestyle information for children unless the guardian has specifically consented to it.

10. Cookies and analytics

The Wellspring website uses no tracking cookies, no advertising, and no third-party analytics. The fonts on the page are loaded from Google Fonts — Google receives the IP address of the computer loading the page, but no other identifying data. We will update this notice if that ever changes.

11. Security

• TLS 1.2+ on every public endpoint.
• Encrypted database storage.
• Private network (no direct internet access to the database).
• Role-based access control.
• Short-lived device access keys at event tables.
• Audit log of every access to your record.

If we ever discover a compromise of your personal information, we will notify you and the Information Regulator as soon as reasonably possible (POPIA §22).

12. Contact us