Data Controller: Grace of God Mission Asaba
Physical Location: 33 Arthur Richard Street, Akwuebulu (Cable Point), Asaba, Delta State, Nigeria
1. Our Commitment to Your Privacy
Grace of God Mission Asaba ("the Church", "we", "us", or "our") is committed to honoring and protecting the privacy of members, visitors, donors, and inquirers who interact with our ministry through this website and digital platforms. This Privacy Notice describes our practices under the Nigeria Data Protection Act (NDPA) 2023 and the General Application and Implementation Directive (GAID) 2025 issued by the Nigeria Data Protection Commission (NDPC).
2. Personal Data We Collect & Processing Activities
We apply strict data minimisation principles (NDPA s.24(1)(c)). We only collect information that is strictly necessary for pastoral care, ministry communication, transaction fulfillment, and community connection:
Contact Inquiries
Data: Full Name, Email Address, Phone Number, and Message text.
Purpose: To reply to inquiries, provide information on service schedules, and provide pastoral assistance.
Lawful Basis: Consent (NDPA s.25(1)(a)) and Legitimate Ministry Interest (s.25(1)(f)).
Prayer Petitions & Wall
Data: Prayer petition text; Name, Email, and Phone number are strictly optional.
Purpose: Pastoral intercession. Requests shared to the Community Prayer Wall are completely anonymised.
Lawful Basis: Explicit Consent (NDPA s.25 & s.30).
Praise Reports & Testimonies
Data: Title, Testimony story, Author Name, optional Phone/Email.
Purpose: Community encouragement and thanksgiving. Donors can select "Keep Anonymous".
Lawful Basis: Explicit Consent (NDPA s.25).
Giving & Project Stewardship
Data: Donor Name, Donor Email, Donor Phone (optional), Amount, Transaction Reference.
Payment Processing: Card numbers, bank logins, and BVN/PIN credentials are processed exclusively by Paystack Payments Limited (CBN-licensed PCI-DSS Level 1 Processor). The Church never sees or stores card numbers or bank credentials.
Lawful Basis: Contractual & Ministry Stewardship Fulfillment (NDPA s.25(1)(b)).
3. Children's Privacy Protection (NDPA s.31)
Under Section 31 of the Nigeria Data Protection Act 2023, a child is defined as any individual under the age of 18.
- Our website does not intentionally solicit, collect, or store personal data from individuals under 18 years of age without verified parental or legal guardian consent.
- Public forms (testimony submissions, online contact, and prayer petitions) require confirmation that the submitter is 18 years or older, or submitting with the guidance and consent of a parent or guardian.
- If we discover that personal data of a minor has been collected without verified parental authorization, we will immediately take steps to permanently delete the information from our servers.
4. Cookies, Tracking & Analytics
We respect your digital sovereignty. In compliance with the NDPA and GAID 2025 guidelines:
- Strictly Necessary Cookies: We only set essential HTTP session cookies for authorized administrative portal logins (using secure, HTTP-only, SameSite attributes).
- Zero Behavioral Tracking: We do not run invasive session replay tools (such as Hotjar or Microsoft Clarity) that record your screen, mouse movements, or keystrokes.
- No Third-Party Ad Pixels: We do not deploy Meta/Facebook advertising pixels or Google Tag Manager marketing trackers on this website.
- Self-Contained Fonts & Assets: Typography and styling are bundled to prevent unwarranted telemetry leaks to international third parties.
5. Third-Party Service Processors & Cross-Border Transfers
When third-party technology infrastructure is required to deliver church broadcasts and secure services, transfers are executed under strict contractual safeguards (Data Processing Agreements) pursuant to NDPA Sections 41–43:
• Paystack Payments Limited (Nigeria): Secure payment gateway operations for freewill offerings and projects.
• Vercel Inc. & Render Services: Global edge content delivery network and encrypted application runtime.
• Cloudinary: Media CDN for event flyers and church image galleries.
• YouTube / Google Video: Embedded video broadcast streams using Privacy-Enhanced Mode (youtube-nocookie.com).
6. Data Retention Schedule
We do not retain personal information indefinitely:
| Data Category | Retention Period | Post-Retention Action |
|---|---|---|
| Contact Inquiries | 6 months after resolution | Permanent deletion |
| Prayer Requests | 90 days after prayer period | Permanent deletion or de-identification |
| Financial & Giving Records | 6 years (Nigerian tax & financial compliance) | Secure archival in accordance with financial regulations |
| Security Audit Logs | 12 months | Automated log purge |
7. Your Rights Under Nigerian Law
Under Part VI of the NDPA 2023, you possess the following statutory rights regarding your personal information:
- Right to be Informed: Transparent notice regarding what data is collected and why.
- Right of Access: Request a copy of the personal information we hold concerning you.
- Right to Rectification: Request correction of inaccurate, misleading, or incomplete data.
- Right to Erasure ("Right to be Forgotten"): Request permanent deletion of your data when retention is no longer justified.
- Right to Restrict or Object: Object to processing on legitimate grounds or withdraw consent at any time without detriment.
8. Contact Our Data Protection Team & Regulatory Escalation
To exercise any of your data protection rights, make an inquiry, or report a suspected privacy concern, please contact our administrative office:
Church Administration & Data Protection Officer: Grace of God Mission Asaba
Email: info@ggmasaba.org / privacy@ggmasaba.org
Phone: +234 907 560 2319
Postal Address: No. 33 Arthur Richard Street, Akwuebulu (Cable Point), Asaba, Delta State, Nigeria
If you believe your rights under the Nigeria Data Protection Act have not been satisfactorily addressed, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.