Last modified on August 9,
2021
As noted in the policy
below, the English language version of the Privacy Policy and Terms of Use will
govern your relationship with CityWell Church. While
the English version will govern, you can also use an automatic translation tool
like Google Translate to
view the documents in your language.
Important:
Please Read This First
From the beginning of our
process to launch a new live-giving church in CityWell
Church has been dedicated to using technology to reach people for Christ, help
them follow Him, and equip church leadership to be effective and efficient.
Our place at the forefront
of digital ministry has always been driven by our passion to see technology
leveraged to help people find hope, peace, and joy in the incomparable love of
Christ. The CityWell Church app and our websites are
tools we offer to serve our attenders and visitors by connecting them to one
another and equipping them on their journey to becoming fully devoted followers
of Christ.
Every digital product and
service we provide is created with great care and intentionality. Each one
designed to help more people pursue a deeper relationship with God in a safe
and secure manner. We craft these tools as an act of ministry to serve you, and
you have choices in your experience. You choose what you access. You choose
what you share, and with whom. Your data is yours. CityWell
Church does not sell your information, nor will we share it with others without
your consent.
And every aspect of CityWell Church’s digital tools
are completely free, with no strings attached and no advertising. Our intent is
to remove every possible barrier so you’re able to focus on getting to know God
more intimately.
Please read this Privacy
Policy carefully because it discusses how we will collect, use, share and
process your personal information. By using CityWell
Church sites and services, you agree to this Privacy Policy and its terms.
We welcome any questions or
comments you may have about this Privacy Policy and our privacy practices. If
you have any questions or comments, you may contact us by mail at CityWell Church, attn.: CityWell
Church Support, PO Box 494, Coatesville PA 19320, or by email at help@CityWell.Church.
Definitions
To make this document
easier to read, we’re going to use some shorthand throughout. For example, when
we say “our sites” or “CityWell Church sites”
(whether we reference them individually or collectively) we’re talking about
the websites and applications offered by CityWell
Church, including (but not limited to) CityWell.Church,
gear.CityWell.Church, and Live.CityWell.Church, together with their subdomains and
content. These are owned and operated by CityWell
Church LLC, together with its parents, affiliates, and subsidiaries, which
we’ll refer to as “CityWell Church,” “us,” or “we”
throughout this policy. When we refer to persons interacting with CityWell Church in this policy, we’ll use the term “you.”
Brief
Overview
This Privacy Policy
outlines the types of data we collect from your interactions with CityWell Church and how we process that information. You
have choices about how your personal information is accessed, collected, shared
and stored by CityWell Church, which is discussed
below. We take the privacy of the information you provide and that we collect
seriously and implement security safeguards designed to protect your data,
which are also discussed below.
In general, the information
we collect depends on the services you request. In addition to personal
information that you provide (such as your name, email address, financial
information and other personally-identifiable information), we collect Internet
and other network activity information with cookies and other automated
technologies as discussed below. We use the data we collect and that you
provide as well as inferences we make from that information as follows:
·
To provide, support and personalize our sites and services;
·
To create, maintain, customize and secure a CityWell
Church profile or account, if any;
·
To process your requests and respond to your
inquires;
·
To provide information on our products or services;
·
To maintain the safety, security and integrity of CityWell Church sites and the infrastructure that
facilitates use of our sites;
·
For internal development and analysis of our products and
services;
·
To fulfill any other purpose for which you provide it;
·
To carry out our obligations and enforce our rights;
·
As described in this Privacy Policy;
·
In a manner we may describe when you provide the information; and
·
For another purpose with your consent.
Your Profile
and Information You Provide to Us
We collect personal data
from you when you provide it to us both offline and online. You do not need to
provide personal information to us to use the CityWell
Church sites; however, we allow you to create a profile which allows us to
tailor our sites and services to be a more personalized experience. To create a
profile, we require your first and last name, your email address and a password
to authenticate you when you try to access your profile. Beyond the personal information
needed to create a profile, you have choices about what additional information
you provide to us, which may include your zip code, the names of your family
members, gender, social security number, and your martial
status, all of which will be stored in association with your profile. Certain
information may be required based on your specific request, such as your social
security number for employment inquiries and volunteer requests; we will notify
you of this at the time of such a request. We also collect information about
you when you send, receive, or engage in communications with us, including when
you submit personal information or requests by emailing help@CityWell.Church. We
retain those communications to process your inquiries, respond to your
requests, and improve our sites and our services.
If you have a profile with
us, the information you provide us is generally associated with your profile
and is stored internally in our third-party relationship management system or
“CRM system.” We will use this information to authenticate you and allow you to
access your specific profile. We create user profiles for off-line purposes as
well, which include volunteerism and inquiries concerning employment. We may
combine the information you provide us for your profile and interactions with
our sites with information you provide us through other CityWell
Church sites, services and products and inferences we make from the same for
our internal development to improve the overall quality of our sites, services
and products. We may also make recommendations to you for other CityWell Church services based on the information you
provide and we infer.
Your
Posts
Our CityWell
Church sites have a wide array of functionality, including streaming video,
creating prayer requests, and identifying and communicating with your CityWell Church groups and teams. Some CityWell
Church sites may allow you to publish, distribute and display certain content,
which we will refer to as “posted” and the content as “posts.” Posts may be
made on public areas of websites and social media accounts you access through
our sites or may otherwise be transmitted to third parties. Please keep in mind
that if you disclose personal information in a public manner whether through
collaborative postings, social media, message boards, or other public online
forums, this information may be collected and used by others. We cannot control
the actions of other users or third parties with whom you choose to share your
posts. Therefore, we cannot and do not guarantee that your posts will not be
viewed by unauthorized persons, nor do we accept any liability associated with
your posts.
Giving
If you choose to provide a
voluntary donation through those CityWell Church
sites where you are able to make a donation, then and
only then will you be prompted and required to provide credit card, bank
account, and other payment information necessary to process the transaction. We
will collect the designation for your donation, if you provide one, the CityWell Church campus designated for your donation (if
any), and personal information such as your name, address, phone number and/or
email address to ensure that your donation is used for the purpose you request
and to provide you with a “Annual Giving Statement” that itemizes your
donation(s) for tax purposes or your personal use. This information (with the
exception of your financial information) is stored in connection with your
profile if you have created one for another purpose; or, if you have no
preexisting profile with us, we will use this information to create a profile
for you in our internal CRM system. We will not store or otherwise process
financial information provided to us online for the purposes of making a donation. As of the date of this Policy, we use Subspash and Simple Donation to process your online
donation payments. For information on how these third parties process your
information, please refer to their privacy policies which may be found
here: https://www.subsplash.com/; https://simpledonation.com/. For
donations you provide to us in person or by mail, we store your financial
information in our databases in an encrypted form for as long as necessary to
process your donation and as required by applicable law and GAAP accounting
principles.
CityWell Church Gear
With respect to those CityWell Church sites where you are able to purchase CityWell Church-branded clothing and other items, which
include Gear.CityWell.Church,
your personal and financial information is provided and shared with our
third-party contractors that we use to process your order. These third parties
are identified at the time of your purchase. For information on how those
companies use, store, maintain and disclose your information, please refer to
their respective privacy policies or contact them directly.
Volunteers
and Employment Inquiries
You may apply to be a
volunteer for miscellaneous activities and events in person at a CityWell Church campus, over the phone and through one or
more of our sites. You may also apply for employment in person and through our
sites. The information we require for volunteer and employment applications are
your first and last name, telephone number, address, social security number,
date of birth and, in the case of a job inquiry, your employment history. We
will use this information to create a profile or associate it with your profile
if one exists. We will use your social security number and date of birth solely
for a background check in connection with your application to be a volunteer
and/or employee, and will not share either with any other party except for
third party service providers that enable us to perform background checks which
are obligated not to share your information or use it for any other purpose. If
you become an employee of CityWell Church, your
personal information is also used in connection with your employment.
As a ministry volunteer,
you may have access to third-party software which allows you to schedule and
check-in to your volunteer activity, as well as manage other
volunteer activity. This location-based information is stored in association
with your profile to enable you to see your past volunteerism, and we also use
it for our own internal analysis of volunteerism.
Automatic
Data Collection Technologies
By agreeing to our Privacy
Policy, you agree to the use of cookies and similar technologies (for example,
web beacons, pixels, tags, and device identifiers which we collectively refer
to as “cookies”) as described in this policy. If you use CityWell
Church sites without changing your browser or device settings to disable
cookies, we assume that you consent to receive all cookies provided through CityWell Church sites.
We use cookies to recognize
you and/or your device(s) on, off, and across the different applications of our
sites and devices. Cookies help to facilitate the best possible user experience
of our sites as they allow us to recognize you and maintain your user
preferences from session to session, help us keep your account safe, and
generally improve the functionality of the products and services offered
through CityWell Church sites. They also help us
ensure that profile information is used in association with the correct
profile. Importantly, we do not use cookies to facilitate
interest-based ads from third parties for third party goods or services.
We log usage data when you
use CityWell Church sites, including when you view or
click on content, browser type, browser language, perform a search or request,
the date and time of your request, install an update, seek new functionality,
or use one or more tools offered through our sites. We use cookies to identify
you and log your use. When you access or leave our sites, we receive the URL of
both the site you came from and the one you go to next. We also get information
about your IP address, proxy server, operating system, web browser and add-ons,
device identifier and features, and/or ISP or your mobile carrier. If you use
our sites from a mobile device, that device will send us data about your
location based on your phone settings and access you have granted the CityWell Church sites as discussed below.
We store this information
and information pertaining to your use of our sites in connection with your
profile. We do not share any of your personally identifiable information along
with your device identification or location without your explicit permission.
We advertise on third party sites such as Facebook and Google and use third
party software development kits (“SDKS”) to attribute a download of a CityWell Church application on to the advertisement placed
on the third party site. We may provide these third
parties with aggregate information concerning ads placed on their sites and
downloads that result from those ads.
We use this information to
provide a tailored CityWell Church site experience
for you and to communicate with you more effectively. The information is also
collected to determine the aggregate number of unique devices using our sites,
track total usage, and analyze usage data to provide you with a better
experience and to improve the quality of our services. If you do not want us to
collect this information you should cease use of our sites.
Although most internet
browsers accept cookies by default, you can control these types of technology
through your browser settings and similar tools and agree to refuse all cookies
altogether. If you refuse to accept cookies by activating the appropriate
setting on your browser or smartphone, you may prohibit us from delivering the
full capability of our sites.
Please note that we cannot
regulate other sites, content, or applications of third-parties, which may
place their own cookies or other files on your computer, collect data or
solicit personal information from you. They may use this information to provide
you with interest-based (behavioral) targeted content. We do not control these
third parties’ tracking technologies or how they may be used. If you have any
questions about targeted content, you should contact the responsible provider
directly.
WiFi and GPS
Some of our sites use GPS
information to identify when you are near one of our physical locations. You
will be given the opportunity to provide consent for us to use this information
when you first download or begin to use our sites. If you provide that consent,
we use that information to enable push notifications related to interactions
with our CityWell Church sites and physical
locations. You also have the ability to manually initiate a GPS location search
to identify whether you are at one of our physical locations. When using
certain CityWell Church sites, you can provide us
with your GPS location through your browser, zip code, or city, which will be
processed by a third-party search engine. We do not store this information
outside of your device. Once your particular session of use of the feature
ends, we will cease to have access to your GPS location unless you use the
feature again. After your first use of this functionality and consent for us to
use your GPS location, we will assume we have that consent unless you revoke it
through the settings of your mobile device.
We also collect and use the
wireless (or “WiFi”) permissions of your mobile
device to determine if you are connected to a WiFi or
cellular network. This information is used to provide an optimized user
experience by providing higher resolution content to a user who is on a
high-speed WiFi connection rather than a cellular
network. WiFi permissions are also used for casting
content with Chromecast and similar devices. This information is not shared by CityWell Church.
CityWell Church Content
We collect the manner you
use the content available through our sites and the language in which you
choose to utilize that content. We also may collect and store your posts. We
process this information to allow you to access and use content and posts
through each session of your use of our sites. It is your choice whether to
create, access or store information and content in our sites. If you do, we
will we store it in association with your profile for so long as you opt not to
delete it. We may use information about your use of our sites and the
inferences we make from that use to provide recommendations to you of other CityWell Church sites, products, services and content.
Communications
from Us to You
From time to time, we may
contact you as set forth below. You may opt out of receiving certain
communications from us by modifying the settings of your application (where
applicable) or by contacting us at the information below.
Recommendations and General
Information
We use the data we have
about you and inferences we make from that data to recommend certain content
and functionality as well as additional products and services offered by CityWell Church. We may contact you through push
notification, email, mail or in-app messages to discuss these recommendations,
how to use our sites, and other news messages.
Giving
If you have given a
donation to us, we use the data we collect about that donation to inform you of
the impact of your giving. We will also contact you periodically in the future
to inquire if you would like to give to another program or campus or purpose.
We may contact you through push notification, email, mail or in-app messages to
discuss these opportunities.
Security, Legal and
Technical Issues
We use your personal
information to respond to and resolve technical issues and complaints
concerning our sites and as necessary for security purposes or to investigate
possible fraud, violations of law or agreement or attempts to harm self or
others. We may use your information to contact you about these accounts,
security, legal and other service-related issues. Please be aware that you
cannot opt-out of receiving such messages from us.
Notice
We may use your personal
information to provide notice regarding a security incident or data breach, by:
(i) sending a message to the email address you
provide (as applicable); (ii) posting to a publicly facing page of CityWell Church sites or through an in-app messages; (iii)
through major statewide media; and/or (iv) telephonic means, including calls
and/or text messages, even if sent via automated means including automated
dialers. Standard text and data messaging rates may apply from your carrier.
Notices sent by email will be effective when we send the email, notices we
provide by posting will be effective upon posting and by in-app messaging when
the message is made, and notices we provide through telephonic means will be
effective when transmitted or dialed. You consent to receiving electronic
communications from CityWell Church relating to your
use and access of the services provided by CityWell
Church. It is your responsibility to keep your email address and any other
contact information you provide to us current so that we may provide these
communications to you.
Analytics
and Performance
We internally analyze the
personal data available to us and use of content found on our sites. In some
cases, we work with trusted third parties to perform this research, under
controls that are designed to protect your privacy as discussed below. We may
disclose statistics concerning the use of our site in an aggregated manner with
de-identified and anonymized information that does not disclose any particular
user or that user’s personally-identifying information. For example, we may use
your data to generate statistics about overall usage of one of our sites
worldwide or in specific geographic regions.
We also use de-identified
and aggregate user data to market our sites, including communications that
promote membership and network growth. Where we share stats of our growth
publicly, we make sure to analyze and publish the data in an aggregated form,
protecting your privacy and keeping your identity and personal information
confidential. We use data, including data collected through use of our sites,
public feedback and information inferred from this data to conduct internal
research and development in order to provide a better overall experience on CityWell Church sites, measure the performance of our sites
and increase use of our sites and their features. This is done by making
changes to CityWell Church sites that are generally
available, as well as sending messages suggesting functionality and content.
Disclosure
of Your Information
We do not share your
personal data with any third-party advertisers or ad networks for third party
advertising purposes. We may disclose your personal information to third
parties as discussed below.
Disclosure on Your Behalf
We may disclose personal
information that we collect or you provide as described in this Privacy Policy
to fulfill our obligations, the purpose for which you provide it, a purpose you
request or a purpose for which we have your consent.
Disclosure by You
If and when you share
information through our sites, that information is viewable by you and by
anyone else you choose to share it with. If you give access to your account to
other applications and services, based on your approval, those services would
then have access to your shared information. The use, collection and protection
of your data by such third party services are subject
to those third parties’ policies.
Internal Disclosure
We will share your personal
data internally within CityWell Church to help
combine the personal information covered across the different aspects of CityWell Church sites and our other products and services
to help provide services to you in a manner that is personalized and useful to
you and others. For example, we can personalize potential services to recommend
to you using cookies or similar technologies that track what functionality you
have already opted to receive.
Service Providers
We may disclose personal
information that we collect or you provide as described in this Privacy Policy
to contractors, service providers and other third parties we use solely to
support our sites (such as cloud hosting, maintenance, analysis, audit, payments,
fraud detection, communication, and development). These third parties will have
access to your information as reasonably necessary to perform tasks on our
behalf and are obligated not to disclose it to others or use it for other
purposes.
Content Providers
We utilize certain third
parties to provide content on our sites. We do not share personal information
of users with these third parties. We may, however, provide these third parties
with analytics concerning the use of their content using de-identified and
anonymized data.
Legal Process and Subpoena
It is possible that we will
need to disclose information about you when required by law, subpoena, or other
legal process. We may dispute third party demands when we believe, in our
discretion, that the requests are overbroad, vague, or lack proper authority,
but we do not promise to challenge every demand. We may also need to disclose
your information if we have a good faith belief that disclosure is reasonably
necessary to (i) investigate, prevent, or take action
regarding suspected or actual illegal activities or to assist government
enforcement agencies; (ii) enforce our agreements with you; (iii) investigate
and defend ourselves against any third-party claims or allegations; (iv)
protect the security or integrity of our sites; or (v) exercise or protect the
rights and safety of CityWell Church, our users,
personnel, you, or others. We also reserve the right to confidentially disclose
personal information we have about you in connection with a potential or actual
merger or acquisition such as the sale of all or substantially all of our
assets.
Your
Requests
Certain laws provide for
requests concerning personal information. To make such a request with respect
to your personal information, you may send us an e-mail to help@CityWell.Church. You may
also contact us at: Life Church, Inc., attn.: CityWell
Church Support, PO Box 494, Coatesville PA 19320. When contacting us, please
indicate your name, address, email address, and what personally identifiable
information you request to be accessed, corrected, or removed. We may decline
to process requests if we cannot verify the requestor's identity, if we believe
the request will jeopardize the privacy of others, if we believe the request
would violate any law or legal requirement or cause the information to be
incorrect, or for a similar legitimate purpose. We will not discriminate
against you for exercising any of your rights under applicable law. We do not
charge a fee to process or respond to a verifiable request concerning your
personal information unless it is excessive, unduly burdensome, repetitive, or
manifestly unfounded. If we determine that the request warrants a fee, we will
tell you why we made that decision and provide you with a cost estimate before
completing your request.
If you ask that we modify
or delete some or all of your personal information, we will retain your
personal data if reasonably necessary to comply with our legal obligations
(including law enforcement requests and obligations concerning financial
records and tax returns), meet regulatory requirements, resolve disputes,
maintain security, prevent fraud and abuse, enforce our agreements or fulfill
any others requests from you (for example, to opt-out of further messages or
for a copy of your data). Additionally, third-parties addressed in this policy
may have their own policies with respect to data retention and deletion. We
have no control of information you have shared with others through one of our
sites after you close your account or asked to delete information or attempted
to delete your account yourself. Your information and content you have shared
may continue to be displayed in the services of others (for example, search
engine results) until they refresh their cache.
Security
and Protection
We implement security
safeguards designed to protect data. These include using encryption for your
data while it is being transmitted between your device or browser and our
servers and while it is at rest. Data provided to us through our sites is also
stored in an ISO 27017-certified infrastructure management system, meaning it
has been audited and found in compliance with the requirements of the
management system standards ISO 27017, an internationally recognized code of
practice for information security controls for cloud services. However, given
the nature of communications and information technology, and that the use of
the internet has inherent risks, although we monitor for possible vulnerabilities
and attack, we cannot warrant or guarantee that information provided to us
through our sites or stored in our systems or otherwise will be absolutely free
from unauthorized intrusion by others, nor can we warrant or guarantee that
such data may not be accessed, disclosed, altered, or destroyed by breach of
any of our physical, technical, or managerial safeguards.
Church
Online
CityWell Church
allows users to access its services through an interactive platform called
Church Online. Where you use Church Online, we collect your first name, last
name, nick name, email and phone number to create your Church Online account.
We also collect your age, gender, and time zone, date of birth, and city and
state where you provide it. Where you create a Church Online profile, the
automatic data collection technologies referenced above are used to log your IP
address and phone carrier to help associate your uses of your Church Online
account from session to session and to better facilitate Church Online chat communications.
In addition to the content and posts noted above, Church Online allows users to
chat with other users and create other shareable posts, such as emojis and
reactions to certain content, where you “raise your hand” in Church Online, and
what content you choose to stream and access when using this site. We store
this information in association with your Church Online account for so long as
you do not delete the content.
Children
A parent or guardian may
consent to the use of our sites or services by a minor. However, we ask that
you discuss the risks of sharing personal information on the Internet with your
children and require that they refrain from communicating with any third
parties or share any personal information online or otherwise without the
supervision of a parent or guardian. Should you allow your minor child to use
our sites or services, you shall be solely responsible for providing
supervision of the minor’s use of the same and assume full responsibility for
the processing of any information provided to us by that minor. Where you
associate your minor child’s information with your account, we will assume you
consent to our processing of that information in accordance with this policy
and other privacy notices and terms we may provide to you from time to time.
Where we are provided a minor’s information by an adult or a minor while
accompanied by an adult, we will assume that the parent or guardian consents to
our use and processing of that information in accordance with this policy and other
privacy notices and terms we may provide to you from time to time. If you
believe we might have any information from or about a minor child without
parental or guardian consent, please contact us at the information below.
Processing
of Data
We will collect and process
personal data about you where we have lawful bases. Lawful bases include
consent, contract and other legitimate interests. Such legitimate interest
include protection to you, us and third parties, to comply with applicable law,
to enable and administer our internal processes, to manage corporate
transactions, to generally understand and improve our relationships, and to
enable us and other users of our sites to connect with you to exchange
information, provided that the foregoing adequately protects your rights and
freedoms. Where we rely on your consent to process personal data, you have the
right to withdraw or decline your consent at any time and where we rely on
legitimate interests, you have the right to object. If you have any questions
about the lawful bases upon which we collect and use your personal data, please
contact us at the information below.
Third-party
Information Collection
This Privacy Policy applies
only to sites and apps that are owned and operated by CityWell
Church. Please keep in mind that our sites may contain links to other websites
or apps. You are responsible for reviewing the privacy statements and policies
of those other websites you choose to link to or from one of our sites, so that
you can understand how those websites collect, use and store your information.
We are not responsible for the privacy statements, policies or content of other
websites or apps, including websites you link to or from a CityWell
Church site. Websites containing co-branding (referencing our name and a third
party’s name) contain content delivered by the third party and not us. If you
choose to link to other websites, applications, and services or profiles you
have with third party applications, you will provide the personal data stored on
those applications to CityWell Church. For example,
you may link your Facebook account to your profile, providing personal
information you have opted to share through Facebook to CityWell
Church. When you do so, we are provided with your Facebook (or other applicable
social media) username. You may revoke the link with such accounts and third party applications by modifying your settings with
those applications. As noted above, third party sites that link to or are
associated with our sites may collect information through the use of automated
technologies such as cookies. We have no control over such collection and use,
which are subject to the privacy policies of those third parties.
Users From Outside the United States
We are based out of Pennsylvania
within the United States and your use and this Privacy Policy are governed by
the laws of the United States and the State of Pennsylvania. If you are using
one of our sites from outside this state or country, please be aware that your
information may be transferred to, stored, and processed in the United States
where our servers are located and our central database is operated. We process
data both inside and outside of the United States and rely upon contractual
commitments between us and companies transferring personal data that require
the protection and security of such data for your privacy. The data protection
and other laws of the State of Pennsylvania might not be as comprehensive and
may differ from those in your state or country. By using a CityWell
Church site, you consent to your information being transferred to our
facilities and to the facilities of those third-parties with whom we share it
as described in this Privacy Policy.
Changes
to Our Privacy Policy
We may update our Privacy
Policy from time to time to reflect changes in our practices. As we improve our
sites, this may also mean the collection of new data or new ways to use data.
If we collect materially different personal data or materially change how we
use your data, we may modify this Privacy Policy. We will post any changes to
our Privacy Policy on this page. The date the Privacy Policy was last modified
is identified at the top of the page. You are responsible for ensuring we have
an up-to-date active and deliverable email address for you concerning any
changes and for periodically visiting this Privacy Policy to check for any
changes.
Contact
Information
To ask questions or comment
about this Privacy Policy and our privacy practices, you may contact us at: CityWell Church, Inc., attn.: CityWell
Church Support, PO Box 494, Coatesville PA 19320, or at help@CityWell.Church.