Ministry Portal Privacy Policy

Version: 2026-05-21 Effective Date: May 21, 2026

This Privacy Policy describes how Shadow Mountain Community Church en Español ("SMCC en Español", "we") collects, uses, shares, and protects the personal information of those who use the Ministry Portal ("the Portal").

We recognize that the Portal processes deeply personal information — formative responses, faith decisions, recorded prayers, ministerial participation — and we take that responsibility with pastoral seriousness, not only legal seriousness.

Spanish governs in case of conflict. This English version is provided for accessibility. If any conflict arises between the English and Spanish versions, the Spanish version prevails.

1. Data Controller

Shadow Mountain Community Church en Español 2100 Greenfield Dr., El Cajon, CA 92019, United States Privacy contact: portal@shadowmountain.org Phone: (619) 590-1754

We operate the Portal as a ministry under the umbrella of Shadow Mountain Community Church, a 501(c)(3) church registered in California.

2. Summary

| Quick question | Short answer | |---|---| | Do you sell my data? | Never. We do not sell, rent, or trade personal data. | | Is there advertising in the Portal? | No. No ad trackers, no social media pixels. | | Who owns the Portal content? | Two categories: (a) tool-produced materials and ministerial information belong to SMCC; (b) your responses, messages, chats, photos, and identity remain yours. See Terms §6. | | Can SMCC use my likeness or name for promotion? | Yes. By accepting the Terms you grant SMCC a perpetual license over your ministerial content, name, and contact information to promote events and activities on public and social media. See Terms §6.2. | | How much does the Portal cost? | Completely free for all users. The Shadow Mountain en Español ministry covers the operating cost. | | Is my content used to train AI? | Not for general models. Yes, it is processed by AI when you use features marked with AI, but providers do not retain it for training. | | Can I delete my account? | Yes. Write to portal@shadowmountain.org. | | Where is my data stored? | On Google Cloud (Firebase) servers in the United States. |

3. Information We Collect

3.1 Information You Provide

Account data: name, email, password (encrypted by Firebase Auth — never visible to us in plain text), profile photo, gender (used for ministerial assignments per church practices), assigned ministry, role.
Formative content: course responses (Paideia, Arjé, Doulos, Logos), recorded prayers, documented pastoral decisions, verse memorization progress.
Communications: messages exchanged with other team members through the Portal, conversations with AI assistants (Ministry Helper, Tech Support, course tutors).
Administrative requests: form data (memorials, events, weddings), including contact names and phone numbers, descriptions, uploaded photos.
Bug reports and feedback: information submitted via the bug report form.

3.2 Information Generated by Your Use

Attendance and participation: Sunday check-ins, event attendance, attendance streaks.
Formation progress: course XP, achievements, levels, task submissions, peer reviews, time spent.
Gamification: tokens, avatar level, day count (Psalm 90:12).
Anonymous aggregate metrics: ministerial statistics (not individually identifiable).

3.3 Automatic Technical Information

Device information: browser type, operating system, language, time zone.
IP addresses and login records (stored in auth_logs for security audit, typically 12 months).
Cookies and local storage: Firebase Authentication uses secure cookies (__session, firebase:authUser) to maintain your session. The Portal stores local preferences (dark/light theme, language) in localStorage.
Usage metrics: AI usage logs (ai_usage), aggregated error reports.

3.4 Information We Do NOT Collect

Payment data: the Portal does not process donations or charge subscriptions. If this feature is added in the future, this policy will be updated.
Biometric data (fingerprints, facial recognition).
Precise geolocation data (no GPS).
HIPAA health data (we do not operate as a medical provider).
Third-party advertising trackers (Google Analytics, Meta Pixel, etc. — we use none).

4. Legal Bases and Purposes

We process your information on the following legal bases:

| Legal basis | When it applies | |---|---| | Consent | When accepting these terms at login, when uploading devotional content, when using AI features. | | Legitimate ministerial interest | To coordinate ministries, prevent abuse, maintain Portal security, generate anonymous statistics. | | Legal obligation | Retention of accounting records, response to valid subpoenas, mandatory reporting (e.g., child abuse under CANRA). | | Vital interest | To protect your life or that of a third party in emergencies. |

Purposes include:

Providing Portal features and authenticating you;
Coordinating your ministry and course participation;
Generating internal communications (messages, push notifications, reminders);
Processing administrative requests (memorials, events);
Promoting the events and activities of SMCC en Español ministries on public and social media, pursuant to the perpetual license granted in Terms §6.2;
Improving the Portal and preventing abuse;
Complying with legal obligations.

5. Sensitive Religious Data

We recognize that much of the Portal's information is sensitive religious data (beliefs, spiritual practices, pastoral conversations). Under the framework of the United States Constitution (First Amendment) and applicable state laws, churches enjoy special protections to process religious adherence data of their own members for exclusively ecclesial purposes.

However, we voluntarily impose the following guarantees:

We do not share religious data with third parties except the strictly necessary processors listed in Section 7.
We do not use Pastoral Decision data or private pastoral conversations for profiling, communication segmentation, or AI training.
We do not transfer sensitive religious data to other organizations (including the English-language parent church, Shadow Mountain Community Church) without your explicit consent.
Clergy-penitent privilege: "Pastoral Decision"-type conversations recorded with the Senior Pastor are protected under the clergy-penitent privilege doctrine recognized in California (Cal. Evid. Code §1030 et seq.).

We never sell personal data. We share information only in these cases:

6.1 With Other Portal Members

Your name, profile photo, ministry, and role are visible to other authenticated users (necessary to coordinate ministry).
Your pastoral decisions and private prayers are not visible to anyone else (not even to administrators).
Posts you make in public Portal channels (announcements, visible comments) are visible according to the design of each feature.

6.2 With Third-Party Processors

See Section 7 for the full list.

6.3 By Legal Obligation

We may disclose information if required by:

A valid court order or subpoena;
Applicable law (including the duty to report child abuse under California's Child Abuse and Neglect Reporting Act, Penal Code §11164 et seq.);
To protect SMCC's rights, property, or safety, ministry members, or the general public;
In the case of a merger, acquisition, or ecclesial restructuring (with prior notice to users).

6.4 With Your Consent

Any other disclosure is made only with your prior, explicit consent.

7. Third-Party Processors

The Portal uses the following third-party services that may process personal information on our behalf. All are subject to their respective privacy policies and data processing agreements:

| Provider | Purpose | Data processed | Location | |---|---|---|---| | Google Cloud / Firebase | Authentication, database, storage, serverless functions | All Portal data | United States (us-central) | | Vercel | Portal hosting and CDN | Web traffic, server logs | United States / global edge | | Anthropic (Claude) | AI processing for devotionals, assisted writing, course tutors | Content sent to AI features | United States | | Google (Gemini) | Image generation and complementary AI processing | Prompts and visual references | United States | | eSpace | Calendar sync and resource availability | Event data | United States | | Box | Secondary file storage (when enabled) | Uploaded files, metadata | United States | | Web Push Service | Browser push notifications | Push endpoint, browser subscription | Varies by user's browser |

AI providers (Anthropic, Google) are contractually obligated not to use processed content to train their general models.

If we add a material new processor, we will update this list and the effective date of this policy.

8. Retention Period

| Category | Retention | |---|---| | Active account | While you have ministerial ties to SMCC en Español. | | Archived account (no active ties) | 24 months after last activity, then anonymization or deletion. | | Courses: tasks, peer reviews | Permanent under your UID (it's your formative history). Anonymizable on request. | | Messages between users | 24 months, then cold archive. | | Authentication logs (auth_logs) | 12 months, then deletion. | | AI usage logs (ai_usage) | 6 months aggregated, then anonymization. | | Public forms (memorial, etc.) | Retained for the operational need of the event + 36 months for pastoral reference. | | Consent records (users/{uid}/consents) | Permanent while account exists + 7 years post-closure for legal evidence. |

Some data may be retained longer if required by law or necessary to defend against a legal claim.

9. Your Rights

Under the California Consumer Privacy Act (CCPA/CPRA) and similar state laws in Virginia, Colorado, Connecticut, and Texas, you have the following rights:

9.1 Right to Know

You may request to know:

The categories and specific elements of personal information we hold about you;
The sources of that information;
The commercial or ministerial purposes of processing;
The third parties with whom we share information.

9.2 Right to Deletion

You may request that we delete your personal information, subject to legal exceptions (accounting records, legal obligations, defense of claims).

9.3 Right to Correct

You may request that we correct inaccurate information. Some corrections (name, photo, gender) can be made directly at /profile.

9.4 Right to Portability

You may request a copy of your personal information in a structured, commonly used format (JSON, CSV).

9.5 Right to Non-Discrimination

We will not discriminate against you for exercising these rights. Since the Portal is free and non-commercial, there are no financial incentives tied to consent.

9.6 Right to Opt Out of "Sale" or "Sharing"

We do not sell or share personal data within the meaning of CCPA/CPRA. You do not need to do anything to avoid "sale" — we simply do not engage in it.

9.7 Rights Regarding Automated Decisions

The Portal does not make automated decisions that produce significant legal effects about you (no automatic scoring limits your ministerial participation, for example). If this changes, we would notify you.

10. How to Exercise Your Rights

Send your request to portal@shadowmountain.org indicating:

Your full name and email associated with the account;
The right you wish to exercise;
Specific detail (if applicable);
Your preferred response (email, call, in person).

Verification: we will confirm your identity before processing requests involving sensitive data (typically via a code sent to your registered email).

Timeframes: we will respond within 45 days (extensible to 90 days in complex cases, with notice). No cost under normal circumstances.

Authorized agent: you may designate a written authorized agent to act on your behalf.

Appeal: if we deny your request, you may appeal by replying to the same email. If you remain unsatisfied, you may file a complaint with the California Attorney General's office (oag.ca.gov/privacy) or the equivalent authority in your state.

11. Children's Privacy

11.1 Individual Accounts Only for Adults

The Portal restricts individual account registration to adults (18 years or older). We do not accept direct registration from minors.

11.2 Minor Participation Under Guardian-Held Accounts

The participation of minors in ministry activities (attendance, courses, family programs) is recorded under the account of an authorized leader, coordinator, parent, or legal guardian, always with written parental consent.

For children under 13, the additional protections of the Children's Online Privacy Protection Act (COPPA, 15 U.S.C. §6501 et seq.) apply: reinforced parental verification, prohibition on collecting personal data outside the strictly authorized ministerial context, and parental right of inspection and deletion at any time.

If you discover that a minor created an individual account without authorization, write to portal@shadowmountain.org and we will delete their data without delay.

12. Cookies and Similar Technologies

The Portal uses:

| Technology | Purpose | Origin | |---|---|---| | Session cookies (__session, firebase:authUser:*) | Keep your session signed in | Firebase Auth | | Security cookies (__cf_bm, etc.) | Anti-bot protection | Vercel / Cloudflare (when applicable) | | localStorage | Preferences (theme, language, last portal visited) | Portal | | IndexedDB | Offline resource cache | Portal (Service Worker / PWA) | | sessionStorage | Temporary form state | Portal |

We do not use advertising or cross-site tracking cookies.

You may manage cookies from your browser, but disabling them may prevent you from logging in.

13. Security

We implement reasonable technical and organizational measures to protect your information:

Encryption in transit (HTTPS / TLS 1.2+);
Encryption at rest (provided by Google Cloud / Firebase);
Strong authentication (Firebase Auth, tokens with short expiration);
Role-based access control verified both client- and server-side (withAuth middleware);
Firestore rules restricting access by collection and by owner;
Audit logs of sensitive accesses;
Periodic security reviews of code and dependencies.

However, no system is 100% secure. In the event of a security breach affecting personal data, we will notify you without undue delay and in accordance with the timeframes required by applicable law (Cal. Civ. Code §1798.82 et seq.).

14. International Transfers

The Portal is operated from the United States and most data is stored on U.S. servers. If you access the Portal from outside the U.S., your information will be transferred to the U.S. for processing. By using the Portal, you consent to this transfer.

15. Links to External Sites

The Portal may contain links to third-party sites (YouTube videos, external biblical resources, SMCC social media). We are not responsible for the privacy practices of those sites. Review their policies before providing information.

16. Changes to This Policy

We may update this Privacy Policy occasionally. When we make material changes:

We will update the effective date at the top;
We will post a notice in the Portal;
We will ask you to accept the new version at login if the changes affect your rights or the processing of sensitive data.

Version history is available on request.

17. Contact

To exercise your rights, file complaints, or ask questions about this policy:

Shadow Mountain Community Church en Español Attn: Portal Privacy Officer 2100 Greenfield Dr., El Cajon, CA 92019, United States Email: portal@shadowmountain.org Phone: (619) 590-1754

If you have a complaint we do not resolve satisfactorily, you may contact:

California Attorney General's Office: oag.ca.gov/privacy
Federal Trade Commission (U.S.): ftc.gov/complaint
Your state's privacy authority (Texas, Virginia, Colorado, Connecticut have their own offices).

Version 2026-05-21 — Effective: May 21, 2026. This policy replaces any prior privacy practices, written or verbal.