PRIVACY POLICY FOR TRUE CHRISTIAN MATRIMONIAL
1. Introduction and Scope
True Christian Matrimonials (“we,” “us,” “our,” “the Platform”) operates a faith-based matrimonial application and web platform (the “App/Service”) to facilitate Christian marriages and related matchmaking services.
This Privacy Policy explains how personal information is collected, used, stored, shared, and protected when you access or use our App, websites, and related services, in compliance with:
• The Data Protection Act, No. 3 of 2021 (Zambia)
• The Constitution of Zambia, Article 17 – Right to Privacy
• The Electronic Communications and Transactions Act, 2021 (Zambia)
• The Cyber Security and Cyber Crimes Act, 2021 (Zambia)
• Applicable international data protection standards (including, where relevant, principles from the EU General Data Protection Regulation (GDPR) for users in the EU/EEA)
This Policy applies to all users (“you,” “your,” “Member”) accessing our services from Zambia and globally. By registering or using our App, you consent to the collection, processing, and sharing of your personal information as described here. If you do not agree, you must immediately stop using the App.
We act as a Data Controller under the Zambia Data Protection Act for all personal information processed through our services.
2. Christian Mission Statement
This platform is designed for practicing Christians seeking marriage within the Christian faith. By registering, you affirm that:
• You are a baptized Christian or are actively attending Christian fellowship.
• You are seeking marriage in accordance with Christian principles.
• You consent to faith-based matching criteria, which may include denomination, church attendance, pastoral references, and other Christian compatibility indicators.
We may require a pastoral reference and church affiliation details as part of your profile and verification process.
3. Information We Collect
3.1 Information You Provide (Direct Collection)
To provide matchmaking and related services, you may be required or allowed to submit the following categories of data:
• Identity & Profile Data: Full name, date of birth, gender, photograph(s), video profiles, nationality, government issued ID (e.g., NRC/passport) for verification, marital status (single, divorced with decree, widowed with death certificate), residential/postal address.
• Contact Data: Mobile number, email address, emergency contact details (where relevant).
• Faith Data (Sensitive Personal Data): Christian denomination, church affiliation, pastor’s contact details, baptism certificate, statements of faith, church attendance, and pastoral references.
• Sensitive Personal Data: Religious beliefs, health information (including disability status and other health matters you choose to share), biometric data (photo, video, voice recording, other identity verification), financial standing information to support matchmaking or verification, where voluntarily provided.
• Professional & Educational Data: Educational qualifications, employment details, occupation, employer name, income bracket or range (optional), proof of employment if requested.
• Preference & Family Data: Partner preferences, family background, cultural and community details, dietary preferences, lifestyle choices, and (if culturally relevant) information such as horoscope, where voluntarily provided.
• Payment & Billing Data: Mobile money transaction IDs, credit/debit card details (processed through PCI DSS compliant third party gateways), bank account information, billing address, subscription details.
• Communication & Interaction Data: Messages and chats within the App, “likes” or expressions of interest, support requests, emails, call recordings (where permitted), and other communication records.
• User-Generated Content: Profile descriptions, photos, videos, testimonials, feedback, reviews, and success stories (published only with explicit consent).
3.2 Information Collected Automatically
When you access or use the App, we automatically collect certain technical information, including:
• Device & Technical Data: IP address, device ID, IMEI, MAC address, browser type, operating system, app version, language settings, and similar identifiers.
• Usage Data: Login timestamps, pages/screens visited, search queries, matches viewed, clicks, session duration, referral URLs, and interaction patterns.
• Location Data: Approximate location derived from IP or precise geolocation with your consent.
• Cookies & Similar Technologies: Cookies, pixels, SDKs, and other tracking technologies used for session management, analytics, and (with consent) marketing.
3.3 Information from Third Parties
We may receive additional information about you from third parties, which is combined with data we already have:
• Social Login Providers: If you sign up or log in using accounts such as Google, Apple, or other providers (if enabled), we may receive details such as your name, email address, profile photo, and other data you permit sharing.
• Verification and Background Check Partners: Identity verification services, background check agencies, church/pastoral references, educational and employment verifiers, fraud detection partners, and similar providers, with your explicit consent.
• Payment Processors and Financial Institutions: Confirmation of payment status, transaction references, chargeback information, and limited financial details strictly necessary to process and reconcile payments.
4. Legal Basis for Processing
We process personal information in accordance with the Zambia Data Protection Act and applicable international standards on the following legal bases:
1. Explicit Consent: You provide personal and sensitive personal data voluntarily for matchmaking and related services, and grant explicit consent at the time of registration and when uploading or submitting specific information.
2. Contractual Necessity: Processing is necessary to perform the contract between you and us, including creating your profile, searching for compatible matches, and enabling communication.
3. Legal Obligations: We process and retain certain information to comply with statutory requirements, tax and accounting obligations, fraud and crime prevention laws, and orders of courts or competent authorities.
4. Legitimate Interests: We process data to prevent fraud, ensure network and information security, improve our services, and protect our legal rights, while respecting your fundamental rights and freedoms.
5. Public Interest and Law Enforcement: Where required or permitted by law, we may process data for law enforcement cooperation and public safety purposes.
Special categories of data (such as religious beliefs, health information, and biometric data) are processed only with your explicit consent or where otherwise permitted by law, and are subject to enhanced safeguards.
For users located in the EU/EEA, processing may also rely on GDPR legal bases, including explicit consent, contractual necessity, compliance with legal obligations, and legitimate interests, with all corresponding rights preserved.
5. How We Use Your Information
Your information is used strictly for defined, legitimate purposes, including:
• Creating, managing, and verifying your profile and account.
• Matching you with compatible prospects using your profile, preferences, and faith-related parameters.
• Enabling communication between members through in-app messaging or other controlled channels.
• Conducting identity, age, and background verifications through authorized third parties, with consent.
• Providing customer support, resolving complaints, and handling technical issues.
• Processing payments, managing subscriptions, and handling refunds or chargebacks as applicable.
• Conducting analytics to understand usage patterns, improve algorithms, and enhance user experience.
• Ensuring platform security, detecting and preventing fraud, abuse, and prohibited content.
• Publishing success stories and testimonials only where you provide explicit, written consent.
• Complying with legal, regulatory, and law enforcement requirements.
Sensitive personal data is not used for solely automated decision making that produces legal or similarly significant effects on you without your explicit consent or appropriate safeguards.
6. Age, Eligibility, and Verification
Our service is intended for adults who are legally eligible to marry in their respective jurisdictions.
• You must be at least 18 years old or of the minimum marriageable age applicable in your jurisdiction, and in any case not below the minimum permitted under Zambian law for marriage or engagement to marry.
• We may require and verify government issued identification documents to confirm your age and identity before or after profile activation.
• If we discover that a minor or ineligible person has registered, the account will be terminated immediately and data will be deleted as soon as practicable, subject to any legal retention requirements.
7. Data Sharing and Disclosure
7.1 Sharing With Other Members
To achieve the purpose of the platform, certain parts of your profile are visible to other members:
• Profile information such as first name, age range, denomination, education, occupation, photographs, and preferences may be visible to registered members, depending on your in app privacy settings.
• Direct contact details (such as full phone number or email address) will not be displayed publicly and are shared, if at all, only through controlled mechanisms (for example, upon mutual match or with your explicit consent).
You can adjust visibility options through the privacy settings provided in the App, subject to minimum profile requirements needed for effective matchmaking.
7.2 Service Providers (Processors)
We engage vetted third party service providers under written agreements that require them to process personal data strictly according to our instructions and in compliance with applicable data protection laws.
These may include:
• Cloud hosting and infrastructure providers.
• Payment gateways and financial institutions that are PCI DSS or similarly certified.
• SMS, email, and communication service providers (including WhatsApp or similar APIs where used).
• Analytics and crash-reporting providers (such as Google Analytics with IP masking or equivalent).
• Identity, background, and fraud prevention service providers.
All such providers are prohibited from using your data for their own purposes and may only process data as necessary to deliver services to us.
7.3 Legal and Regulatory Disclosures
We may disclose your information where required or permitted by law, including:
• To courts, tribunals, regulators, law enforcement agencies, or competent authorities in response to lawful requests, subpoenas, or orders.
• To governmental authorities responsible for tax, anti money laundering, cybercrime, or similar statutory objectives.
• To safeguard our rights, property, or safety, or the rights, property, or safety of our users or the public, including investigating fraud, harassment, abuse, or violations of our Terms of Service.
7.4 Corporate Transactions
If we are involved in a merger, acquisition, restructuring, or asset sale, user data may be transferred to the acquiring or successor entity, subject to:
• Prior notice where practicable, and
• Commitment by the successor to honor this Privacy Policy (or an updated policy that provides equal or higher level of protection).
You may have the right to discontinue use and request deletion or portability of your data in such cases, subject to legal retention requirements.
7.5 International Data Transfers
Personal data may be stored and processed in Zambia or in other countries where we or our service providers maintain facilities.
• Where data is transferred outside Zambia, we ensure that appropriate safeguards are in place, such as contractual clauses consistent with the Zambia Data Protection Act and recognized international standards.
• We transfer data only to jurisdictions that provide an adequate level of protection or pursuant to contractual or other safeguards, or with your explicit consent, where required.
8. Data Retention
We retain personal information only for as long as necessary for the purposes described in this Policy or as required by law.
Typical retention periods include:
• Active Accounts: For the duration of your membership and for a defined period afterward to manage any queries, disputes, or legal obligations. For example, certain records may be retained for several years in line with evidence and tax laws.
• Inactive Accounts: If you do not log in for a specified period (e.g., 1–2 years), your profile may be deactivated and ultimately anonymized or deleted, subject to legal retention needs.
• Financial and Transaction Data: Retained for the period mandated by tax, accounting, and financial regulations (often up to 7 years).
• Backups: System backups containing your data may be retained for a limited period and then securely overwritten or destroyed.
When data is no longer required, it is either securely deleted or irreversibly anonymized so it can no longer be linked to you.
9. Your Rights as a Data Subject
Subject to applicable law, you have multiple rights regarding your personal information.
These generally include:
• Right of Access: To obtain confirmation of whether we hold personal data about you and to receive a copy of such data.
• Right to Rectification: To correct incomplete or inaccurate information.
• Right to Erasure (“Right to be Forgotten”): To request deletion of your personal data where it is no longer necessary for the purposes for which it was collected or where you withdraw consent, subject to legal retention requirements.
• Right to Restriction of Processing: To ask us to limit processing in certain circumstances, such as where accuracy is contested or processing is unlawful.
• Right to Data Portability: To receive your data in a structured, commonly used, and machine readable format, and to transmit it to another controller where technically feasible.
• Right to Object: To object to processing based on our legitimate interests, including for direct marketing.
• Right to Withdraw Consent: To withdraw consent at any time for processing that is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, contact us using the details in Section 13. We may need to verify your identity before responding to your request. We aim to respond within statutory timeframes specified by applicable laws.
If you are dissatisfied with our response, you may lodge a complaint with the Zambia Data Protection Commission or other competent data protection authority in your jurisdiction.
10. Cookies and Tracking Technologies
We use cookies and similar technologies to operate our services and improve your experience.
Types of cookies include:
• Essential Cookies: Required for core functions such as authentication, account security, and basic operations; these cannot be disabled through cookie settings.
• Functional Cookies: Store preferences, such as language, and enhance usability.
• Analytics Cookies: Collect aggregated usage metrics to help us understand user behavior and improve performance; you may opt out where such functionality is provided.
• Marketing Cookies: Used to deliver personalized content or measure the effectiveness of campaigns; used only with your consent where required by law.
Third parties (such as analytics or advertising providers) may also set cookies, which are subject to their respective privacy policies. You can manage cookie preferences through your browser settings or in app controls, but disabling some cookies may impact functionality.
11. Children’s Privacy
Our services are not directed to persons below the minimum legal age for marriage or other age limits prescribed by applicable law.
• We do not knowingly collect personal data from children or minors who are not eligible to marry.
• If we become aware that we have collected personal data from an ineligible minor, we will promptly deactivate the account and delete data as soon as practicable, unless we are required to retain it for legal or safety reasons (for example, to assist law enforcement in child protection matters).
12. Prohibited Content and Misuse
There is a zero tolerance policy for abusive or unlawful use of the platform, including but not limited to:
• Content involving minors or any form of child exploitation.
• Pornographic, sexually explicit, or obscene material.
• Content promoting hatred or discrimination based on race, tribe, ethnicity, nationality, gender, or religion.
• Fraudulent solicitations, scams, or attempts to obtain money or personal information under false pretenses.
• Impersonation, identity theft, or misrepresentation of marital status or religious affiliation.
• Content that threatens national security, public order, or public morals under applicable law.
We may use automated tools and human moderation to detect, block, and report such content, including to law enforcement or other competent authorities where required.
13. Security Safeguards
We implement appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
Measures include:
• Encryption of data at rest (e.g., AES 256) and in transit (e.g., TLS 1.2/1.3 or higher).
• Role based access controls, strong authentication, and least privilege policies for staff.
• Secure hosting infrastructure with recognized certifications such as ISO 27001, where applicable.
• Regular security assessments, vulnerability scans, and penetration testing by qualified professionals.
• Staff training and confidentiality obligations for employees and contractors.
• Incident response procedures, including notification to regulators and affected users within legally required timeframes in case of a significant data breach.
Despite robust safeguards, no system is completely secure, and you are responsible for maintaining the confidentiality of your login credentials and for logging out of shared devices.
14. Marketing and Communication Preferences
With your consent where required, we may send you:
• Match suggestions and service notifications via email, SMS, in app messages, or other channels.
• Christian marriage resources, event invitations, and newsletters.
• Promotional or marketing communications about our services or selected partners.
You may control your communication preferences through in app settings, unsubscribe links in emails, or by contacting us directly. Opting out of marketing messages does not affect service related communications (for example, account alerts or security notices).
15. Third Party Links and Integrations
Our App may contain links or integrations to third party websites or services, including church websites, counselling providers, payment processors, or other partners.
• These third parties operate independently and have their own privacy policies.
• We are not responsible for their privacy, security, or data handling practices, and you should review their policies before providing any personal information or using their services.
16. Limitation of Liability
To the maximum extent permitted by applicable Zambian law and other applicable laws:
• We are not liable for unauthorized access, disclosure, loss, or destruction of data that occurs despite reasonable security measures and that is beyond our reasonable control.
• We are not responsible for actions of other users or third parties, including misuse of data you choose to share, or for content or services provided by third party sites or integrations.
• Nothing in this Policy limits any non excludable rights or remedies available to you under applicable law.
17. International and Jurisdiction-Specific Provisions
17.1 Zambia
• Governing Law: Laws of Zambia.
• Jurisdiction: Courts of Zambia.
• Supervisory Authority: Zambia Data Protection Commission or other competent authority designated under the Zambia Data Protection Act.
Users in Zambia have the rights outlined in Section 9, as well as any additional protections granted by Zambian law.
17.2 Users in Other Countries
For users located outside Zambia, this Privacy Policy applies to processing carried out by us as the Data Controller, subject to any mandatory provisions of your local laws that apply.
Where required, we will adapt our practices to comply with local data protection requirements, including for users located in the EU/EEA under GDPR.
18. Changes to This Privacy Policy
We may update this Policy from time to time to reflect changes in law, technology, or our services.
• Material changes will, where required, be notified to you through in app messages, email, or other reasonable means, typically at least 30 days before they take effect.
• The “Last Updated” date at the top of this Policy indicates when it was most recently revised.
• Continued use of the App after changes take effect constitutes your acceptance of the revised Policy.
19. Contact, Data Protection Officer, and Complaints
If you have questions, concerns, or requests about this Privacy Policy or how your data is handled, you may contact:
Data Protection Officer (DPO)
[Full Name]
True Christian Matrimonials
[Full Zambian Address]
Phone: +91-9878767656
General Privacy Contact
Email: info@truechristian.com
You also have the right to lodge a complaint with the Zambia Data Protection Commission or your local data protection authority if you believe your data protection rights have been violated.
20. Consent and Acknowledgment
By clicking “I Agree,” registering an account, or using our services, you:
1. Confirm that you have read and understood this Privacy Policy.
2. Provide explicit consent to the processing of your personal and sensitive personal data as described, including cross border transfers where applicable.
3. Affirm that you are a Christian seeking marriage and that the information you provide is accurate and truthful.
4. Acknowledge that this Privacy Policy forms part of a legally binding electronic agreement between you and us, together with our Terms of Service.
5. Confirm that you are eligible to marry under the laws of your jurisdiction and, where relevant, under Zambian law.
If you create a profile on behalf of another individual, you warrant that you have obtained that person’s explicit written consent to share their personal and sensitive data and that you accept full responsibility for the accuracy and legality of the information provided.
