This is a translation provided for convenience. In case of discrepancy, the Spanish version prevails.

1. Data controller

This policy explains how Congrega processes the personal data of people who visit www.congrega.es, sign up for its webinars, contact us or contract the Congrega CRM application, under Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD).

For any privacy question, write to soporte@congrega.es.

2. What data we process and where it comes from

We only process data you give us directly or that is generated when you use the website and the application:

Data about each church's members entered in the application is not processed by Congrega on its own behalf: see section 4.

3. Why we use your data, on what legal basis and for how long

Each use of your data has a legal basis under article 6 GDPR and a retention period:

PurposeDataLegal basisRetention
Manage your webinar sign-up and send you the session link. Contact details, church and your question. Your sign-up request (art. 6.1.b GDPR). 24 months after the webinar, unless you become a customer.
Answer your enquiries and send you the information or quote you ask for. Contact details, church and your enquiry. Your request (art. 6.1.b GDPR). 24 months after the last communication.
Provide the contracted service: set-up, user accounts, support and service notices. Customer data and user accounts. Performance of the contract (art. 6.1.b GDPR). For the duration of the contract.
Invoice and meet accounting and tax obligations. Billing and payments. Legal obligation (art. 6.1.c GDPR). 6 years (art. 30 of the Spanish Commercial Code).
Protect the website and the application against unauthorised access, fraud and automated (spam) sign-ups. Technical data and access logs. Legitimate interest in the security of the service (art. 6.1.f GDPR). 12 months. The IP address stored with a webinar sign-up is kept as long as the sign-up.
Measure website use to improve it. Technical data (analytics cookies). Your consent to cookies (art. 6.1.a GDPR). See the Cookie policy.

We do not use your data to make automated decisions or build profiles with effects on you, and we never sell it.

Where processing is based on your consent, you can withdraw it at any time (for cookies, with the “Cookie settings” link in the footer). Withdrawing it does not affect what we did before with your consent.

When a period ends, we block the data for as long as needed to deal with possible legal liabilities and then delete it.

4. Data churches store in the application

Each church that contracts Congrega CRM is the controller of the data about its members, families, attendees and volunteers that it enters in the application. Congrega acts as data processor (art. 28 GDPR): it stores and processes that data only to provide the service and following the church's instructions.

Specifically, Congrega undertakes to:

  1. Process that data only to provide the service, never for its own or commercial purposes.
  2. Not disclose it to third parties, except to the providers needed for the service (section 5) or where required by law.
  3. Require confidentiality from everyone who may access it.
  4. Apply appropriate security measures, bearing in mind that this data may reveal religious beliefs, a special category of data (art. 9 GDPR).
  5. Help the church respond to its members' rights and notify it without delay of any security breach.
  6. When the contract ends, give the church, if it asks within the following 30 days, a copy of its data in a commonly used format (for example, Excel), and then delete it, unless the law requires it to be kept.

These obligations are set out in the data processing agreement Congrega signs with each church.

If you are a member of a church that uses Congrega and want to access, correct or delete your data, contact your church, which decides on it. If you write to us, we will forward your request to the church.

5. Who we share data with

We do not give your data to third parties for their own purposes. It is only accessed by the providers we need to provide the service, under a data processing agreement that obliges them to protect it and use it only according to our instructions:

If you click the WhatsApp link, the conversation is governed by WhatsApp's (Meta's) privacy policy.

We may also disclose data to the Tax Agency, courts or other authorities when required by law.

International transfers. Some providers may process data outside the European Economic Area, mainly in the United States. In those cases we only work with companies certified under the EU-US Data Privacy Framework or that sign the standard contractual clauses approved by the European Commission, which guarantee protection equivalent to European standards.

6. Your rights

You may exercise these rights at any time and free of charge over the data Congrega processes as controller:

To exercise them, write to soporte@congrega.es with the subject “Data protection”, stating which right you want to exercise. We will only ask for an identity document if we have reasonable doubts about your identity. We will reply within one month at most.

If you believe we have not handled your data properly, you can lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

7. Security, minors and changes

Security. We apply technical and organisational measures to protect data: encrypted connections (HTTPS), encrypted passwords, role-based access within each church, separation of each church's data and regular backups.

Minors. The website and contracting Congrega are aimed at adults who manage a church. We do not knowingly collect data from children under 14 through the website. If a church records data about minors in the application, the church is responsible for obtaining the consent of their parents or guardians.

Changes. We may update this policy to reflect legal or service changes. We will always publish the version in force on this page and, if the change is significant, notify our customers by email.