Privacy Policy

1. Who we are

The App is operated by [Legal entity name / developer name]("we", "us", "our").

Depending on your setup, your organisation (for example your SACCO or employer) may act as data controller for member data, and we may process personal data as a processor or service provider on their behalf. Where we act as controller for certain technical or account data, we describe that below.

• Contact (privacy): vote@sibonelo.org.sz
• Postal address (optional): Plot 6 & 7 Erf No.368, Mahleka Street, P.O. Box 4307, Manzini

2. Scope

This policy applies to the Sibonelo App and related services we provide in connection with the App. It does not apply to third-party websites or services we link to.

3. Information we collect

We collect information that you provide, that is generated when you use the App, and that comes from your device as needed to run the service.

3.1 Account and profile information

• Name, email address, phone number
• Membership or account identifiers (for example membership number)
• Organisation or company association
• Authentication credentials (passwords are stored using secure practices; we do not store plaintext passwords in readable form where hashing applies)

3.2 App usage and election-related data

Subject to your organisation's configuration:

• Participation in elections, nominations, and voting
• Records associated with eligibility (for example registration or attendance flags as configured by your organisation)
• Timestamps and audit-style records needed to operate elections fairly

3.3 Device and technical data

• Device type, operating system version, and app version
• IP address and approximate connection diagnostics
• Crash logs or performance data used to maintain reliability and security
• Push notification tokens if you enable notifications

3.4 Optional features

If you enable optional features (for example notifications), we process only what is needed for those features.

We do notknowingly collect precise location (GPS) through this policy's scope unless we explicitly tell you otherwise in the App and update this policy.

4. How we use your information

We use information to:

We do not sell your personal information.

5. Legal bases (where applicable)

If you are in the European Economic Area (EEA), UK, or similar jurisdictions, we rely on one or more of:

• Performance of a contract — providing the App and features you request
• Legitimate interests — security, fraud prevention, improving reliability (balanced against your rights)
• Consent — where we ask explicitly (for example optional notifications)
• Legal obligation — where the law requires processing

Your organisation may rely on additional bases for member processing; see their notices where relevant.

6. Sharing of information

We may share information with:

• Your organisation — administrators and systems they operate
• Service providers — hosting, infrastructure, analytics or crash reporting, email or messaging, as strictly needed to run the App (subprocessors)
• Authorities — when required by law or valid legal process

We require service providers to protect personal data appropriately and use it only for the purposes we specify.

7. International transfers

If personal data is transferred outside your country (for example to servers in another region), we take steps required by applicable law (such as appropriate safeguards or contractual clauses).

8. Retention

We retain personal data only as long as necessary to:

• Provide the App and features
• Meet legal, regulatory, or organisational retention requirements
• Resolve disputes and enforce our terms

Retention periods may be set by your organisation's policies as well as ours.

9. Security

We use technical and organisational measures designed to protect personal data, including encryption in transit where appropriate, access controls, and secure handling of credentials. No method of transmission or storage is 100% secure; we work to reduce risk in line with industry practice.

10. Your rights and choices

Depending on where you live, you may have rights to:

• Access a copy of your personal data
• Correct inaccurate data
• Delete certain data, subject to legal exceptions
• Object to or restrict certain processing
• Withdraw consent where processing is consent-based
• Lodge a complaint with a supervisory authority

To exercise rights, use Contact us in the App or email vote@sibonelo.org.sz. Your organisation may also handle certain requests as controller.

Android settings

You can manage App permissions in Android Settings → Apps → Sibonelo → Permissions. You may uninstall the App at any time.

11. Children's privacy

The App is not directed at children for whom the service is inappropriate under local law (for example financial or membership services). We do not knowingly collect personal information from children below the minimum age required by law for such services. If you believe we have collected data from a child in error, contact us and we will take appropriate steps.

12. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated policy at [https://your-domain.com/privacy-policy]and revise the "Last updated" date. For material changes, we may provide additional notice (for example in the App), where required by law.

13. Third-party platforms

If you download or update the App through an app marketplace, your device vendor, marketplace operator, or network provider may collect information according to their own policies. Those practices are not governed by this Privacy Policy.

14. Contact us

For privacy questions or requests:

• Email: vote@sibonelo.org.sz
• In-app: Contact / Support section within Sibonelo