Church Service and Operator Agreement
Version 1.0, 18 October 2026
In short, for church leaders
Your church is responsible for its member list and church life; Strong Steeple keeps them safe and runs the app for you. Under POPIA that makes your church the responsible party for the member register and Strong Steeple your operator (sections 20 and 21).
What Strong Steeple does
Strong Steeple is a church app on the web (app.strongsteeple.co.za), iPhone and Android. Members use it for church, group and event chats, notices, sermons, events, serving rosters, availability, polls and shared files. Admins approve members, manage groups and rosters, and post content.
Who is responsible for what
| Area | Your church | Strong Steeple |
|---|---|---|
| Member register and church life (membership, approvals, roles, groups, serving teams, rosters, availability, profile details admins see, birthday reminders, messages and content in your church's spaces) | Responsible party: decides who is on it and why | Operator: stores and processes it only on your instructions |
| Strong Steeple's platform data (accounts and sign-in, sessions and devices, push tokens, notification settings, pinned churches, consent records, deletion requests, content reports, website enquiries) | Not responsible | Responsible party |
| Telling members the church uses Strong Steeple | Yes, using the member notice at the end of this page | Gives members its own Privacy Policy at sign-up |
| Consent for under-18s | Gets and keeps a parent or guardian's written consent | Removes a child's details if consent is missing |
| Security of the system | Keeps admin logins safe; picks trustworthy admins | Hosting, encryption, access control, breach response |
| Requests from members (copy, correct, delete) | Decides on requests about the register | Helps you answer them; members can delete their own account in the app |
What your church must do
- Have someone with authority accept this agreement when registering the church in the app.
- Name your church's Information Officer, or a deputy, for POPIA questions.
- Appoint admins you trust, and remove them when they step down.
- Only add people you have a good reason to add, such as members who asked to join.
- Give members the member notice at the end of this page (read it out, print it or email it).
- Get a parent or guardian's consent before adding anyone under 18, and keep a copy.
- Tell support@strongsteeple.co.za straight away if you think an admin account has been misused.
Automatic deletions
By accepting the agreement, your church tells Strong Steeple to delete some data automatically (clause 4.7). When a member leaves your church or deletes their account, their messages, reactions and roster entries go. Sermons, notices and files an admin published stay, without their name. Old notifications, expired shared files and old reports are also cleared on a fixed schedule.
Religious information
Being on a church's list shows a person's religious beliefs, which POPIA treats as special personal information (section 26). Your church may process its own members' religious information (section 28(1)(a)). It may not pass it to anyone else without the member's consent (section 28(3)). Strong Steeple also asks every member for explicit consent when they create an account (section 27(1)(a)).
The agreement
Agreement version: 1.0. Effective date: the date the Church signs or accepts it.
This agreement sets the terms on which a church uses Strong Steeple. It is also the written operator contract POPIA section 21(1) requires between a responsible party and its operator.
1. Parties
1.1 Strong Steeple, a sole proprietorship owned by Jaco Louw, of 15A Dovehouse Road, Gillitts, Durban, 3625, South Africa, email support@strongsteeple.co.za, phone 082 568 0206 ("Strong Steeple", "we", "us").
1.2 The church named in the Church Registration and Consent Form ("the Church", "you").
1.3 This agreement starts when the Church's authorised signatory signs the form, or accepts it online (the "Start Date").
2. Definitions
2.1 Words defined in POPIA section 1 have the same meaning here, including responsible party, operator, data subject, processing, personal information and special personal information.
2.2 In this agreement:
- Admin means a person the Church gives admin rights in the Service.
- Account Data means the personal information Strong Steeple holds as responsible party for its own platform data, listed in clause 4.3.
- Church Data means the Church's member register and church-life data, described in clause 4.1.
- Instructions means the Church's documented instructions, as set out in clause 4.2.
- Member means any person whose details are in the Church Data, whether or not they have claimed an account.
- Privacy Policy and Terms of Use mean Strong Steeple's published policies at strongsteeple.co.za, as updated from time to time.
- Security Compromise means any case where there are reasonable grounds to believe Church Data has been accessed or acquired by an unauthorised person (POPIA section 22).
- Service means the Strong Steeple web app at app.strongsteeple.co.za, the iOS and Android apps, and related support.
- Sub-operator means a third party Strong Steeple uses to process Church Data, listed in Annexure A.
3. The Service
3.1 Strong Steeple gives the Church a private space in the Service. In it the Church can manage members and approvals, admins, groups and serving teams, rosters and availability, events, chats, notices, sermons, polls and shared files.
3.2 We may improve or change features. We will not reduce the privacy or security protections in this agreement without notice under clause 11.
3.3 Fees. The Service is currently free to churches. Strong Steeple may introduce fees later, but only after giving the Church at least 60 days' written notice of the fees and payment terms. The Church may end this agreement under clause 9.1 before any fee applies, and will then owe nothing. Strong Steeple is not registered for VAT; if that changes, the notice will say whether VAT applies.
3.4 There is no formal service level. We use reasonable efforts to keep the Service available and give notice of planned downtime where practical, but do not guarantee it will always be available or error-free.
3.5 Each Member who creates or claims an account also accepts the Terms of Use and Privacy Policy. If those documents and this agreement conflict on the handling of Church Data, this agreement wins.
4. Roles of the parties
4.1 The Church is the responsible party for the Church Data. This is its member register and church-life data:
- membership, approval status and roles;
- groups and serving teams;
- rosters, event assignments and availability;
- the profile details Admins see and manage as part of the register: name, email address, photo, mobile number, date of birth and gender (optional);
- birthday reminders to Admins; and
- messages and other content posted in the Church's spaces, including chats, sermons, notices and files.
4.2 Strong Steeple is the Church's operator for the Church Data. We process it only with the Church's knowledge or authorisation (section 20(a)) and only on its Instructions. The Instructions are:
- this agreement, including the standing deletion instructions in clause 4.7;
- the settings the Church chooses and the actions its Admins take in the Service; and
- written instructions emailed to support@strongsteeple.co.za by the Church's Information Officer, deputy or authorised signatory.
4.3 Strong Steeple is the responsible party for its own platform data (Account Data). This covers:
- user accounts and sign-in: email address, password hash, and Google or Apple sign-in identifiers;
- sessions, IP addresses and device details;
- push notification tokens, notification settings and pinned churches;
- each user's POPIA consent record;
- deletion requests and content reports filed with Strong Steeple; and
- website enquiries.
Strong Steeple asks every user for explicit consent (section 27(1)(a)) covering its own processing and the transfers in clause 6.7. The Privacy Policy governs Account Data.
4.4 Member records created by Admins. An Admin may create a Member record directly. Strong Steeple sends the person nothing at that point, and the record gets a random password no one knows. The person can take over the account later in one of two ways:
- they try to sign up with the same email address, and Strong Steeple emails a claim link to that address; following it, they set a password and give their own consent; or
- they sign in with Google or Apple using that email address, and are then shown the consent page before they can use the Service.
A Member added without an email address never gets an account. Until a person takes over their record, all of it is Church Data. Once they do, their membership of the Church stays Church Data and their account becomes Account Data.
4.5 If we believe an Instruction would break POPIA or another law, we will tell the Church and may decline to follow it.
4.6 We will not use Church Data for our own purposes, sell it, or use it for marketing. We use it only to provide, secure and support the Service.
4.7 Standing deletion instructions. By accepting this agreement, the Church instructs Strong Steeple to make these deletions automatically, as the Privacy Policy describes (section 8). Each counts as an Instruction under clause 4.2:
- When a Member deletes their account: they can do this themselves in the app (Settings → Delete account), which takes effect immediately, or, if they cannot sign in, by email or the request form. Their messages, reactions, poll votes, memberships and roster entries are deleted, and only a record of the old account number and the date is kept. Sermons, notices and files they published as an Admin stay with the Church, with their name removed.
- When a Member leaves the Church: their messages, reactions and sermons in the Church's spaces are deleted, along with their group memberships, roster entries and availability for the Church.
- Routine clean-up:
- notifications are deleted after 90 days, or when they expire if that is later;
- unused sign-ins are deleted after 6 months;
- content reports are deleted 1 year after the last action on them; and
- shared files are deleted 30 days after they expire.
Where an item is Account Data (sign-ins, and reports filed with Strong Steeple), Strong Steeple deletes it as responsible party under the same schedule. The Church should export anything it needs to keep before these deletions happen.
5. The Church's obligations
5.1 Lawful basis. The Church must add or approve a person only where it has a lawful reason under section 11, for example that the person is a member or asked to join. It may process religious information only about people who belong to the Church or as its aims require (section 28(1)(a)).
5.2 Only what is needed. The Church must enter only the details it needs (section 10) and keep them accurate (section 16). Optional fields, such as gender, should be left blank unless the Church needs them.
5.3 Member notice. The Church must tell its Members, before or as soon as reasonably possible after adding them, that it uses Strong Steeple and what it holds (section 18). The member notice at the end of this page may be used.
5.4 Children. Accounts are only for people aged 18 or over. The Church must not add anyone under 18 unless a parent or guardian has consented first (sections 34 and 35(1)(a)). The Church must:
- get that consent in writing or another form it can produce later;
- keep a record of it for as long as the child's details are in the Service;
- show it to Strong Steeple on request; and
- remove the child's details if consent is withdrawn.
For children, the Church should enter only the name and the groups they belong to, unless the parent or guardian agrees to more.
5.5 Admins and access. The Church must:
- appoint as Admins only people who need access and whom it trusts;
- remove an Admin's rights promptly when they step down or leave;
- make sure Admins keep their logins secret, use strong passwords and never share accounts; and
- make sure Admins keep Church Data confidential and use it only for church purposes.
The Church is responsible for what its Admins do in the Service.
5.6 Information Officer. The Church must name its Information Officer (or deputy) in the Registration Form and keep that detail up to date. The Church is responsible for its own registration with the Information Regulator where required.
5.7 No onward sharing. The Church must not supply Members' religious information, such as an exported member list, to anyone else without the Member's consent (section 28(3)).
5.8 Requests from Members. The Church decides requests to see, correct or delete Church Data (sections 23 to 25). It must respond within a reasonable time and may ask us for help under clause 6.5. Members can also delete their own account in the app at any time, which makes the deletions in clause 4.7.
5.9 Report misuse. The Church must tell us without delay at support@strongsteeple.co.za if it suspects an Admin account has been misused or compromised.
6. Strong Steeple's obligations as operator
6.1 Confidentiality (section 20). We treat Church Data as confidential. We disclose it only to Sub-operators under clause 6.6, or where the law requires.
6.2 Security (sections 19 and 21(1)). We keep appropriate, reasonable technical and organisational measures to protect Church Data against loss, damage, unauthorised destruction and unlawful access. Annexure B summarises them. We review them at least once a year.
6.3 Security Compromises (sections 21(2) and 22). If we have reasonable grounds to believe Church Data has been accessed or acquired by an unauthorised person, we will:
- notify the Church's main contact and Information Officer immediately (section 21(2));
- give these details as soon as they are known, and in any case within 72 hours of becoming aware: what happened, what data and which Members are likely affected, what we have done, and what the Church can do;
- help the Church notify the Information Regulator and affected Members under section 22; and
- keep a record of the compromise and our response.
Where Account Data is affected, we notify the Regulator and the people concerned ourselves, as responsible party. We handle every Security Compromise under Strong Steeple's Security Compromise Response Procedure.
6.4 People with access. Only the Strong Steeple Information Officer has access to production systems. Anyone else given access in future will be bound in writing to keep Church Data confidential.
6.5 Helping with requests. We will help the Church answer Members' requests under sections 23 to 25 and objections under section 11(3). If we receive a request about Church Data, we will pass it to the Church within 5 business days. We will not answer it on the Church's behalf unless the Church asks us to, or it also concerns Account Data. Account deletions, whether made in the app or requested by email or the request form, follow clause 4.7.
6.6 Sub-operators. The Church authorises us to use the Sub-operators in Annexure A. We will:
- bind each Sub-operator by written terms that protect Church Data at least as well as this agreement;
- stay responsible to the Church for what our Sub-operators do;
- tell the Church's main contact and Information Officer by email at least 30 days before adding or replacing a Sub-operator; and
- if the Church objects on reasonable grounds, try to resolve it. If we cannot, the Church may end this agreement under clause 9.1.
6.7 Transfers outside South Africa (section 72). Our Sub-operators are in the Netherlands, the European Union and the United States (Annexure A). We transfer Church Data only to recipients bound by a law, binding corporate rules or a binding agreement that gives protection substantially similar to POPIA (section 72(1)(a)). The Church agrees to these transfers. Members also consent to them at sign-up (section 72(1)(b)).
6.8 Return and deletion when the agreement ends. When this agreement ends:
- on a request made within 30 days after the agreement ends, we will send the Church a copy of its member list as a spreadsheet (CSV file) within 30 days of the request;
- once any requested copy has been sent, or 30 days after the agreement ends if none is asked for, or sooner if the Church asks, we delete the Church Data from live systems;
- backups roll off within about 7 days after deletion;
- we confirm deletion to the Church in writing; and
- Members' own accounts are not deleted, as they are Account Data. Each Member stops belonging to the Church. Their messages, reactions, group memberships, roster duties and availability for that Church are deleted, as Privacy Policy section 8 describes.
We may keep Church Data longer only where the law requires it (section 14), and only for that purpose.
6.9 Showing compliance. We keep records of our processing. Once a year, on request, we will answer the Church's reasonable written questions about how we protect Church Data.
6.10 Requests from authorities. If a public body asks us for Church Data, we will tell the Church first, unless the law forbids it.
7. Special personal information
7.1 Being a Member shows a person's religious beliefs, which is special personal information (section 26). Children's details are also specially protected (section 34).
7.2 The Church processes its Members' religious information under section 28(1)(a). We process it for the Church as its operator, under that authorisation. Strong Steeple also asks every user for explicit consent at sign-up (section 27(1)(a)), covering its own processing and the transfers in clause 6.7.
7.3 Neither party will supply Members' religious information to a third party without the Member's consent (section 28(3)). Sub-operators process it only on our instructions to run the Service.
7.4 Admins and Members should not record other special personal information, such as health or criminal records, in notes, chats or notices unless there is a lawful reason (section 27). The Church is responsible for what its Admins record.
7.5 The Church decides what to make public, such as its address, public events, sermons and notices. It must not publish a Member's personal information publicly without that Member's consent.
8. Acceptable use and content
8.1 The Church, its Admins and Members must follow the Terms of Use. They must not post anything illegal, abusive, hateful, harassing, infringing, spammy or misleading.
8.2 The Church must not use the Service to try to reach other churches' data, to send unsolicited marketing, or to upload other people's personal information without a lawful reason.
8.3 The Church keeps the rights in content it posts. It gives Strong Steeple a licence to host, store, display and distribute that content only to run the Service (Terms of Use section 6).
8.4 We may remove content, or restrict an account, that breaks the Terms of Use or the law. Where it concerns the Church's own content, we will tell the Church's main contact, unless that would be unlawful or unsafe.
9. Suspension and termination
9.1 The Church may end this agreement at any time by email to support@strongsteeple.co.za from its main contact, Information Officer or authorised signatory.
9.2 Strong Steeple may end this agreement on at least 60 days' written notice.
9.3 We may suspend the Church's space, or an Admin's access, straight away if there is a serious security risk, unlawful use, or a material breach of this agreement. Where we can, we will first give the Church 14 days to fix the problem.
9.4 If Strong Steeple stops offering the Service altogether, we will give at least 90 days' notice.
9.5 However the agreement ends, clause 6.8 (return and deletion) applies. Clauses 6.1, 7, 10 and 12 continue to apply after it ends.
10. Liability
10.1 To the extent the law allows, Strong Steeple's total liability to the Church for all claims arising from this agreement or the Service is limited to the fees the Church paid Strong Steeple in the 12 months before the claim arose, or R1,000 if no fees were paid.
10.2 Neither party is liable to the other for indirect or consequential loss, including loss of profit, data or goodwill.
10.3 Nothing in this agreement limits or excludes liability for gross negligence or wilful misconduct, or any liability or right that the law does not allow to be limited, including rights under POPIA and, where it applies, the Consumer Protection Act 68 of 2008.
10.4 Each party is responsible for its own breaches of POPIA.
11. Changes to this agreement
11.1 We may update this agreement. We will email the Church's main contact and Information Officer at least 30 days before a change takes effect.
11.2 For a material change, an authorised person for the Church must accept the new version in the app or in writing. The Service records which version was accepted, when and by whom.
11.3 If the Church does not accept a change, it may end this agreement under clause 9.1 before the change takes effect.
11.4 Changes to Annexure A follow clause 6.6.
12. Governing law and general terms
12.1 This agreement is governed by the laws of the Republic of South Africa.
12.2 The parties will first try to settle any dispute by talking in good faith for 30 days. After that, either party may take the dispute to court. The parties consent to the jurisdiction of the Magistrates' Court under section 45 of the Magistrates' Courts Act 32 of 1944. Otherwise, the High Court of South Africa, KwaZulu-Natal Division, Durban, has jurisdiction. This does not stop anyone complaining to the Information Regulator.
12.3 This agreement, the Registration and Consent Form and the annexures are the whole agreement between the parties about the Service.
12.4 The Church may not transfer this agreement to anyone else without our written consent. We may transfer it to a buyer of the Strong Steeple business, with notice to the Church, if the buyer takes on these obligations.
12.5 Notices under this agreement may be given by email to the addresses in clause 13 and the Registration and Consent Form. Online acceptance counts as signature under the Electronic Communications and Transactions Act 25 of 2002.
13. Contact details
Strong Steeple: Jaco Louw, owner and Information Officer, 15A Dovehouse Road, Gillitts, Durban, 3625. Email support@strongsteeple.co.za. Phone 082 568 0206.
The Church: the main contact and Information Officer named in the Registration and Consent Form.
Annexure A: Sub-operators
Strong Steeple uses these Sub-operators as at the agreement's effective date. Changes are notified under clause 6.6.
| Sub-operator | What it does | Personal information involved | Where | Protection for the transfer (section 72) |
|---|---|---|---|---|
| DigitalOcean | Hosts the app, database and uploaded files | All Service data, including Church Data | Amsterdam, Netherlands | EU GDPR; DigitalOcean data processing agreement |
| Brevo | Sends emails such as claim links, password resets and notifications | Name, email address, email content (church name, parts of messages) | European Union | EU GDPR; Brevo data processing agreement. Any move to another email provider will be notified under clause 6.6 |
| Android push notifications (Firebase Cloud Messaging), Google sign-in, support inbox (Gmail) | Push tokens, notification content, sign-in details, support emails | Mainly United States | Firebase push: Google's Firebase data processing terms. Support inbox (Gmail): Google's standard consumer terms; no data processing agreement yet. Personal details are kept out of support emails or support@ moves to Google Workspace (Cloud Data Processing Addendum). Google sign-in: Google acts for the user under its own terms and is not an operator for this, so no data processing agreement is needed. | |
| Apple | iPhone and iPad push notifications (APNs), Sign in with Apple | Push tokens, notification content, sign-in details | United States | APNs push: Apple's developer and data protection terms. Sign in with Apple: Apple acts for the user under its own terms and is not an operator for this, so no data processing agreement is needed. |
Scripture text and audio come from bible.helloao.org, which a Member's device reaches directly. We send it no personal information, so it is not a Sub-operator.
Annexure B: Security measures
Strong Steeple keeps these measures in place and reviews them at least once a year.
| Area | Measure |
|---|---|
| Encryption in transit | All traffic uses HTTPS |
| Encryption at rest | The hosting provider encrypts the database and stored files |
| Passwords | Stored only as a hash, never in plain text |
| Access between churches | Admins see only their own church's members; members cannot see other churches' private data |
| Production access | Limited to the Information Officer, using individual keys |
| Account security | Sign-in records keep IP address and device type to spot misuse |
| Backups | Hosting provider database backups, which roll off after about 7 days |
| Logs | Short-lived technical request logs only |
| Third parties | No advertising or analytics tools; only the Sub-operators in Annexure A |
| Content safety | Members can report content; the owner reviews reports by email and removes content where needed |
| Breach response | Strong Steeple's Security Compromise Response Procedure |
Member notice template
Churches can read this out, print it in a bulletin or email it. Fill in the words in square brackets. It helps meet the church's duty to tell members about its processing (POPIA section 18).
How [Church name] uses Strong Steeple
[Church name] uses the Strong Steeple app to keep in touch with you: chats, notices, events, sermons, groups and serving rosters.
Who we are. [Church name], [church physical address], keeps the member details described below.
What we keep about you. Your name and, if you have an account, your email address. Your photo, mobile number, date of birth and gender are voluntary: leaving them out only means features like birthday greetings won't work for you. We also keep your groups and serving teams, roster duties, the availability you give, whether you are an approved member, and the messages you post in our church's spaces. Our admins use your date of birth for birthday greetings.
Why. To run church life together: so you can be added to groups and rosters and get the news that matters to you. We only add people who belong to our church or ask to join.
Who sees it. Our church admins see the details above. Other members see your name, photo, and the groups and rosters you are in where the app shows them. Outside the church, only Strong Steeple and its service providers handle your details, to run the app. We will not give your details to anyone else without your consent.
Strong Steeple's part. Strong Steeple runs the app for us. Your details are stored on servers in the Netherlands. Emails go through a provider in the European Union, and app notifications through Google and Apple in the United States, so your name, our church's name and parts of messages pass through those places. Strong Steeple uses only providers bound to protect your information, and may not use your details for anything else. When you create your own account, Strong Steeple asks for your consent, and its Privacy Policy at app.strongsteeple.co.za/privacy explains how it looks after your account.
Children. We add children under 18 only with a parent or guardian's consent.
Your rights. You can ask to see what we hold, have it corrected or deleted, or object to how we use it. You can change most of your details yourself in the app, and delete your account at any time under Settings → Delete account. If you can't sign in, email support@strongsteeple.co.za or use the form at app.strongsteeple.co.za/account-deletion. Contact [name of church Information Officer] at [email or phone]. You may also complain to the Information Regulator at enquiries@inforegulator.org.za or 010 023 5200.