Privacy Policy

Tembiya.net Privacy Policy

1. Brief Overview

Here’s a summary of what you can expect to find in our Privacy Policy, which cover all Tembiya.net-branded products and services:
Making your experience personal.
When you use any one of our applications or sites, the information we collect is for the purpose of offering a more personalized experience.

How we use your data.
The Privacy Policy clearly outlines the types of data we collect from your activity, and how we use that information to enhance your Tembiya.net experience. We do not share your personally identifiable data with any third-party advertisers or advertisement networks.

Your privacy protected.
When you see stats we share and celebrate about Tem language engagement around the world, we make sure to analyze the data in a way that protects your privacy. When this information is published, it is only in an aggregated form that does not disclose your personally identifiable information. In addition, we implement industry standard security safeguards designed to protect your data.

It’s your experience.
Our Privacy Policy makes it clear what rights you have when using Tembiya.net, including accessing, sharing, changing and deleting your personal data. We also address how data collection technologies help provide functionality and insight to help you fully engage with Tembiya.net and the Tem language materials.

2. Privacy Policy

Last modified on April 10, 2020

3. Definitions

To make this document easier to read, we’re going to use some shorthand throughout. For example, when we say “Tembiya.net,” we’re talking about:

• These Tembiya.net mobile applications
  
  • Tem Scripture Apps
  • Tem Keyboards
• The www.Tembiya.net website
• These Tembiya.net applications on other platforms
  
  • Tem Scripture apps for iPhone or iPad
  • Tem Keyboards

Tembiya.net products are owned and operated by The Tem Language Committee (CLTem) and/or Association Bible Tem (ABTem), which we’ll refer to as “CLTem,” “ABTem,” “us,” or “we” throughout this policy. We allow use of Tembiya.net by unregistered users, which we’ll call “Visitors,” as well as registered users, or “Members.” When we refer to both in this policy, we’ll use the term “Users” or “you.”

4. Accepting the Terms

Please read this Privacy Policy carefully because it discusses how we will collect, use, share and process your personal information, and by accessing Tembiya.net you agree to this Privacy Policy and its terms and consent to having your data transferred to and processed in the Togo or our partners in Germany or United States.

We welcome any questions or comments you may have about this Privacy Policy and our privacy practices. If you have any questions or comments, you may contact us at: [CLTem at tembiya.net] or [info @ tembiya.net] or use the contact link at the bottom of this page.  

5. How We Use Your Information

We do not share your personal data with any third-party advertisers or ad networks for their advertising purposes. We use data that we collect about you or that you provide to us, including any personal information, as follows:

1. To provide you with Tembiya.net, and any other information, products, or services that you request from us;
2. As described in this Privacy Policy;
3. To fulfill any other purpose for which you provide it;
4. To carry out our obligations and enforce our rights under this Privacy Policy;
5. In any other way we may describe when you provide the information; and
6. For any other purpose with your consent.

Your ability to access Tembiya.net is not contingent on you providing us with your personal information and you may decline to submit personal information to us, however, that may prohibit us from providing you with certain Tembiya.net services and/or functionality.

6. Facilitating Your Use of Tembiya.net

We use your personal data to provide certain functionality of Tembiya.net depending on the functionality you use and choose and the personal data you agree to provide. We use the data that we have about you to provide, improve, and personalize Tembiya.net, including with the help of automated technologies discussed in this policy and the inferences that we make from information we collect.

7. Recommendations

We use the data we have about you and inferences we make from that data to recommend certain content and functionality as well as additional products and services offered through Tembiya.net. For example, based upon a Reading Plan you complete, we may suggest additional Plans to you. We may contact you through push notification, email, or in-app messages to discuss these recommendations, how to use Tembiya.net, and other Tembiya.net news messages.

8. Service-Related Messages

We do not collect your email address so we will not be contacting you about account, security, legal and other service-related issues. We may at some future point offer in-app messages or push notifications but these are not yet available.

9. Analytics and Performance

We desire to see Tem language engagement increase throughout the world. We use the personal data available to us to observe social, economic, and geographic trends as they pertain to the teachings of the Holy Scriptures and specific Bible verses. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish our insights but only in an aggregated form that does not disclose your personally identifiable information. For example we may use your data to generate statistics about overall usage of Tembiya.net worldwide and in specific countries and geographic regions.

10. Security and Technical Issues

We use the data (which can include your communications) to investigate, respond to and resolve complaints, legal, security and technical issues concerning Tembiya.net. We use your data and communications if we think it is necessary for security purposes or to investigate possible fraud or violations of law or this Privacy Policy and/or attempts to harm others.

Information We Collect and How We Collect It

11. Information You Provide to Us

You are not required to provide any personal information to use Tembiya.net website or cell phone apps.

12. Sensitive Data

By downloading and using Tembiya.net applications, we do not assume that you are of any particular religious group or are expressing to us any particular religious belief; we merely assume that you are interested in the Tem language Scriptures, such as the Bible. We do not require that users provide such beliefs to us or provide any other sensitive data such as race, ethnicity, philosophical beliefs, or physical or mental health to create or maintain a Tembiya.net Member account. It is your choice whether to provide such sensitive information should it be an option to do so. If you choose to provide any sensitive information, it may be used by ABTem to create a more personalized Tembiya.net experience like other non-sensitive information you provide. In any event, ABTem will only process sensitive data you provide to us for ABTem’s legitimate activities on your behalf and will not disclose this information without your express consent. We will maintain your information subject to appropriate safeguards discussed in this policy and otherwise provided by ABTem. Should you have any questions, feel free to contact us at  [info @ tembiya.net] or use the contact link at the bottom of this page. 

13. Use For Other Services

We may combine the information you submit under your account with information you provide us through other ABTem services and products as well as inferences we make from this information to provide you with a better experience and to improve the quality of all services and products provided to you by ABTem.

14. Your Posts and Contributions.

When Tembiya.net allows you to provide information to be published, distributed, or displayed, we refer to that as “posted,” which can be on public areas of Tembiya.net, websites you access through Tembiya.net or transmitted to other users of Tembiya.net or third parties, all of which we’ll call “User Contributions.” For example, these include activities such as creating a Note, making a comment on a friend’s post, or creating a Verse Image.

Please keep in mind that if you disclose personal information in a public manner whether through collaborative postings, social media, message boards, or other public online forums, this information may be collected and used by others. User Contributions are posted and transmitted at your own risk. We cannot control the actions of other users or third parties with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons, nor do we accept any liability associated with your User Contributions.

15. Automatic Data Collection Technologies.

Service Use. We log usage data when you use Tembiya.net, including when you view or click on content, browser type, browser language, perform a search or request, the date and time of your request, install an update, seek new functionality, or use one or more tools offered through Tembiya.net. We use log-ins, device information internet protocol (“IP”) addresses, to track general usage trends that will not personally identify any user.

Device ID and Location. When you access or leave Tembiya.net, we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. We also receive data from your devices and networks, including location data. If you use Tembiya.net from a mobile device, that device will send us data about your device and GPS location based on your phone settings and access you have granted Tembiya.net.

We use this information to provide a tailored Tembiya.net experience for you and to communicate with you more effectively. The information is also collected to determine the aggregate number of unique devices using Tembiya.net and/or parts of Tembiya.net, track total usage, and analyze usage data to improve Tembiya.net functionality for all Members and Visitors. We may combine this information with information from third parties to provide you with a better experience and to improve the quality of our service.

We do not share any of your personally identifiable information along with your device identification or location without your explicit permission. When required by your device operating system or internet browser, we will ask you to opt-in before we use GPS or other tools to identify your precise location. However, we may automatically collect certain details of your use of Tembiya.net, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through Tembiya.net. We may collect information about your computer and mobile device and internet connection, including the mobile device’s unique device identifier, IP address, operating system, browser type, and mobile network information. If you do not want us to collect this information you should cease use of Tembiya.net.

Your Communications Directly To Us. We collect information about you when you send, receive, or engage with messages with us, including when you submit personal information or requests by emailing [CLTem at tembiya.net] or [info @ tembiya.net] or use the contact link at the bottom of this page. We retain those communications to process your inquiries, respond to your requests, and improve our services.

Personal Information. We may tie information we do collect automatically as described above to personal information you provide to us to tailor Tembiya.net to you and make suggestions about Tembiya.net services and functionality as described above. ABTem is consistently seeking new and improved ways to offer Tembiya.net and increase Tem language and Bible engagement. As we improve Tembiya.net, this may mean the collection of new data or new ways to use data. Because Tembiya.net is dynamic, and we continuously seek to offer new features, we may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

Third-party Information Collection

This Privacy Policy applies only to sites and apps that are owned and operated by ABTem. Please keep in mind that Tembiya.net may contain links to other websites or apps. You are responsible for reviewing the privacy statements and policies of those other websites you choose to link to or from Tembiya.net, so that you can understand how those websites collect, use and store your information. We are not responsible for the privacy statements, policies or content of other websites or apps, including websites you link to or from Tembiya.net. Websites containing co-branding (referencing our name and a third party’s name) contain content delivered by the third party and not us.

ABTem cannot regulate other sites, content, or applications linked or provided from within Tembiya.net and our various web sites and services. Some content or applications, including partner offers, on or in Tembiya.net may be served by third-parties, including content providers, application providers, analytics companies, your mobile device manufacturer, and your mobile service provider. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services. They may use this information to provide you with interest-based (behavioral) targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible provider directly.

Disclosure of Your Information

16. Disclosure on Your Behalf

We may disclose personal information that we collect or you provide as described in this Privacy Policy to fulfill our obligations, the purpose for which you provide it, for any other purpose you request when you provide the information, or for any other purpose for which we have your consent.

17. Disclosure by You

When you share information through Tembiya.net, that information is viewable by you and by anyone else you chose to share it with. If you give access to your Tembiya.net account to other applications and services, based on your approval, those services would then have access to your shared information. The use, collection and protection of your data by such third party services is subject to those third parties’ policies.

18. Internal Disclosure

We will share your personal data internally within ABTem to help combine the personal information covered across the different aspects of Tembiya.net and our other products and services to help provide services to you in a manner that is personalized and useful to you and others. For example, we can personalize potential services to recommend to you using cookies or similar technologies that track what functionality you have already opted to receive.

19. Disclosure to Our Service Providers

We may disclose personal information that we collect or you provide as described in this Privacy Policy to contractors, service providers and other third parties we use solely to support our mission (such as cloud hosting, maintenance, analysis, audit, payments, fraud detection, communication, and development). For example, some of the Tembiya.net platforms used to send emails and notifications are built and managed by third parties, so some of your information is sent securely to those services to provide such functionality. They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

20. Legal Process

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of Tembiya.net; or (5) exercise or protect the rights and safety of ABTem, our Members and/or Visitors, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority, but we do not promise to challenge every demand.

21. Your Rights to Deleting, Accessing and Correcting Your Information

For personal data that we have about you, you have the following rights:

• Deletion. You may ask us to erase or delete all or some of your personal data. Please note that doing so may limit your ability to use certain functionality of Tembiya.net. Please note that an email address is required to have a Member account.
• Correction/Modification: You may edit some of your personal data through your account or ask us to change, update, or fix your data in certain cases, including if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (for example, if we have no legal right to keep using it) or to limit our use of it (for example, if your personal data is inaccurate or unlawfully held).
• Right to Access and/or Take Your Data: You can ask us for a copy of your personal data you provided to us.

To make these or any other requests with respect to your personal information, you may send us an e-mail to  [CLTem at tembiya.net] or [info @ tembiya.net] or use the contact link at the bottom of this page. We ask that individuals making requests identify themselves and identify the information requested to be accessed, corrected or removed before we process any requests. We may decline to process requests if we cannot verify the requestor's identity, if we believe the request will jeopardize the privacy of others, if we believe the change would violate any law or legal requirement or cause the information to be incorrect, or for a similar legitimate purpose. In any case, where we provide information access, deletion or correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

If you choose to close your account or ask that we modify or delete some or all of your personal information, we will retain your personal data if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or fulfill any others requests from you (for example, to opt-out of further messages or for a copy of your data).

Use of Tembiya.net includes several functions, including selection of Bible reading plans, creating scripture bookmarks, highlighting certain portions of scripture, creating notes and moments concerning scripture, searching the Bible based on an emoji or keyword, saving and sharing certain verses and creating images from certain Biblical text. Unless you have included personally-identifiable information in content created with this functionality (such as a personal image or address or first and last name), content created with this functionality is not considered personal data by ABTem, as it generally concerns Bible text and content and not any one user specifically. As a result, ABTem reserves the right to maintain this information, including inferences made with this information after deletion of an account. For example, while we will delete your email address if your account is deleted, we will maintain and reserve the right to use and share what Bible verses were shared, highlighted, etc. by you in a manner that does not identify you personally. We will also retain our aggregate count of the number to total Tembiya.net applications downloaded which would include the fact of you downloading Tembiya.net without maintaining personal information associated with that account.

We have no control of information you have shared with others through Tembiya.net after you close your account or asked to delete information or attempted to delete your account yourself. Your information and content you have shared may continue to be displayed in the services of others (for example, search engine results) until they refresh their cache.

22. Notice to California Residents – California Privacy Rights

If you are a California resident and have provided us with personal information, California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (the “Act”) and the California Business and Professions Code. As required by the Act, we will provide you with the categories of personally identifiable information that we collect through Tembiya.net and the categories of third party persons or entities with whom such personally identifiable information may be shared for direct marketing purposes at your request. California law requires us to inform you, at your request, (1) the categories of personally identifiable information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. The Act further requires us to allow you to control who we can and cannot share that information with. To obtain this information, please send a request to [CLTem at tembiya.net] or [info @ tembiya.net] or use the contact link at the bottom of this page, and include the phrase “California Privacy Request” in the subject line. When contacting us, please indicate your name, address, email address, and what personally identifiable information you do not want us to share with third parties. Please allow thirty (30) days for a response. Also, please note that there is no charge for controlling the sharing of your personally identifiable information or requesting this notice.

23. Security and Protection

We implement industry standard security safeguards designed to protect your data. However, given the nature of communications and information technology, and that the use of the internet has inherent risks, although we regularly monitor for possible vulnerabilities and attack, we cannot warrant or guarantee that information provided to us through Tembiya.net or stored in our systems or otherwise will be absolutely free from unauthorized intrusion by others, nor can we warrant or guarantee that such data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

24. Processing of Data

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, such as providing Tembiya.net and Tembiya.net functionality you request and acting in accordance with this Privacy Policy) and other legitimate interests. Such legitimate interest include protection to you, us and other Members and third parties, to comply with applicable law, to enable and administer our business, to manage corporate transactions, to generally understand and improve our business and user relationships, and to enable us and other users of Tembiya.net to connect with you to exchange information, provided that the foregoing adequately protects your rights and freedoms.

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at [CLTem at tembiya.net] or [info @ tembiya.net] or use the contact link at the bottom of this page. 

25. Users From Outside Togo and USA

Tembiya.net is designed and launched from Togo but your use of Tembiya.net and this Privacy Policy is governed by the laws of the United States and the Republic of Togo. If you are using Tembiya.net from a different country, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated, but this data is also accessed and used for app improvement in Togo. We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. This includes contractual commitments between us and companies transferring personal data that require the protection and security of such data. The data protection and other laws in Togo, the United States, and other countries might not be as comprehensive as those in your country. By using Tembiya.net, you consent to your information being transferred to our facilities and to the facilities of those third-parties with whom we share it with as described in this Privacy Policy.

26. Changes to Our Privacy Policy

We may update our Privacy Policy from time to time to reflect changes in our practices. We will post any changes to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will provide a notice that the Privacy Policy has been updated. The date the Privacy Policy was last modified is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Policy to check for any changes.

27. Children Under the Age of 16

We do not collect personal information from any person we actually know is under the age of 16 without the consent of the parent or legal guardian of that minor. A parent or guardian may consent to the use of Tembiya.net by a minor, which parent or guardian is solely responsible for providing supervision of the minor’s use of Tembiya.net and assumes full responsibility for the interpretation and use of any information or suggestions provided through Tembiya.net. If you believe we might have any information from or about a child under 16, please contact us at [CLTem at tembiya.net] or [info @ tembiya.net] or use the contact link at the bottom of this page. If we learn and have confirmation we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.

28. Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, you may contact us at: [CLTem at tembiya.net] or [info @ tembiya.net] or use the contact link at the bottom of this page. 

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