KwayaPro Privacy Policy

The digital home for African church choirs

Last updated: September 26, 2026

1. Who this policy covers

This Privacy Policy explains how KwayaPro collects, uses, shares, and protects personal data when you use the KwayaPro mobile application and any related services (together, the “Service”). KwayaPro is operated by Simon Peter Kyagulanyi, an individual developer based in Nansana, Uganda.

KwayaPro is a choir management platform for church choirs, primarily in Uganda and East Africa. It helps choirs manage membership, rehearsal scheduling, attendance, learning-track audio, song programs, choir chat, and (for choirs on the Pro plan) subscription billing via MTN Mobile Money.

This policy applies to:

KwayaPro's user base today is Uganda only. If that changes, this policy will be updated accordingly.

2. Our role: data controller

For the personal data described in this policy, Simon Peter Kyagulanyi is the data controller — deciding what data is collected and why. Where third-party service providers (§6) process data on our behalf (Firebase/Google Cloud, MTN Mobile Money), those providers act as our data processors for that specific data.

Contact for privacy matters:
Email: [email protected]
Based in: Nansana, Uganda

No separate Data Protection Officer is currently appointed — as an individual developer operation, privacy inquiries are handled directly by Simon Peter Kyagulanyi at the email address above.

3. Information we collect

We collect the following categories of personal data. Each is tied to a specific feature — we do not collect data we don't have a concrete product reason to use.

3.1 Account and identity data

3.2 Choir membership data

3.3 Voice recordings (sensitive)

A recording of your singing voice is not the same as ordinary contact information — it can be used to identify you, and in some jurisdictions is treated similarly to biometric data. See §7 for exactly how consent works for this feature today. You can decline to have your voice recordings uploaded without losing access to the rest of the Service, though you may then rely on other members' recordings to learn your part instead.

3.4 Attendance and RSVP data

3.5 Data about you entered by other users

Choir Leaders/Directors may enter or reference information about you when scheduling rehearsals, marking attendance on your behalf, or messaging you in choir chat. If someone else in your choir enters data about you, this policy governs our handling of it the same way as data you enter yourself — but we are not able to verify its accuracy the way we can for self-reported data. Contact us (§14) if data about you entered by someone else is inaccurate.

3.6 Choir chat and communications

3.7 Payment data (Pro plan only)

3.8 Technical and diagnostic data

3.9 Data we do not collect

For clarity: KwayaPro does not currently collect precise device location, does not use third-party advertising trackers, and does not sell personal data to third parties (see §6.4).

4. How we use your information

PurposeData usedLegal basis (see §5)
Creating and securing your accountPhone/email, auth identifiersContract necessity
Operating choir membership, roles, and permissionsMembership dataContract necessity
Letting you learn your voice partVoice recordingsConsent (§7)
Scheduling and tracking rehearsalsAttendance/RSVP dataContract necessity
Choir communicationChat messages/attachmentsContract necessity
Processing Pro plan paymentsPhone number, transaction dataContract necessity
Sending you notifications you'd expect (reminders, messages)FCM token, notification contentContract necessity / consent (notification permission)
Diagnosing and fixing crashesCrash/device diagnosticsLegitimate interest
Preventing abuse (e.g., invite-code brute-forcing, payment spam)Request metadata, rate-limit countersLegitimate interest (security)
Complying with legal obligationsAs requiredLegal obligation

We do not use your data for automated decision-making that produces legal or similarly significant effects about you, and we do not use it to build advertising profiles.

5. Legal bases for processing

Depending on the data and purpose, we rely on:

  1. Performance of a contract — most of KwayaPro's core functionality (membership, attendance, chat, scheduling) is data processing necessary to provide the Service you or your choir signed up for.
  2. Consent — specifically for voice recordings (§7) and any purpose beyond what's needed to run the Service. You can withdraw consent at any time (§8); this doesn't affect processing already carried out under consent given before withdrawal.
  3. Legitimate interests — for security, fraud/abuse prevention, and diagnosing technical problems, balanced against your right not to have your data used in ways you wouldn't reasonably expect.
  4. Legal obligation — where a law (including Uganda's Data Protection and Privacy Act, 2019, or applicable tax/financial-recordkeeping law for Pro plan payments) requires us to retain or disclose specific data.

6. Who we share your information with

We do not sell your personal data. We share data only as follows:

6.1 Service providers (data processors)

We use Google Firebase / Google Cloud Platform to host and run KwayaPro's backend:

These providers process this data on our behalf, under their own data processing terms, and we have configured access controls so that, for example, one choir cannot read another choir's data.

6.2 MTN Mobile Money

For Pro plan subscriptions, we send your phone number and the payment amount to MTN Uganda's Mobile Money Collections API to initiate a payment request. MTN then handles authorization directly with you (via their own app, USSD, or SIM toolkit flow) and returns a transaction result to us. MTN's own privacy practices govern their handling of this data during that process — see MTN Uganda's own privacy policy on their website.

6.3 International data transfers

Because our infrastructure runs on Google Cloud and Cloudflare, your data is processed outside Uganda regardless of where our users are. Our Cloud Functions, and the Firestore instances they read and write, run in Google Cloud's us-central1 region (Iowa, USA); audio and image files are stored on Cloudflare's global network. We rely on our providers' own contractual safeguards for cross-border data processing as part of our agreement with them.

6.4 What we don't do

6.5 Legal disclosures

We may disclose personal data if required to by law, court order, or governmental request, or where necessary to protect the rights, property, or safety of KwayaPro, our users, or the public.

7. Voice recording consent

Because a voice recording is more sensitive than ordinary profile data, here is exactly what happens today when you use the Studio recording feature or upload a voice-part recording:

  1. Recording audio requires your device's own microphone permission, which Android/iOS will prompt you for the first time the app tries to record. No recording happens without this OS-level permission being granted.
  2. Choosing to record and upload a voice-part track is itself how you give consent for that recording to be used as a learning aid and shared with other members of your choir — there is not currently a separate in-app consent screen beyond this action and the OS permission prompt.
  3. Recordings are only accessible to members of the same choir, enforced by our server-side access rules — not publicly accessible.
  4. You (or, for a recording someone uploaded on your behalf as part of choir administration, your choir's Director/Leader) can delete an uploaded recording at any time. Withdrawing consent going forward means the recording is removed and no longer shared, though we can't retroactively erase a copy another member may have already listened to, downloaded, or cached locally before removal.

We may add a more explicit, separate consent step before recording in a future update; this section will be updated to match if we do.

8. Your rights

Depending on applicable law (including Uganda's Data Protection and Privacy Act, 2019), you have the right to:

  1. Access — request a copy of the personal data we hold about you.
  2. Rectification — ask us to correct inaccurate or incomplete data.
  3. Erasure ("right to be forgotten") — ask us to delete your personal data, subject to §8.1 below.
  4. Restriction — ask us to limit how we use your data in certain circumstances.
  5. Objection — object to processing based on legitimate interests.
  6. Portability — request your data in a portable format, where technically feasible.
  7. Withdraw consent — for any processing based on consent (notably voice recordings, §7), at any time, without affecting the lawfulness of processing before withdrawal.
  8. Complain — lodge a complaint with Uganda's Personal Data Protection Office (PDPO), or the relevant supervisory authority in your jurisdiction, if you believe we've mishandled your data.

To exercise any of these rights, contact us at [email protected]. We will respond within a reasonable time, and in any event within the timeframe required by applicable law.

8.1 What "erasure" actually means for a shared choir record

When you request account deletion, in the app (Profile → Delete Account), we apply different handling depending on the kind of data involved, because some of it is shared with other choir members in ways that a blanket delete would silently break for them:

In short: data that is fundamentally about you and only you (your identity, your recorded voice) is deleted outright. Data that is a shared choir record you merely participated in has your personal identity stripped out but the record itself preserved for the choir's continuity. This deletion is a genuine, irreversible operation once triggered, and can only be initiated by you, authenticated as the account owner — not by anyone else on your behalf, including choir Leaders.

If you're a choir's Leader, account deletion is blocked until you transfer leadership to another member — a self-service in-app flow (Members & Roles → hand off leadership), since a choir needs someone able to manage billing, members, and roles at all times. Once a transfer is accepted, the former Leader's account deletion proceeds normally.

9. Data security

We use industry-standard measures appropriate to the sensitivity of the data involved, including:

No system is perfectly secure. If we become aware of a data breach affecting your personal data, we will notify affected users and, where required by law, the relevant supervisory authority, without undue delay.

10. Children's data

KwayaPro is intended for use by adults only. You must be at least 18 years old to create an account or otherwise use the Service. We do not knowingly collect personal data from anyone under 18, including voice recordings. If we become aware that we've collected data from someone under 18, we will delete it.

This is a policy stance, not a technical age-verification mechanism — the Service does not currently ask for or confirm your age at signup. If you are a choir Leader considering onboarding members under 18 (e.g., a youth choir), the Service is not yet built for that and you should not add them as individual account holders under this policy.

11. Data retention

Data categoryRetention
Account/profile dataUntil you request account deletion (§8.1), then permanently deleted
Choir membership recordsUntil you leave the choir or delete your account
Voice recordingsUntil deleted by an authorized uploader, or permanently deleted upon your account deletion (§8.1)
Attendance/RSVP recordsRetained for the life of the choir's account; anonymized upon your account deletion (§8.1)
Chat messagesRetained for the life of the choir's account; anonymized upon your account deletion (§8.1)
Payment/transaction recordsRetained as required by applicable Ugandan tax and financial record-keeping law
Crash/diagnostic dataPer Firebase Crashlytics' default retention period (typically around 90 days)

12. Cookies and similar technologies

KwayaPro is a mobile app, not a website with cookie-based tracking. We do not use advertising cookies or cross-app tracking. Our web pages at kwayapro.app (this policy and our invite-link landing pages) do not run any analytics or tracking scripts.

13. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you via an in-app notice or push notification before the changes take effect, and update the "Last updated" date above. Continued use of the Service after changes take effect constitutes acceptance of the updated policy, except where a change requires fresh consent (e.g., a new use of voice recordings), in which case we will ask for it explicitly.

14. Contact us

Questions, requests, or complaints about this policy or our data practices:

If you're not satisfied with our response, Uganda's Personal Data Protection Office (PDPO) is the relevant supervisory authority for complaints about the handling of personal data in Uganda.