Privacy Policy

Section 1 – Introduction & Scope

This Privacy Policy explains how Champion Ministries, Inc., d/b/a Groundwire (“Groundwire,” “we,” “us,” “our”) collects, uses, stores, shares, and protects personal information when you access or use any of our websites, subsites, mobile applications, chat platforms, or digital services (collectively, the “Services”).

This Privacy Policy applies to all Groundwire operated digital properties, including but not limited to:

• Groundwire.net
• ChasingChrist.online
• JesusCares.com
• aJesusLeImporta.com
• Any additional websites, subsites, or digital platforms operated now or in the future

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

1.1 Who We Are

Groundwire is a nonprofit Christian ministry registered as:

• A 501(c)(3) organization in the United States
• A recognized charitable organization in the United Kingdom

Groundwire operates multiple digital platforms designed to offer spiritual encouragement, faith based content, and opportunities for users to engage in live interactions with trained volunteers (“Coaches”).

1.2 Cross Jurisdictional Application

Groundwire operates from the United States but serves users worldwide. This Privacy Policy is designed to comply with:

• U.S. federal and state privacy standards
• The U.K. General Data Protection Regulation (UK GDPR)
• The U.K. Data Protection Act 2018
• Applicable international data protection principles

Where privacy rights differ by jurisdiction, we apply the protections required by the laws applicable to your location. If any provision of this Privacy Policy conflicts with mandatory rights under U.K. law, those U.K. rights prevail for U.K. users.

1.3 Who This Policy Applies To

This Privacy Policy applies to:

• Visitors to our Sites
• Users who engage in chat or messaging features
• Individuals who submit prayer requests, questions, or forms
• Individuals who create accounts or provide contact information
• Donors who give financially through our Sites
• Individuals who interact with Groundwire through email, SMS, or other communication channels

This Privacy Policy does not apply to:

• Third party websites or platforms linked from our Sites
• Third party services integrated into the Sites
• Employees, contractors, or volunteers acting in an official capacity (covered by internal policies)

1.4 Children’s Privacy

Groundwire does not knowingly collect personal data from:

• Children under 14 in the United States
• Children under 13 in the United Kingdom

If we learn that personal data has been collected from a child below these age thresholds, we will delete it promptly.

Groundwire does not offer services intended for children, and we do not knowingly solicit or process children’s data.

1.5 Acceptance of This Policy

By using the Services, you consent to the collection, use, and processing of your information as described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, you must discontinue use of the Services.

1.6 Relationship to the Terms & Conditions

This Privacy Policy is incorporated into and forms part of our Terms & Conditions. If there is any conflict between the Terms & Conditions and this Privacy Policy regarding the handling of personal data, this Privacy Policy controls.

Section 2 – Information We Collect

Groundwire collects information that you voluntarily provide, information automatically collected through your use of the Services, and information received from third party partners who support our ministry operations. The types of information we collect depend on how you interact with our Sites and Services.

2.1 Information You Provide Directly

We may collect personal information that you voluntarily submit through the Sites, including:

2.1.1 Contact Information

• Name
• Email address
• Phone number
• Mailing address (if provided)

Used for communication, follow up, donor receipts, and ministry engagement.

2.1.2 Chat and Message Content

When you engage in live chat or submit forms, we collect:

• Messages you send to Coaches
• Prayer requests
• Questions or comments
• Any information you choose to share

Important: Chat interactions are intended for spiritual encouragement, not professional counseling. You should avoid submitting sensitive personal information unless necessary.

2.1.3 Donation Information

If you make a financial contribution, we collect:

• Donation amount
• Payment method (processed securely by third party payment processors)
• Billing information
• Donation history

Groundwire does not store full credit card numbers or bank account details. All payment processing is handled by PCI compliant third party providers.

2.1.4 Account Information

If you create an account on any Groundwire platform, we may collect:

• Username
• Password (encrypted)
• Profile details you choose to provide

2.1.5 Communication Preferences

We collect information about:

• Email subscription choices
• SMS opt ins
• Notification settings

2.2 Information Collected Automatically

When you use the Sites, we automatically collect certain technical information to improve functionality, security, and user experience.

2.2.1 Device & Technical Data

• IP address
• Browser type and version
• Device type and operating system
• Language settings
• Time zone

2.2.2 Usage Data

Such Usage Data includes but is not necessarily limited to:

• Pages visited
• Links clicked
• Time spent on pages
• Referring URLs
• Interaction logs (e.g., chat timestamps)

This information helps us maintain site performance, security, and analytics.

2.2.3 Cookies & Similar Technologies

We use cookies, pixels, and similar tools to:

• Maintain session functionality
• Remember preferences
• Improve site performance
• Analyze usage patterns

Users may adjust cookie settings through their browser or device.

2.3 Information from Third Party Sources

We may receive information from:

• Donation processors
• Email service providers
• Analytics platforms
• Ministry partners who support operational functions

This information is used solely for ministry operations, donor stewardship, analytics, and compliance.

2.4 Sensitive Information

Groundwire does not request or require sensitive personal data such as:

• Government identification numbers
• Medical or health records
• Financial account numbers
• Information about minors

If you voluntarily submit sensitive information through chat or forms, you do so at your own discretion. We strongly encourage users not to share unnecessary sensitive information.

2.5 Children’s Data

We do not knowingly collect personal information from:

• Children under 14 in the United States
• Children under 13 in the United Kingdom

If such information is discovered, it will be deleted promptly.

Section 3 – How We Use Your Information (Purposes & Legal Bases)

Groundwire uses the information we collect to operate our ministry, provide spiritual encouragement, maintain the security and functionality of our Sites, process donations, and comply with legal obligations. The specific purposes for which we use personal information are outlined below.

Where required by law (including UK GDPR), we also identify the legal bases that permit us to process personal data.

3.1 To Provide and Operate the Services

We use personal information to:

• Deliver site content
• Facilitate live chat interactions
• Respond to prayer requests or questions
• Provide follow up communication when appropriate
• Maintain account functionality

Legal bases (UK GDPR):

• Performance of a contract (Article 6(1)(b))
• Legitimate interests (Article 6(1)(f)) – providing spiritual support and maintaining platform functionality

3.2 To Communicate With You

We may use your information to:

• Respond to inquiries
• Send ministry updates or newsletters (with consent where required)
• Provide donor receipts or confirmations
• Notify you of changes to our policies or services

Legal bases:

• Consent (Article 6(1)(a))
• Legitimate interests (Article 6(1)(f)) – ensuring effective communication with users and donors
• Legal obligation (Article 6(1)(c)) – for donor receipts and required notices

3.3 To Facilitate Donations and Donor Stewardship

If you make a financial contribution, we use your information to:

• Process your donation
• Provide tax receipts
• Maintain donation history
• Comply with nonprofit reporting requirements
• Communicate with you about donor related matters

Legal bases:

• Performance of a contract (Article 6(1)(b))
• Legal obligation (Article 6(1)(c)) – nonprofit compliance
• Legitimate interests (Article 6(1)(f)) – donor stewardship and financial accountability

3.4 To Improve and Secure the Sites

We use technical and usage data to:

• Monitor site performance
• Diagnose technical issues
• Prevent fraud or abuse
• Enhance user experience
• Analyze trends and usage patterns

Legal bases:

• Legitimate interests (Article 6(1)(f)) – ensuring security, stability, and improvement of the Services

3.5 To Maintain Safety and Integrity

We may use information to:

• Protect users and volunteers
• Detect harmful, abusive, or unlawful behavior
• Enforce age restrictions
• Comply with safety related legal obligations
• Respond to misuse of the Services

Legal bases:

• Legitimate interests (Article 6(1)(f)) – protecting users and the ministry
• Legal obligation (Article 6(1)(c))

3.6 To Comply With Legal and Regulatory Requirements

We may process personal information to:

• Respond to lawful requests from authorities
• Maintain nonprofit compliance
• Fulfill tax, audit, or reporting obligations
• Enforce our Terms & Conditions

Legal bases:

• Legal obligation (Article 6(1)(c))
• Legitimate interests (Article 6(1)(f)) – protecting our legal rights

3.7 With Your Consent

In certain cases, we process information only with your explicit consent, such as:

• Email newsletters
• SMS communications
• Certain cookie categories (where required)
• Optional surveys or feedback submissions

You may withdraw consent at any time, as described in Section 9.

3.8 No Automated Decision Making

Groundwire does not use personal information for:

• Automated decision making
• Profiling that produces legal or significant effects

Section 4 – How We Share Your Information

Groundwire does not sell your personal information. We share information only when necessary to operate our ministry, provide the Services, comply with legal obligations, or protect users and the organization. Any sharing is limited, controlled, and consistent with this Privacy Policy.

4.1 Service Providers and Ministry Partners

We may share personal information with trusted third party service providers who assist us in operating the Services, including:

• Website hosting and infrastructure
• Chat platform providers
• Email and SMS communication tools
• Donation and payment processors
• Analytics and performance tools
• Security and fraud prevention services
• Data storage and backup providers

These providers may access personal information only to perform services on our behalf and are contractually required to:

• Protect your information
• Use it only for the purposes we specify
• Comply with applicable U.S. and U.K. privacy laws

Groundwire does not authorize service providers to use your information for their own marketing or commercial purposes.

4.2 Donation Processing

When you make a financial contribution, your payment information is processed by secure, PCI compliant third party payment processors. We may share:

• Name
• Billing address
• Donation amount
• Email address (for receipts)

Groundwire does not store full credit card numbers or bank account details.

4.3 Legal, Safety, and Compliance Requirements

We may disclose personal information when necessary to:

• Comply with applicable laws, regulations, or legal processes
• Respond to lawful requests from government authorities
• Protect the rights, safety, and security of users, volunteers, staff, or the public
• Enforce our Terms & Conditions
• Detect, prevent, or address fraud, abuse, or security issues

We evaluate all requests carefully and disclose only what is legally required.

4.4 Internal Ministry Operations

Personal information may be shared within Groundwire for:

• Operational support
• Donor stewardship
• Ministry coordination
• Training and quality assurance
• Safety and compliance

Access is limited to authorized personnel and volunteers who require the information to perform their roles.

4.5 Aggregated or De‑Identified Information

We may share aggregated, anonymized, or de‑identified information that cannot reasonably be used to identify an individual. Examples include:

• Usage statistics
• Site performance metrics
• General demographic trends

This information is used for analytics, reporting, and improving the Services.

4.6 Third Party Integrations

Some features of the Sites may integrate with third party platforms (e.g., embedded videos, analytics tools, or communication systems). These third parties may collect information directly from you according to their own privacy policies.

Groundwire does not control third party data practices and encourages users to review those policies.

4.7 No Sale of Personal Information

Groundwire does not:

• Sell personal information
• Rent personal information
• Exchange personal information for commercial gain

This applies to all users, including U.S. residents, U.K. residents, and donors.

4.8 International Data Transfers

Because Groundwire operates globally, personal information may be transferred to:

• The United States
• The United Kingdom
• Other jurisdictions where our service providers operate

When transferring data internationally, we use appropriate safeguards, such as:

• Standard Contractual Clauses (SCCs)
• Data processing agreements
• Security and encryption measures

These safeguards ensure compliance with UK GDPR and other applicable laws.

Section 5 – Data Retention

Groundwire retains personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, maintain accurate financial and donor records, and support the operational needs of our ministry.

Retention periods vary depending on the type of information and the context in which it is collected.

5.1 General Retention Principles

We retain personal information based on:

• The purpose for which it was collected
• Legal, regulatory, and nonprofit compliance requirements
• Operational needs (e.g., safety, fraud prevention, donor stewardship)
• User expectations and consent
• Technical limitations and system architecture

When information is no longer needed, we securely delete, anonymize, or de‑identify it.

5.2 Chat and Communication Records

Messages submitted through live chat, prayer requests, or contact forms may be retained for:

• Training and quality assurance
• Safety and risk management purposes
• Operational support
• Compliance with legal obligations

Where required by law, we may delete or anonymize chat records upon request, unless retention is necessary for safety, legal, or operational reasons.

5.3 Donor and Financial Records

Donation related information is retained to:

• Provide tax receipts
• Maintain accurate financial records
• Comply with U.S. and U.K. nonprofit reporting requirements
• Support donor stewardship

Financial records are retained for the period required by applicable law, including:

• U.S. IRS regulations
• U.K. Charity Commission and HMRC requirements

Groundwire does not store full credit card numbers or bank account details.

5.4 Account Information

If you create an account on any Groundwire platform:

• Account information is retained while your account is active
• If you request deletion, we will remove or anonymize your account information unless retention is required by law or necessary for safety or operational reasons

Some residual data may remain in backups for a limited period due to technical constraints.

5.5 Technical and Usage Data

Technical logs, analytics data, and security related information may be retained to:

• Maintain site performance
• Detect and prevent fraud or abuse
• Improve user experience
• Support operational analytics

This data is typically retained for shorter periods and may be anonymized or aggregated.

5.6 Legal and Compliance Retention

We may retain information for longer periods when necessary to:

• Comply with legal obligations
• Respond to legal requests or investigations
• Enforce our Terms & Conditions
• Protect the safety and integrity of the Services

Retention periods may vary depending on jurisdictional requirements.

5.7 Deletion and Anonymization

When personal information is no longer required:

• It is securely deleted, or
• It is anonymized so it can no longer be linked to an identifiable individual

Anonymized data may be retained for analytics, reporting, or operational improvement.

Section 6 – Data Security

Groundwire is committed to protecting the personal information entrusted to us. We implement administrative, technical, and physical safeguards designed to secure your information from unauthorized access, disclosure, alteration, or destruction.

While no online system can guarantee absolute security, we take reasonable and appropriate measures to protect your data.

6.1 Technical Safeguards

We use industry standard security technologies, including:

• Encrypted connections (HTTPS/TLS)
• Secure data transmission
• Firewalls and intrusion detection systems
• Access control mechanisms
• Regular security patching and updates
• Encrypted password storage

These measures help protect information during transmission and storage.

6.2 Administrative Safeguards

We limit access to personal information to authorized personnel and volunteers who require it to perform their roles. Administrative safeguards include:

• Role based access controls
• Confidentiality agreements
• Staff and volunteer training
• Monitoring and audit logs
• Policies governing data handling and retention

Groundwire staff and volunteers are trained to handle personal information responsibly and in accordance with this Privacy Policy.

6.3 Physical Safeguards

Where applicable, we protect physical systems and environments through:

• Secure facilities
• Restricted access to servers and storage systems
• Environmental controls
• Backup and recovery procedures

These safeguards help prevent unauthorized physical access to data.

6.4 Third Party Security

When we use third party service providers (e.g., hosting, payment processing, analytics), we require them to:

• Maintain appropriate security measures
• Protect personal information
• Comply with applicable U.S. and U.K. privacy laws
• Process data only according to our instructions

We do not authorize third party providers to use your information for their own purposes.

6.5 No Guarantee of Absolute Security

While we strive to protect your information, no method of transmission or storage is completely secure. You acknowledge that:

• You provide information at your own discretion
• Online communication carries inherent risks
• We cannot guarantee absolute protection against unauthorized access or breaches

If a data breach occurs, we will notify affected users in accordance with applicable laws, including UK GDPR and U.S. state breach notification requirements.

6.6 User Responsibilities

You are responsible for:

• Using secure devices and updated software
• Protecting your account credentials
• Avoiding the submission of unnecessary sensitive information
• Not sharing passwords or login details with others

If you believe your information has been compromised, please contact us immediately using the information in Section 12.

Section 7 – Questions or Suggestions

Depending on your location and applicable law, you may have certain rights regarding your personal information. Groundwire is committed to honoring these rights and providing clear, accessible ways to exercise them.

These rights apply to all users where required by law, including residents of the United Kingdom and certain U.S. states.

7.1 Rights for U.K. Users (UK GDPR & Data Protection Act 2018)

If you are located in the United Kingdom, you have the following rights:

7.1.1 Right of Access

You may request a copy of the personal information we hold about you.

7.1.2 Right to Rectification

You may request correction of inaccurate or incomplete information.

7.1.3 Right to Erasure (“Right to Be Forgotten”)

You may request deletion of your personal information when:

• It is no longer needed
• You withdraw consent
• You object to processing
• We processed it unlawfully

This right may be limited when retention is required for legal or safety reasons.

7.1.4 Right to Restrict Processing

You may request that we limit how your information is used.

7.1.5 Right to Object

You may object to processing based on:

• Legitimate interests
• Direct marketing

We will honor objections unless we have compelling legal grounds.

7.1.6 Right to Data Portability

You may request your information in a structured, commonly used, machine readable format.

7.1.7 Right to Withdraw Consent

You may withdraw consent at any time.

7.1.8 Right to Lodge a Complaint

You may file a complaint with the U.K. Information Commissioner’s Office (ICO).

7.2 Rights for U.S. Users

While U.S. privacy laws vary by state, Groundwire voluntarily extends certain rights to U.S. users where feasible, including:

7.2.1 Access and Correction

You may request:

• A copy of your personal information
• Corrections to inaccurate or incomplete information

7.2.2 Deletion

You may request deletion of your personal information, subject to:

• Legal obligations
• Donor record retention requirements
• Safety and fraud prevention needs

7.2.3 Opt Out of Communications

You may opt out of:

• Email newsletters
• SMS messages
• Promotional communications

Operational or safety related communications may still be sent where permitted by law.

7.2.4 Donor Privacy

Groundwire does not sell or share donor information for marketing purposes.

7.3 How to Exercise Your Rights

You may submit a request to exercise your rights by contacting us using the information in Section 12 of this Privacy Policy.

To protect your information, we may need to:

• Verify your identity
• Request additional details
• Decline requests that are unlawful or compromise the safety of others

We will respond within the timeframe required by applicable law.

7.4 Limitations on Rights

Your rights may be limited when:

• We must retain information for legal, financial, or safety reasons
• Requests would compromise the privacy of others
• Requests are manifestly unfounded or excessive
• Technical limitations prevent immediate deletion

We will explain any limitations that apply.

Section 8 – Cookies & Tracking Technologies

Groundwire uses cookies and similar technologies to provide, secure, and improve the Services. Cookies help us understand how users interact with our Sites, personalize content, maintain session functionality, and support essential operations such as analytics and security.

Where required by law (including in the United Kingdom), we obtain consent before placing non essential cookies on your device.

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They allow the website to recognize your device and remember certain information about your visit.

Cookies may be:

• Session cookies (deleted when you close your browser)
• Persistent cookies (stored until they expire or are deleted)
• First party cookies (set by Groundwire)
• Third party cookies (set by external service providers)

8.2 Types of Cookies We Use

8.2.1 Strictly Necessary Cookies

These cookies are essential for the Sites to function and cannot be disabled. They support:

• Page navigation
• Security features
• Session management
• Basic functionality

Legal basis: Legitimate interests (ensuring the Sites function properly).

8.2.2 Performance & Analytics Cookies

These cookies help us understand how users interact with the Sites, including:

• Pages visited
• Time spent on pages
• Click patterns
• Technical performance

We use this information to improve site functionality and user experience.

Legal basis: Consent (UK users); Legitimate interests (U.S. users).

8.2.3 Functional Cookies

These cookies remember your preferences, such as:

• Language settings
• Display preferences
• Saved form inputs

Legal basis: Consent (where required); Legitimate interests (enhancing user experience).

8.2.4 Marketing & Communication Cookies

Groundwire does not use invasive advertising trackers. However, we may use limited tools to:

• Measure the effectiveness of ministry campaigns
• Track engagement with emails or content
• Support donor related communications

Legal basis: Consent (UK users); Legitimate interests (U.S. users).

8.3 Third Party Cookies

Some cookies are placed by trusted third party partners, including:

• Analytics providers
• Chat platform providers
• Video hosting services
• Email and SMS communication tools
• Donation processors

These partners may collect information directly according to their own privacy policies.

Groundwire does not permit third parties to use cookies for their own marketing purposes on our Sites.

8.4 Cookie Controls

You may manage or disable cookies through:

• Your browser settings
• Device settings
• Cookie consent tools (where available)

If you disable certain cookies, some features of the Sites may not function properly.

8.5 Do Not Track (DNT) Signals

Some browsers offer a “Do Not Track” feature. Groundwire does not currently respond to DNT signals because:

• There is no industry standard interpretation
• Many essential functions rely on basic tracking

We continue to monitor developments in this area.

8.6 Other Tracking Technologies

We may use additional tools such as:

• Pixels
• Tags
• Local storage
• Server logs

These technologies help us:

• Maintain security
• Analyze performance
• Improve user experience

They operate similarly to cookies and are governed by this Privacy Policy.

Section 9 – Consent & Communication Preferences

Groundwire processes certain types of personal information based on your consent. When consent is required by law, we obtain it clearly and transparently. You may withdraw your consent at any time, and we provide simple ways to manage your communication preferences.

9.1 When We Rely on Consent

We rely on your explicit consent for the following types of processing:

• Email newsletters or ministry updates
• SMS/text messaging
• Certain cookie categories (where required by law)
• Optional surveys, testimonials, or feedback submissions
• Any processing that is not strictly necessary for the operation of the Services

Consent is always voluntary, and declining consent will not affect your ability to use the core features of the Sites.

9.2 How We Obtain Consent

Consent may be obtained through:

• Checkbox selections
• Opt in forms
• SMS confirmation messages
• Cookie consent banners
• Written or electronic acknowledgments

We do not use pre checked boxes or implied consent where explicit consent is required (e.g., under UK GDPR).

9.3 Withdrawing Consent

You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before the withdrawal.

You may withdraw consent by:

• Clicking “unsubscribe” links in emails
• Replying “STOP” to SMS messages (where applicable)
• Adjusting cookie settings in your browser or device
• Contacting us using the information in Section 12

Once consent is withdrawn, we will stop the related processing unless another lawful basis applies.

9.4 Email Preferences

You may choose to:

• Subscribe to ministry updates
• Unsubscribe from newsletters
• Adjust the types of emails you receive

We honor email opt out requests promptly and in accordance with applicable laws. Operational or safety related communications may still be sent where permitted by law.

9.5 SMS/Text Messaging Preferences

If you opt in to receive SMS messages:

• You may withdraw consent at any time by replying “STOP”
• Message and data rates may apply
• We do not send SMS messages without explicit opt in consent

We do not use SMS for crisis intervention or emergency response.

9.6 Cookie Preferences

Where required by law (including in the United Kingdom), you may:

• Accept or reject non essential cookies
• Adjust cookie settings at any time
• Withdraw cookie consent through browser or device controls

Essential cookies cannot be disabled because they are necessary for the Sites to function.

9.7 Donor Communication Preferences

Donors may choose:

• Whether to receive donor related updates
• Whether to receive fundraising appeals
• Whether to remain anonymous

Groundwire does not sell or share donor information for marketing purposes.

9.8 Limitations on Withdrawal

In some cases, we may continue processing your information after consent is withdrawn when:

• Required by law
• Necessary for nonprofit financial records
• Needed for safety, fraud prevention, or abuse detection
• Required to enforce our Terms & Conditions

We will explain any limitations that apply.

Section 10 – Third‑Party Websites & External Links

The Sites may contain links to third party websites, applications, platforms, or services that are not owned or controlled by Groundwire. This Privacy Policy applies only to Groundwire operated Sites and Services.

We are not responsible for the privacy practices, content, security, or policies of third party websites.

10.1 No Control Over Third Party Practices

When you click a link to a third party website or interact with embedded third party content, you may be providing information directly to that third party.

Groundwire does not:

• Control third party data collection practices
• Endorse or guarantee third party privacy standards
• Monitor third party security measures
• Assume responsibility for third party content or services

Your interactions with third party websites are governed by their own privacy policies and terms.

10.2 Types of Third Party Integrations

Third party services may include:

• Embedded videos or media players
• Social media integrations
• Analytics tools
• Payment processors
• Email or SMS delivery services
• Chat platform providers
• Ministry partners providing operational support

These third parties may collect information directly from you according to their own policies.

10.3 Donation Processing

When you make a donation, your payment information is processed by secure, PCI compliant third party payment processors.

These processors may collect:

• Name
• Billing address
• Payment method
• Donation amount

Groundwire does not store full credit card numbers or bank account details.

10.4 External Links Shared by Users

If users share links within chat or other submission features:

• Groundwire does not verify or endorse such links
• You access user shared links at your own risk
• We may remove or block links that are unsafe or inappropriate

This protects users and maintains a safe ministry environment.

10.5 Responsibility for Reviewing Third Party Policies

We strongly encourage you to review the privacy policies and terms of any third party website you visit.

You are responsible for understanding:

• What information third parties collect
• How they use and share that information
• Their security practices
• Their cookie and tracking policies
• Their data retention and deletion practices

Groundwire cannot guarantee the privacy or security of information you provide to third parties.

10.6 Third Party Advertising

Groundwire does not sell personal information to advertisers and does not host invasive advertising networks.

If any sponsored or partnered content appears on our Sites, it will be clearly identified and governed by this Privacy Policy and our Terms & Conditions.

Section 11 – International Data Transfers

Groundwire operates from the United States and serves users worldwide. As a result, personal information may be transferred to, stored in, or processed in countries other than your own, including the United States and the United Kingdom.

We take steps to ensure that all international data transfers comply with applicable privacy laws, including UK GDPR and U.S. nonprofit standards.

11.1 Why Your Information May Be Transferred

We may transfer personal information internationally for reasons such as:

• Operating and hosting our websites
• Facilitating live chat and communication tools
• Processing donations
• Storing data in secure cloud environments
• Using third party service providers located in other countries
• Providing support, analytics, or operational services

These transfers are necessary for Groundwire to provide the Services globally.

11.2 Transfers to the United States

If you are located outside the United States, your personal information may be transferred to and processed in the U.S., where data protection laws may differ from those in your home country.

We protect such transfers through:

• Contractual safeguards
• Security measures
• Limited access controls
• Data processing agreements with service providers

11.3 Transfers from the United Kingdom

For users located in the U.K., we comply with the requirements of:

• The U.K. General Data Protection Regulation (UK GDPR)
• The Data Protection Act 2018

When transferring personal information outside the U.K., we rely on:

• Standard Contractual Clauses (SCCs) approved by the U.K.
• International Data Transfer Addendums (IDTAs)
• Appropriate safeguards required by law

These mechanisms ensure that your information receives a level of protection essentially equivalent to U.K. standards.

11.4 Transfers by Third Party Service Providers

Some of our trusted service providers may process data in multiple jurisdictions. We require all such providers to:

• Use appropriate legal transfer mechanisms
• Protect your information with strong security measures
• Process data only according to our instructions
• Comply with applicable U.S. and U.K. privacy laws

We do not authorize service providers to use your information for their own purposes.

11.5 Your Rights Regarding International Transfers

Depending on your location, you may have the right to:

• Request information about international transfers
• Understand the safeguards we use
• Obtain a copy of applicable transfer mechanisms (where legally permissible)

You may exercise these rights using the contact information in Section 12.

11.6 Risks of International Transfers

While we take reasonable steps to protect your information, international transfers may involve risks such as:

• Different privacy laws
• Varying levels of government access
• Differences in enforcement mechanisms

Groundwire mitigates these risks through contractual, technical, and organizational safeguards.

Section 12 – Contact Information

If you have questions about this Privacy Policy, need to exercise your privacy rights, or wish to contact us regarding any aspect of your personal information, you may reach us using the details below.

Groundwire is the parent organization responsible for all data processing activities across our Sites and Services.

12.1 United States Contact Information

Champion Ministries, Inc. d/b/a Groundwire
Attn: Privacy & Data Protection
P.O. Box 1323 Castle Rock, CO 80104
United States
Phone: (303) 660 3582
Email: info@groundwire.net

This contact information may be used for:

• Privacy rights requests
• Questions about data use
• Donor related inquiries
• Concerns about chat interactions
• Requests for correction or deletion of personal information

12.2 United Kingdom Contact Information

For users located in the United Kingdom, Groundwire maintains a charitable presence and provides a dedicated contact point for privacy related matters.

Groundwire UK
Attn: UK Data Protection
[Insert UK mailing address]
Phone (303) 660‑3582
Email: info@groundwire.net

12.3 Exercising Your Rights

To exercise your privacy rights (access, correction, deletion, objection, portability, or consent withdrawal), please contact us using the information above.

To protect your information, we may:

• Verify your identity
• Request additional details
• Decline requests that are unlawful or compromise the safety of others

We respond within the timeframe required by applicable law.

12.4 Reporting a Security or Privacy Concern

If you believe:

• Your information has been accessed without authorization
• You received a suspicious communication claiming to be from Groundwire
• You have identified a potential vulnerability

Please notify us immediately at info@groundwire.net. We take all reports seriously and will investigate promptly.

Section 13 – Changes to This Privacy Policy

Groundwire may update or modify this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make updates, we do so transparently and in a way that allows you to stay informed about how your information is handled.

13.1 How We Provide Notice of Changes

When this Privacy Policy is updated, we will:

• Post the revised version on our Sites
• Update the “Last Updated” date at the top of the Policy
• Provide additional notice when required by law (e.g., email or banner notification for material changes)

Your continued use of the Sites after changes are posted constitutes acceptance of the updated Privacy Policy.

13.2 Material Changes

If we make material changes — meaning changes that significantly affect:

• What information we collect
• How we use or share information
• Your privacy rights
• Your choices or consent options

— we will provide clear, prominent notice and, where required, request renewed consent.

13.3 Non‑Material Changes

Non‑material updates may include:

• Clarifications
• Reorganization of content
• Updates to terminology
• Improvements to readability
• Corrections of minor errors

These updates will be posted without additional notice.

13.4 Your Responsibility to Review Updates

We encourage you to review this Privacy Policy periodically, so you remain informed about:

• How your information is used
• Your rights and choices
• Any changes in our data handling practices

If you do not agree with any updates, you must discontinue use of the Sites and Services.

Section 14 – Accessing, Updating, or Correcting Your Information

Groundwire is committed to maintaining accurate and up‑to‑date information.

You may request access to, correction of, or updates to the personal information we hold about you. We provide reasonable and lawful means to help you keep your information current.

14.1 Requesting Access to Your Information

You may request a copy of the personal information we maintain about you. This may include:

• Contact details
• Communication history
• Donation records
• Account information
• Chat or form submissions (where retained)

We will provide this information in accordance with applicable laws and within required timeframes.

14.2 Requesting Corrections or Updates

If any of your information is inaccurate, incomplete, or outdated, you may request that we:

• Correct it
• Update it
• Supplement missing details

We may request additional information to verify accuracy before making changes.

14.3 Requesting Deletion

You may request deletion of your personal information when:

• It is no longer needed
• You withdraw consent
• You object to processing
• We processed it unlawfully

Deletion may be limited when retention is required for:

• Legal compliance
• Donor record obligations
• Safety, fraud prevention, or abuse detection
• Enforcement of our Terms & Conditions

We will explain any limitations that apply.

14.4 Updating Communication Preferences

You may update your communication preferences at any time, including:

• Email subscriptions
• SMS opt ins
• Donor related communications
• Ministry updates

You may adjust preferences through unsubscribe links, SMS commands, or by contacting us directly.

14.5 Identity Verification

To protect your privacy, we may need to verify your identity before fulfilling requests. Verification may include:

• Confirming contact details
• Requesting additional information
• Validating account ownership

We do this to prevent unauthorized access or changes.

14.6 How to Submit a Request

You may submit access, correction, or deletion requests using the contact information in Section 12.

We respond within the timeframe required by applicable law.

Section 15 – User Generated Content

Some features of the Sites allow you to submit content, such as chat messages, prayer requests, comments, form submissions, or other materials (“User Generated Content”). By submitting such content, you acknowledge and agree to the terms outlined in this section.

15.1 Content You Submit

User Generated Content may include:

• Chat messages
• Prayer requests
• Testimonies or stories
• Feedback or survey responses
• Form submissions
• Any other information you voluntarily provide

You are responsible for ensuring that any content you submit:

• Is accurate
• Does not violate the rights of others
• Does not include unnecessary sensitive information
• Complies with our Terms & Conditions

15.2 No Expectation of Confidentiality

While Groundwire treats your information with care and protects it according to this Privacy Policy, User Generated Content submitted through chat or forms is not confidential counseling or therapy.

You should avoid sharing:

• Medical or mental health diagnoses
• Financial account numbers
• Government identification numbers
• Sensitive personal details unless necessary

Groundwire is a ministry, not a clinical or professional service.

15.3 How We Use User Generated Content

We may use User Generated Content to:

• Provide spiritual encouragement
• Respond to your questions or requests
• Train and support volunteers
• Improve the quality and safety of the Services
• Monitor for abuse, fraud, or harmful behavior
• Comply with legal obligations

We do not use User Generated Content for advertising or commercial purposes.

15.4 Monitoring and Moderation

Groundwire may monitor or review User Generated Content to:

• Maintain a safe environment
• Detect harmful or abusive behavior
• Ensure compliance with our Terms & Conditions
• Protect users, volunteers, and the ministry

We may remove or restrict content that:

• Is harmful, abusive, or inappropriate
• Contains sensitive information
• Violates our Terms & Conditions
• Poses a safety or legal risk

15.5 Sharing of User Generated Content

We do not publicly share User Generated Content unless:

• You provide explicit written permission, or
• It is anonymized and cannot identify you

Examples include:

• Anonymous testimonies
• Aggregated prayer request trends
• De‑identified ministry impact reports

We never share identifiable User Generated Content without consent unless required by law.

15.6 Retention of User Generated Content

User Generated Content may be retained as described in Section 5 (Data Retention) for:

• Safety and risk management
• Training and quality assurance
• Operational support
• Legal compliance

We delete or anonymize content when it is no longer needed.

15.7 Prohibited Content

You may not submit content that includes:

• Threats, harassment, or abusive language
• Illegal activity
• Sensitive personal information about others
• Content intended to harm yourself or others
• Spam or malicious links
• Copyrighted material you do not own

We may take action to protect users and the ministry when prohibited content is submitted.

Section 16 – Children’s Privacy

Groundwire is committed to protecting the privacy and safety of young people. Our Sites and Services are not intended for children, and we do not knowingly collect personal information from individuals below the age thresholds described below.

16.1 Age Restrictions

Groundwire does not knowingly collect or process personal information from:

• Children under 14 in the United States
• Children under 13 in the United Kingdom

These age thresholds align with applicable privacy laws and with our Terms & Conditions.

If you are below the applicable age threshold, you may not use the Sites or submit any personal information.

16.2 No Services Directed to Children

Groundwire’s Sites and Services:

• Are designed for adults and older teens
• Do not offer programs targeted to children
• Do not knowingly solicit information from children
• Do not knowingly allow children to create accounts or engage in chat

Any content that may be accessible to minors is intended for general audiences and does not involve data collection from children.

16.3 If We Learn We Have Collected Information from a Child

If we discover that personal information has been collected from a child below the applicable age threshold:

• We will delete the information promptly
• We may disable related accounts or submissions
• We may take steps to prevent further access
• We may notify the parent or guardian when appropriate

We encourage parents or guardians who believe their child has submitted information to contact us immediately using the details in Section 12.

16.4 Parental Responsibility

Parents and guardians are responsible for:

• Monitoring their children’s online activity
• Ensuring children do not access the Sites
• Contacting us if they believe a child has submitted information

Groundwire does not provide parental consent mechanisms because our Services are not intended for children.

16.5 Teen Users Above the Minimum Age

For teens who meet the minimum age requirement:

• We encourage caution when sharing personal information
• We recommend avoiding sensitive or identifying details
• We may limit or restrict access if safety concerns arise

Groundwire is a ministry environment, not a counseling or crisis intervention service.

16.6 Compliance with Applicable Laws

This section is designed to comply with:

• U.S. privacy standards
• The U.K. General Data Protection Regulation (UK GDPR)
• The Data Protection Act 2018
• Best practices for nonprofit organizations

We update our practices as laws evolve.

Section 17 – Additional Disclosures for U.K. Users

If you are located in the United Kingdom, the following additional disclosures apply to the processing of your personal information under the U.K. General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

17.1 Data Controller

For users in the United Kingdom, the data controller responsible for your personal information is:

Groundwire UK
Attn: Data Protection
[Insert UK mailing address]
Email: info@groundwire.net

Groundwire UK works in coordination with Groundwire (U.S.) to provide ministry services and support.

17.2 Lawful Bases for Processing

Under UK GDPR, we must identify the lawful bases on which we process personal information. Depending on the context, we rely on:

• Consent – for newsletters, SMS, certain cookies, and optional submissions
• Legitimate Interests – for ministry operations, analytics, fraud prevention, donor stewardship, and site functionality
• Contractual Necessity – when providing services you request
• Legal Obligations – for financial records, tax compliance, and required reporting
• Vital Interests – in rare cases involving safety or preventing harm

We process sensitive information only when you voluntarily provide it and only for ministry related purposes.

17.3 Your Rights Under UK GDPR

In addition to the rights described in Section 7, U.K. users have the right to:

• Understand how long we retain personal information
• Know whether we use automated decision making (we do not)
• Request details about international transfer safeguards
• Request restrictions on processing in specific circumstances

You may exercise these rights using the contact information in Section 12.

17.4 Complaints to the ICO

If you believe we have not handled your information in accordance with UK GDPR, you may file a complaint with the:

Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
United Kingdom
Website: https://ico.org.uk

We encourage you to contact us first so we can address your concerns.

17.5 International Transfers

As described in Section 11, when transferring personal information outside the U.K., we rely on:

• Standard Contractual Clauses (SCCs)
• International Data Transfer Addendums (IDTAs)
• Appropriate safeguards required by law

These mechanisms ensure your information receives a level of protection essentially equivalent to U.K. standards.

Section 18 – U.S. State‑Specific Disclosures

Some U.S. states have enacted privacy laws that provide residents with additional rights regarding their personal information. Many of these laws include exemptions for nonprofit organizations. While Groundwire is not subject to most state privacy statutes, we voluntarily provide the following disclosures for transparency.

This section applies only to residents of states with active consumer privacy laws, including but not limited to: California, Colorado, Connecticut, Virginia, and Utah.

18.1 Nonprofit Exemption

Groundwire is a nonprofit religious organization. Under current state privacy laws:

• California (CCPA/CPRA) – nonprofits are exempt
• Colorado (CPA) – nonprofits are exempt
• Connecticut (CTDPA) – nonprofits are exempt
• Virginia (VCDPA) – nonprofits are exempt
• Utah (UCPA) – nonprofits are exempt

Because of these exemptions, many rights and obligations under these laws do not apply to Groundwire.

However, we voluntarily extend certain rights to all U.S. users as described in Section 7.

18.2 Categories of Personal Information We Collect

For transparency, the categories of information we may collect include:

• Identifiers (e.g., name, email address)
• Internet or device activity (e.g., IP address, browser type)
• Communication content (e.g., chat messages, prayer requests)
• Donation related information (processed by third party payment providers)
• General location information

We do not collect:

• Government ID numbers
• Biometric data
• Precise geolocation
• Protected class data unless voluntarily submitted

18.3 How We Use and Share Personal Information

We use and share information as described in:

• Section 3 – How We Use Your Information
• Section 4 – How We Share Your Information

Groundwire does not:

• Sell personal information
• Share personal information for cross‑context behavioral advertising
• Use personal information for targeted advertising
• Use automated decision making that produces legal or significant effects

18.4 Your State‑Specific Rights

Even though Groundwire is exempt from most state privacy laws, we voluntarily allow U.S. users to request:

• Access to personal information
• Correction of inaccurate information
• Deletion of personal information
• Opt out of promotional communications

These rights are described in Section 7 and may be exercised using the contact information in Section 12.

18.5 Sensitive Personal Information

Groundwire does not use or disclose sensitive personal information for purposes that require special notice under state laws. Any sensitive information you voluntarily submit (e.g., in a prayer request) is used solely for ministry related purposes.

18.6 California “Shine the Light” Disclosure

California Civil Code §1798.83 allows California residents to request information about how their personal information is shared with third parties for direct marketing.

Groundwire does not share personal information with third parties for their own marketing purposes.

18.7 Appeals Process (Colorado, Connecticut, Virginia)

Some state laws require an appeals process for denied privacy requests. Although Groundwire is exempt, we voluntarily offer an internal review process.

If your request is denied, you may request an appeal by contacting us using the information in Section 12.