Privacy Policy
Effective date: August 23, 2026 · Last updated: August 23, 2026
Draft for attorney review — not yet published. Bracketed [placeholders] must be filled in with counsel before this page goes live.
This Privacy Policy explains how Grupp LTD. (“Grupp,” “we,” “us,” or “our”) collects, uses, discloses, and protects information when you use the Grupp mobile app, web app, and website (together, the “Service”).
Grupp is software that community organizations — veteran service organizations, churches, clubs, and similar member-based groups (each, an “Organization”) — use to manage members, meetings, communications, and contribution records. If you’re a Member of an Organization using Grupp, some of the information described below is provided about you by your Organization’s administrators, not by you directly. See “Information Organizations Provide About Members” below.
If you do not agree with this Policy, please do not use the Service.
1. Who We Are
Grupp LTD. is a [STATE OF INCORPORATION] [entity type, e.g. corporation] with its principal place of business at [PRINCIPAL BUSINESS ADDRESS]. You can reach us at [privacy@yourdomain.com] with any questions about this Policy.
2. Information We Collect
2.1 Information you provide directly
- Account information: username, email address, password, display name, profile photo, headline, location, and “about” text you add to your profile.
- Content you create: posts, comments, likes, photos, videos, and files you upload to the social feed; chat messages and any media (photos, video, audio, files) you send in conversations.
- Communications: anything you send us directly, e.g. support requests.
2.2 Information Organizations provide about Members
Organizations use Grupp to manage their members, and Organization administrators may enter or upload the following about people they identify as Members — including people who have not created their own Grupp account:
- Name, role/title, and area of service or committee assignment
- Location
- Membership/participation status (active, suspended, dismissed)
- Contribution and dues records: amounts, dates, type (dues, levy, fundraiser, voluntary contribution), and status (pending, paid, overdue, waived). Most of this is a record the Organization enters, for example to track who has paid dues in cash or by check — but if the Organization has connected Stripe, a Member can instead pay a Pending record in-app by card. See Section 8 for what that changes about how Grupp handles funds and payment data.
- Donation records: donor name and email, amount, category, and an optional anonymous flag. As with contributions, this may be a record the Organization enters for a gift made outside the Service, or — if the Organization has connected Stripe — the record created automatically when a donor pays in-app by card. See Section 8.
- Meeting records: attendance, agendas, minutes, action items (which may name the person assigned), and fines (which may name the member and the reason).
- Prayer requests: request text and requester name, with an option for the Organization or requester to mark the request anonymous (in which case we still process the underlying data but display it as anonymous within the Organization).
- Contact persons, hosting/rotation schedules, and officials’ names, roles, and photos.
Because this information is entered by the Organization rather than the individual, the Organization — not Grupp — is responsible for having a lawful basis to collect and share this information with us, and for responding to that individual’s requests about it in the first instance. See Section 7 (“Organizations as Data Controllers”).
2.3 Organization information
If you administer an Organization, we collect the Organization’s name, address, city, country, phone number, email, type, and, if you choose to enable location-based features, its geographic coordinates and geofence radius.
2.4 Device, technical, and usage information
- Device data: device identifier, device type and model, operating system version, app version, network type, and IP address at registration.
- Push notification tokens: Firebase Cloud Messaging tokens (Android/general) and Apple VoIP push tokens (iOS), used to deliver notifications and incoming-call alerts.
- Call metadata: who called whom, call type, and start/end/duration timestamps for voice and video calls made through the Service. We do not store the audio/video content of calls.
- Usage/activity logs: actions like logging in, creating a post, commenting, attending an event, attending a meeting, or recording a donation, together with a timestamp and, in some cases, additional metadata used to improve the Service.
- Crash and diagnostic data: on Android, crash reports are sent to Firebase Crashlytics; we automatically strip passwords, tokens, and session identifiers from this data before it is sent. (This is not yet enabled on iOS/desktop, where crash details are kept only in a local log on your device.)
2.5 Information from cookies and similar technologies (website only)
Our marketing website uses:
- Sentry, to capture and help us fix website errors (request/response data is scrubbed of tokens, passwords, and authorization headers before being sent).
- Trustpilot, an embedded widget that lets visitors view and submit reviews; Trustpilot may collect information directly from your browser under its own privacy policy.
- ipapi.co, on the Pricing page, which receives your IP address to estimate your country so we can show prices in your local currency; no account is created.
We do not use advertising or cross-site tracking cookies, and the mobile/web app does not include third-party analytics or advertising SDKs.
3. How We Use Information
We use the information described above to:
- Provide, operate, and maintain the Service, including authentication, organization/member management, the social feed, chat, calling, and notifications;
- Let Organization administrators manage members, meetings, contribution and donation records, and related organizational content;
- Send transactional and service communications (e.g. password resets, push notifications you’ve enabled);
- Monitor, secure, and troubleshoot the Service, including detecting fraud, abuse, and security incidents;
- Improve and develop the Service, including through aggregated usage analysis; and
- Comply with legal obligations and enforce our Terms of Service.
We do not sell personal information, and we do not use member or contribution data to serve third-party advertising.
4. How We Share Information
We share information:
- Within an Organization: a Member’s profile and Organization-entered records (contributions, donations, meeting notes, etc.) are visible to that Organization’s administrators and, depending on the Organization’s settings, to other Members of that Organization.
- With service providers who process data on our behalf, currently including:
- Amazon Web Services (AWS) — hosting, database (RDS), file storage (S3), content delivery (CloudFront), video processing (MediaConvert), and caching (ElastiCache) infrastructure, and AWS Simple Email Service (SES) for transactional email.
- Firebase (Google) — push notifications and (Android only, currently) crash reporting.
- Stripe — payment processing for Organizations that connect a Stripe account to accept in-app card payments for dues/contributions and donations (see Section 8). Stripe collects your card details directly through its own hosted checkout or in-app payment form; we never receive or store your full card number, expiry date, or security code.
- Sentry — error monitoring for our website and backend.
- Trustpilot — reviews widget on our marketing website.
These providers are contractually restricted to using data only to provide services to us.
- For legal reasons, if required to comply with a legal obligation, protect the rights, property, or safety of Grupp, our users, or the public, or in connection with a merger, acquisition, or sale of assets (with notice to affected users where required by law).
- With your consent, for any other purpose you approve.
We do not otherwise sell, rent, or share personal information with third parties for their own marketing purposes.
5. Data Retention
We retain information for as long as your account or your Organization’s account is active, and for a reasonable period afterward to comply with legal obligations, resolve disputes, and enforce our agreements. An Organization administrator can request deletion of Organization data, and an individual can request deletion of their own account data, as described in Section 9.
6. Data Security
We use technical and organizational measures designed to protect information, including:
- Passwords are stored using bcrypt hashing, not in plain text;
- Login credentials are additionally encrypted in transit using RSA/AES session encryption in the mobile and web apps, on top of standard TLS;
- Infrastructure access controls, network segmentation, and secrets management via AWS Secrets Manager.
No method of transmission or storage is 100% secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you and any applicable regulator as required by law.
7. Organizations as Data Controllers
When an Organization uses Grupp to store information about its Members — including contribution records, meeting attendance, or prayer requests — the Organization determines what information to collect and why. In that relationship, the Organization acts as the data controller and Grupp acts as a data processor/service provider, processing that data only as instructed by the Organization and as needed to provide the Service. Organizations are responsible for:
- Having a lawful basis (e.g. consent, legitimate interest, or another applicable basis) to provide Member information to Grupp;
- Responding to Members’ requests to access, correct, or delete their information, with our reasonable technical assistance; and
- Their own compliance obligations under applicable law with respect to the data they input.
Organization customers may request a Data Processing Agreement by contacting [legal@yourdomain.com].
8. Payments and Donations — What Grupp Does and Doesn't Do
Whether Grupp is involved in moving money for a contribution, dues, or donation record depends on whether the Organization has connected a Stripe account through the Service:
If the Organization has not connected Stripe (the default): contribution, dues, and donation records are entered manually by the Organization (or its administrators) to track amounts collected offline (cash, check) or through the Organization’s own external payment tools (for example, a Stripe Payment Link, PayPal.me, or Venmo handle the Organization sets up itself). Any actual payment is made directly to the Organization through that external tool, which has its own privacy policy and terms — Grupp is not a party to that transaction and does not receive your card or bank details.
If the Organization has connected Stripe (“Stripe Connect”): a Member or donor can instead pay a Pending record in-app by card. Card details are entered directly into a Stripe-hosted payment form (Stripe Checkout or Stripe’s native in-app payment sheet) and go straight to Stripe — Grupp’s servers never receive or store your full card number, expiry date, or security code. Grupp’s servers do receive and store the resulting payment status, amount, and Stripe-assigned identifiers (a Checkout Session or PaymentIntent ID) so the contribution/donation record can be automatically marked paid. If you save a card for faster future payments, Grupp stores a Stripe Customer ID linking your account to that saved card inside Stripe’s systems — not the card details themselves.
In this flow, the payment is first received by Grupp’s own Stripe platform account, which deducts a transaction fee (see our Terms of Service) and transfers the remainder to the Organization’s connected Stripe account. This means that, unlike the manual/external-link path above, Grupp is a party to the transaction for Stripe’s own payment processing and — per Stripe’s terms for this account structure — is the party Stripe holds responsible for handling disputes and chargebacks on these in-app payments, not the Organization. Grupp still never sees your raw card details in either case; those are handled entirely by Stripe.
Which path applies to a given record is visible in the app — a “Pay by Card” button only appears once the Organization has connected Stripe. The external-link option remains available to, and is unaffected for, Organizations that prefer not to connect Stripe.
9. Your Rights and Choices
Depending on where you live, you may have rights to access, correct, delete, or receive a copy of your personal information, and to opt out of certain processing. To exercise these rights:
- If your account was created directly by you, contact us at [privacy@yourdomain.com].
- If your information was entered by an Organization you belong to (see Section 2.2), please contact that Organization first — they control the record — and we will assist them as needed.
California residents: you have rights under the California Consumer Privacy Act (CCPA/CPRA), including the right to know, delete, and correct personal information, and to opt out of the sale or sharing of personal information (we do not sell or share personal information as those terms are defined by CCPA). To exercise these rights, contact us at the address above.
Residents of other U.S. states with comprehensive privacy laws (e.g. Virginia, Colorado, Connecticut, Utah, and others) have similar rights; contact us and we will honor requests as required by the law applicable to you.
[Add EU/UK/GDPR section here if the Service is offered to users in those regions — legal basis for processing, right to lodge a complaint with a supervisory authority, and international transfer safeguards.]
We will not discriminate against you for exercising your privacy rights.
10. Children's Privacy
The Service is not directed to children under 13 (or the relevant minimum age in your jurisdiction), and we do not knowingly collect personal information from them. If you believe a child has provided us with personal information, contact us at [privacy@yourdomain.com] and we will delete it.
11. International Data Transfers
Our infrastructure is hosted in the United States. If you access the Service from outside the United States, your information will be transferred to and processed in the United States, which may have different data protection laws than your country.
[Add specifics if Organizations outside the U.S. are supported, e.g. Standard Contractual Clauses.]
12. Changes to This Policy
We may update this Policy from time to time. If we make material changes, we will notify you by email or in-app notice before the changes take effect. The “Last updated” date above reflects the most recent revision.
13. Contact Us
Grupp LTD.
[PRINCIPAL BUSINESS ADDRESS]
[privacy@yourdomain.com]