Privacy Policy – Zemen Calendar

Last updated: February 26, 2026

This mobile application "Zemen Calendar" (package: com.ethiopiancalendar.app) is developed and published by Zemen Studio (Filmon Seare) and provides an Ethiopian calendar service with church and event management. This policy explains how we collect, use, and protect your personal data in accordance with the General Data Protection Regulation (GDPR) and French data protection law.

1. Data Controller

As the data controller, we determine the purposes and means of processing your personal data and are committed to protecting it in accordance with applicable regulations.

2. Application Features

Our application offers the following services:

• Ethiopian Calendar: Conversion between Gregorian and Ethiopian calendars, Ethiopian holidays
• Church Management: Creation and management of churches, member registration
• Religious Events: Creation, management, and distribution of church events
• Authentication System: Registration, login, OTP verification
• Push Notifications: Event reminders and important notifications
• Premium Subscriptions: Advanced features for churches and users
• Feedback System: Bug reports and improvement suggestions
• Multilingual Support: Interface in French, English, and Amharic

2. Data Collected

2.1 Identification Data

• Full Name: For account identification
• Email Address: For login and communications
• Phone Number: For OTP verification and SMS notifications
• Password: Securely hashed (bcrypt)

2.2 Profile Data

• Preferred Language: French, English, or Amharic
• User Role: Standard user, admin, super admin
• Notification Preferences: Types of notifications desired

2.3 Church Data

• Church Name: For identification
• Description: Information about the church
• Address: Church location
• Contact Information: Phone and email contact
• Members: List of member users

2.4 Event Data

• Title and Description: Event details
• Date and Time: Event scheduling
• Recurrence: For recurring events
• Associated Church: Link to organizing church

2.5 Technical Data

• IP Address: Collected for session management, account security, and fraud prevention. Your IP address allows approximate location detection. This data is retained as long as the session is active.
• Device Identifiers (Push Token): We collect an Expo Push Token (unique device identifier) to send push notifications. This token is stored on our servers and associated with your account. It is not shared with third parties.
• Device Information: Type, operating system, version
• FCM Token: For push notifications
• Error Logs: For debugging and improvement
• Usage Statistics: Anonymized for analysis

2.6 Diagnostics Data

• Device Information: Device model, screen resolution
• OS Version: Operating system version
• User-Agent: Browser and app identification
• Performance Data: App crashes, loading times, errors

This diagnostic data is collected to improve application performance and functionality.

2.7 Payment Data

• Stripe Customer ID: For subscriptions
• Payment History: For subscription management
• No Banking Data: Processed only by Stripe

2.8 In-App Purchases

• Purchase Tokens: Tokens provided by Google Play to validate your purchases
• Transaction IDs: Unique identifiers for each transaction
• Purchase Status: To verify and manage your subscriptions

This financial data is collected solely to validate your in-app purchases via Google Play. It is not shared with third parties.

3. Use of Data

We use your data to:

• Provide our services: Calendar, church management, events
• Authentication: Secure login and verification
• Notifications: Event reminders and important information
• Customer Support: Response to feedback and requests
• Improvement: Performance analysis and development
• Security: Protection against fraud and abuse
• Billing: Management of premium subscriptions

4. Legal Basis for Processing (Article 6 GDPR)

In accordance with Article 6 of the GDPR, we process your personal data on the following legal bases:

4.1 Performance of Contract (Article 6.1.b)

Processing necessary for the performance of the contract you have entered into with us:

• Creating and managing your user account
• Providing Ethiopian calendar services
• Managing your church membership
• Creating and managing events
• Processing your payments and subscriptions
• Sending notifications related to subscribed services
• Customer support and responding to your requests

4.2 Consent (Article 6.1.a)

Processing based on your explicit consent:

• Sending promotional push notifications
• Processing data relating to your religious affiliation (see section 5)
• Marketing communications by email or SMS
• Sharing your profile with other church members

You may withdraw your consent at any time by modifying your preferences in the application or by contacting us. Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

4.3 Legal Obligation (Article 6.1.c)

Processing necessary to comply with our legal obligations:

• Retention of billing data (10 years - French Commercial Code)
• Retention of transaction data (tax obligations)
• Response to judicial requisitions
• Compliance with anti-fraud obligations

4.4 Legitimate Interest (Article 6.1.f)

Processing based on our legitimate interest, respecting your rights and freedoms:

• Security: Protection against fraud, abuse, and unauthorized access (IP address collection, connection logs)
• Service improvement: Anonymized usage analysis to improve the application
• Technical diagnostics: Performance data collection to fix bugs
• Non-payment prevention: Subscription management and reminders

You have the right to object to this processing (see "Your Rights" section).

5. Sensitive Data (Article 9 GDPR)

5.1 Nature of Sensitive Data Collected

• Church membership: Your registration as a member of an Ethiopian Orthodox church may reveal your religious beliefs
• Participation in religious events: Your participation in church events may also reflect your religious practices

5.2 Legal Basis for Processing Sensitive Data

In accordance with Article 9.2.a of the GDPR, we process this sensitive data only on the basis of your explicit consent, which you provide when:

• Registering for the application
• Requesting to join a church
• Registering for a religious event

5.3 Your Guarantees

• Free consent: You are not required to join a church to use the calendar features
• Withdrawal possible: You can leave a church and delete this data at any time
• Confidentiality: Only members and administrators of the church can see your membership
• No sharing: This data is never shared with third parties for commercial purposes

6. Third-Party Services Used

6.1 Stripe

For payment processing and subscriptions. Stripe collects and processes your payment data according to its own privacy policy.

6.2 Firebase Cloud Messaging (FCM)

For sending push notifications. Google collects technical data according to its privacy policy.

6.3 SMS Services

For sending OTP verification codes.

6.4 Analytics Services

For application improvement (anonymized data only).

6.5 Expo

For managing push notifications via Expo Push Token. Expo processes device identifiers according to its privacy policy.

6.6 Google Play Billing

For validating in-app purchases. Google processes transaction data according to its privacy policy.

7. International Data Transfers

7.1 Destination Countries

Your data may be transferred to:

• United States: Stripe, Google (FCM, Google Play), Expo

7.2 Applicable Safeguards

These transfers are governed by the following mechanisms, in accordance with Articles 44 to 49 of the GDPR:

• Standard Contractual Clauses (SCC): Our providers have signed the Standard Contractual Clauses approved by the European Commission (Implementing Decision 2021/914), ensuring a level of protection equivalent to that of the EU.
• Data Privacy Framework (DPF): Certain US providers are certified under the EU-US Data Privacy Framework.
• Supplementary measures: Encryption of data in transit and at rest, pseudonymization where possible.

7.3 Detail by Provider

You may obtain a copy of the applicable safeguards by contacting us at the address provided at the end of this document.

8. Data Security

9. Data Sharing

We never sell your personal data. We may share your data only in the following cases:

• With your consent: For specific features
• Third-party services: Stripe, FCM, Expo, SMS services (according to their policies, see section 7)
• Legal obligation: If required by law or judicial authority
• Protection: To prevent fraud or abuse
• Church members: Your name may be visible to other members of your church (with your consent)

10. Your Rights (Articles 15 to 22 GDPR)

In accordance with the GDPR and French data protection law, you have the following rights:

• Right of access (Art. 15): Obtain a copy of your personal data
• Right to rectification (Art. 16): Correct your inaccurate or incomplete information
• Right to erasure (Art. 17): Request the deletion of your data ("right to be forgotten")
• Right to restriction (Art. 18): Limit the processing of your data
• Right to portability (Art. 20): Receive your data in a structured, readable format
• Right to object (Art. 21): Object to the processing of your data
• Right to withdraw consent: Withdraw your consent at any time

10.1 How to Exercise Your Rights

You can exercise your rights in several ways:

• By email: filmonseare@gmail.com
• Via the application: Settings > Privacy section
• By mail: Filmon Seare, Paris 18e, France

We will respond to your request within one month. This period may be extended by two months for complex requests, in which case you will be informed.

10.2 Data Deletion

You can request the deletion of your data at any time:

• Complete Account Deletion: Request the deletion of your account and all associated data via https://filmons.github.io/privacy-policy/delete-account.html
• Partial Data Deletion: Request the deletion of specific data while keeping your account via https://filmons.github.io/privacy-policy/delete-data.html

10.3 Complaint to the CNIL

11. Data Retention

We retain your personal data only for as long as necessary for the purposes for which it was collected, in accordance with Article 5.1.e of the GDPR.

11.1 Detailed Retention Periods

11.2 Data Deletion

• Upon request: Data deleted within 30 days
• Inactive account: After 3 years of inactivity, you will be notified before deletion
• Archiving: Certain data may be archived for legal obligations with restricted access

12. Cookies and Similar Technologies

Our mobile application does not use traditional web cookies, but may use:

• Local Storage (AsyncStorage): User preferences stored on the device
• Authentication Tokens: Stored locally securely for the session
• Application Cache: To improve performance
• Notification Identifiers: Expo Push Token and FCM Token

These technologies are necessary for the application to function and are not used for advertising tracking purposes.

13. Protection of Minors

• Our application is not intended for children under 15 years of age.
• We do not knowingly collect personal data from children under 15 without verifiable parental consent.
• If you are a parent or guardian and discover that your child under 15 has provided us with personal data without your consent, please contact us immediately.
• If we discover that we have collected data from a minor under 15 without parental consent, we will delete this data as soon as possible.

14. Changes to This Policy

We may update this privacy policy to reflect changes in our practices or for legal reasons. In the event of a substantial modification:

• We will inform you via a notification in the application
• We will send an email to affected users if necessary
• The "last updated" date at the top of this page will be changed
• For modifications affecting your rights, we will request your renewed consent if required by law

We encourage you to regularly review this policy to stay informed of our data protection practices.

15. Contact and Support

To exercise your rights or ask questions:

• Email: filmonseare@gmail.com (response within 72 hours)
• Application: Settings > Support / Feedback section
• Mail: Zemen Studio – Filmon Seare, Paris 18e, France

The application Zemen Calendar is available on Google Play Store.

16. Legal Compliance

This privacy policy complies with the following regulations:

• GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data
• French Data Protection Act: Law No. 78-17 of 6 January 1978 on data processing, files and freedoms (as amended)
• LCEN: Law No. 2004-575 of 21 June 2004 on confidence in the digital economy (for connection logs)
• French Commercial Code: Articles L.123-22 et seq. (retention of accounting documents)

In the event of a conflict between this policy and applicable regulations, the regulations shall prevail.