Effective Date: [1 January 2021]
Last Updated: [26 February 2026]

Choices Trust ("we," "us," "our") operates the website https://choicestrust.org/ and the mobile application known as the Choices App.

We are committed to protecting your personal information in accordance with:

• The General Data Protection Regulation (EU) 2016/679 ("GDPR")
• The UK GDPR (where applicable)
• The Protection of Personal Information Act 4 of 2013 ("POPIA") of South Africa
• Any other applicable data protection laws

This Privacy Policy explains how we collect, use, store, and protect your personal information.

By using our website or mobile application, you consent to the practices described in this policy.

For purposes of GDPR and POPIA, Choices Trust is the Data Controller (GDPR) and Responsible Party (POPIA).

Contact details:
Website: https://choicestrust.org/
Email: choicestrust1@gmail.com

If required by law, an Information Officer (POPIA) has been appointed.

When users download books through our website using the free e-commerce module, we collect:

• Full name
• Email address
• Physical address
• Phone number (optional)

We do not collect or store credit card or payment details for free downloads.

When users install and use the Choices App, we collect:

• First name
• Gender

No surnames, addresses, payment information, or contact details are required in the app.

We process personal information under the following lawful bases:

To provide book downloads and access to the app services.

To:

• Maintain distribution records
• Prepare infrastructure for potential future commercial sales
• Ensure system functionality and continuity

Our legitimate interests do not override your fundamental rights and freedoms.

Where retention or disclosure is required by applicable law.

We collect personal information solely for:

• Processing book download requests
• Maintaining internal records of distribution
• Supporting operational continuity of our store system
• Personalizing chatbot responses within the Choices App

We do not use personal data for:

• Selling or trading information
• Advertising
• Behavioral profiling
• Automated decision-making
• Marketing communications without consent

We collect only the personal information necessary to fulfill the stated purposes.

Phone number collection is optional.

App data is limited to minimal personalization inputs.

Personal information is retained only for as long as reasonably necessary to:

• Maintain operational and distribution records
• Support store continuity
• Comply with legal obligations

User details entered into the Choices App remain stored within the app-side database until:

• The application is uninstalled, or
• App data is cleared

Once the app is uninstalled, locally stored user data is removed from the device.

We do not sell, rent, trade, or distribute personal information to third parties.

Personal information may be shared only:

• With hosting or technical service providers acting as Data Processors or Operators
• Where required by law, court order, or regulatory authority

All service providers are required to process data in compliance with GDPR and POPIA and under appropriate data processing agreements.

If personal data is transferred outside the European Economic Area or South Africa, we ensure that appropriate safeguards are in place, including:

• Standard Contractual Clauses
• Adequacy decisions
• Contractual data protection obligations

We implement appropriate technical and organizational measures to protect personal information against:

• Unauthorized access
• Loss
• Misuse
• Alteration
• Disclosure

While we take reasonable steps to safeguard data, no system can guarantee absolute security.

If you are located in the EU or UK, you have the right to:

• Access your personal data
• Rectify inaccurate data
• Request erasure ("right to be forgotten")
• Restrict processing
• Object to processing based on legitimate interest
• Data portability
• Withdraw consent where processing is based on consent
• Lodge a complaint with a supervisory authority

If you are located in South Africa, you have the right to:

• Be notified that personal information is being collected
• Access your personal information
• Request correction or deletion
• Object to processing
• Lodge a complaint with the Information Regulator (South Africa)

Information Regulator (SA):
https://www.justice.gov.za/inforeg/

Our website and app are not specifically directed at children under the age of 13 (or applicable minimum age in relevant jurisdictions).

If we become aware that we have collected personal information from a child without appropriate consent, we will take reasonable steps to delete such information.

Our website may use essential cookies required for core functionality.

We do not use advertising or behavioral tracking cookies.

Where required by law, users will be provided with appropriate cookie notices.

In the event of a data breach involving personal information:

• We will investigate promptly
• Notify relevant supervisory authorities where legally required
• Notify affected individuals where there is a risk to their rights and freedoms

We reserve the right to update this Privacy Policy at any time. Updates will be published on this page with a revised effective date.

Continued use of our services constitutes acceptance of any updates.

If you have questions regarding this Privacy Policy or wish to exercise your rights, contact:

Choices Trust
Website: https://choicestrust.org/
Email: choicestrust1@gmail.com