Privacy Policy

Effective Date:  1 January 2021
Last Updated:  19 October 2026

This Privacy Policy explains how Choices Trust (“we”, “us”, “our”) collects, uses, stores and protects personal information when you use the website at choicestrust.org (the “Website”) and the Choices mobile app (the “App”). We are committed to handling your information in line with the General Data Protection Regulation (GDPR), the UK GDPR where it applies, South Africa’s Protection of Personal Information Act (POPIA), and other laws that apply to us.

1. Who is responsible for your information

Choices Trust is the data controller under the GDPR and the responsible party under POPIA. You can contact us through the Website or by email at choicestrust1@gmail.com. Where the law requires it, we appoint an Information Officer who can be reached at the same address.

2. What information we collect

On the Website

When you download a free copy of the Choices book through the Website, we ask for your full name, email address and physical address, and optionally a phone number. No payment details are collected for free downloads.

In the App

Your account. To use the App you create an account with an email address and a password. Sign-in is handled on our behalf by a specialist sign-in service, Clerk, which stores your email address and your password in encrypted form. Our own systems never see your password. You may also enter a first name, which is optional, and the App shows it where the course addresses you by name.

Your work in the course. As you go through the course, the App stores:

• your typed answers to the questions in each module;
• the choice you make at the end of each module (Choice A or Choice B), and the history of any changes to it;
• your journal entries, including their date, title, mood and tags;
• your goals and your check-ins against them;
• your progress, such as which modules and sections you have completed;
• your settings, such as text size and display theme.

What we do not collect. The App does not collect your location, contacts, photos, files, health information or payment details. It does not use advertising, analytics or tracking services, and it sends no notifications.

3. Why we collect it, and the legal basis

We use your Website form details to send you the free book and to keep a record of distribution. The legal basis is the performance of a contract with you, and our legitimate interest in keeping distribution records.

We use your account details and your work in the course to let you sign in and to keep your course work safe across phones and reinstalls. The legal basis is the performance of a contract with you: providing the App.

We use the Choice A or Choice B totals across all users to understand how the course is being used. These totals are only ever seen in aggregate and are never linked to a name by the people who see them. The legal basis is our legitimate interest in improving the course.

We use technical logs and deletion records to keep the App secure and to respond to deletion requests. The legal basis is our legitimate interest in security, and our legal obligations.

We do not sell personal information, use it for advertising, build profiles of individuals, make automated decisions about you, or send marketing without your consent.

4. How your work is protected

Encrypted on our servers. Your typed answers, journal entries, goals, check-ins and notes are encrypted on our servers with a key that is unique to your account, so that they cannot be read as ordinary text in our database. The Choice A or B you select in each module, and your progress, are stored without that encryption so that Choices Trust can see overall totals, such as how many people chose Choice A in a module, without reading anyone’s writing.

Nobody at Choices Trust reads your entries. Your answers and journal are yours. We can reset or delete your account when you ask us to, but we do not look at what you have written.

In transit. All communication between the App and our servers, and between the App and the sign-in service, is encrypted.

On your phone. The App keeps a working copy of your course work on your phone so that you can use it without a signal. That copy is removed when you delete the App from the phone. The App does not include its data in Google’s automatic phone backups.

Limits. No system can guarantee absolute security. If we become aware of a breach that puts your rights at risk, we will investigate promptly, notify the relevant authorities where the law requires it, and notify you.

5. Who we share it with

We do not sell, rent, trade or otherwise distribute your personal information to third parties. We use a small number of service providers who process information on our behalf and under our instructions:

• Clerk, which provides the App’s sign-in service and holds your email address and encrypted password;
• our hosting provider, which runs the App’s servers and database;
• the Website’s e-commerce platform, which handles free book downloads.

Each provider is bound by a data processing agreement and may only use your information to provide its service to us. We may also disclose information where the law, a court order or a regulator requires it.

6. International transfers

Our service providers may store information outside your country, including in the European Union, the United Kingdom and the United States. Where information leaves the EU, the UK or South Africa, we rely on safeguards such as the European Commission’s Standard Contractual Clauses, adequacy decisions, and contractual obligations on the provider.

7. How long we keep it

Website. Book download records are kept for as long as reasonably necessary for distribution records, store continuity and legal compliance.

App. Your account and your course work are kept for as long as your account exists. When you delete your account, everything in it is erased immediately and permanently (see section 8). We keep a record that a deletion took place, holding no personal content, so that we can show the deletion was carried out.

8. Deleting your account

You can delete your account at any time, in two ways:

• In the App: open Settings, choose “Delete my account”, and confirm. Your sign-in, your answers, your choices, your journal, your goals, your check-ins, your progress, your name and your settings are erased immediately. This cannot be undone.
• Without the App: see section 14 below, or email choicestrust1@gmail.com from the email address you used for the App and ask for your account to be deleted. We will delete it and reply to confirm.

If you would like a copy of your writing first, use the export option in the App’s Settings before deleting.

9. Your rights

Under the GDPR and UK GDPR you have the right to access your information, to have it corrected, to have it erased, to restrict or object to its processing, to receive it in a portable form, to withdraw consent where processing is based on consent, and to complain to a supervisory authority.

Under POPIA you have the right to be told when your information is collected, to access it, to have it corrected or deleted, to object to its processing, and to complain to the Information Regulator (justice.gov.za/inforeg).

In the App you can exercise most of these rights yourself: your answers and journal can be edited at any time, exported from Settings, and erased by deleting your account. For anything else, contact us at choicestrust1@gmail.com.

10. Children

The Website and the App are not directed at children under 13, or under the minimum age in your country if that is higher. If we learn that we have collected information from a child without the consent the law requires, we will delete it.

11. Cookies

The Website may use essential cookies that are needed for it to work. [Choose one: “We do not use advertising or behavioural tracking cookies.” OR “We use a website analytics service that places cookies to measure how the Website is used; these cookies do not identify you to us and are not used for advertising.”] Where the law requires it, we show a cookie notice on the Website. The App does not use cookies.

12. Changes to this policy

We may update this policy from time to time. The latest version is always published on this page with its date. If a change materially affects how we handle your information, we will tell you in the App or on the Website.

13. Contact

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

14. Delete your Choices account

Choices is a course from Choices Trust. You can delete your account and everything in it at any time.

If you still have the app

Open the app, go to Settings, choose Delete my account, and confirm. Your account is deleted immediately.

If you no longer have the app

Email choicestrust1@gmail.com from the email address you used for Choices, with the subject line “Delete my Choices account”. We will delete your account and reply to confirm. We do not need any other information from you, and you do not need to reinstall the app.

What is deleted

• Your sign-in: your email address and your password.
• Your answers in every module, and the Choice A or B you made in each.
• Your journal entries.
• Your goals and your check-ins.
• Your progress, your name and your settings.

Deletion is immediate and permanent. It cannot be undone or recovered. A record that a deletion took place is kept, with no personal content in it.

If you would like a copy of your writing, use the export option in the app’s Settings before you delete your account.

A copy that is still stored inside the app on a phone is removed when the app is deleted from that phone.

Choices Trust, choicestrust1@gmail.com