Privacy Policy

SECTION 1

Who We Are

Wellspring is a church-planting and coaching programme operated by Wisconsin Evangelical Lutheran Synod (WELS) ("Wellspring", "we", "us", "our"), of N16W23377 Stone Ridge Drive, Waukesha, WI 53188, USA.

Wellspring is a programme of the Asia-Oceania Team of WELS World Missions (the Wisconsin Evangelical Lutheran Synod). Wellspring is not itself a church body, and groups that form through Wellspring are not "Wellspring churches."

For the purposes of data protection law, Wisconsin Evangelical Lutheran Synod (WELS) is the data controller for personal information collected through livewellspring.org and through the Wellspring programme.

Privacy contact: admin@livewellspring.org

Postal: N16W23377 Stone Ridge Drive, Waukesha, WI 53188, USA

Representative for the EU/UK, if appointed: None currently appointed. Contact the privacy address above.

SECTION 2

Who This Policy Covers

This policy applies to:

Visitors to livewellspring.org, including anyone who reads a page, downloads a resource, or watches an embedded video.
Enquirers who submit the Reach Out form, respond to one of our advertisements, or contact us by email or messaging app.
Planters accepted into the Wellspring programme, and the coaching records kept about them.
Coaches and other volunteers who serve in the programme.
Members who hold an account for access to gated resources.
Supporters and partners who correspond with us.

It does not cover the internal member records of any Gospel Group or Local Church. Those groups are independent of Wellspring and responsible for their own handling of information.

SECTION 3

The Information We Collect

3.1 Information you give us directly

This comes from our Reach Out form, an advertisement lead form, member sign-up, or an email or message you send us.

Your name — so we know who we are talking to.
Your email address — so we can reply, and send you what you asked for.
Your phone or WhatsApp number — because in most of our regions the relationship runs on messaging rather than email.
Your country or city — so we can route you to a Coach who is actually near you and speaks your language.
Where you are right now, meaning your starting point — so we understand what kind of help would be useful.
Anything you write to us in a form, an email or a message — context for the first conversation.
Account details, if you register for gated resources — to give you access. Passwords are handled by our website platform and we never see them.
Your newsletter preference — so we only send what you asked for.

3.2 Information created while we walk with you

If you enter the Wellspring programme, we keep a coaching record. This is the heart of what we hold, and it is the part we handle most carefully.

Programme status — your stage in the pathway, dates, and whether you are active.
Digging Deeper record — notes on the doctrinal conversations, where there was agreement, where there were open questions, and whether you were ready to continue.
Walk notes — short notes made by your Coach after each Walk: what you talked about, what you are working on, what to follow up.
Waypoint reads — the quarterly reading of the Four Habits and the group's stage.
Visit notes — observations from an in-person visit.
Group information — the group's stage, the number of adults gathering, its language and region, and which group or pathway it came from.
Coach assignment history — who has coached you and when.
Flags — anything raised that needs attention or care.

3.3 Information about your faith

Almost everything in section 3.2, and much of section 3.1, tells us something about your religious beliefs and religious practice.

Most data protection laws that apply to us treat religious belief as a special category or sensitive personal information, which means it gets a higher standard of protection and usually requires your explicit consent. We treat all Wellspring coaching records as sensitive information, whether or not the law in your country requires it.

We ask for your explicit, informed consent before creating a coaching record about you, and we explain at that point what will be written down and who will see it. See section 10 for how we reduce this risk in practice.

3.4 Information we collect automatically

When you use livewellspring.org we collect:

IP address and approximate location derived from it
Device type, operating system, browser and language
Pages viewed, time on page, referring page, and exit page
Whether you clicked through from an advertisement, and which one (UTM parameters)
Which resources you opened or downloaded
Cookie and similar identifiers

Most of this is only collected if you allow it. See section 6 and our separate Cookie Notice.

3.5 Photographs, video and recordings

Coaching conversations may be held over video call. We record or transcribe a call only where everyone on the call has been told and has agreed.
We sometimes film or photograph gatherings, visits and interviews for use in Wellspring materials. We ask for signed consent before filming, we explain where the material may appear, and you may decline without any effect on your place in the programme.
If you have asked us not to show your face, name or location, we honour that, including in material already published, as far as we are practically able.

3.6 Information from other people

Referrals. Someone may put your name forward as a possible Planter. Where that happens we will tell you at first contact who referred you.
Referral partners. People sometimes come to Wellspring through the Academy of Lutheran Studies / TELL pathway. In those cases we may receive your name, contact details, course progress and the referrer's note. We will tell you at first contact that this is where your details came from.
Advertising platforms. If you fill in a lead form inside Facebook or Instagram, we receive the answers you gave there.

3.7 What we do not collect

We do not collect payment card details. The site does not process payments or donations.
We do not ask for government identification numbers.
We do not buy contact lists.
We do not knowingly collect information from anyone under 18. See section 13.

SECTION 4

Why We Use Your Information

To reply to your enquiry and connect you with a Coach. We use your contact details and your note. Our basis is your consent, and steps taken at your request before you enter the programme.
To run the coaching relationship. We use the coaching record described in 3.2 and your contact details. Our basis is your explicit consent, and performance of our agreement with you.
To keep the pathway working when a Coach changes. We use coach assignment history and group lineage. Our basis is our legitimate interest in continuity of care, balanced against your privacy.
To send you resources, newsletters or updates you asked for. We use your email address and preferences. Our basis is your consent, and you can withdraw it at any time.
To understand how the site is used and improve it. We use analytics data. Our basis is your consent where required, and otherwise our legitimate interest in a site that works.
To reach people who might be looking for something like Wellspring. We use advertising identifiers and audiences. Our basis is your consent.
To keep the site and our records secure. We use technical logs. Our basis is our legitimate interest in security.
To report on the programme to those who fund and oversee it. We use aggregated, de-identified counts. Our basis is our legitimate interest in accountability.
To meet legal obligations and respond to lawful requests. We use whatever is required. Our basis is legal obligation.
For safeguarding, and to respond to a serious concern. We use whatever is relevant. Our basis is protecting the vital interests of a person, and our legitimate interest in safety.

Where we rely on consent, you may withdraw it at any time. Withdrawing consent does not undo what was lawfully done before you withdrew it.

Where we rely on legitimate interests, you may object. We will stop unless we have compelling grounds that override your objection, and we will explain them to you.

SECTION 5

Reporting and Statistics

Wellspring reports on how the programme is going: how many Planters are active, how many groups have formed, how consistently Walks are happening. These reports go to programme leadership, to WELS World Missions, and to partners who support the work.

Those reports use counts and aggregates, not named individuals. Named information is shared beyond your Coach and the core Wellspring team only where you have agreed to it, or where safeguarding requires it.

SECTION 6

Cookies and Similar Technologies

We use cookies and similar technologies for four purposes: to make the site work, to remember your preferences, to understand how the site is used, and to reach people through advertising.

Only the first category runs without your permission. Everything else stays off until you turn it on.

Third-party content embedded in our pages — video players, live resource views — is blocked until you consent, because loading it lets that third party see that you visited the page.

Full detail, including a table of every cookie we set, is in our Cookie Notice. You can change your choices at any time from the "Cookie preferences" link in the site footer.

SECTION 7

Who We Share Your Information With

We do not sell your personal information. We never have and we will not.

7.1 People inside Wellspring

Your Coach. They see your coaching record. That is the point of it.
The Wellspring core team. A small group who run the pathway, the CRM and coach assignment.
A new Coach, if your coaching is reassigned.

7.2 The wider church

WELS World Missions and the Asia-Oceania Team, as the body that oversees Wellspring.
Sister church bodies and national partners, where you are being connected to a local church body, and with your agreement.
Asia Lutheran Seminary / TELL, where you came to us through that pathway or are being referred back to it, and with your agreement.

7.3 Service providers who process data for us

These organisations handle information on our instructions and are not permitted to use it for their own purposes.

Wix.com Ltd hosts the website, the forms and member accounts. Data is held in Israel, the EU and the USA.
Airtable, Inc. holds the programme CRM — enquiries, Planters, Coaches, groups and Walks. Data is held in the USA.
Make (Make.com) automatically transfers form submissions into the CRM. Data is held in the EU.
Google LLC provides analytics and advertising. Data is held in the USA and globally.
Meta Platforms, Inc. provides advertising, lead forms and measurement. Data is held in the USA and globally.
Zoom Communications, Inc. provides video coaching calls, including recordings and transcripts. Data is held in the USA and globally.
An email platform, not yet selected, will handle newsletters and programme email. Location to be confirmed before launch.
Telegram and WhatsApp (Meta) are used for day-to-day messaging with Coaches and the team. Data is held globally.
A36.Co provides strategy, brand and systems consultancy to Wellspring. Data is held in the Philippines.

We keep this list current. If you would like the specific terms we have in place with any of them, ask us.

7.4 Others

Professional advisers — auditors, lawyers, insurers — where needed and under a duty of confidence.
Authorities, where we are legally required to disclose, or to protect someone from serious harm.
A successor body, if Wellspring is ever transferred to another organisation. You would be told before that happened.

SECTION 8

Sending Information Across Borders

Wellspring operates across Asia and Oceania, and the tools we use are hosted mostly in the United States and the European Union. This means your information will be transferred out of the country you live in.

Where the law of your country requires a transfer safeguard, we rely on one or more of:

your explicit, informed consent to the transfer;
standard contractual clauses or equivalent contractual protections with the provider;
the necessity of the transfer to perform an agreement made with you or at your request;
a transfer to a country recognised as offering an adequate standard of protection.

Country-specific notes:

Philippines — transfers are made in accordance with the Data Privacy Act of 2012. We remain accountable for information transferred abroad.
Australia — we take reasonable steps under Australian Privacy Principle 8 before disclosing information overseas.
Japan — transfers are made with your prior consent, having told you the destination country.
Thailand, Malaysia, Singapore, Hong Kong, India — we rely on your consent and on contractual safeguards with the receiving provider.
European Economic Area and United Kingdom — we rely on standard contractual clauses and, where required, on a transfer risk assessment.

You may ask us for details of the safeguard used for any particular transfer.

SECTION 9

How Long We Keep It

An enquiry that did not proceed is kept for 24 months from our last contact, then deleted.
An enquiry that led to a conversation but not into the programme is kept for 24 months from the decision, then deleted.
An active Planter record, including Walk and Waypoint notes, is kept for as long as you are in the programme.
A Planter record after you leave is kept for 36 months, then reduced to a minimal record of your name, your dates, and group lineage.
The minimal lineage record is kept indefinitely, because the history of which group came from which cannot be reconstructed later. You may ask for this to be held under initials only.
A member account for gated resources is kept until you close it, or after 24 months of inactivity.
A newsletter subscription is kept until you unsubscribe.
Photographs, video and recordings are kept for as long as the material is in use, unless you withdraw consent.
Website analytics are kept for 14 months at most.
Correspondence is kept for 24 months, unless it forms part of a coaching record.
Anything we must keep by law is kept for the period the law requires.

When a retention period ends we delete the record or reduce it to non-identifying form.

SECTION 10

Security

10.1 What we do technically

Access to the CRM is restricted to named people who need it, and reviewed regularly.
Accounts protecting personal data require multi-factor authentication.
Data is encrypted in transit, and at rest by our providers.
We keep the number of places your information lives as small as we can.
We review who has access whenever a Coach or team member changes role.

10.2 What we do because of where we work

Some of the people Wellspring walks with live in places where being identified as a Christian, or as someone gathering others, carries real risk.

We take the following position, and you can hold us to it:

You may ask to be recorded under initials, a first name only, or a chosen name. We will not treat this as a lesser form of participation.
You may ask us not to record your city, only your region or language.
You may ask your Coach to keep Walk notes minimal — dates and follow-ups only, without content.
You may ask us not to photograph or film you, at any time, including after you previously agreed.

If you are unsure what is safest, ask your Coach or write to admin@livewellspring.org and we will talk it through before anything is written down.

10.3 Honesty about limits

No system is perfectly secure, and we use third-party platforms whose security we do not control. We will tell you promptly if a breach occurs that is likely to affect you, and we will notify the relevant authority where the law requires it.

SECTION 11

Your Rights

Depending on where you live, you have some or all of the following rights. We extend all of them to everyone, regardless of country, as a matter of policy.

To be told what we hold about you and what we do with it.
To see a copy of your information, including your coaching record.
To correct anything inaccurate or incomplete.
To delete your information, subject to anything we must keep by law.
To restrict how we use it while a question is being resolved.
To object to a use we base on legitimate interests, and to direct marketing at any time.
To withdraw consent at any time, including consent to a coaching record, to photography, or to cookies.
To take your information with you in a portable format.
To not be subject to a decision made purely by automated means. We do not make any decision about you by automated means alone. Group health readings and stage readings are made by a person.
To complain to your data protection authority. See section 14.

To exercise any of these, write to admin@livewellspring.org. We will respond within 30 days, or sooner where the law requires. We may need to verify who you are first. There is no charge unless a request is manifestly excessive, and we will tell you before any charge.

If you ask us to delete your coaching record, we will also tell your Coach that the record is gone, so nobody is working from a copy.

SECTION 12

Direct Marketing

We send:

Replies and practical information relating to your enquiry or your place in the programme. These are not marketing and continue as long as the relationship does.
Newsletters, resource announcements and invitations, only if you asked for them.

Every marketing message carries a one-click unsubscribe. You can also write to admin@livewellspring.org. We action unsubscribes within 5 business days and in any case within the period your country's law requires.

We do not use your coaching record to target advertising at you.

SECTION 13

Children

Wellspring's website and forms are intended for adults. We do not knowingly collect personal information from anyone under 18 through this site, and you should not submit a form if you are under 18.

Gospel Groups often include whole families, and children may be present at gatherings. Wellspring's records count adults, not children, and do not hold information about individual children.

If you believe a child has given us personal information, write to admin@livewellspring.org and we will delete it.

Photography and video at gatherings follows our safeguarding practice: no identifiable image of a child is captured or published without the documented consent of a parent or guardian.

SECTION 14

Complaints

Please come to us first — admin@livewellspring.org. We would rather fix something than have you take it elsewhere unresolved.

You also have the right to complain directly to your data protection authority:

Philippines — National Privacy Commission, privacy.gov.ph
Australia — Office of the Australian Information Commissioner, oaic.gov.au
Japan — Personal Information Protection Commission, ppc.go.jp
Thailand — Personal Data Protection Committee, pdpc.or.th
Malaysia — Jabatan Perlindungan Data Peribadi, pdp.gov.my
Singapore — Personal Data Protection Commission, pdpc.gov.sg
Hong Kong — Privacy Commissioner for Personal Data, pcpd.org.hk
India — Data Protection Board of India
United Kingdom — Information Commissioner's Office, ico.org.uk
European Economic Area — your national supervisory authority
Elsewhere — your national or state privacy regulator, if one exists

SECTION 15

Changes to this Policy

We will update this policy when what we do changes. The version number and date at the top always tell you which version you are reading.

If a change materially affects how we use information about you, we will tell you directly — by email, or through your Coach — before it takes effect. We will not quietly widen what we do with sensitive information.

Previous versions are available on request.

SECTION 16