Draft for legal review. This document has not yet been approved by a Barbados lawyer and may change before My Meeting Turn launches.
Privacy Policy
1. Who is responsible for your data
Walton Hunte, trading as UBevents246, [registered address], Barbados, operates My Meeting Turn and is the data controller for the personal data described here, under the Barbados Data Protection Act, 2019. Contact: ubevents246network@gmail.com (please write "Privacy" in the subject). [If a Data Protection Officer is appointed, add their name and contact here.]
The organizer of each meeting also decides what information about members is recorded in their meeting, and is responsible for using it fairly and only for that meeting.
2. What we collect
- Account details: your name, email address, optional mobile number and password (stored only in scrambled, hashed form).
- Meeting records: the meetings you organize or join, your payout position, the rules you accepted, contributions due and paid, payment dates, methods and references, verification and rejection notes, payouts, receipts, disputes and announcements.
- Proof of payment: photos or PDFs you or your organizer upload, such as bank transfer screenshots.
- Invitations: the name, email or phone number an organizer enters to invite someone, and "offline" member names entered by an organizer.
- Plan payments (organizers): the plan, amount, discount code, invoice number and PayPal order and transaction references. PayPal handles your card or PayPal account details; we never receive your full card number.
- Support: messages you send us and our replies.
- Security and usage: sign-in times, the IP address and actions recorded in our audit log, and the cookies needed to keep you signed in.
Financial information: your contribution and payout records describe money you paid or received. Barbados law treats a person's financial record or position as sensitive personal data, so we only process it with your explicit consent, which you give when you create your account, and only to run your meetings.
3. Why we use it, and our legal basis
- To provide the Service: accounts, meetings, schedules, records, receipts and reminders (performance of our agreement with you, and your explicit consent for financial information).
- To show the people in your meeting what they need: organizers see members' payment records; members see their own records and, if the organizer chose it, the payout order (names and positions only).
- To take plan payments and keep business and tax records (our agreement with you and our legal obligations).
- To keep the Service safe: preventing fraud and misuse, investigating disputes and keeping an audit log (our legitimate interests in a secure, trustworthy service).
- To answer your support requests.
- To meet legal obligations and respond to lawful requests from authorities.
We do not sell your data, and we do not use your meeting or financial records for advertising. We only send you service emails (such as invitations, reminders, receipts and security messages). We will ask separately before sending you any marketing.
4. Who can see your information
- People in your meeting, as described above.
- Our support staff, only when needed to help you, resolve a dispute or keep the Service secure. Staff access to meetings is recorded.
- Service providers who help us run the Service, under contract and only on our instructions:
- Website hosting and databases: Hostinger [confirm entity and server location];
- Payments for organizer plans: PayPal;
- Email delivery and our support mailbox: [confirm email provider(s), e.g. Hostinger mail and Google Gmail];
- Fonts used by the app are loaded from Google Fonts, which receives your IP address when the page loads.
- Authorities, if the law requires it, or to protect someone's safety or our legal rights.
If you share an invitation using WhatsApp, the message is sent from your own WhatsApp account; we do not send WhatsApp messages or access your contacts.
5. Storing data outside Barbados
Some of our service providers store or process data on servers outside Barbados (for example in the United States or Europe). We choose providers with appropriate safeguards, and by creating an account you consent to this transfer for the purposes in this policy. [Lawyer to confirm transfer basis and whether Data Protection Commissioner authorisation is needed.]
6. How long we keep it
- Account details: while your account is open. When you ask us to delete your account (Profile > Request account deletion) we remove or anonymise your My Meeting Turn profile within 30 days, except as below. My Meeting Turn uses your UBevents246.net website sign-in; that website account (used for tickets and the shop) is only closed if you ask for that too.
- Meeting records (contributions, payouts, receipts, disputes and the audit log): 7 years after the meeting closes, because every member relies on the shared record and it may be needed to settle disagreements or meet legal obligations. After an account is deleted, its name in shared records is replaced with "Former member" where possible.
- Proof-of-payment files: 2 years after the meeting closes, unless they are part of an open dispute.
- Plan payments and invoices: 7 years, for accounting and tax.
- Invitations not accepted: deleted 90 days after they expire.
- Support messages: 2 years after the request is closed.
7. How we protect it
We use encrypted connections (HTTPS), hashed passwords, private storage for proof-of-payment files that can only be opened by the right people, access checks on every page, rate limits against password guessing, and an audit log that cannot be edited. No system is perfectly secure. If a data breach is likely to put you at risk we will tell you, and we will notify the Data Protection Commissioner without undue delay and, where feasible, within 72 hours, as the law requires.
8. Your rights
Under the Data Protection Act, 2019 you can ask us to:
- give you a copy of the personal data we hold about you;
- correct data that is wrong or incomplete;
- delete your data, or restrict how we use it, where the law allows (some meeting records must be kept as explained above);
- stop using your data where we rely on our legitimate interests;
- give you your data in a portable format;
- withdraw your consent at any time. This does not affect what we did before. Because the Service cannot run meetings without processing payment records, withdrawing consent means closing your account.
Email ubevents246network@gmail.com or use Help & support. We will reply within 30 days, and may need to confirm your identity first. If you are not satisfied, you can complain to the Data Protection Commissioner of Barbados.
9. Cookies
The app uses only the cookies needed to keep you signed in, protect forms and remember a preview or session. It does not use advertising or tracking cookies. The rest of the UBevents246.net website has its own cookie notice.
10. Children
The Service is for adults aged 18 and over. We do not knowingly collect data about children. If you think a child has an account, contact us and we will remove it.
11. Changes
If we change this policy in a way that matters, we will tell you in the app or by email before the change takes effect.