Last Updated: 25 September 2026
1. Who we are
African Christian College (“ACC”, “we”, “us”) is a Christian higher education institution in the Kingdom of Eswatini and a charitable organization in the United States of America. ACC is the data controller for the personal information described in this policy.
- Address: Past Tubungu Estates, Matsapha; PO Box 331, Manzini M200, Kingdom of Eswatini
- Privacy contact: privacy@africanchristiancollege.org; +268 7847 9360
- Data Protection Officer: Chief Operations Officer. Please address post to “The Data Protection Officer” at our postal address.
- Registration: ACC is registered as a data controller with the Eswatini Data Protection Authority (EDPA) of the Eswatini Communications Commission (ESCCOM), as required by section 46 of the Data Protection Act, under registration number DC-CI202-16022026. Our Data Protection Officer is also registered with the EDPA.
- In the United States: ACC is a US 501(c)(3) charitable organisation, EIN 26-0412537, PO Box 80036, Austin, TX 78708
We write this policy in plain language on purpose. If anything here is unclear, ask us and we will explain.
2. What this policy covers
This policy applies to personal information ACC collects through:
- our website, africanchristiancollege.org
- the ACC Admissions Portal, where people apply to study at ACC
- the ACC Alumni Network at alumni.africanchristiancollege.org, where graduates stay connected with ACC and each other
- email, WhatsApp, phone and social media conversations with ACC
- donations, newsletters, events and partner relationships
It applies wherever you are: in Eswatini, elsewhere in Africa, the United States, Europe or anywhere else.
Our alumni site, alumni.africanchristiancollege.org, is hosted by Almashines Technologies, and Almashines’ privacy policy explains how the platform itself handles your data. ACC uses the information you share there to keep you connected with ACC, share news and events, invite you to support ACC, and invite graduates to volunteer as admissions interviewers. The rest of this policy applies to that information once ACC holds it.
Current students, former students, and staff are covered by additional policies covering student and employment records.
3. Information we collect
What we collect depends on how you interact with us. Most of it you give us directly.
| If you are… | We may collect | Where it comes from |
|---|---|---|
| A website visitor | The IP address and browser type your device sends, and the pages you request, recorded in our server logs | Your browser, automatically |
| A donor or supporter | Name, email, phone, postal address, gift history, payment confirmation, communication preferences, church or organisation | You, our payment processor |
| A newsletter subscriber | Name, email, country, what you open and click | You, our email service |
| Alumni | Name, contact details, graduation year and programme, church & ministry role, location, student details, work history, profile photo, and anything you choose to post | You, our records |
| An applicant | See the list below | You, your church leader, your interviewer, our automated document reader |
| A church leader named by an applicant | Name, church, phone, email, and your responses | The applicant, then you |
| An alumni interviewer | Name, contact details, location, interview notes | You |
Applicants. Through the Admissions Portal we collect: your name and contact details; date of birth and gender; marital status and, if married, your marriage certificate; how many children you have; nationality; national ID or passport number; academic certificates and transcripts; your church and church leader’s contact details; your written responses; your photograph; audio recordings of your interview; and the messages you exchange with ACC.
Sensitive information. Your religious affiliation and gender are treated as sensitive under data protection law. As a Christian institution, church involvement is part of how we assess applicants, and we collect it with your explicit agreement and use it only for admissions and your studies. We ask your gender because places and accommodation are allocated by gender.
We do not collect payment or store card numbers. Online gifts are processed by our donation platform, Kindful Fundraising by Bloomerang, using Bloomerang Payments with Stripe as the card gateway. Your card details go directly to the payment processor; we receive only a confirmation and the last four digits.
4. How we use your information, and why we are allowed to
We use personal information only for the purposes below. Data protection laws require a lawful reason for each use; ours are listed alongside.
| Purpose | Lawful reason |
|---|---|
| Assess and decide on your application to ACC | Steps you ask us to take before enrolling you; your explicit agreement for information about your faith and your church |
| Contact you about your application by WhatsApp and email | Steps you ask us to take before enrolling you |
| Collect recommendations and arrange interviews | Steps you ask us to take before enrolling you |
| Enrol and support admitted students | Our agreement with you as a student |
| Process donations and send receipts | Our agreement with you; legal and tax obligations |
| Send newsletters, prayer updates and appeals | Your consent (you can unsubscribe at any time or ask us at any time to stop direct marketing under section 44 of the Act ) |
| Thank donors and keep supporters informed of our work | Our legitimate interest in stewarding relationships with supporters (you can object at any time and we will stop) |
| Keep our website working, secure, and useful | Our legitimate interest in running a secure website |
| Meet audit, accreditation, tax and legal requirements | Legal obligation |
| Protect someone’s safety in an emergency | Vital interests |
We do not sell, rent, or trade personal information, including donor lists.
5. Applying through the Admissions Portal
Applying to African Christian College involves more people and services than most websites. Below is what applying involves, and which parts we ask your permission for.
| What happens when you apply | Your choice |
|---|---|
| We read and assess everything you send us, including your transcripts and certificates | Part of applying – we tell you, and there is nothing to agree to |
| We contact you by WhatsApp and email about your application | Part of applying |
| We arrange an interview with an ACC graduate near you, and share your name and contact details with them | Part of applying |
| We record your interview as audio and keep the recording | Part of applying |
| We hold information about your faith and your church, and ask your church leader about you | You must agree. We are a Christian institution and active church membership is an entry requirement, so we cannot consider an application without this. |
| We record your gender | You must agree. We have a set number of places for men and for women, so we cannot consider an application without this |
| We use an automated AI service to read your documents first to pull out your grades | Optional. Your application is unaffected if you say no; a member of staff enters details instead |
| We use your photograph in ACC materials, and in a congratulations image if you are admitted | Optional. Your application is unaffected if you say no |
Your interviewer is a volunteer, not an ACC employee. They are an ACC graduate living near you. They receive only your name and contact details, and agree to use them only to arrange and hold your interview, and not to keep them afterwards.
A computer reads your documents first; a member of ACC staff checks every application, whether or not the computer reads it first. Your certificates, transcripts and ID documents, and your interview audio, are processed by Google’s Gemini AI service to extract your grades and produce a transcript. We use the paid tier of this service, under which Google does not use what we send to train or improve its models, and processes it only to return the result to us. Google may keep the material briefly to detect misuse of the service. Google does not guarantee what country this processing happens in.
No decision is made by the system alone. The portal converts grades and checks entry requirements automatically. The Admissions Coordinator checks every automated result, and the Admissions Committee makes every admission decision. You can ask for any automated result to be reviewed.
Withdrawing agreements. You can withdraw any permission at any time, either in your portal account or by emailing our Data Protection Officer. Withdrawing is as easy as giving permission, and it does not affect anything we lawfully did before you withdrew. If you withdraw your agreement about your faith, your church, or your gender, we cannot continue with your application; we will tell you this before you confirm. Withdrawing your agreement to automated document reading or to the use of your photograph has no effect on your application.
When the wording changes. If we change the wording in a meaningful way, we will ask you again rather than assume your agreement.
Your sign-in link is personal to you. We sign you in to the portal with a single-use link sent to you by WhatsApp (rather than a password). Anyone holding that link can open your application, so please don’t forward it. Links expire, and you can request a new one at any time.
6. Who we share information with
We share only what each person or service needs for its part of the work.
| Recipient | What they receive | Why |
|---|---|---|
| Admissions Coordinator | Your full application | Runs the admissions process |
| Admissions Committee | Your full application file | Makes enrolment decisions |
| Readiness assessment reviewers | Your essay | Marking (preaching-school route only) |
| Your church leader | Your name and that you have applied | To give a recommendation |
| An ACC graduate near you | Your name and contact details | To arrange and hold your interview |
| Google (Workspace, Firebase, Drive, Gmail) | Documents, application data, reports, email | Storage, hosting and delivery |
| Meta (WhatsApp) | Messages and media sent through WhatsApp | Our main channel with applicants |
| AI processing service (Google Gemini) | Certificates, transcripts, ID documents, interview audio | Automated reading and transcription |
| Bloomerang (Kindful Fundraising, Bloomerang Payments) | Donor name, contact details, gift details | Processing and recording donations |
| hCaptcha | Interaction signals on the donation form | Blocking automated abuse |
| Email and newsletter service (MailChimp) | Name, email, preferences | Sending updates |
| ACC Student Information System | Admitted students’ records only | Becomes your student record |
| Almashines | Your alumni profile and activity | Running the Alumni Network |
| Auditors, accreditation bodies, regulators, tax authorities | What the law or an audit requires | Legal and accreditation duties |
Service providers process information for us under their standard terms, which require them to keep it secure and to use it only to provide their service. Some, such as our alumni platform, also process information for their own purposes under their own privacy policies, which we link to above.
Our donation platform also uses service providers of its own for analytics and performance monitoring. These receive information about the pages a donor visits, but not the details entered on the donation form. We do not control these and cannot switch them off; Bloomerang’s privacy policy governs them.
7. Where your information is stored
Where your information sits depends on the service holding it.
Admissions Portal data stays in the region. Applications, consent records, messages and decisions are held in Google’s Johannesburg data centre (africa-south1), within the Southern African Development Community.
Some information is processed outside the region. Documents and photographs are stored in Google Drive, staff email runs through Gmail, and both may be processed in other countries. Documents and interview audio sent for automated reading are processed by Google’s Gemini service. WhatsApp messages pass through Meta’s systems. Donation data is held by Bloomerang on Amazon Web Services infrastructure, encrypted at rest; we have asked them to confirm the region in which it is stored. Alumni Network data is held by Almashines, whose files are served from Amazon Web Services in Singapore.
When information leaves Eswatini, we rely on protections recognised by the Data Protection Act: our providers’ data processing terms, standard contractual clauses where they apply, and independent security certifications such as SOC 2 and PCI DSS, which we have reviewed.
By applying, donating or subscribing, you are not giving up your rights because your data is stored abroad. Section 10 applies wherever your data is held.
8. How long we keep it
We keep information only as long as we need it for the purpose it was collected, or as the law requires.
| Information | How long |
|---|---|
| ID and passport scans, unsuccessful applicants | Deleted 24 months after the intake closes |
| Other application data | Kept so returning applicants keep their history across intakes; deleted after 5 years of inactivity or on request |
| Interview recordings | Deleted when the intake concludes or when you enrol |
| Admitted students | Moved to the Student Information System and kept under ACC’s student records policy |
| Church leader contact details | 12 months after the application concludes, unless the student enrols, then held as part of their record |
| Donation records | 7 years for tax and audit purposes |
| Newsletter subscriptions | Until you unsubscribe |
| Sensitive information (faith, church, gender, children) | Held with the rest of your application, and deleted on the same schedule |
When the period ends, we securely delete information or de-identify it so it cannot be reconstructed (section 13 of the Data Protection Act).
9. How we protect it
We use technical and organisational safeguards appropriate to the sensitivity of the information. These include sign-in and role-based access so staff and volunteers see only what their role needs, encryption in transit and at rest provided by our hosting platforms, audit records of who agreed to what, and commitments from staff who handle personal information.
Applicant documents are held in a restricted shared drive that only staff accounts can open. Portal sign-in uses single-use links rather than passwords, so there is no password for an applicant to lose or reuse. Access to applications is limited to the Admissions Coordinator, the Admissions Committee, and staff whose role requires it.
No system is perfectly secure. If a breach puts your information at risk, we will notify the Eswatini Data Protection Authority as soon as reasonably possible and within 72 hours of becoming aware of it, in line with the Authority’s breach reporting procedure, and we will tell you promptly if you are affected.
10. Your rights
Wherever you live, you can ask us to:
- tell you what information we hold about you, and give you a copy
- correct anything that is wrong or incomplete
- delete your information, where we no longer need it or have no legal reason to keep it
- stop or limit how we use it, including objecting to fundraising or marketing
- move information you gave us to another organisation, in a common format
- withdraw consent at any time (this does not undo anything we did lawfully before)
- have a person review any automated result that affects you
How to ask. Applicants can view their agreements and withdraw them in the portal. For anything else, email privacy@africanchristiancollege.org. We may ask you to confirm your identity. We will reply within 30 days and will not charge you or treat you differently for asking.
Complaints. Please contact us first so we can try to put things right. You can also complain to the Eswatini Data Protection Authority (EDPA), part of the Eswatini Communications Commission, which enforces the Data Protection Act (section 34): ESCCOM Head Office, Plot 11/850, MR103, Ezulwini; telephone +268 2406 7000; email dataprotection@esccom.org.sz; online complaint form at www.edpa.org.sz.
If you are elsewhere, you may also have rights under your own country’s law — including the EU and UK, South Africa under POPIA, and US states with consumer privacy laws. We extend the rights above to everyone regardless of where you live, and we will honour local rights where they apply. We do not sell or share personal information for targeted advertising.
11. Cookies and analytics
Our own website uses only essential cookies. These come from Cloudflare, which protects the site from attacks and automated abuse. We do not use analytics, advertising, or cross-site tracking cookies on africanchristiancollege.org, so there is no cookie banner to accept or decline.
Our donation pages are different. The donation form is provided by Bloomerang, and its pages set their own cookies, including analytics cookies, and use hCaptcha to block automated abuse. These are set by Bloomerang rather than us, and we cannot turn them off. Bloomerang’s privacy policy describes them.
The Admissions Portal stores information in your own device. So that you don’t lose work, your draft application and documents waiting to upload are stored on the device you’re using, not sent to us, until you submit. If you clear your browsing data, or use a different device, anything unsaved is gone.
12. Other things you should know
Children. Our websites are not directed at children under 13, and we do not knowingly collect their information online. When you apply, we ask only how many children you have. If you are admitted, we ask their names and dates of birth at enrolment so we can plan housing and meals. Applicants under 18 need the consent of a parent or guardian, which the portal records before the application continues.
Church leaders. If an applicant names you as their church leader, we hold your name, church and contact details so we can ask for a recommendation. We tell you this when we first contact you. You can ask us to remove your details at any time.
Donors. We use donor information to process gifts, issue receipts and keep you informed about ACC. We never sell or exchange donor lists. You can ask us to stop contacting you, or to contact you less, at any time.
Links to other sites. Our websites link to other sites, such as social media and payment pages. Their privacy practices are their own.
Changes to this policy. We will post any update here and change the date at the top. For significant changes we will tell applicants and subscribers directly, and ask for fresh consent where the law requires.