Privacy Policy

This Privacy Policy explains how ZENTRA HOLDINGS (PVT) LTD (“Zentra Holdings”, “we”, “us”, or “our”) collects, uses, and protects personal data when you use Manna (“the Service”), a free daily Bible verse and prayer companion delivered over WhatsApp. By subscribing to and using the Service, you consent to the practices described here. If you do not agree, please do not use the Service.

1. Who we are

Manna is operated as a community service by Zentra Holdings, a company registered in Sri Lanka and based in Colombo. For any privacy question or request, contact us at info@zentraholdings.org.

2. What data we collect

We collect only what is needed to deliver the Service:

• Your WhatsApp phone number — so we can send your daily verse and prayer and recognise you as a subscriber.
• The information you choose to share — the situations, feelings, hopes, or prayer requests you send us in your own words.
• Inferred topics — general themes drawn from what you share (for example, “grief”, “exams”, “new job”) so we can match a relevant verse to your circumstances.
• Language preference — English, Sinhala, or Tamil.
• Message and delivery records — basic logs of messages sent and received, used to operate the Service and honour opt-outs.

We do not ask for your name, address, financial details, or any official identification, and you should not send them. The Service is free, so we never collect payment information.

3. Why we collect it and our legal basis

We use your data solely to provide and operate the Service: to send your daily verse, to match scripture and reflections to what you are going through, to facilitate the anonymous prayer exchange, to respond to your messages, and to comply with the law. We process your data on the basis of your explicit consent, which you give when you subscribe and which you can withdraw at any time (see Section 8).

4. Sensitive personal data and consent

Information about your religious beliefs and your personal circumstances (such as health, emotional wellbeing, or family situation) is sensitive — sometimes called “special category” data. We treat it with particular care and process it only with your explicit, informed consent, given freely when you choose to join and each time you choose to share something with us. You are always in control of what you tell us; you may share as much or as little as you wish, and you may share nothing at all and still receive a daily verse.

5. How the prayer exchange is anonymised

If you take part in the prayer exchange, a request you share may be passed to another subscriber to pray over, and you may receive someone else’s request in return. Before any request is shared, we anonymise it: we never include your phone number, and we remove or generalise details that could identify you. Requests are shared only as a short, general summary for the purpose of prayer. Please avoid including names, contact details, or other identifying information in what you share; you are responsible for the content you choose to send.

6. Messages are sent through WhatsApp

The Service is delivered over WhatsApp. Your messages to and from Manna are therefore also processed by WhatsApp and are subject to WhatsApp’s own terms and privacy policy, which are outside our control. Manna is an independent service and is not affiliated with, endorsed by, or sponsored by WhatsApp or Meta Platforms, Inc.

7. Sharing your data

We do not sell, rent, or trade your personal data, and we do not use it for advertising. We share data only in these limited circumstances:

• Anonymised prayer requests shared within the Service for the purpose of prayer, as described in Section 5.
• Trusted service providers (such as secure hosting or messaging infrastructure) who process data on our behalf, under confidentiality obligations and only as needed to run the Service.
• Where required by law, regulation, or a valid legal request, or to protect the rights, safety, and security of users or the public.

8. Opting out and deleting your data

You can stop the Service at any time by replying STOP to any message; we will stop sending you messages. To request deletion of the personal data we hold about you, email us at info@zentraholdings.org and we will delete it, except where we are required to retain limited records by law.

9. Data retention

We keep your data only for as long as you remain subscribed and for a short period afterwards to honour opt-outs and meet legal obligations. The free-text content you share is retained only as long as needed to deliver the Service and is then deleted or further anonymised. When you ask us to delete your data, we act promptly.

10. Security

We take reasonable technical and organisational measures to protect your data against unauthorised access, loss, or misuse. No service can be guaranteed completely secure, but we work to keep what you share with us safe and private.

11. Children

Manna is intended for adults. It is not directed at children, and we do not knowingly collect data from anyone under 18. If you believe a child has subscribed, please contact us and we will remove their data.

12. Your rights under Sri Lanka’s Personal Data Protection Act

We handle personal data in line with the Personal Data Protection Act, No. 9 of 2022 of Sri Lanka. Subject to that Act, you have the right to access the personal data we hold about you, to ask us to correct it if it is inaccurate, to withdraw your consent, to ask us to delete your data, and to object to or restrict certain processing. To exercise any of these rights, contact us at info@zentraholdings.org.

13. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above, and significant changes will be communicated through the Service where appropriate. Continued use of the Service after an update means you accept the revised policy.

14. Contact us

If you have any question about this policy or how your data is handled, please write to us at info@zentraholdings.org. We are Zentra Holdings (Pvt) Ltd, Colombo, Sri Lanka.