Privacy

Last changed on Oct 13.

Who this is about

Ulgama is a record-keeping system for nonprofit organizations: their documents, tasks, people, programs and money records. It is made and run by Charwa LLC. This page covers the website at app.ulgama.com and the Ulgama app for iPhone.

An organization that uses Ulgama decides who its members are and what is kept. The records are the organization's; Charwa LLC keeps and protects them on its behalf. If an organization invited you, questions about what it keeps about you go to that organization first.

What is kept

• Your sign-in. An email address, a password kept only in a form that cannot be read back, and your second step: a passkey, or an authenticator app with recovery codes. The secret part of a passkey never leaves your device. Codes by text message or email are not used.
• Your membership. A short handle that others see, your roles, and your name and contact details where your organization recorded them. Names and contact details are stored encrypted and shown only to members whose role allows it; every look is recorded.
• What you do here. The tasks you complete, the documents you file, the decisions you make, and when. This record cannot be changed or erased, by design: it is how an organization shows what happened.
• What your organization files. Policies, certificates, insurance papers, minutes, expenses, gift records and the like. Some of these mention people.
• Where you are signed in. For each browser or phone: the kind of device, the internet address it used, the name you gave a phone, and when it was last used, so that you or an administrator can sign it out. Our servers also log the internet address and time of each request, for security, for a limited period.
• On the iPhone app. A token from Apple so that a badge can be shown. A scan you make is encrypted on the phone and removed from it once it is uploaded.

Two things are kept out on purpose. Attendance is counted, not named: Ulgama records how many people came to an event, not who. And the link between a gift and the person who gave it is encrypted with a key that the organization holds and Charwa LLC does not.

What is not done

• No advertising, no tracking across websites or apps, and no analytics service.
• No selling, renting or sharing of anyone's data for marketing.
• No cookies from other companies. The website sets only the cookies it needs to work: one that keeps you signed in and one that protects forms; a third may remember a language you chose.
• The app asks for the camera and for a photo only to scan a document you choose, and for Face ID only to unlock itself. It does not read your contacts, your location or anything else on your phone.

Who else handles the data

• Google Cloud, in the United States: the servers, the database, document storage, encryption keys and backups.
• Google Workspace: delivers the system's email, such as notices and password links.
• Apple: delivers notifications to the iPhone app. A notification carries an identifier and a count, never a name or the contents of a record.
• Cloudflare: answers the lookup of our internet address. It does not carry or see the traffic.
• Public registers: when an organization switches on a check against a public register, such as the tax authority's list of exempt organizations or a city's licence list, the organization's own public details, such as its tax number or street address, are looked up there. Nothing about a person is sent.

Nobody else receives data from Ulgama unless the organization itself sends it, for example through an export, or the law requires it. In that case only what is required is handed over.

How it is protected

All traffic is encrypted. Sensitive fields are encrypted in the database, each organization under its own key, and documents are encrypted where they are stored. The database itself keeps each organization's records apart from every other's. Uploads are checked for malware. Signing in needs a second step, and roles with wide access need a passkey. A web session ends after 30 minutes without use and after 12 hours in any case.

How long it is kept

• Records are kept for as long as the organization keeps them. The system does not delete a filed document or the record of what was done: they are the organization's proof.
• When you leave an organization, an administrator ends your access and your browsers and phones are signed out at once. What you did as a member stays in the organization's records under your handle.
• Backups are encrypted, kept for 400 days and then deleted.
• The iPhone app wipes what it holds when you sign out, after five wrong PINs, after seven days without being unlocked, and when the phone is signed out from the web.

Your choices

• In the menu you can change your sign-in security and see and sign out the browsers and phones you are signed in on.
• To see, correct or remove what an organization keeps about you, or to have your access ended, ask that organization's administrator.
• You can also write to us at hello@ulgama.com. We pass a request on to the organization and help it answer. Where the law gives you rights over your personal data, we respond as it requires.

Children

Ulgama is for the people who run an organization or help in it. It is not directed to children under 13, and nobody can make an account for themselves: access is given only by an organization's administrator.

Changes and contact

When this page changes, the date at the top changes. Questions: Charwa LLC, hello@ulgama.com.