This data privacy notice explains why and how Jehovah’s Witnesses collect and use publishers’ personal data, and describes the rights publishers have to their personal data. References in this notice to “you” or “your” are references to individuals who are unbaptized or baptized publishers a in a congregation of Jehovah’s Witnesses and whose personal data Jehovah’s Witnesses process in connection with maintaining and administering the religion and religious activities of Jehovah’s Witnesses.

Jehovah’s Witnesses operate globally. In this notice, “Religious Organization,” “our,” “we,” or “us” refers to the worldwide religious organization of Jehovah’s Witnesses or refers to one or more of the entities used by Jehovah’s Witnesses. These entities include the local congregation, local branch office, and other entities used by Jehovah’s Witnesses. One or more of these entities are the data controller of your personal data, depending on the nature of your interaction with us. Watch Tower Bible and Tract Society, A.s.b.l. is the data controller for publishers in congregations in Luxembourg.

As outlined in the book Organized to Do Jehovah’s Will, we collect personal data directly from you, from publicly available sources, or from others when you become a publisher so that you may participate in religious activities in connection with your worship and so that you may receive spiritual support.—1 Peter 5:2.

If you have any questions regarding the use of your personal data, please send an email to the following address:

LGL-Luxembourg@jw.org

If you wish to contact your local data protection officer, please send an email to the following address:

DataProtectionOfficer.LU@jw.org

You will find more information on the use of your personal data below.

The personal data we collect about you

You voluntarily supply the majority of the personal data we collect and use to maintain and administer the religion and religious activities of Jehovah’s Witnesses. Because of this, you will generally find the personal data we collect and use to be obvious. This data includes the following:

• Basic data, such as your name, date of birth, and gender

• Contact data, such as your postal address, email address, telephone numbers, and your emergency contact information

• Spiritual data, such as your date of baptism, “anointed” or “other sheep,” any role or assignment you have in the local congregation or within the Religious Organization, your field ministry activity, your spiritual status and any dates associated with that status, and other similar information related to your spiritual well-being.

The personal data we collect about you may also include special categories of personal data (special category data). Special categories include ethnic origin and religious beliefs, among others.

Purposes and legal bases for which we use your personal data

Our policy is to collect only the personal data necessary for our purposes and to process it lawfully on a valid, legal basis.

When you become a publisher, we collect and use your personal data lawfully in accordance with our legitimate interest in maintaining and administering the religion of Jehovah’s Witnesses so that you may participate in religious activities in connection with your worship and receive spiritual support. When the data we process reveals any special categories of personal data, such as your religious beliefs, we process the data with appropriate safeguards and do not disclose it without your consent outside the Religious Organization. We consider and balance any potential impact to you and your rights before we process your personal data for our legitimate interests.

We may also use your personal data to comply with a legal obligation. In the event of an emergency, we may use as a basis your vital interests or those of another person to process personal data.

Generally, we do not process personal data based on consent, since we can usually rely on another legal basis. However, we rely on consent when you have provided your explicit consent to processing your personal data. Please note that minors’ data is processed with the consent of the parent or legal guardian.

The table below describes the ways we use your personal data and the legal bases we rely on. Please contact the local data protection officer using the contact information above if you need additional details.

Retention

We retain personal data only for as long as it is needed for the purposes described in the section “Purposes and legal bases for which we use your personal data” above.

To determine the appropriate retention period for personal data, we consider the applicable legal requirements and the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for which we process your personal data, and whether we can achieve those purposes through other means.

Globally, retention periods may vary in different countries or jurisdictions and are set in accordance with local legal and regulatory retention requirements. Personal data may also be held for longer periods if extended retention periods are required by law or regulation and in order to establish, exercise, or defend our legal rights.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes. In that case, we may use this information indefinitely without further notice to you.

If you would like to know more about the retention periods we apply to your personal data, please contact the local data protection officer using the contact information above.

Transfers of personal data

Jehovah’s Witnesses operate globally. This requires us to centralize some operations, such as information technology services provided to entities. Some information will be accessed by multiple entities used by Jehovah’s Witnesses when necessary in connection with the purposes described in this notice and as outlined in the book Organized to Do Jehovah’s Will. For example, when you choose to move to a different congregation, your personal data (basic, contact, and spiritual data) is transferred to your new congregation. In some cases, the local branch office(s) of Jehovah’s Witnesses may process your personal data so that you may continue to participate fully in religious activities in your new congregation and so that we may keep our ecclesiastical records up-to-date. This may include transfers to countries outside the European Union (EU)/ European Economic Area (EEA) and to countries that do not have laws that provide specific protection for personal information.

We take appropriate security and legal precautions to ensure the safety and integrity of personal data that is transferred within the Religious Organization. When we collect your personal data within the EU/EEA, transfers outside the EU/EEA will be only

• to a recipient located in a country that provides an adequate level of protection for your personal data; and/or

• under an agreement which satisfies EU requirements for the transfer of personal data to data processors or data controllers outside the EU/EEA, such as standard contractual clauses approved by the European Commission; and/or

• with your consent.

Data security

We protect the confidentiality and security of information we obtain in the course of our activities. Access to such information is limited, and policies and procedures are in place that are designed to safeguard the information from loss, misuse, and improper disclosure.

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing while taking into account the state of the art; the costs of implementation; the nature, scope, context, and purposes of processing; and the risk of varying likelihood and severity for the rights and freedoms of natural persons. These measures include, but are not limited to the following:

• access control, confidentiality, and integrity;

• communications and operations security;

• the pseudonymization, anonymization, and encryption of personal data;

• assessing and evaluating the effectiveness of technical and organizational measures to ensure the security of processing.

We ensure that those who have permanent or regular access to personal data or who are involved in processing personal data are trained and informed of their rights and responsibilities.

Disclosures of personal data

We may share your personal data in the following circumstances:

• if this is appropriate for the purposes described in the section “Purposes and legal bases for which we use your personal data.” This includes within the Religious Organization;

• if required by applicable law;

• if we believe that such a disclosure is appropriate to protect and defend our rights, property, or safety;

• if needed to comply with a judicial proceeding, court order, or other legal obligation, or a regulatory or government inquiry; or

• if we have your consent.

Third-party recipients of personal data include the following:

• Regulatory bodies

• The courts, police, and law enforcement agencies

• Service or support providers

Your legal rights in relation to personal data

You may have certain rights under your local law in relation to the personal information we hold about you. These may include the following rights:

• The right to be informed about how your personal data is used. You have the right to be informed about how we will use and share your personal data.

• The right to access personal data. You have the right to obtain confirmation of whether we are processing your personal data and the right to access to your personal data.

• The right to have inaccurate personal data rectified. You have the right to have any inaccurate or incomplete personal data rectified, for example, if you change your contact information.

• The right to have personal data deleted in certain circumstances. This is also known as the “right to be forgotten.” This is not an absolute right that requires all personal data to be deleted. We will assess each request carefully in accordance with applicable laws.

• The right to withdraw consent. If we process personal data based on consent, you have the right to withdraw consent at any time. Generally, we do not process personal data based on consent, since we usually rely on another legal basis.

• The right to restrict processing of personal data in certain circumstances. This right arises if you are disputing the accuracy of personal data, if you have raised an objection to processing, if processing of personal data is unlawful and you oppose erasure and request restriction instead, or if the personal data is no longer required by us but you require the personal data to be retained to establish, exercise, or defend a legal claim.

• The right to data portability. The right to data portability applies only if the processing is based on your consent or if the personal data must be processed for the performance of a contract and the processing is carried out by automated means.

• The right to object to processing of personal data in certain circumstances. You have the right to object to our processing if we are processing your personal data based on legitimate interests.

You may exercise any of your rights by contacting the data controller using the contact information above or by contacting the local congregation.

We may need to request specific information from you to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you are concerned about an alleged breach of data protection law or other regulation by Jehovah’s Witnesses, you may contact the local data protection officer using the contact information above. The local data protection officer will investigate your inquiry and inform you about how it will be handled. You also have the right to complain to the data protection authority responsible for enforcement of data protection law in the country where you reside, or in the place where the alleged infringement occurred, or to refer the matter to a court of competent jurisdiction.

Changes to this notice

Data practices of Jehovah’s Witnesses may change from time to time because of changes to religious activities, the law, or the nature of technology. If changes are needed to this Use of Personal Data page, those changes will be posted on this page so that publishers are always aware of what information is collected and how it is used. Please check back periodically for changes to this page.