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Privacy Policy

Efficacy, Applicability and Acceptance

This Privacy Policy (the “Policy”) is effective from January 27th, 2021.

It is applicable to your use of the Site www.theqfoundation.org, the Equity and Visualization Platform (the “EVO Platform”) and its applicable hosted services and sites, including evohub.org (collectively the “Services”). Please review carefully. If you do not agree to our Policy, please do not access and utilize the Site and Services as your access and use will be deemed your acceptance of this Policy.

This Policy does not apply to third parties, who/which we do not own or control, including but not limited to our vendors, integrated or available applications, software or services and any participating authorities or parties utilizing on of our platforms to process housing and financial assistance applications.

If you applied for assistance through our EVO Platform and are concerned how your processing agency is retaining and utilizing your data, you should contact that agency to request its data policies as we have no control over such agency and their data policies.

We do not knowingly nor willingly collect, retain, use or disclose any information or documents from anyone under the age of 14. Parents and guardians applying for assistance may be requested to provide information about their children in order to verify and process their application for assistance, but we do not take any information from children themselves.

If you are under the age of 14, please do not use this Site and/or Services and do not provide us any information about yourself.

California Consumer Privacy Act (CCPA) and the EU General Data Protection Regulation (GDRP)

This Site and its Services are not meant to be utilized by residents of the EU. While this Site and Services are meant to be utilized by California residents, we are a nonprofit corporation and not covered by the California Consumer Privacy Act. However, we understand and acknowledge that in order to seek housing assistance you are providing us personal data (both personally identifying information (PII) and non-public personal information (NPI)), which we will protect with requisite security, transparency, accountability and integrity in accordance with this Policy.

Third Party Services

We may offer/link to third party services as part of this Site and our Services. These third parties are independent of us. We do not own nor control them nor their data collection, use and retention policies. If you choose to use a third party service, please carefully review such third party’s privacy policy before accepting, as their privacy policy controls how they will use, process and retain your data.

We use Plaid, Inc. (“Plaid”) to collect your financial data, confirm your bank, credit and loan account details, verify your bank balances and loan liabilities, verify your identity, authenticate your accounts and review your eligibility for our subsidies. If you agree to use Plaid you are authorizing your financial institutions to release your personal, banking and other financial information to us and Plaid and you agree that Plaid’s access, storage, processing and retention of your personal, banking and financial information will be governed in accordance with Plaid’s privacy policy, available at  https://plaid.com/legal/#end-user-privacy-policy, which may be amended from time to time.

Collection of Your Information

We automatically collect the following information from you:

Log information: We log how you access the Services, including your IP address, the date and time you accessed the Services, the referring URL and your browser configurations and preferences. We also log your activity on the Site and Services, for instance, what pages and/or content you view, and if you are a Registered User, what features and functions you utilize. For instance, if you are an applicant to any of our programs through the Site or the Services, we log when you apply and if you are a reviewing agent, we log what applications you review and verify.

Device information: We log what device you are using to access the Services, including what type of device, your device unique identifier and any information that your device provides based on the settings you have set on the device you utilize to access the Services.

Geolocation information: We log your location by your IP address and any other contact information you provide to us.

We collect information you choose to provide to us:

Contact information: We receive and retain the contact information you provide to us, for instance when you become a member of our organization or a registered user for any of our Services (for instance the EVO Platform; a “Registered User”) or contact details you supply when applying for assistance.

Content information: We receive, process and retain content, communications and documents that you transmit and/or submit through the Site and Services.

Personal and Financial Data: If you are applying for assistance through the Site and Services, you will be requested to provide personal data to determine your eligibility for assistance and process your application, including both PII and NPI such as your name, contact details, residence, demographic information, including your race, sex, sexual orientation, education level, employment status, employment history, health status and health history, housing information and history, marital status and family unit information, financial information, including but not limited to bank balances and pay stubs and any evidentiary documents, including identity documents.

You may also choose to use Plaid to provide us the above information. If you choose to use Plaid, you will be providing us information on your banking, investment and loan accounts including (i) account balances, including the real-time available balances of your bank accounts (ii) balance owed, credit limit, interest rate and transaction history and payment due dates for your credit cards (iii) amounts owed, interest rate, transaction history, loan type, payment terms, guarantor/s and lender/s of any of your loans (iv) asset identification, quantity, price, cost basis, fees and transaction history of your investment accounts (v) account information, including account number, routing number, transaction history and owner information (vi) employer information if connecting your payroll account and (vii) identity information associated with your accounts (collectively, the information in the foregoing paragraphs shall be “Personal and Financial Information”).

If you are a landlord that is utilizing our Services to obtain subsidies for your tenants or receiving rent from us on behalf of your tenants, we retain your contact information, your proof of ownership documentation, your W9 and your bank account information for us to provide the rental payments to you and other information you provide to us or communication you have with us in order for your tenants to receive rental relief and for you to receive rent through our rental assistance programs.

 

Use of Your Information

We do not sell your personal data, whether PII or NPI.

We only collect and process your PII and NPI as necessary in order to review, verify and process your application for assistance. Your Personal and Financial Information is first used by us to verify your identity, to verify your eligibility for our subsidy programs (financial need and residency for instance as may be required by the particular subsidy program), your banking information allows us to verify your account details and that you are the owner of the account provided, your landlord information allows us to pay your rent directly to your landlord, your real-time banking information (if you have connected Plaid) allows us to verify that you have sufficient funds for us to withdraw your portion of rent or other subsidy and avoid overdraft and return fees (if possible as we may not always be able to verify and/or prevent a withdrawal depending on your bank). We utilize the financial and account information you provide on the ACH form or debit card form to withdraw money from your account or debit card for your portion of rent or other subsidized payment.

If you are a landlord, we collect and process your contact, ownership and bank information as necessary in order to process rental assistance and provide rental payments to you on behalf of your tenants receiving rental assistance.

We may utilize your Contact Information to contact you to respond to any requests and/or questions from you, to verify and process your application for assistance or to inform you of any amendments to this policy or the Terms of Service. We may also send you emails to
notify you of any upcoming upgrades and/or updates that may cause some disruption or interruption in the provision of the Services to you and/or important security information respecting the Site and/or the Services.

If you are a member, we will send you regular newsletters. If you are a Registered User of the EVO Platform, we may on occasion send you emails informing you of upcoming features and functions and other promotional messages and you may receive a prompt to opt in to receive our newsletter.

We reserve the right to use aggregate and anonymized data (i.e. information that cannot be reasonably connected to you) for any legal purpose, including but not limited to research and development, including but not limited to enhancement and development of our Services and the development of new Services and/or products and compiling data sets to show COVID-19’s impact on different population sectors of our community, including in order to better inform public policy for more effective housing assistance for our community on the local, regional, state and federal level.

We may use your information as necessary to: protect the security of our Services, investigate any security breaches and/or fraud, conduct audits, to pursue any of our rights in court and/or to defend ourselves from any claims.

We may utilize your site analytics (how you use the Services, including what features and functions you use, how long you use them, when and where you access them) in order to improve our features and functions, develop new Services and provide better Services to you.

Your Choices

If you are applying for assistance for the available programs through our Services, in compliance with the law, we cannot delete your application and the information and documents you submit with it at your request, but must retain your information and documents as required by applicable laws, regulations and ordinances respecting applications for financial and housing assistance. If you are accessing and utilizing the Site and Services in performance of your duties to your organization, we will retain your information in accordance with and subject to applicable laws, regulations and ordinances and any agreement we may have with your organization.

If you are a Registered User of any of our Services, you cannot opt out of notifications respecting amendments to our policies, security and other administrative and operating notifications but you can opt out of any promotional and marketing material we may email you.

Members and anyone that opts into our newsletter can always opt out of receiving it.

Retention of Your Information

We will retain your information in order to provide the Services to you, in order for us to conduct audits, enforce our rights and as necessary in order to comply with applicable laws, regulations and ordinances.

Third party vendors, such as Plaid, will access, process and retain your information in accordance with their privacy policies.

Participating third party authorities and organizations of our EVO Platform, as applicable, which we have disclosed your data to through the Services in accordance with this Policy, may also retain your data to comply with applicable laws and audits.

Disclosure of Your Information

We disclose your information to our sub-contractors as required in order for us to provide the Services to you. For instance, we use a third-party cloud provider.

If you are utilizing the Services to apply for assistance through the EVO Platform and accompanying Services, we disclose your information as necessary to participating authorities and organizations which manage and operate the program or programs you are applying for, in order for your application to be processed. If you are applying for rental relief, we disclose this to your landlord and provide a subsidy letter, a change of subsidy letter and/or a rental assistance agreement to your landlord as necessary in order for you to receive your rental assistance.

We may disclose your information as is necessary to comply with applicable law and regulations and requirements, including the service of a subpoena, court order or request under a governmental investigation.

We may disclose your data in aggregate and anonymized form (i.e. information that cannot be reasonably connected to you) to any party and the public for any reason subject to applicable law.

Cookie Policy

We use cookies to enable our users to utilize the services and for Google Analytics.

Cookies are data packets that are cached on your web browser and sent to the server to identify you and your preferences. Cookies are necessary to allow users to register with a site and to set preferences. We thus have to use cookies for users to login and set their preferences. We use both session cookies (cookies that remember your input from page to page during a single session) as well as persistent cookies (so that we can remember your preferences if you are a Registered User of any of our Services).

We also use cookies for Google Analytics which provides us performance metrics for our Site and Services by collecting your IP address but no PII or NPI. To find out more on Google Analytics, see https://analytics.google.com/analytics/web/provision/#/provision

Amendments to this Policy

We may amend this Policy from time to time, including to comply with changes in applicable laws and regulations. Any change we make will apply prospectively. We will notify you of upcoming changes by posting the amendments here and if you have registered an account with us, by email to the email address associated with your account.

Contact Us!

If you have any questions or concerns respecting this Policy or the collection, use and retention of your data, feel free to contact our Privacy Policy Coordinator at privacy@EVOhub.org.

We take your concerns seriously. While our goal is to respond to you within forty-five (45) days from receipt of your request, for numerous reasons, we may not be able to meet our goal. However, we will respond within a reasonable time from your request.

We will not discriminate against you, including but not limited to denying you utilization of the Services, for any request and we welcome any questions or concerns you may have as we take the security and integrity of your data and our transparency and accountability respecting our collection, retention, use and disclosure of your data with due gravity.