1. Introduction

Africatown Community Land Trust (“ACLT” is committed to protecting the privacy of individuals and communities we serve in Washington State. This Privacy Policy explains how we collect, use, disclose, and safeguard information in compliance with Washington State laws and relevant federal regulations, including financial, property, health, and related data protections.

2. Information We Collect

We may collect:

• Personal Information: Name, contact details, demographic data, and service-related records.
• Service Information: Eligibility documentation, case notes, and program participation records.
• Donor Information: Payment details, donation history, and communication preferences.
• Financial Information (Housing/Lending Services):
  • Loan applications, promissory notes, escrow records, collateral documentation, and payment history.
  • Creditworthiness information, income verification, and property-related disclosures.
• Technical Information: Website usage data, IP addresses, cookies, and analytics.
• Medical Information: Information related to your health or medical equipment supplies or needs, where applicable.
• Billing Information: Payment details necessary for processing transactions.
• Usage Data: Data about how you interact with our website, including access times, pages visited, and clicks.

3. How We collect Information

We will collect, use, or disclose personal information for consent‑based purposes only when you provide a clear, affirmative opt‑in. By checking a consent box, signing a form, or otherwise expressly indicating agreement, you authorize the processing of your information for the stated purposes. You may withdraw consent at any time by contacting us, and we will cease processing based solely on consent unless another lawful basis applies. We collect information through:

• Website Forms: Information you provide on our website through forms, including contact forms, subscription forms, and service inquiries.
• Direct Communication: Details you provide during interactions with our customer service or service delivery teams or through forms signed by you..
• Cookies and Tracking Technologies: Tools that help us understand your preferences and improve website functionality.

4. How We Use Information

We use information to:

• Deliver and improve services and service offerings..
• Communicate with clients, donors, and partners., respond to inquiries, provide updates, and facilitate transactions.
• Maintain accurate records for compliance with Washington’s Consumer Protection Act (RCW 19.86).
• Process donations and issue IRS-compliant receipts.
• Evaluate borrower credibility and lender risk in compliance with federal lending standards.
• Conduct program evaluation (aggregate, non-identifiable data).
• SMS Notifications: With your consent, we may send SMS notifications regarding services or orders.

5. Information Sharing

We do not sell or rent personal information. We may share information only:

• With Consent: When individuals authorize disclosure.
• Service Providers: With vendors assisting in operations (e.g., IT, escrow agents, payment processors).
• Financial Institutions: When required to facilitate loan servicing or collateral release.
• Legal Requirements: When required under Washington law or federal law (e.g., IRS, HUD, CFPB).
• Program Reporting: Aggregated, non-identifiable data may be shared with funders.

6. Data Protection

We implement safeguards consistent with Washington’s data breach notification law (RCW 19.255), federal financial privacy standards (Gramm-Leach-Bliley Act), and IRS donor confidentiality rules.

We implement security measures to protect your personal information from unauthorized access, alteration, or disclosure, including:

• Encryption: Sensitive data is encrypted during transmission and storage.
• Access Controls: Access to personal information is restricted to authorized personnel.
• Monitoring and Audits: Regular checks ensure data integrity and compliance with industry standards.
• If a breach occurs, we will notify affected individuals and the Washington Attorney General as required

7. Retention

Information is retained only as long as necessary to fulfill service, legal, and reporting obligations, consistent with Washington nonprofit recordkeeping requirements and federal lending regulations.

8. Your Rights

Under Washington law and applicable federal regulations, individuals may:

• Request access to their personal and financial information we hold.
• Ask for corrections or updates in your data.
• Withdraw consent for certain uses.
• Opt-Out: Unsubscribe from communications or SMS notifications at any time.

9. Children’s Privacy

We comply with the Children’s Online Privacy Protection Act (COPPA) and Washington law. We do not knowingly collect information from children under 13 without parental consent.

10. Health Information (if applicable)

If we provide health-related services, we comply with the Health Insurance Portability and Accountability Act (HIPAA) and Washington health privacy laws.

11. Financial Data Handling (Housing & Lending Services)

For clients engaged in housing or lending programs:

• Loan Applications: Information is used solely to evaluate eligibility and borrower credibility.
• Escrow & Collateral Records: Maintained securely and disclosed only to authorized parties.
• Credit & Income Data: Used strictly for compliance with lending standards and never shared beyond required institutions.
• Oversecuritization Arguments: Borrower data may be used to demonstrate lender protection and compliance in negotiations.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on our website with a revised effective date.

13. Contact Us

For questions or concerns about this Privacy Policy, please contact:

Africatown Community Land Trust