Privacy Policy

0) Plain-English Summary

• We collect only what we need to provide services (account info, contact details, program data).
• In the HALO pilot, we may store compliance-support data (e.g., reminders, training progress, departure verifications) and optional trust-wallet/escrow info for prepaid return travel.
• We never sell personal data. We share only with service partners you use or approve, or when legally required.
• You can access, correct, delete, or export your data. California and EEA/UK rights are supported.
• Security: encryption in transit/at rest, access controls, audits, incident response.
• We keep data only as long as needed, then delete or de-identify it.

1) Information We Collect

Account & Contact: name, email, phone, country/region, preferred language, membership level.

Program Data (NPIE): event registrations, volunteer history, skills, training progress, messages.

HALO Pilot Data (opt-in): identity verification artifacts; travel plans; check-ins; reminders; verified departures (where available); community service hours; employer referrals; training/exam results; optional PRRTT trust-wallet/escrow contributions and disbursements; REEScore™ signals used to prioritize coaching.

Payments: handled by PCI-compliant processors; we store only tokens/metadata (no full card numbers).

Technical: IP, device, browser, OS, pages visited, session duration, and cookies/analytics described below.

Sensitive Data: We avoid collecting sensitive data unless you knowingly provide it and consent is required by law (e.g., wellness notes for support referrals). We are not a healthcare provider and do not offer medical care.

2) How We Use Your Information

• Deliver, improve, and secure our websites, apps, and services.
• Provide immigration-compliance coaching, case tracking, reminders, verified departures where possible, and advocacy letters.
• Operate the HALO trust-wallet/escrow (if you opt-in) and issue return-travel disbursements per program rules.
• Run training/employment pipelines (e.g., Cyber Defense), match candidates with partners, and verify outcomes.
• Process payments, send receipts and service notifications, and respond to questions.
• Research & reporting: de-identified statistics to improve programs and demonstrate impact (never for selling data).
• Legal: meet compliance, detect fraud/abuse, and respond to lawful requests.

4) When We Share (and When We Don’t)

We do not sell personal data. We share only as needed to operate services you choose or as required by law:

• Service Partners (opt-in programs): training providers, employers (with your consent), community organizations, and event operators (e.g., festivals) to coordinate enrollment, access, and safety.
• Financial Processors: to process payments and manage trust-wallet/escrow transactions.
• Consular/Agency Liaisons (case-by-case, with consent or legal basis): to verify departures or provide advocacy letters.
• Vendors: hosting, email/SMS, analytics, security, and support tooling under strict contracts (DPAs/SCCs where required).
• Legal: to comply with law, protect rights, or respond to lawful process.

5) Legal Bases

• Consent (e.g., HALO pilot enrollment, trust-wallet/escrow, sharing with employers/partners).
• Contract (to provide services you request, e.g., training, membership, payment).
• Legitimate Interests (improve services, prevent fraud, community safety) balanced against your rights.
• Legal Obligation (tax, reporting, compliance).
• Vital Interests (rare, e.g., safety or emergency situations).

6) Your Rights

EU/EEA & UK (GDPR/UK GDPR): access, rectify, erase, restrict, port data, and object; withdraw consent anytime.

California (CCPA/CPRA): know/access, correct, delete, opt-out of “sale”/“sharing” (we don’t sell), and limit sensitive data use.

To exercise rights: contact us. We respond within the legal timeframe.

7) Security

• Encryption in transit and at rest for core systems; tokenization for payments.
• Role-based access, MFA for staff, least-privilege permissions.
• Audit logs, vulnerability scanning, third-party assessments where applicable.
• Breach response plan: notify you and regulators when required by law.

No system is perfect. By using our services, you understand internet risks; we continuously improve safeguards.

8) Data Retention

• Account records: life of account + up to 3 years.
• HALO trust-wallet/escrow records: up to 7 years (financial/legal).
• Operational logs/analytics: 12–18 months (then aggregated/de-identified).
• We delete or de-identify when purpose is fulfilled or retention expires.

9) International Transfers

Your data may be processed in the U.S., Tonga, or other locations. When required, we use approved safeguards (e.g., Standard Contractual Clauses) and assess partners for appropriate protection.

10) Children & Teens

Our website is for people 13+. HALO enrollment for those under 18 requires a parent/guardian’s consent and appropriate documentation.

11) Cookies & Analytics

We use necessary cookies for login and security, and optional analytics to improve features. You can manage preferences in your browser and (where available) our cookie banner.

12) Automated Decision-Making

REEScore™ helps prioritize coaching/outreach. We do not make decisions with legal or similarly significant effects solely by automated means.

13) Changes to this Policy

We may update this policy to reflect improvements or legal changes. We will post the new date at the top and, if material, notify you by email or site notice.