This Privacy Policy describes how Step Fund, an initiative of the One Planet Research Foundation ("Step Fund," "we", “us” or "our") handles personal information that we collect through our digital properties that link to this Privacy Policy, including our website (collectively, the “Service”), as well as through social media, our marketing activities, our live events and other activities described in this Privacy Policy.  

Personal information we collect

Information you provide to us.  Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, email address, mailing address and phone number.

• Demographic Information, such as your city, state, postal code, gender, date of birth and age.

• Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise. 

• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

• Familial data, such as the number of people living in your home and annual household income.

• Financial information, such as your monthly income and expenses, economic standing or outstanding debts.

• Government-issued identification numbers, such as national identification number (e.g. Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card.

• Housing information, such as prior experience with homelessness, proof of rent due, and the need for loan (e.g. eviction notices or past-due bills).

• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources, such as government agencies, public records and other publicly available sources.

• Our affiliate partners, such as our affiliate network provider and publishers.

  
  
  

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place. 

• Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. 

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.  

These technologies are used for the following purposes:

• Technical operation. To allow the technical operation of the Service.

• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en. 

• Essential. Essential cookies are necessary to allow the technical operation of our Service (for example to remember information you entered on a previous page).

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so. 

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery.  We may use your personal information to:

• provide, operate and improve the Service and our business;

• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;

• communicate with you about the Service, including by sending announcements, updates, and support and administrative messages;

• understand your needs and interests, and personalize your experience with the Service and our communications; and

• provide support for the Service, and respond to your requests, questions and feedback.

Research and development.  We may use your personal information for academic research and  research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect.  We make personal information into anonymous data by removing information that makes the data personally identifiable to you.  We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Compliance and protection.  We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 

• audit our internal processes for compliance with legal and contractual requirements or our internal policies; 

• enforce the terms and conditions that govern the Service; and 

• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

With your consent.  In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.  

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.  

Affiliates.  Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers.  Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics). 

Payment processors. Any payment information you provide is collected and processed directly by our payment processors, such as PayNearMe.  PayNearMe may use your payment data in accordance with its privacy policy, https://www.paynearme.com/doc/bn_user/privacy. You may also sign up to be billed by your mobile communications provider, who may use your payment data in accordance with their privacy policies.

Advertising partners.  Third-party advertising companies for the interest-based advertising purposes described above. 

Third parties designated by you. We may share personal information with third parties (such as research universities) where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested.

Nonprofit and marketing partners. Third parties with whom we co-sponsor events or promotions.

Professional advisors.  Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. 

Your choices 

Opt-out of marketing communications.  You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.  Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.  

Cookies. Most browsers let you remove or reject cookies.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, the Service may not work properly.  For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. 

You will need to apply these opt-out settings on each device from which you wish to opt-out.  

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above. 

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties.  In addition, our content may be integrated into web pages or other online services that are not associated with us.  These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party.  We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security 

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. 

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Children  

The Service is not intended for use by anyone under 13 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us.  If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means.  Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

Greater Los Angeles Homeless Management Information System (LA HMIS) - PRIVACY NOTICE

THIS PRIVACY NOTICE EXPLAINS UNDER WHAT CIRCUMSTANCES WE MAY USE AND DISCLOSE YOUR INFORMATION FROM THE LA HMIS. THIS NOTICE ALSO EXPLAINS YOUR RIGHTS REGARDING YOUR CONFIDENTIAL INFORMATION.

PLEASE READ IT CAREFULLY.

Better Angels Inc. collects and shares information about individuals who access our services. The information is confidentially stored in a local electronic database called the Greater Los Angeles Homeless Management Information System (LA HMIS). The LA HMIS securely records information (data) about persons accessing housing and homeless services within Greater Los Angeles.

We ask for your permission to share confidential personal information that we collect about you and your family. This confidential information is referred to as Protected Personal Information (PPI). We are required to protect the privacy of your PPI by complying with the privacy practices described in this Privacy Notice.

Why We Collect and Share Information
The information we collect and share in the HMIS helps us to efficiently coordinate the most effective services for you and your family. It allows us to complete one universal intake per person; better understand homelessness in your community; and assess the types of resources needed in your local area. By collecting your information for HMIS, we are able to generate statistical reports requested by the Department of Housing and Urban Development (HUD) and other federal partners.

The Type of Information We Collect and Share in the HMIS

We collect and share both PPI and general information obtained during your intake and assessment, which may include but is not limited to:

• Name and contact information

• Social security number

• Birthdate

• Demographic information such as gender and race/ethnicity

• History of homelessness and housing (including current housing status and where and when services have been accessed)

• Self-reported medical history including any mental health and substance abuse issues

• Case notes and services

• Case manager's contact information

• Income sources and amounts; and non-cash benefits

• Veteran status

• Disability status

• Household composition

• Emergency contact information

• Domestic violence history

• Photo (optional)

How Your Personal Information Is Protected in the HMIS

Your information is protected by passwords and encryption technology. Each HMIS user and Participating Organization must sign an agreement to maintain the security and privacy of your information. Each HMIS user or Participating Organization that violates the agreement may have access rights terminated and may be subject to further penalties.

How PPI May Be Shared and Disclosed

Unless restricted by other laws, the information we collect can be shared and disclosed under the following circumstances:

• To provide or coordinate services.

• For payment or reimbursement of services for the Participating Organizations.

• For administrative purposes, including but not limited to HMIS Administrator(s) and developer(s), and for legal, audit personnel, and oversight and management functions.

• For creating de-identified PPI.

• When required by law or for law enforcement purposes.

• To prevent a serious threat to health or safety.

• As authorized by law, for victims of abuse, neglect, or domestic violence.

• For academic research purposes.

Other uses and disclosures of your PPI can be made with your written consent.

Providing Your Consent for Sharing PPI in the HMIS

If you choose to share your PPI in the LA HMIS, we must have your written consent. Exception: In a situation where we are gathering PPI from you during a phone screening, street outreach, or community access center sign-in, your verbal consent can be used to share your information in HMIS. If we obtain your verbal consent, you will be requested to provide written consent during your initial assessment. If you do not appear for your initial assessment, your information will remain in HMIS until you revoke your consent in writing.

You have the right to receive services even if you do not consent to share your PPI in the LA HMIS.

How to Revoke Your Consent for Sharing Information in the HMIS

You may revoke your consent at any time. Your revocation must be provided either in writing or by completing the Revocation of Consent form. Each Participating Organization that entered information into HMIS will continue to have access to your PPI, but the information will no longer be available to any other Participating Organization. 

Your Rights to Your Information in the HMIS

You have the right to receive the following, no later than five (5) business days of your written request:

• A correction of inaccurate or incomplete PPI;

• A copy of your consent form;

• A copy of the LA HMIS Privacy Notice;

• A copy of your HMIS records; and

• A current list of Participating Organizations that have access to your HMIS data.

You can exercise these rights by making a written request to this organization.

Right to Make Corrections

If you believe that your PPI in HMIS is incorrect or incomplete, you have the right to request a correction. To ask for either of these changes, send a written request, including the reason why you believe the information is incorrect or incomplete, to the HMIS Administrator of the organization that entered the information into HMIS. The organization may turn down your request if the information:

• Was not created by the organization you are requesting the change from;

• Is not part of the information that you would be allowed to look at and copy;

• Is related to another individual;

• Is found to be correct and complete.

• Is otherwise protected by law.

However, if your request for correction is denied, you have the right to request that the following language is entered next to a particular entry: “The participant disputes the accuracy of this entry.”

Your Privacy Rights Regarding Your Information in the HMIS

If you believe your privacy rights have been violated, you may send a written grievance to this organization. You will not be retaliated against for filing a grievance.

If your grievance is not resolved to your satisfaction, you may send a written grievance appeal to the HMIS Administrator for your CoC.

Amendments to this Privacy Notice

The policies in this notice may be amended at any time. These amendments may affect information obtained by this organization before the date of the change. Amendments regarding use or disclosure of PPI will apply to information (data) previously entered in HMIS, unless otherwise stated. All amendments to this privacy notice must be consistent with the requirements of the federal HMIS privacy standards. This organization must keep permanent documentation of all privacy notice amendments.

How to contact us

• Email: info@stepfund.org 

• Mail: The STEP Fund, 10573 W Pico Blvd., Suite 228, Los Angeles, CA 90064

• Phone:  213-478-1464