Privacy Policy

Last Updated: December 2024

1. Introduction

This Privacy Policy describes how [Entity Name] ("we," "us," or "our") collects, uses, discloses, and protects your personal information when you use the Affordable Housing Initiative Application System (the "System").

We are committed to protecting your privacy and complying with the Personal Information Protection Act (PIPEDA) and other applicable privacy laws in British Columbia, Canada.

2. Information We Collect

2.1 Information You Provide

We collect information that you voluntarily provide when using the System:

• Email Address: Used for communication and application tracking
• Consent Records: Timestamps and IP addresses when you provide consent
• Application Data: Information you submit as part of your housing application

2.2 Identity Verification Information

When you complete identity verification through Persona.io, the following information may be collected:

• Biometric Data: Facial recognition data for identity verification
• Government ID: Information from your government-issued identification
• Verification Results: Pass/fail status and confidence scores

Important: We do NOT store your biometric data or government ID images. These are processed by Persona.io and only verification results are returned to us.

2.3 Automatically Collected Information

• IP Address: Collected when you provide consent (for audit purposes)
• Browser Information: Basic technical information about your device and browser
• Usage Data: Information about how you interact with the System

3. How We Use Your Information

We use your personal information for the following purposes:

• Application Processing: To process and evaluate your housing application
• Identity Verification: To verify your identity and prevent fraud
• Communication: To send you updates about your application status
• Compliance: To comply with legal obligations and maintain records
• System Improvement: To improve the System and user experience

4. Legal Basis for Processing

We process your personal information based on:

• Consent: You provide explicit consent at multiple checkpoints
• Contractual Necessity: Processing is necessary to evaluate your application
• Legal Obligation: We may be required to retain certain records by law

5. How We Share Your Information

5.1 Third-Party Service Providers

We share your information with the following third-party service providers:

• Persona.io: Identity verification and biometric processing
• Hosting Provider: Render.com for application hosting and data storage

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

5.2 Legal Requirements

We may disclose your information if required by law, court order, or government regulation.

5.3 No Sale of Information

We do NOT sell, rent, or trade your personal information to third parties for marketing purposes.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information:

• Encryption: Data is encrypted in transit (TLS/SSL) and at rest
• Access Controls: Limited access to personal information on a need-to-know basis
• Secure Infrastructure: Hosted on secure, SOC 2 compliant infrastructure
• Regular Audits: Periodic security assessments and updates

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

8. Your Rights

Under PIPEDA and applicable privacy laws, you have the right to:

• Access: Request access to your personal information
• Correction: Request correction of inaccurate information
• Withdrawal of Consent: Withdraw consent at any time (may affect application processing)
• Complaint: File a complaint with the Privacy Commissioner of Canada

9. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:

[Entity Name]
[Address]
[Email]
[Phone]