Privacy Policy

1. Information We Collect

1.1 Personal Information You Provide

We collect information you voluntarily provide when using the Application, including:

• Account Information: Name, email address, phone number, username, and password when you create an account;
• Profile Information: Demographic information, location data, living situation, employment status, and other personal details you choose to provide;
• Health and Wellness Information: Information about your physical health, mental health status, substance use history, medications, medical diagnoses, and wellness goals;
• Social Services Information: Details about your use of social services, case management needs, benefits enrollment, and resource requirements;
• Communications: Messages, responses to assessments and surveys, feedback, and other communications you send through the Application;
• Financial Information: If applicable, payment information, income details, or financial assistance requirements;
• Emergency Contact Information: Contact details for individuals you designate as emergency contacts;
• User Content: Any content, materials, or information you submit, post, or transmit through the Application.

1.2 Information Collected Automatically

When you use the Application, we automatically collect certain information, including:

• Device Information: Device type, operating system, unique device identifiers, mobile network information, and device settings;
• Usage Information: Features used, actions taken, frequency and duration of activities, interaction with AI features, and Application performance data;
• Location Information: Precise or approximate location data from GPS, WiFi, or cellular technology, when you grant location permissions;
• Log Information: Internet Protocol (IP) address, browser type, pages visited, time spent on pages, access times and dates, and other system activity;
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, pixels, and similar technologies to enhance functionality and analyze usage patterns;
• Metadata: Information about files stored on your device, which may include photographs, contacts, and address book information, when you grant relevant permissions.

1.3 Information from Third-Party Sources

We may receive information about you from:

• Service Providers: Third parties that provide services on our behalf;
• Partner Organizations: Social services agencies, healthcare providers, and community organizations you authorize to share information;
• Public Databases: Publicly available sources and government databases;
• Research Partners: Academic institutions and research organizations collaborating with us;
• Other Users: Information other users provide about you in connection with referrals or shared experiences.

1.4 Sensitive Information

Given the nature of our services, we may collect sensitive information including:

• Health conditions and medical history;
• Mental health status and psychological assessments;
• Substance use and addiction history;
• Housing status and homelessness history;
• Criminal justice involvement;
• Social Security numbers or government-issued identification numbers;
• Biometric information, where permitted by law.

You explicitly consent to our collection and processing of such sensitive information for the purposes described in this Policy.

2. How We Use Your Information

2.1 Primary Uses

We use the information we collect to:

• Provide Services: Deliver the Application's features and functionality, including AI-powered assistance and resource recommendations;
• Personalization: Customize your experience and provide tailored content, recommendations, and services based on your needs and preferences;
• Communication: Send you notifications, alerts, updates, and administrative messages about the Application and available resources;
• Support Services: Respond to your requests, questions, and feedback, and provide customer support;
• Assessment and Monitoring: Conduct assessments of your needs, track progress toward goals, and monitor wellness indicators;
• Resource Coordination: Connect you with appropriate services, benefits, and community resources;
• Account Management: Create and manage your account, verify your identity, and maintain accurate records.

2.2 AI and Machine Learning

We use your information to:

• Train, test, and improve our AI models and algorithms;
• Generate AI-powered responses and recommendations;
• Analyze patterns to enhance predictive capabilities;
• Develop new features and services;
• Conduct research on AI applications for social services.

2.3 Analytics and Improvements

We use information for:

• Performance Monitoring: Analyze Application usage, performance metrics, and system stability;
• Quality Improvement: Identify areas for enhancement and develop new features;
• Research: Conduct internal research and analysis to improve our services;
• Trend Analysis: Understand usage patterns and user needs across our user base.

2.4 Legal and Safety Purposes

We may use your information to:

• Compliance: Comply with legal obligations, regulatory requirements, and legal processes;
• Safety: Protect the safety, rights, and property of our users, the Company, and the public;
• Fraud Prevention: Detect, prevent, and address fraud, security breaches, and prohibited activities;
• Terms Enforcement: Enforce our Terms of Service and other agreements;
• Emergency Situations: Respond to emergency situations affecting your safety or the safety of others.

3. How We Share Your Information

3.1 Service Providers

We share information with third-party service providers that perform services on our behalf, including:

• Cloud storage and hosting providers;
• Analytics and performance monitoring services;
• Communication and notification services;
• Payment processors (if applicable);
• Customer support platforms;
• Security and fraud prevention services.

3.2 Partner Organizations

With your consent, we may share information with:

• Healthcare providers and medical professionals;
• Social services agencies and case management organizations;
• Housing assistance programs;
• Employment services;
• Educational institutions;
• Government benefit programs;
• Community support organizations.

3.3 Research Partners

We may share de-identified or aggregated information with:

• Academic institutions conducting research;
• Public health organizations;
• Policy research organizations;
• Other research entities studying homelessness, social services, or AI applications.

3.4 Business Transfers

We may share information in connection with:

• Mergers, acquisitions, or sales of company assets;
• Corporate reorganizations or restructurings;
• Bankruptcy or dissolution proceedings;
• Other business transactions where information transfer is necessary.

3.5 Legal Obligations and Rights Protection

We may disclose information when we believe it necessary to:

• Comply with applicable laws, regulations, or legal processes;
• Respond to lawful requests from public authorities;
• Protect and defend our rights, property, and interests;
• Protect against legal liability;
• Prevent or investigate possible wrongdoing;
• Protect the safety of any person;
• Address emergencies or situations involving potential harm.

3.6 Aggregated and De-Identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you for any purpose, including public research, advocacy, and policy development.

3.7 Consent-Based Sharing

We may share your information for any other purpose with your explicit consent.

4. Data Retention

4.1 Retention Periods

We retain your information for as long as necessary to:

• Provide you with the Application and services;
• Maintain records of services provided;
• Comply with legal obligations;
• Resolve disputes and enforce agreements;
• Conduct research and analysis;
• Support our legitimate business interests.

4.2 Deletion Practices

When information is no longer necessary for these purposes, we will:

• Delete or destroy the information securely;
• De-identify the information so it cannot be associated with you;
• Archive the information subject to appropriate safeguards.

4.3 Retention of De-Identified Data

We may retain de-identified data indefinitely for research, analysis, and service improvement purposes.

5. Data Security

5.1 Security Measures

We implement administrative, technical, and physical safeguards designed to protect your information, including:

• Encryption of data in transit and at rest;
• Access controls and authentication requirements;
• Regular security assessments and audits;
• Employee training on data protection;
• Incident response procedures;
• Secure data disposal practices.

5.2 Security Limitations

Despite our security measures, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of your information. You use the Application and provide information at your own risk.

5.3 Breach Notification

If we become aware of a security breach affecting your personal information, we will notify you in accordance with applicable law and our incident response procedures.

6. Your Rights and Choices

6.1 Access and Portability

You have the right to:

• Access personal information we hold about you;
• Receive a copy of your information in a structured, commonly used format;
• Request transmission of your information to another service provider where technically feasible.

6.2 Correction and Update

You may:

• Update or correct your account information through the Application;
• Request correction of inaccurate information we hold about you;
• Supplement incomplete information.

6.3 Deletion

You may request deletion of your personal information, subject to certain exceptions such as:

• Information necessary to complete transactions or provide services you requested;
• Information we are required to retain by law;
• Information necessary for legitimate business purposes;
• Information used for research or public interest purposes.

You can permanently delete your Casey account and associated personal data at any time — from within the Casey app, or from the web without reinstalling the app at caseyapp.ai/delete-account.

6.4 Restriction of Processing

You may request that we restrict processing of your information in certain circumstances, such as when you contest accuracy or object to processing.

6.5 Objection to Processing

You have the right to object to certain processing of your information, including processing for direct marketing purposes.

6.6 Withdrawal of Consent

Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.

6.7 Communication Preferences

You may:

• Opt out of promotional communications by following unsubscribe instructions;
• Adjust notification settings within the Application;
• Contact us to update communication preferences.

6.8 Location Information

You may disable location services through your device settings, though this may impact Application functionality.

6.9 Do Not Track

The Application does not currently respond to Do Not Track signals. We may track your activities across websites and services to provide personalized experiences.

6.10 Exercising Your Rights

To exercise any of these rights, contact us at connect@enableyou.org. We may request information to verify your identity before responding to requests.

7. Children's Privacy

7.1 Age Restrictions

The Application is not intended for individuals under eighteen (18) years of age. We do not knowingly collect personal information from children under 18.

7.2 Parental Rights

If we learn we have collected information from a child under 18 without parental consent, we will delete that information. Parents who believe we have information about their child should contact us at connect@enableyou.org.

8. California Privacy Rights

8.1 California Consumer Privacy Act (CCPA)

California residents have additional rights under the CCPA, including:

• Right to know what personal information we collect, use, disclose, and sell;
• Right to request deletion of personal information;
• Right to opt-out of the sale of personal information (we do not sell personal information);
• Right to non-discrimination for exercising privacy rights.

8.2 Categories of Information

We collect the following categories of personal information as defined by the CCPA:

• Identifiers;
• Personal information categories listed in California Customer Records statute;
• Protected classification characteristics;
• Commercial information;
• Biometric information;
• Internet or network activity information;
• Geolocation data;
• Sensory data;
• Professional or employment information;
• Education information;
• Inferences drawn from personal information.

8.3 Shine the Light

California residents may request information about disclosure of personal information to third parties for direct marketing purposes by contacting us at connect@enableyou.org.

9. International Data Transfers

9.1 Cross-Border Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States, which may have different data protection laws.

9.2 Transfer Safeguards

When we transfer information internationally, we implement appropriate safeguards, including:

• Standard contractual clauses;
• Data processing agreements;
• Compliance with applicable legal frameworks;
• Technical and organizational security measures.

9.3 Consent to Transfer

By using the Application, you consent to the transfer of your information to countries outside your country of residence.

10. Third-Party Services and Content

10.1 Third-Party Links

The Application may contain links to third-party websites, services, or content. This Policy does not apply to third-party services, which are governed by their own privacy policies.

10.2 Third-Party Data Collection

Third parties may collect information about you when you use the Application through:

• Analytics services;
• Advertising networks;
• Social media integrations;
• Embedded content;
• APIs and SDKs.

10.3 No Liability

We are not responsible for the privacy practices of third parties. We encourage you to review third-party privacy policies before providing information.

11. AI-Specific Privacy Considerations

11.1 AI Sub-Processor and Data Flow

Casey's AI assistant is powered by the Microsoft Azure OpenAI Service, which acts as our AI sub-processor. To generate responses and match you with relevant services, the Application sends the following data to the Azure OpenAI Service:

• The chat messages you send to the AI assistant;
• Relevant context drawn from your profile (such as your stated needs, situation, and goals) needed to produce a useful, personalized response.

This data is processed within EnableYou, LLC's own Microsoft Azure tenant. Azure OpenAI uses it solely to generate the assistant's response to you and to support service-matching within the Application. We do not send your data to any other AI provider, and we do not send more profile information than is reasonably necessary to answer your request.

11.2 No Use of Your Data to Train AI Models

Microsoft Azure OpenAI Service is used by us strictly as a data processor. Under Microsoft's Azure OpenAI Service terms:

• Your prompts (inputs) and the completions (outputs) generated for you are not used to train, retrain, or improve any OpenAI or Microsoft foundation models;
• Your prompts and completions are not shared with OpenAI;
• Your prompts and completions are not made available to other Microsoft customers.

This is a data-processor relationship: the Azure OpenAI Service processes your data only to deliver the Application's features to you, and not to develop, train, or commercialize AI models.

11.3 Human Review

A limited number of authorized EnableYou personnel may review AI interactions, only for the following purposes:

• Safety and abuse monitoring, including responding to content you report or flag;
• Quality assurance of the assistant's responses;
• Compliance verification and meeting our legal obligations.

AI interactions are not reviewed for the purpose of training AI models.

11.4 Your Consent and How to Withdraw It

Before you first use the AI assistant, the Application asks you to review and explicitly agree to this AI data processing through an in-app consent step that names Microsoft Azure OpenAI Service and describes the data sent to it. You can withdraw your consent at any time from the Application's settings. Withdrawing consent disables the AI assistant features, but you keep access to your profile and other saved data and may re-grant consent later. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

12. Updates to This Policy

12.1 Policy Changes

We may update this Policy periodically to reflect:

• Changes in our practices;
• Legal requirements;
• New features or services;
• User feedback;
• Industry developments.

12.2 Notification of Changes

We will notify you of material changes by:

• Posting the updated Policy in the Application;
• Updating the "Effective Date";
• Sending notice to your registered email;
• Providing in-Application notifications.

12.3 Acceptance of Changes

Continued use of the Application after Policy updates constitutes acceptance of changes. If you disagree with changes, discontinue use of the Application.

13. Contact Information

13.1 Privacy Inquiries

For questions about this Policy or our privacy practices, contact:

Privacy Officer
EnableYou, LLC
Email: connect@enableyou.org

13.2 Data Protection Officer

For data protection matters:

Email: connect@enableyou.org

13.3 General Support

For general Application support:

Email: connect@enableyou.org
Website: www.caseyapp.ai

13.4 Response Time

We endeavor to respond to privacy inquiries within thirty (30) days of receipt.

14. Legal Bases for Processing (For EEA/UK Residents)

If you are located in the European Economic Area or United Kingdom, our legal bases for processing your information include:

14.1 Consent

Processing based on your explicit consent, which you may withdraw at any time.

14.2 Contract Performance

Processing necessary to perform our contract with you or take pre-contractual steps at your request.

14.3 Legal Obligations

Processing necessary to comply with our legal obligations.

14.4 Vital Interests

Processing necessary to protect your vital interests or those of another person.

14.5 Legitimate Interests

Processing necessary for our legitimate interests or those of third parties, except where overridden by your interests or rights.

15. Additional Disclosures

15.1 No Sale of Personal Information

We do not sell, rent, or trade your personal information to third parties for monetary consideration.

15.2 Automated Decision-Making

The Application uses automated systems including AI to make recommendations and provide services. You have the right to request human review of automated decisions that significantly affect you.

15.3 Data Minimization

We collect only the information reasonably necessary to provide our services and fulfill the purposes described in this Policy.

15.4 Privacy by Design

We incorporate privacy considerations into the development and operation of our Application and services.

15.5 Accountability

We maintain records of our processing activities and privacy practices to demonstrate compliance with applicable privacy laws.