Privacy Policy
Version 2.0 • Effective January 15, 2025
1. Introduction
The Way Home, LLC ("TWH," "we," "us," "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect Personal Information through our Services.
Data Controller: The Way Home, LLC
4320 Dr. Martin Luther King Jr. Blvd., Kansas City, Missouri 64130
Data Protection Officer: [email protected]
2. Information We Collect
2.1 Information You Provide
- Account registration data
- Investment preferences and history
- Communications with us
- Survey responses
2.2 Automatically Collected Information
- Device identifiers and IP addresses
- Browser type and operating system
- Usage data and analytics
- Cookies and similar technologies
2.3 Third-Party Sources
We may obtain information from:
- Identity verification services
- Public records databases
- Credit reporting agencies (with consent)
- Professional data providers
2.4 Sensitive Information
With explicit consent, we collect:
- Demographic data (race, ethnicity, gender identity)
- Financial information
- Government identifiers (for compliance)
3. Legal Basis for Processing
We process Personal Information based on:
4. How We Use Information
We use Personal Information to:
- Provide and personalize Services
- Process investments and donations
- Comply with legal obligations
- Prevent fraud and enhance security
- Send communications (with consent)
- Improve Services through analytics
6. Data Retention
| Data Type | Retention Period |
|---|---|
| Account data | Duration of account plus 2 years |
| Investment records | 7 years (tax compliance) |
| Marketing data | 3 years from last interaction |
| Technical logs | 90 days |
| Cookies | Per cookie type (session/2 years) |
7. Your Privacy Rights
Access & Portability
Right to obtain copy of Personal Information in structured format
Correction
Right to correct inaccurate information
Deletion
Right to request deletion, subject to legal obligations
Opt-Out
Right to opt-out of marketing, data sales, and automated decisions
8. State-Specific Rights
California Residents (CCPA/CPRA)
- Right to know categories collected
- Right to non-discrimination
- Right to limit use of sensitive data
- Response within 45 days to verified requests
Colorado, Connecticut, Virginia Residents
- Right to opt-out via Universal Opt-Out Mechanisms
- Data portability rights
- Right to correct inaccuracies
Additional State Rights
Delaware, Iowa, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, and Tennessee residents have rights under respective state laws effective 2025.
9. Children's Privacy
Services are not directed to individuals under 18. We do not knowingly collect information from minors. If discovered, we will promptly delete such information.
11. AI and Automated Processing
We Use AI For:
- Investment matching
- Risk assessment
- Fraud detection
- Personalized recommendations
Your Rights:
- Request human review
- Understand decision logic
- Correct input data
- Opt-out where permitted
13. Security Measures
We implement commercially reasonable measures including:
Encryption
Multi-Factor Auth
Access Controls
Regular Audits
18. Contact Information
Mailing Address
The Way Home
4320 Dr. Martin Luther King Jr. Blvd.
Kansas City, Missouri 64130
Data Protection Officer: [email protected]
We may update this Policy with 30 days' notice for material changes. Continued use constitutes acceptance.