Privacy Policy

Our Commitment to Your Privacy

At T.O.O.L.S. Inc., we understand the importance of privacy and confidentiality, especially for individuals in the justice system. This Privacy Policy explains how we collect, use, protect, and share your personal information.

What Information We Collect

Information You Provide

• Account Information: Name, email, phone number, mailing address
• Profile Data: Educational background, employment history, program interests
• Progress Data: Course completions, certificates earned, goal tracking
• Communication: Messages with case managers, support requests

Automatically Collected Information

• Technical Data: IP address, browser type, device information
• Usage Data: Pages visited, time spent, features used
• Cookies: Session management, preferences (see Cookie Policy)

How We Use Your Information

We use your information to:

• Provide reentry support services and case management
• Track your progress and provide personalized recommendations
• Communicate with your assigned case manager (with your consent)
• Improve our services and develop new features
• Generate anonymized reports for grant funding (no personal identifiers)
• Comply with legal obligations when required by law

Data Protection & Security

Encryption

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted
• At-Rest Encryption: Your data is encrypted when stored in our databases
• Secure Authentication: Industry-standard OAuth 2.0 and Azure Active Directory

Access Controls

• Role-Based Access: Only authorized staff can view your information
• Audit Logs: All data access is logged and monitored
• Regular Security Audits: Third-party penetration testing and vulnerability assessments

Law Enforcement & Data Sharing

1. Court Order or Subpoena: When legally compelled by a valid court order
2. Imminent Threat: If we believe disclosure is necessary to prevent serious harm or death
3. Child Abuse: As mandated reporters, we must report suspected child abuse

What We Do Share (With Your Consent)

• Case Managers: Information necessary to provide support services
• Program Partners: Verified employers, educational institutions, housing providers
• Grant Funders: Anonymized, aggregated data with no personal identifiers

Your Rights & Controls

You have the right to:

• Access: Request a copy of all data we hold about you
• Correct: Update inaccurate or incomplete information
• Delete: Request deletion of your account and all associated data
• Opt-Out: Decline data sharing with specific partners
• Portability: Export your data in a machine-readable format

How to Exercise Your Rights

We will respond to requests within 30 days.

Data Retention

• Active Accounts: Data retained while your account is active
• Inactive Accounts: Deleted after 2 years of inactivity
• Legal Requirements: Some records may be retained longer to comply with legal obligations
• Your Request: You may request immediate deletion at any time

Third-Party Services

We use the following trusted partners:

• Azure (Microsoft): Cloud hosting and authentication
• Supabase: Database and authentication services
• Google Analytics: Anonymous usage statistics (opt-out available)

These partners comply with GDPR, CCPA, and other privacy regulations.

Children's Privacy

Our services are not intended for individuals under 18 without parental consent. If we discover we have collected data from a minor without consent, we will delete it immediately.

California Privacy Rights (CCPA)

California residents have additional rights:

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of sale of personal information
• Right to non-discrimination for exercising CCPA rights

We do NOT sell your personal information.

Changes to This Policy

We will notify you of material changes by:

• Email to your registered address
• Prominent notice on our website
• In-app notification

Contact Us

If you have questions about this Privacy Policy or our data practices: