Privacy Policy

Effective date: [05/01/2020]

Lasko Refuge LLC ("Lasko Refuge," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains what information we collect through our website at laskorefuge.org (the "Site"), how we use it, who we share it with, and the choices you have.

Please read this policy carefully. By using the Site, you agree to the practices described here. If you do not agree, please do not use the Site.

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01 A note about resident and health information

This Privacy Policy applies to information collected through our public website. It does not govern the confidential health, treatment, or substance use records we maintain in the course of providing recovery housing and related services. Those records are protected under separate federal and state confidentiality laws, including the federal substance use disorder confidentiality regulations at 42 CFR Part 2 and, where applicable, the Health Insurance Portability and Accountability Act (HIPAA). We do not disclose that information except as permitted or required by those laws.

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02 Information we collect

We collect information in the following ways.

**Information you provide directly.** When you fill out our application form, our grievance form, a donation form, or otherwise contact us by email or through the Site, you may provide information such as your name, email address, phone number, mailing address, and any details you choose to include in your message or application. Because we provide recovery housing, some information you choose to share with us may relate to your health, substance use history, or recovery. You are not required to share sensitive information through the Site, and you should share only what you are comfortable providing through a website form.

**Application and grievance forms.** Our application and grievance forms are hosted by a third party form provider (Fillout). Information you submit through those forms is collected and processed by that provider on our behalf and then made available to us. Your use of those forms is also subject to the form provider's own privacy practices.

**Donation information.** If you make a donation through the Site, payment is processed by a third party payment processor. We receive confirmation of your donation and limited details such as your name and donation amount. We do not collect or store your full payment card number on our own systems.

**Information collected automatically.** Like most websites, our Site and its hosting platform automatically collect certain technical information when you visit, such as your IP address, browser type, device information, pages viewed, and the dates and times of your visits. This information is collected through cookies and similar technologies.

**Cookies and analytics.** Our Site uses cookies and similar technologies to operate the Site, remember your preferences, and understand how visitors use the Site. You can control cookies through your browser settings. Disabling cookies may affect how the Site functions.

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03 How we use your information

We use the information we collect to:

- Respond to your inquiries, applications, and grievances
- Evaluate applications for our recovery housing programs
- Process and acknowledge donations
- Operate, maintain, secure, and improve the Site
- Communicate with you about our programs and services
- Comply with our legal obligations and enforce our policies

We do not sell your personal information.

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04 How we share your information

We share personal information only in the following circumstances.

**Service providers.** We share information with third party vendors who perform services on our behalf, such as our website host (Wix), our form provider (Fillout), our payment processor, and analytics providers. These providers may access your information only to perform services for us and are expected to protect it.

**Legal and safety reasons.** We may disclose information when we believe in good faith that disclosure is necessary to comply with the law, respond to legal process, protect the rights, property, or safety of Lasko Refuge, our residents, staff, or others, or to prevent harm.

**Business transfers.** If Lasko Refuge is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction, subject to this policy.

We do not share confidential substance use or treatment records except as permitted under 42 CFR Part 2, HIPAA, and applicable state law.

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05 Third party links and platforms

Our Site links to third party platforms, including our application and grievance forms, our donation processor, and our social media pages on Facebook and Instagram. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third party site or service you use.

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06 Data security

We take reasonable administrative, technical, and physical measures to protect the information we collect. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. You share information through the Site at your own risk.

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07 Data retention

We keep personal information for as long as necessary to fulfill the purposes described in this policy, to comply with our legal obligations, resolve disputes, and enforce our agreements. When information is no longer needed, we take reasonable steps to delete or de-identify it.

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08 Your choices and rights

Depending on where you live, you may have rights regarding your personal information, such as the right to request access to, correction of, or deletion of the personal information we hold about you, and the right to opt out of certain uses. Oregon residents may have rights under the Oregon Consumer Privacy Act. To exercise any of these rights, contact us using the information below. We may need to verify your identity before responding to your request.

You can also opt out of promotional emails at any time by following the unsubscribe instructions in the email or by contacting us directly.

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09 Children's privacy

The Site is intended for adults and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information through the Site, please contact us and we will take appropriate steps to delete it.

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10 Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the effective date at the top of this page. We encourage you to review this policy periodically. Your continued use of the Site after any changes indicates your acceptance of the updated policy.

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11 Contact us

If you have questions about this Privacy Policy or how we handle your information, please contact us:

Email: [nathan@laskorefuge.org]