PRIVACY POLICY

Effective Date: August 14, 2026
Last Updated: August 14, 2026

1. PURPOSE AND COMMITMENT TO PRIVACY

Here’s To Life, Inc. (“HTL,” “we,” “us,” or “our”) and HTL Social Enterprises, LLC (“HTL Social Enterprises”) are committed to protecting the privacy, confidentiality, security, and dignity of individuals who interact with our organizations.

This Privacy Policy explains how we collect, use, disclose, maintain, and protect information obtained through our websites, online platforms, applications, programs, services, educational activities, employment processes, fundraising activities, commercial operations, and other interactions with us.

Our organizations serve individuals, families, communities, students, program participants, clients, donors, customers, employees, applicants, contractors, partners, and other stakeholders. We recognize that some information provided to us may be personal, confidential, financial, employment-related, housing-related, or health-related.

We therefore seek to collect only information that is reasonably necessary for legitimate organizational, legal, operational, programmatic, educational, employment, or commercial purposes.

2. ORGANIZATIONS COVERED BY THIS POLICY

This Privacy Policy applies to information collected by or on behalf of:

Here’s To Life, Inc.

Here’s To Life, Inc. is a nonprofit organization that may provide or administer community-based services, housing services, supportive services, workforce development, education, recovery-related services, outreach, referrals, and other community programs.

HTL Social Enterprises, LLC

HTL Social Enterprises, LLC is an affiliated commercial enterprise that may conduct business activities including, but not limited to, apparel, printing, merchandise, food, consulting, training, digital services, e-commerce, and other social-enterprise activities.

HTL and HTL Social Enterprises may operate separate programs, websites, systems, payment platforms, databases, and customer or participant relationships. Information will be handled according to the purpose for which it was collected and applicable legal and contractual requirements.

3. INFORMATION WE COLLECT

Depending on the nature of your interaction with us, we may collect the following categories of information.

3.1 Information You Provide Directly

You may voluntarily provide information when you:

• Apply for or participate in a program;
• Request services;
• Complete an intake or eligibility application;
• Register for a class, course, workshop, or training program;
• Create an account;
• Submit a housing application;
• Request housing assistance;
• Contact our staff;
• Submit a referral;
• Apply for employment;
• Become an employee, contractor, volunteer, or intern;
• Make a donation;
• Purchase goods or services;
• Subscribe to communications;
• Submit a contact form;
• Participate in surveys or evaluations;
• Register for an event;
• Submit a complaint, grievance, or request;
• Communicate through email, telephone, text message, social media, or other channels.

Information may include:

• Name;
• Mailing address;
• Email address;
• Telephone number;
• Date of birth;
• Emergency contact information;
• Employment information;
• Education information;
• Program participation information;
• Housing information;
• Demographic information;
• Financial information;
• Payment information;
• Identification information;
• Professional information;
• Application information;
• Information voluntarily provided in communications;
• Other information reasonably necessary to provide requested services.

4. SENSITIVE AND CONFIDENTIAL INFORMATION

Certain programs may require the collection of information that is more sensitive than ordinary contact information.

Depending upon the program and applicable requirements, this may include:

• Health-related information;
• Disability-related information;
• Treatment or recovery-related information;
• Housing status;
• Income information;
• Benefits eligibility information;
• Social-service information;
• Government identification information;
• Family or household information;
• Employment information;
• Criminal-background information where legally permitted and necessary;
• Information relating to program eligibility;

Other confidential information provided by or about a participant.

We limit access to sensitive information to individuals who have a legitimate business, programmatic, legal, contractual, or operational need to access it.

We do not sell confidential client information.

5. HEALTH INFORMATION AND HIPAA

Some HTL programs may involve information concerning an individual's health, treatment, recovery, disability, or other health-related circumstances.

HIPAA does not automatically apply to every organization that handles health information. The HIPAA Privacy Rule applies to covered entities and business associates as defined under federal law.

When HTL or an affiliated entity is subject to HIPAA with respect to a particular activity, HTL will handle protected health information in accordance with applicable HIPAA requirements, contractual obligations, and other applicable privacy laws.

Where applicable, HTL may maintain separate:

Notice of Privacy Practices, HIPAA policies, Business Associate Agreements, confidentiality procedures, security policies, and/or program-specific privacy requirements.

This Privacy Policy does not replace a legally required HIPAA Notice of Privacy Practices.

6. HOUSING AND SUPPORTIVE-SERVICE INFORMATION

HTL may administer or participate in housing, rental assistance, supportive housing, homelessness prevention, housing navigation, recovery, or other social-service programs.

Information collected through these programs may include:

• Household composition;
• Housing history;
• Income;
• Employment;
• Benefits;
• Rental information;
• Landlord information;
• Eligibility documentation;
• Program participation;
• Case-management information;
• Referrals;
• Service plans;
• Documentation required by funding agencies;
• Information required for compliance, reporting, auditing, or reimbursement.

Such information will be used primarily to determine eligibility, provide services, administer programs, document service delivery, comply with funding requirements, and meet legal and contractual obligations.

When a funding agency, governmental entity, auditor, evaluator, or other authorized party requires information, HTL may disclose information as permitted or required by applicable law, regulation, grant agreement, contract, or program requirements.

7. EDUCATION AND TRAINING INFORMATION

HTL may operate or administer educational and workforce-development programs, including online learning platforms and learning management systems.

Information collected may include:

• Student name;
• Contact information;
• Enrollment information;
• Course registration;
• Attendance;
• Assignments;
• Grades or evaluations;
• Certificates;
• Completion status;
• Instructor communications;
• Career information;
• Employment outcomes;
• Credential information;
• Payment information;

Academic or training records.

• Educational information will be used to administer programs, communicate with students, provide instruction, document completion, evaluate program effectiveness, provide career support, satisfy accreditation or regulatory requirements, and comply with applicable funding requirements.

8. INFORMATION COLLECTED AUTOMATICALLY

When you visit our websites or use our online platforms, certain information may be collected automatically.

This may include:

• IP address;
• Browser type;
• Device type;
• Operating system;
• General geographic information;
• Pages visited;
• Referring website;
• Date and time of access;
• Website interactions;
• Login activity;
• Cookies and similar technologies.
• We may use this information to:
• Maintain website functionality;
• Improve website performance;
• Understand website usage;
• Protect against fraud and abuse;
• Troubleshoot technical problems;
• Improve user experience;
• Maintain security;
• Analyze traffic and engagement.

9. COOKIES AND TRACKING TECHNOLOGIES

Our websites and third-party service providers may use cookies, pixels, tags, analytics tools, and similar technologies.

Cookies may be used to:

• Keep users logged in;
• Remember preferences;
• Improve website functionality;
• Analyze website traffic;
• Measure marketing performance;
• Improve services;

Detect fraudulent or suspicious activity.

You may be able to control cookies through your browser settings.

Disabling certain cookies may affect the functionality of portions of our websites.

10. HOW WE USE INFORMATION

We may use information for legitimate organizational purposes, including:

Service Delivery

To provide, coordinate, manage, and improve services.

Program Administration

To determine eligibility, administer programs, document participation, and evaluate outcomes.

Housing Services

To determine eligibility, coordinate housing assistance, communicate with landlords and partners, and satisfy applicable program requirements.

Education and Workforce Development

To administer enrollment, instruction, assessments, credentials, career services, and workforce programs.

Employment

To process employment applications, conduct onboarding, manage employment relationships, administer payroll and benefits, and meet legal obligations.

Donations and Fundraising

To process donations, maintain donor records, issue acknowledgments, and communicate with donors.

Commercial Transactions

HTL Social Enterprises may use customer information to process orders, provide products or services, communicate with customers, process payments, and manage business operations.

Communications

We may use contact information to communicate regarding services, appointments, applications, purchases, classes, events, organizational announcements, or other requested information.

Security

We may use information to detect, investigate, prevent, and respond to fraud, abuse, unauthorized activity, security incidents, and other threats.

Legal and Regulatory Compliance

We may use information when necessary to comply with applicable laws, regulations, court orders, subpoenas, contracts, grants, audits, or governmental requirements.

11. WHEN WE MAY SHARE INFORMATION

We may disclose information to appropriate third parties when necessary and legally permitted.

These parties may include:

• Government agencies;
• Funding agencies;
• Grant administrators;
• Program partners;
• Service providers;
• Contractors;
• Consultants;
• Auditors;
• Accountants;
• Attorneys;
• Technology providers;
• Payment processors;
• Learning-management-system providers;
• Housing providers and landlords;
• Referral organizations;
• Employers and workforce partners;
• Insurance providers;
• Background-check providers;
• Emergency-service providers;
• Law enforcement when legally required or permitted;

Other parties authorized by the individual.

We seek to limit disclosures to information reasonably necessary for the purpose of the disclosure.

12. SERVICE PROVIDERS AND VENDORS

We may use third-party companies to perform services on our behalf.

These may include providers for:

• Website hosting;
• Cloud storage;
• Email;
• Text messaging;
• Payment processing;
• E-commerce;
• Customer relationship management;
• Learning management;
• Accounting;
• Payroll;
• Human resources;
• Data analytics;
• Cybersecurity;
• Marketing;
• Communications;
• Scheduling;

Document management.

Service providers may have access to information necessary to perform their services but are not authorized to use information for purposes inconsistent with our instructions, contracts, or applicable law.

Where required by law or contract, appropriate confidentiality, security, or data-processing provisions will be implemented.

13. PAYMENT INFORMATION

When you make a purchase, donation, registration payment, or other transaction, payment information may be processed through third-party payment processors.

We generally do not need to maintain complete credit-card numbers when payment processing is performed by an external payment processor.

Payment processors may independently process information according to their own privacy policies and contractual obligations.

HTL Social Enterprises does not intentionally request that customers provide complete payment-card information through unsecured email, text messages, or ordinary website contact forms.

14. DONOR INFORMATION

HTL may collect information from donors, including:

• Name;
• Contact information;
• Donation amount;
• Donation date;
• Payment information;
• Communication preferences;
• Organizational affiliation;
• Other information voluntarily provided.
• Donor information may be used to:
• Process donations;
• Provide receipts;
• Maintain accounting records;
• Meet legal requirements;
• Acknowledge donations;
• Communicate with donors;

Conduct fundraising activities.

HTL does not sell donor lists.

HTL may disclose donor information to service providers that assist with payment processing, accounting, fundraising, communications, or legally required reporting.

15. EMPLOYEE, APPLICANT, CONTRACTOR, AND VOLUNTEER INFORMATION

Information collected from job applicants, employees, contractors, interns, and volunteers may include:

• Resume information;
• Employment history;
• Education;
• References;
• Contact information;
• Identification information;
• Payroll information;
• Tax information;
• Benefits information;
• Performance information;
• Training records;
• Background-check information where permitted;

Other information necessary to administer the employment or volunteer relationship.

Employment-related information may be shared with payroll providers, benefits administrators, insurers, background-check providers, governmental agencies, legal advisors, and other authorized service providers.

16. CHILDREN AND MINORS

Our services may involve children or minors in certain circumstances.

We do not knowingly collect personal information from children through general public-facing websites for purposes unrelated to legitimate program participation.

When services involve minors, information may be collected from parents, guardians, schools, governmental agencies, referral organizations, or other authorized sources as permitted by law.

Where required, appropriate parental or guardian consent will be obtained.

17. SOCIAL MEDIA

HTL and HTL Social Enterprises may maintain social-media accounts and pages.

If you interact with us through a social-media platform, information may also be collected and processed by that platform according to its own privacy policy.

Public comments, posts, reviews, photographs, or other information submitted publicly may be visible to others.

We encourage individuals not to post confidential, health-related, housing-related, financial, or other sensitive information publicly.

18. TEXT MESSAGES AND ELECTRONIC COMMUNICATIONS

If you voluntarily provide a telephone number or email address, we may use it to communicate with you regarding services, appointments, applications, purchases, classes, programs, or other matters related to your relationship with us.

Where required, we will obtain appropriate consent for marketing text messages or other regulated communications.

You may opt out of certain communications by following the instructions contained in the communication or contacting us directly.

Opting out of marketing communications does not necessarily prevent transactional, administrative, legal, or service-related communications.

19. MARKETING COMMUNICATIONS

We may communicate with individuals about:

• Programs;
• Events;
• Classes;
• Services;
• Fundraising opportunities;
• Products;
• Promotions;
• Organizational announcements;
• Newsletters;
• Community activities.

Individuals may unsubscribe from promotional email communications using the unsubscribe mechanism provided in the communication.

We do not condition access to essential services on consent to receive promotional communications.

20. INFORMATION SHARING BETWEEN HTL AND HTL SOCIAL ENTERPRISES

HTL and HTL Social Enterprises are affiliated organizations but may have separate legal, operational, financial, and programmatic responsibilities.

Information may be shared between the organizations only when reasonably necessary and legally permitted for purposes such as:

• Administrative support;
• Accounting;
• Information technology;
• Human resources;
• Shared services;
• Program coordination;
• Customer service;
• Organizational operations;
• Security;
• Legal compliance;

Contract administration.

Sensitive client, health, housing, or program information will not be shared merely because the organizations are affiliated.

Any sharing of protected information must comply with applicable law, contractual requirements, funding requirements, and organizational policies.

21. INFORMATION SECURITY

We use reasonable administrative, technical, and physical safeguards designed to protect information from:

• Unauthorized access;
• Unauthorized disclosure;
• Loss;
• Theft;
• Misuse;
• Alteration;
• Destruction.
• Security measures may include:
• Access controls;
• Password protection;
• Multi-factor authentication where available;
• Role-based access;
• Encryption where appropriate;
• Secure cloud services;
• Physical safeguards;
• Employee confidentiality requirements;
• Security awareness training;
• Vendor controls;
• Backup procedures;
• Incident-response procedures.

No method of transmitting or storing information is completely secure. Therefore, we cannot guarantee absolute security.

22. EMPLOYEE CONFIDENTIALITY

Employees, contractors, volunteers, interns, and other individuals who have access to confidential information may be required to comply with organizational confidentiality and information-security requirements.

Access to confidential information should be limited to the minimum information reasonably necessary to perform assigned responsibilities.

Unauthorized access, disclosure, copying, downloading, photographing, transmitting, or use of confidential information may result in disciplinary action, termination of access, termination of employment or contract, and/or legal action.

23. DATA RETENTION

We retain information for as long as reasonably necessary to:

• Provide services;
• Administer programs;
• Maintain financial records;
• Meet grant requirements;
• Satisfy legal obligations;
• Comply with regulatory requirements;
• Resolve disputes;
• Maintain appropriate business records;
• Protect organizational interests;
• Document program outcomes;
• Complete audits;
• Enforce agreements.

Certain records may be retained for periods longer than necessary for ordinary business operations because of legal, grant, funding, regulatory, tax, employment, housing, or contractual requirements.

When information is no longer required, it may be securely deleted, destroyed, anonymized, or otherwise disposed of in accordance with applicable requirements.

24. DATA BREACHES AND SECURITY INCIDENTS

If we determine that unauthorized access to personal information has occurred, we will evaluate the incident and take reasonable steps to contain, investigate, remediate, and respond to the incident.

Where applicable law requires notification, we will provide legally required notices to affected individuals, governmental authorities, funding agencies, or other parties.

The FTC emphasizes that organizations should make sure their privacy practices match the promises made in their privacy policies and should maintain reasonable security practices.

25. INDIVIDUAL PRIVACY RIGHTS

Depending upon applicable law and the nature of the information involved, individuals may have rights concerning their personal information.

These may include the right to:

• Request access to certain personal information;
• Request correction of inaccurate information;
• Request deletion where legally permitted;
• Request information regarding how personal information is used;
• Withdraw certain consents;
• Opt out of certain marketing communications;
• Request restrictions on certain uses;
• File a privacy-related complaint.

These rights may be subject to legal exceptions and limitations.

For example, we may be required to retain information for legal, regulatory, contractual, funding, accounting, security, or programmatic purposes.

26. REQUESTING ACCESS OR CORRECTION

Individuals who wish to request access to or correction of personal information should submit a written request to:

Privacy Officer
Here’s To Life, Inc. / HTL Social Enterprises, LLC
Privacy Email: info@herestolifeatl.org
Mailing Address: 1115 Ralph David Abernathy Blvd SW, Atlanta, GA 30310

Requests should include enough information to allow us to identify the individual and locate the relevant information.

We may need to verify identity before fulfilling certain requests.

27. VERIFICATION OF PRIVACY REQUESTS

To protect personal information, we may take reasonable steps to verify the identity of an individual submitting a privacy request.

We will not request unnecessary sensitive information solely for identity verification.

If an authorized representative submits a request on behalf of another individual, we may require reasonable documentation demonstrating authorization.

28. INFORMATION ABOUT THIRD PARTIES

This Privacy Policy does not govern the privacy practices of third-party websites, platforms, applications, social-media services, payment processors, vendors, or other external organizations.

Our websites may contain links to third-party websites.

Once you leave our website, the third party's privacy practices may apply.

We encourage users to review the privacy policies of third-party websites before providing personal information.

29. THIRD-PARTY ANALYTICS AND ADVERTISING

We may use third-party analytics and marketing technologies to understand website traffic, engagement, and the effectiveness of communications.

Depending on the technology used, these providers may receive information such as:

• IP address;
• Device information;
• Browser information;
• Website activity;
• Referral information;
• Approximate location;
• Advertising or campaign identifiers.

We will evaluate third-party services before implementation and seek to configure them in a manner consistent with applicable privacy requirements.

30. SALE OF PERSONAL INFORMATION

HTL does not sell client, participant, donor, student, housing, or health information.

HTL Social Enterprises does not sell personal information in exchange for monetary consideration where prohibited by applicable law.

Information may nevertheless be disclosed to service providers and business partners when reasonably necessary to provide services, process transactions, administer programs, operate websites, fulfill orders, or perform legitimate organizational functions.

31. NO DISCRIMINATION FOR PRIVACY REQUESTS

We will not knowingly discriminate against an individual for exercising a privacy right that is legally available to that individual.

However, certain services require information to determine eligibility, provide services, process transactions, satisfy legal requirements, or comply with program requirements.

If information necessary to provide a requested service is not provided, we may be unable to provide that service.

32. GOVERNMENT, LEGAL, AND LAW-ENFORCEMENT DISCLOSURES

We may disclose information when reasonably necessary to:

• Comply with applicable law;
• Respond to a valid subpoena, court order, or legal process;
• Respond to a governmental request;
• Protect the safety of an individual;
• Protect organizational property;
• Investigate fraud or abuse;
• Prevent illegal activity;
• Enforce contracts or policies;
• Defend legal claims;
• Comply with grant or funding requirements.

Where legally permitted, we may seek to limit disclosures to information reasonably necessary for the applicable purpose.

33. EMERGENCY DISCLOSURES

In circumstances involving an emergency or serious threat to health or safety, information may be disclosed to appropriate persons or authorities when permitted or required by law.

The amount of information disclosed will be limited to what is reasonably necessary under the circumstances.

34. RECORDS SUBJECT TO SPECIAL REQUIREMENTS

Certain records may be subject to additional confidentiality or disclosure restrictions.

These may include, depending upon the circumstances:

• Protected health information;
• Substance-use-disorder treatment records;
• HIV/AIDS-related information;
• Mental-health information;
• Domestic-violence or victim-service information;
• Housing-program records;
• Student records;
• Employment records;
• Government-funded program records;
• Legal records;
• Financial records.

Where a special federal or state confidentiality requirement applies, HTL will follow the applicable requirement.

This Privacy Policy does not authorize a disclosure that is prohibited by a more restrictive law, regulation, grant agreement, contract, or confidentiality requirement.

35. DATA MINIMIZATION

HTL and HTL Social Enterprises seek to follow a data-minimization approach.

This means we seek to:

• Collect information for legitimate purposes;
• Avoid collecting information that is unnecessary;
• Limit access to individuals who need it;
• Use information only for appropriate purposes;
• Retain information only as long as reasonably necessary;
• Secure information throughout its lifecycle;
• Dispose of information appropriately.

36. ACCURACY OF INFORMATION

We seek to maintain accurate and reasonably current information.

Individuals are encouraged to notify us when information relevant to their services, account, employment, program participation, or other relationship with us changes.

We may rely on information provided by individuals, governmental agencies, funding sources, referral partners, employers, educational institutions, or other authorized sources.

37. INTERNATIONAL USERS

Our organizations primarily operate in the United States.

Our websites or services may nevertheless be accessible from outside the United States.

Unless otherwise stated, information submitted through our services may be processed and stored in the United States.

Individuals accessing our services from other jurisdictions should understand that privacy laws may differ from those in their jurisdiction.

38. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.

Changes may be made to reflect:

• Changes in law;
• Changes in organizational structure;
• New programs;
• New technologies;
• New services;
• Changes to websites;
• Changes in data practices;
• Security improvements;
• Regulatory requirements.

The updated policy will be posted on applicable organizational websites.

The “Last Updated” date at the beginning of this Privacy Policy indicates when the policy was most recently revised.

39. CONTACT US

Questions, concerns, requests, or complaints concerning privacy may be directed to:

Privacy Officer
Here’s To Life, Inc.
HTL Social Enterprises, LLC

Email: HTLEnt@HTLSocialEnterprises.com

Telephone: 470-772-0000

Mailing Address:1115 Ralph David Abernathy Blvd SW, Atlanta, GA 30310

Individuals may request information concerning our privacy practices or submit a privacy-related complaint through the contact information above.

40. PRIVACY COMPLAINTS

We take privacy concerns seriously.

Individuals are encouraged to first contact HTL so that we can investigate and attempt to resolve the concern.

A privacy complaint should, when possible, include:

• Name;
• Contact information;
• Description of the concern;
• Date or approximate date of the incident;
• Program or service involved;
• Relevant documentation;
• Requested resolution.

HTL will review complaints in accordance with applicable organizational procedures and legal requirements.

41. ORGANIZATIONAL PRIVACY PRINCIPLES

HTL and HTL Social Enterprises are guided by the following principles:

RESPECT

We treat personal information as information entrusted to us.

NECESSITY

We seek to collect information that is reasonably necessary for legitimate purposes.

CONFIDENTIALITY

We limit access to confidential information.

SECURITY

We implement reasonable safeguards designed to protect information.

TRANSPARENCY

We seek to communicate clearly about how information is used.

ACCOUNTABILITY

We expect employees, contractors, volunteers, and service providers to handle information responsibly.

DIGNITY

We recognize that information about housing, health, finances, employment, family circumstances, and other personal matters can significantly affect an individual's dignity and well-being.

42. ACKNOWLEDGMENT

By using our websites, submitting information, participating in applicable programs, purchasing products or services, applying for employment, donating, enrolling in educational activities, or otherwise interacting with HTL or HTL Social Enterprises, you acknowledge that you have had an opportunity to review this Privacy Policy.

Where applicable law requires separate consent, authorization, acknowledgment, or notice, that additional requirement will apply.

DOCUMENT CONTROL

Document Title: Privacy Policy
Organizations: Here’s To Life, Inc. & HTL Social Enterprises, LLC
Effective Date: August 14, 2026
Review Frequency: At least annually and whenever material changes occur in law, technology, programs, organizational structure, or data practices
Responsible Department: Administration / Compliance / Privacy Officer
Version: 1.0

Approved By: ______________________________

Title: ____________________________________

Date: _____________________________________