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EFFECTIVE DATE: FEBRUARY 6, 2026

1. Introduction

Jefferson East, Inc. (“JEI,” “Company,” “we,” “our,” or “us”) is committed to protecting the privacy of all individuals, families, small business owners, and entrepreneurs who seek our assistance or participate in our programs. We understand that the information you share with us is often personal and sensitive in nature. We want to assure you that all personal and business information—whether shared orally, electronically, or in writing—will be handled with the utmost care, in accordance with applicable ethical standards and privacy laws.

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This Privacy Policy explains how JEI collects, uses, discloses, and safeguards your nonpublic personal and business information. It also describes your rights regarding your information and our practices related to SMS/text messaging communications. We encourage you to review it carefully to understand our commitment to confidentiality and the steps we take to protect your data. This Privacy Policy applies to information collected through our website, applications, forms, email correspondence, phone communications, SMS/text messaging programs, and in-person interactions.

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2. Information We Collect

We collect personal information about you from the following sources and in the following categories:

What is Nonpublic Personal and Business Information?

Nonpublic personal and business information refers to any information that identifies an individual or a business and is not otherwise publicly available. This includes, but is not limited to:

• Personal Identifiers: Information such as your name, address, date of birth, phone number (including mobile number), email address, Social Security Number, driver’s license number, or other government-issued identification.

• Demographic and Sensitive Data: Information such as race, ethnicity, gender, or household composition, collected only when required or permitted by law and used solely for program reporting or compliance.

• Personal Financial Information: Details such as your credit history, income, employment information, financial assets, bank account details, and outstanding debts.

• Business Information: Nonpublic data related to your business, including your business name (if not publicly registered), Employer Identification Number (EIN), business address, ownership details, financial statements, tax records, payroll data, vendor information, and other proprietary or operational details shared with JEI in connection with technical assistance, grants, or program support.

• Digital and Application Information: Information collected through applications, forms, or online services, including email correspondence, survey responses, or uploaded documents containing personally or commercially sensitive information.

• SMS/Text Messaging Information: When you opt in to our SMS messaging program, we collect your name and mobile phone number. We use this information solely for the purpose of sending you text message communications as described in this policy.

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JEI does not collect or disclose any information that is publicly available, such as business information already filed with public agencies or listed in public directories, unless it is combined with other nonpublic information you provide.

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Sources of Information

We collect personal information from the following sources:

• Information that you provide on applications, forms, our website, email, or verbally;

• Information about your transactions with us, our affiliates, or others;

• Information we receive from your creditors or employment references, including credit reports;

• Information collected when you opt in to receive SMS/text messages from us.

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3. How We Use Your Information

We use the collected information for the following purposes:

• To provide and improve our housing counseling, technical assistance, and program services.

• To communicate with clients, customers, and program participants regarding inquiries, transactions, and program updates.

• To send SMS/text messages to individuals who have opted in, including appointment reminders, program updates, follow-up communications, and two-way conversations to answer questions.

• To comply with legal obligations, including reporting requirements to Federal (HUD) and State (MSHDA) Housing Authorities.

• To enforce agreements and prevent fraud.

• To evaluate our programs, gather research information, and design future programs.

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4. Legal Basis for Processing

We process personal information based on one or more of the following legal bases:

• Your consent (where required by law, including consent to receive SMS/text messages).

• Performance of a contract or to take steps before entering a contract.

• Compliance with legal obligations.

• Legitimate business interests that do not override your rights and freedoms.

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5. Sharing and Disclosure of Information

We may disclose personal information to the following parties and for the following purposes:

• Financial service providers (such as companies providing home mortgages), for program-related purposes.

• Federal (HUD) and State (MSHDA) Housing Authorities, for program review, monitoring, auditing, research, and/or oversight purposes.

• Any other pre-authorized individual and/or organization, as consented to by you.

• Legal authorities as required by law or to protect our rights.

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The types of information we may disclose include:

• Information you provide on applications, forms, or other communications, which may include your name, address, Social Security Number, employer, occupation, account numbers, assets, expenses, and income.

• Information about your transactions with us, our affiliates, or others, such as account balance, monthly payment, payment history, and method of payment.

• Information we receive from consumer credit reporting agencies, such as credit bureau reports, credit and payment history, credit scores, and creditworthiness.

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We do not sell or rent your personal information to any outside entity. We do not sell, rent, loan, trade, lease, or otherwise transfer to any third party any phone numbers or personal data collected through our SMS/text messaging program for the purpose of initiating a text message to such numbers. Your consent to receive SMS messages is not a condition of purchasing any goods or services from JEI.

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We may share anonymous, aggregated case file information; however, this information will not be disclosed in a manner that would personally identify you. This is done to evaluate our programs, gather research information, and design future programs. We may also disclose personal information about you to third parties as permitted by law.

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6. SMS/Text Messaging Terms and Conditions

Jefferson East, Inc. offers an SMS/text messaging program to communicate with clients and program participants. By opting in to receive text messages from JEI, you agree to the following terms:

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Opt-In and Consent

By providing your mobile phone number and consenting to receive text messages—whether through our website, an application form, or verbally—you expressly consent to receive SMS/MMS messages from Jefferson East, Inc. These messages may include, but are not limited to:

• Appointment reminders and scheduling updates

• Program updates and status notifications

• Follow-up communications regarding your case or inquiry

• Two-way conversational messages to answer your questions

• Satisfaction follow-ups and surveys

Your consent to receive text messages is not required as a condition of receiving any services from JEI.

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Message Frequency

Message frequency may vary depending on the nature of your engagement with JEI. Messages are not recurring automated marketing messages; frequency depends on your active case or program participation.

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Message and Data Rates

Message and data rates may apply. Please contact your wireless carrier for details regarding your messaging plan. JEI is not responsible for any carrier fees or charges associated with receiving text messages.

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Opt-Out

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You may opt out of receiving text messages from JEI at any time by replying STOP to any message you receive from us. After opting out, you will receive a confirmation message stating:

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"Jefferson East, Inc.: You will receive no further messages from us. If this was in error, reply UNSTOP to continue receiving messages."

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After opting out, we will remove your number from our messaging list. No further messages will be sent unless you re-subscribe.

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Help

For assistance, reply HELP to any message you receive from us. You will receive a response such as:

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"Jefferson East, Inc.: For help or information, please contact us via resourcehub@jeffersoneast.org or call (313) 331-7939. Reply STOP to opt out of messaging."

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Carrier Liability

Carriers, including but not limited to AT&T, Verizon, and T-Mobile, are not liable for delayed or undelivered messages. Delivery of text messages is subject to effective transmission by your mobile carrier and is not guaranteed by JEI.

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SMS Data Collection and Privacy

When you opt in to our SMS program, we collect your name and mobile phone number. We use this information solely for sending text message communications as described in this policy. We do not sell, rent, loan, trade, lease, or otherwise transfer for profit any phone numbers or personal data collected through our SMS program to any third party. Your information will be stored securely and retained only as long as you are subscribed to our messaging program or as required by law. You may request deletion of your SMS-related data at any time by contacting us.

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7. Use by Children

Our services are not directed to children. We do not seek or knowingly collect information from individuals under the age of 13, and we request that such individuals do not provide personal information through our services or SMS program.

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8. Your Privacy Rights

Depending on your state of residence, you may have the right to:

• Access and request copies of your personal information.

• Request correction or deletion of your personal information.

• Opt out of certain processing activities, including direct marketing, automated decision-making, and SMS/text messaging.

• Exercise rights under the California Consumer Privacy Act (CCPA) if you are a California resident, including the right to opt out of the sale of personal information.

To exercise your rights, please contact us at resourcehub@jeffersoneast.org

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9. Data Retention and Security

We restrict access to your nonpublic personal information to JEI employees who need to know that information in order to perform their duties. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We train our staff to safeguard client information and prevent unauthorized access, disclosure, or use. We retain personal information as long as necessary for business, program, or legal purposes. SMS-related data is retained only for the duration of your participation in our messaging program unless otherwise required by law.

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10. Compliance with the Telephone Consumer Protection Act (TCPA)

JEI complies with the Telephone Consumer Protection Act (TCPA) and all applicable federal and state regulations governing SMS/text messaging and telecommunications. We will only send text messages to individuals who have provided express consent. You may opt out of receiving messages at any time by following the instructions provided in the message (reply STOP). We process opt-out requests promptly and will not send further messages after receiving your opt-out request. We do not send text messages before 8:00 AM or after 9:00 PM in the recipient’s local time zone.

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11. Cookies and Tracking Technologies

We may use cookies and similar technologies to enhance user experience and analyze website usage. You can manage cookie preferences through your browser settings. Technical data collected may include IP address, browser type, and usage data.

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12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Please review the “Effective Date” at the top of this page to see when this Privacy Policy was last revised. Any changes will be posted with an updated effective date. If we make any material changes, we will notify you as required by law, which may include by email or by means of a notice on our website prior to the change becoming effective. Your continued use of our services following these changes means that you acknowledge the revised Privacy Policy.

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13. Contact Information

If you have any questions or concerns about this Privacy Policy, our SMS messaging program, or wish to exercise any of your privacy rights, please contact us at:

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Jefferson East, Inc.

300 River Place, Suite 5250, Detroit, MI 48207

Email: resourcehub@jeffersoneast.org

Phone: (313) 331-7939

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We try to respond to general privacy inquiries within 30 days or as otherwise required by law. Requests to opt out of our SMS messaging will be processed promptly, typically within one business day.

 

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