Privacy Policy

1. Introduction

Welcome to Tire Swing ("we", "us", "our"). We provide AI-powered software that helps property managers and compliance professionals process tenant eligibility documents and manage income certifications for affordable housing programs, including LIHTC and HUD Project-Based Rental Assistance (Section 8). This Privacy Policy explains what information we collect, how we use it, and how you can contact us.

This policy applies to property managers and compliance professionals who use our Service ("Customers"), as well as tenants and applicants whose information may be processed through the Service ("Data Subjects").

For most tenant and applicant information, we act as a service provider (or "processor") to our Customers, who remain responsible for how and why that data is used.

2. Information We Collect

From Customers (Property Managers):

• Account Information: Name, email address, phone number, organization name, and billing information.
• Property Data: Building addresses, unit details, and program configurations (e.g., LIHTC, HUD PBRA).
• Usage Data: Log data, feature usage, and activity within the Service.

From or About Tenants/Applicants (Processed on Behalf of Customers):

• Identity Information: Name, date of birth, Social Security number, citizenship or immigration status, disability status, and student status.
• Financial Documents: Pay stubs, tax returns (W-2s, 1099s, 1040s), bank statements, benefit award letters, and employer verification forms.
• Income & Asset Data: Employment income, Social Security benefits, pension income, child support, asset balances, and investment returns extracted from uploaded documents.
• Household Composition: Relationships between household members, head of household designation, and dependent status.
• Certification Records: Annual income certifications, move-in/move-out dates, and compliance determination history.

3. How We Collect Information

• Document Uploads: Customers upload tenant eligibility documents to the Service for processing.
• AI & OCR Extraction: We use artificial intelligence and optical character recognition to extract data from uploaded documents.
• Manual Entry: Customers may manually enter or correct information within the Service.
• Automatically: We collect technical data (IP address, browser type, device information) when you access the Service.

4. Use of Your Information

• Process and extract data from tenant eligibility documents using AI and OCR technology.
• Apply affordable housing program rules and requirements (income limits, verification rules, rent calculations).
• Generate and manage tenant income certifications for LIHTC, HUD, and other affordable housing programs.
• Maintain records required for regulatory compliance and audits.
• Improve our AI models and Service accuracy (using aggregated or de-identified data only).
• Provide customer support and troubleshoot issues.
• Communicate with Customers about their accounts and Service updates.

5. AI Processing & Document Analysis

Our Service uses artificial intelligence to extract information from uploaded documents and apply compliance rules. We process documents using third-party AI and OCR providers who are contractually obligated to maintain confidentiality and security. AI-extracted data is presented to Customers for review and approval before being used for official certifications.

We do not use tenant or applicant personal data to train general AI models. Any model improvements are made using aggregated, de-identified data that cannot be linked back to individuals.

6. Sharing of Information

• Service Providers: We share data with third-party providers who help us deliver the Service, including cloud hosting (Supabase, AWS), OCR/AI processing, and payment processing. These providers are contractually bound to protect your data.
• Regulatory Agencies: Customers may export certification data from the Service to submit to HUD, state housing finance agencies, or other regulators as required by affordable housing programs.
• Legal Requirements: We may disclose information if required by law, regulation, subpoena, or court order.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction.

We do not sell personal information to third parties.

7. Data Retention

We retain Customer account data for as long as the account is active and for a reasonable period thereafter.

Tenant and applicant data (including documents and certification records) is generally retained in accordance with affordable housing program requirements, which typically require retention for a minimum of 6 years after the end of a compliance period. Customers are responsible for understanding and communicating their specific retention requirements, and for configuring their use of the Service in line with those requirements.

Upon account termination, Customers may request export of their data within 30 days. After this period, data may be deleted or archived in accordance with our data retention policies and legal obligations.

8. Data Security

We implement technical and organizational measures to protect your data, including:

• Encryption of data at rest and in transit (TLS 1.2+)
• Access controls and authentication requirements
• Security monitoring and periodic security reviews appropriate to the Service
• Employee training on data protection

However, no system is completely secure. We cannot guarantee absolute security of your data.

9. Cookies & Tracking Technologies

We use cookies and similar technologies to operate, secure, and improve the Service. These technologies allow us to keep you logged in, remember preferences, and understand general usage patterns to help improve functionality and performance.

• Essential Cookies: Required for core functionality such as authentication, session management, and security.
• Analytics & Performance Cookies: Used to understand how the Service is accessed and used so we can improve reliability and performance.
• Preference Cookies: Used to remember settings such as language or UI preferences.

We do not use cookies for targeted advertising, cross-site tracking, or selling personal information. You can control cookie preferences through your browser settings, but disabling certain cookies may affect the functionality of the Service.

10. Data Storage & Transfers

Data is stored on servers located in the United States. If you access the Service from outside the United States, your data will be transferred to and processed in the United States.

11. Children's Privacy

The Service is intended for use by property managers and compliance professionals. We do not knowingly collect information directly from anyone under 18 years of age. Household member information for minors may be processed as part of tenant certifications, but this data is provided by adult Customers, not collected directly from minors.

12. Your Rights & Choices

For Customers: You may access, update, or delete your account information through the Service dashboard or by contacting us.

For Tenants/Applicants: We process your data on behalf of property managers. To exercise rights regarding your personal data (access, correction, deletion), please contact the property manager or owner who manages your building. They can work with us to fulfill your request.

For privacy-related requests, contact us at privacy@gettireswing.com.

13. California Privacy Rights

California residents may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected, request deletion, and opt out of the sale of personal information. We do not sell personal information. To exercise your rights, contact us at privacy@gettireswing.com.

For most personal information we handle, we act as a "service provider" to our Customers under the CCPA and process information on their behalf.

14. Changes to This Policy

We may update this Privacy Policy at any time. Material changes will be communicated via email to registered account holders or displayed within the Service. The revised date will be updated at the top of this page.