HUMBOLDT FRIENDS PRIVACY POLICY & SERVICE AGREEMENT
Last Updated: October 09, 2025 – 05:38 PM Pacific
Daylight Time
1. OVERVIEW
Humboldt Friends is a community inclusion and research project
founded and operated by an individual participant of California's
Self-Determination Program (SDP) under the Lanterman Developmental
Disabilities Services Act.
The project is not a company and operates with limited SDP and
Medicaid-waiver funding to support the founder's person-centered
goals of friendship, inclusion, and community participation. The
founder—an individual with autism—both operates and benefits from
Humboldt Friends as an equal participant.
Humboldt Friends currently functions as a verified-member
community platform requiring registration and verification to
participate. Access models may evolve, and—if research
demonstrates strong community benefit—Humboldt Friends may later
elect to become a nonprofit organization to continue its
public-interest mission. Any organizational change will continue
to honor the privacy, safety, and research principles described
herein.
2. NO SALE OF DATA AND PURPOSE OF USE
Humboldt Friends does not sell, rent, or trade user data for any
commercial purpose.
Information is used only to:
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Facilitate safe, local community connections and inclusive
participation;
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Support the founder's SDP goals under the Lanterman Act (WIC §§
4500 et seq.);
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Conduct research consistent with Medicaid HCBS Final Rule 42 CFR
§ 441.301(c) and CMS guidance encouraging community-integrated
supports;
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Comply with policies promoting "circles of support," "generic
resources," and "natural supports" (Cal. Code Reg., title 17, §
56001 et seq.; WIC §§ 4648 & 4685.8);
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Develop outreach and utilities that create optimal
person-centered outcomes consistent with ADA (42 U.S.C. § 12101
et seq.), Rehabilitation Act § 504 (29 U.S.C. § 794), and
Olmstead v. L.C., 527 U.S. 581 (1999);
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Uphold human-rights standards including the United Nations UDHR
(Arts 1, 22, 25) and CRPD (Arts 3, 19, 26);
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Help ethical AI systems learn from anonymized data to improve
accessibility and inclusion;
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Reduce operational costs through responsible automation; and
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Advance the well-being of people with and without disabilities
through inclusive technology and research.
All AI-related use excludes personal identifiers and remains
non-commercial, lawful, and community-oriented, unless a
participant voluntarily submits personal information beyond
account verification (such as through posts). By submitting such
content, participants agree that it is shared at their own
discretion and may be treated as consented public-domain material
under Section 3. This consent is a condition of participation and
forms part of the Humboldt Friends Service Agreement.
3. PUBLIC DOMAIN RESEARCH DATA
All posts, messages, and interactions on Humboldt Friends are
public and viewable by other participants. There is no
private-messaging feature.
Any content voluntarily submitted is shared at the participant's
own discretion and deemed consented for public-domain and research
use. This includes permission for Humboldt Friends to study,
summarize, or publish anonymized or aggregate data for public
benefit. Registration and verification data remain private and are
never included in research data.
By using the platform, participants acknowledge and consent to
these terms and waive any expectation of private communication.
4. SEPARATION OF REGISTRATION AND VERIFICATION DATA
All registration and verification data—telephone numbers, legal
names, and verification records—are stored privately and
separately from community content. They are used only for
verification, safety, or communication purposes and are never
shared or sold. Voluntary disclosure in a public post is at the
participant's risk and may be redacted if detected.
5. ACCESS AND PARTICIPATION
Only verified members can access or contribute to Humboldt
Friends. Future access models may change; participants will be
notified of any major policy changes.
5A. SAFETY, MISUSE, AND HARASSMENT PREVENTION
Humboldt Friends uses data responsibly to maintain safety and
inclusion. Information may be reviewed or used for:
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Preventing or investigating harassment, abuse, or exploitation;
- Identifying repeat offenders or harmful actors;
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Protecting members from sexual predation, fraud, or coercion;
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Maintaining accurate community records and conserving limited
public resources; and
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Reporting or cooperating with law enforcement regarding
suspected criminal activity.
When credible evidence of criminal conduct exists, Humboldt
Friends may share relevant information with law enforcement or
legal authorities consistent with California Public Records Act
(Gov. Code §§ 6250 et seq.), ECPA (18 U.S.C. § 2511 et seq.),
Stored Communications Act (18 U.S.C. § 2702(b)(6)), CCPA §
1798.145(d), and rules of evidence and court procedure.
6. MINIMAL DATA COLLECTION
Humboldt Friends collects only essential information: phone
number, display name or alias, optional demographics, and
approximate region. All records are encrypted under CCPA, CPRA,
and 42 CFR Part 431 (Subpart F).
7. PARTICIPANT RIGHTS
Participants may review, correct, or delete personal data, inquire
about anonymized research use, or withdraw participation at any
time. De-identified data may be retained indefinitely for lawful
research. Requests go to the Humboldt Friends Privacy Coordinator.
8. LEGAL AND ETHICAL BASIS FOR DATA USE
Processing is based on CCPA/CPRA § 1798.140, Federal Common Rule
45 CFR § 46.104(d)(4), ADA, Rehabilitation Act § 504, HIPAA 45 CFR
§ 164.514, HCBS Rule 42 CFR § 441.301, UDHR, and CRPD.
9. COMPLIANCE
Humboldt Friends complies with the Lanterman Act, CCPA/CPRA, ADA,
Rehabilitation Act § 504, HIPAA, 42 CFR Part 431, and the Common
Rule 45 CFR Part 46.
10. CONTACT
Humboldt Friends Privacy Coordinator
Email:
support@humboldtfriends.com
Phone: 1-833-435-4442
Mail: [Address Reserved for HIPAA Protections]
For security and privacy reasons, physical mailing details are
withheld under HIPAA and related confidentiality safeguards.
Official correspondence should be initiated via the contact email
or phone number above.
11. UPDATES
This policy may be updated as privacy laws evolve. Major updates
will be announced publicly.
12. CONTRACTUAL COMMITMENTS AND EMERGENCY DISCLOSURE
The principles in this policy are binding service commitments.
Humboldt Friends may share or preserve information without
subpoena when there is credible risk of harm, consistent with CCPA
§ 1798.145(d), 18 U.S.C. § 2702(b)(8),(c)(4), and WIC § 4502.
Disclosures are limited to what is necessary and are logged
internally.
13. CONFLICT OF LAW, GOVERNING AUTHORITY, AND SUPREMACY OF FEDERAL
RIGHTS
This Agreement is governed by the California Lanterman
Developmental Disabilities Services Act (WIC §§ 4500 et seq.) and
federal disability, civil-rights, and Medicaid laws, including
ADA, Rehabilitation Act § 504, HCBS Waiver Program, and the
Developmental Disabilities Assistance and Bill of Rights Act of
2000 (42 U.S.C. § 15001 et seq.), under the U.S. Constitution's
Contract and Supremacy Clauses. Federal law prevails where
inconsistent state or local law conflicts. By participating, users
agree these terms form a contract executed in California, governed
by California law as supplemented and, when necessary, superseded
by federal law.
14. ELIGIBILITY, MINORS, AND CONTINUING COMPLIANCE
1. Eligibility and Age Restriction —
Participation is limited to adults aged 18 and older. Humboldt
Friends is not intended for minors and does not knowingly collect
data from anyone under 18. If such an account is found, it will be
deleted.
2. Continuing Legal Compliance and Good-Faith Intent
— Humboldt Friends operates in good faith under the spirit of the
following authorities: WIC §§ 4500–4906; WIC §§ 4648, 4685.8; Cal.
Civ. Code § 1798.100 et seq.; Cal. Code Reg., tit. 17 § 56001 et
seq.; ADA; Rehabilitation Act § 504; HCBS Rule 42 C.F.R. §
441.301(c); HIPAA 45 C.F.R. § 164.514; Common Rule 45 C.F.R. Part
46; Stored Communications Act 18 U.S.C. § 2702(b)(8),(c)(4);
Developmental Disabilities Assistance and Bill of Rights Act 42
U.S.C. § 15001 et seq.; UDHR Arts 1, 22, 25; CRPD Arts 3, 19, 26.
Humboldt Friends acknowledges laws may change and affirms its
intent to operate, now and in any future non-profit form, to
fulfill the rights and protections of persons with disabilities
under these frameworks.
3. Periodic Review — This policy and its
operations will be reviewed at least once every three years or
sooner if material legal changes occur.
LEGAL AND ETHICAL OPINION SUMMARY
This policy satisfies California and federal privacy, disability,
and research requirements. It reflects UDHR and CRPD human-rights
standards and follows the Belmont Report principles of Respect for
Persons, Beneficence, and Justice. Humboldt Friends will act
promptly to protect participants and use data only for lawful,
non-commercial research and safety purposes.
Signed October 09, 2025 – 05:38 PM Pacific Daylight
Time
Nathan William Young, Founder / Privacy Coordinator, Humboldt
Friends
_____________________________________
Witness / Advisor (optional) ___________________________