Privacy Agreement

1. Introduction

Caring for Citizens of Alabama, Inc. ("CCA," "we," "us," "our") is a registered 501(c)(3) non-profit organization dedicated to digital equity across Alabama. We help qualified low-income Alabama residents apply for free smartphones and monthly wireless service through the federal Lifeline program, administered by the FCC and funded through the Universal Service Fund managed by USAC.

This Privacy Agreement describes how we collect, use, disclose, and safeguard the Personal Information of individuals who visit our website, submit our eligibility form, participate in our verification process, or otherwise interact with us in connection with the federal Lifeline program.

We comply with applicable U.S. federal and state privacy laws, FCC Lifeline program rules, and USAC data-handling requirements. California residents should review Section 4 for additional rights.

2. What Personal Information May We Collect and Disclose About You?

From our online eligibility form:

• First name and last name
• Email address
• Phone number
• ZIP/postal code, city, and state of residence

During our verification call and in-person process:

• Government-issued photo identification (valid ID, less than 1 year expired)
• Benefit program documentation: EBT card, Medicaid enrollment letter, SSI award letter, Veterans Pension documentation, federal housing/Pell Grant documentation
• Income documentation: W-2, tax return, pay stub, or benefit income letter (for income-based eligibility)
• Existing mobile number (for number porting requests)
• Records of communications via phone, text (SMS), email, or in-person visits

Automatically from website visits:

• IP address, browser type, device type, and operating system
• Pages visited, time spent, and referring URL
• Interaction data collected via cookies or similar tracking technology

3. How Will We Use Your Personal Information?

We use your Personal Information solely to:

• Determine and verify your household's eligibility for the federal Lifeline program per FCC and USAC requirements
• Submit your application to the USAC National Lifeline Accountability Database (NLAD) and the Alabama State Lifeline Registry
• Coordinate free device delivery and monthly wireless service activation with our telecommunications carrier partner(s)
• Contact you via phone, text (SMS), or email about your eligibility status, verification appointment, application progress, and device delivery
• Facilitate number porting if you choose to transfer your existing mobile number
• Comply with FCC Lifeline program rules, USAC recordkeeping and audit requirements, and applicable law
• Improve our website, outreach programs, and application process
• Detect and prevent fraudulent applications or duplicate Lifeline benefit claims

4. State Consumer Privacy Notice

This section applies to residents of California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and other applicable U.S. states. Because the Lifeline program is federally administered, some PI we collect is governed primarily by FCC rules rather than state consumer privacy law. To the extent state law applies, the rights in Section 12 are available to you.

Government-issued identification and benefit eligibility documentation collected in connection with a federal program are handled under the additional protections required by FCC/USAC Lifeline program rules, which may restrict state-law deletion rights where federal recordkeeping obligations apply.

5. PI We Collect and Disclose for Business Purposes

6. PI Does Not Include

• De-identified or aggregated information that cannot reasonably identify you
• Publicly available information from government records
• Information exclusively governed by other applicable federal statutes
• Gov't ID and eligibility documentation handled solely under FCC/USAC Lifeline rules and carrier submission requirements

7. Categories of Sources of PI

• You directly, through our online eligibility form at free-phone-registration.cfcofala.org
• You directly, during our verification phone call at +1 (334) 525-5300
• You directly, during in-person visits to 2424 East South Blvd, Montgomery, AL 36104
• USAC systems and the National Lifeline Accountability Database (NLAD)
• Alabama State Lifeline Registry for program compliance and enrollment verification
• Our website automatically via cookies, analytics, and server logs
• Third-party CRM, scheduling, and communications platforms (GoHighLevel/LeadConnector)

8. Why We Collect PI

• To verify your household's eligibility for the Lifeline free phone program per FCC and USAC requirements
• To submit and track your application in the USAC National Lifeline Accountability Database (NLAD) and Alabama State Lifeline Registry
• To coordinate free device shipment and wireless service activation with our carrier partner(s)
• To communicate with you about your application status, verification appointment, and device delivery (including SMS/phone/email)
• To comply with FCC Lifeline program rules, USAC recordkeeping and audit obligations, and applicable law
• To detect and prevent fraudulent applications, duplicate Lifeline benefit claims, and program abuse
• To maintain records for regulatory audit and program compliance review
• To improve our outreach programs, website, and community application support

9. Sharing or Selling Your PI

We do not sell your Personal Information. We do not share your PI with third parties for cross-context behavioral advertising or marketing purposes. We share PI only as required to administer the Lifeline program:

• With USAC and the FCC as required by federal Lifeline rules, including submission to the National Lifeline Accountability Database (NLAD)
• With the Alabama State Lifeline Registry for state program enrollment and compliance
• With our authorized telecommunications carrier partner(s) solely to activate your free device and monthly service plan
• With technology service providers (CRM, scheduling, communications) under confidentiality obligations
• With government agencies, regulators, or law enforcement as required by applicable law or regulatory audit

Benefit eligibility documentation collected in connection with the Lifeline program is never sold, used for marketing, or shared with any party other than those listed above.

10. Sensitive Personal Data

We collect and process the following Sensitive Personal Information in connection with the Lifeline program:

• Government-issued photo identification - required to verify identity at time of application (must be less than 1 year expired)
• Federal and state benefit program records - EBT card documentation, Medicaid enrollment letters, SSI award letters, Veterans Pension documentation, Federal Pell Grant documentation
• Income documentation - W-2 forms, tax returns, pay stubs, or benefit income letters (for income-based eligibility at or below 135% of federal poverty guidelines)
• Household size and composition - where required for income-based eligibility determination

This Sensitive PI is used solely to verify your eligibility, submit your application to USAC and the Alabama State Lifeline Registry, and activate your free device and service. Access is strictly limited to authorized CCA staff and representatives directly involved in the application and verification process. We implement appropriate physical, technical, and administrative safeguards. We never use Sensitive PI for marketing or any purpose unrelated to Lifeline program administration.

11. How Long We Retain Your PI

• Enrollment records and eligibility documentation are retained for a minimum of 10 years (or such longer period as required by applicable FCC rules and USAC audit requirements)
• Government-issued ID and benefit documentation are retained only as long as required by federal program rules and are securely destroyed thereafter
• Pre-application inquiries that did not result in a completed application are retained in our CRM for a reasonable period, then deleted or de-identified
• Website usage data and communications records are retained as long as reasonably necessary for program operations and legal obligations

12. Your Rights

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

• Know - what PI we have collected, used, and disclosed about you
• Access - a portable copy of your PI
• Correct - inaccurate PI we hold about you
• Delete - your PI, subject to federal Lifeline program recordkeeping requirements and other legal exceptions
• Opt Out - of any sale or sharing of PI (we do not sell or share PI for advertising)
• Limit Use - of Sensitive PI beyond what is necessary to administer your Lifeline application
• Opt Out of SMS/Call - by replying STOP to any text message, or by contacting us directly
• Non-Discrimination - you will not be denied Lifeline program services for exercising your privacy rights

  13. How to Exercise Your Rights

  To submit a privacy rights request - including to access, correct, delete, or opt out of communications - contact us using the information provided in Section 16. We may need to verify your identity before processing your request. You may designate an authorized agent to submit requests on your behalf, subject to identity verification.

  14. Timing

  We will acknowledge receipt of your privacy rights request within 10 business days. We will provide a substantive response within 45 calendar days. If we require additional time due to the complexity of the request or federal program obligations, we will notify you within the initial 45-day window and may extend our response by an additional 45 days with written notice.

  15. Appeals

  If we decline to act on your privacy rights request, we will provide a written explanation, including any applicable federal program obligations that restrict our ability to comply. You may appeal by contacting us via the information in Section 16. We will respond within 45 calendar days. Eligibility and program disputes may also be directed to USAC or the FCC. State residents may additionally submit a complaint to their state Attorney General's office.

  16. Contact Us

  Caring for Citizens of Alabama, Inc.

  2424 East South Blvd, Montgomery, AL 36104

  Phone: +1 (334) 525-5300

  Email: [email protected]

  Website: https://free-phone-registration.cfcofala.org

  Hours: Monday - Saturday, 8:00 AM - 8:00 PM CST

  For privacy-specific inquiries, please include "Privacy Request" in your subject line or message.

  17. Last Revised

  August 2026