Last Updated: 09/09/2025
We are Little Haiti Global Inc. (“LHG,” “we,” “us,” or “our“). Through this website (the “Site“), we provide information about the Little Haiti Global initiative and its Programs (the “Program“). The Site is generally informational and at the moment does not support account creation or direct applications. Users who wish to apply for participation in the Program may do so exclusively through a secure online application platform operated on a separate site (the “Portal“).
This Privacy Policy (the “Privacy Policy“) governs your visit to, access to, and use of the Site and applies only to information collected through the Site.
This Privacy Policy explains how LHG may collect, use, store, process, and disclose information when you visit or use the Site or otherwise interact with us through the Site. It also describes your rights and choices regarding your Personal Information, as well as how you may contact us.
By visiting, accessing, or using the Site, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your Personal Information in accordance with this Privacy Policy and applicable law.
For clarity, this Privacy Policy applies only to information collected via the Site. The Privacy Policy of the Portal is incorporated herein by reference with respect to Portal activity.
This Privacy Policy applies to:
(i) any Personal Information collected through the Site and the Services from individual persons, companies, organizations, applicants, investors, representatives, and any Authorized Users participating in the Program; and
(ii) any Personal Information collected through offline interactions related to your participation in the Program, to the extent such information is processed in connection with the Site or Portal and the Services.
This Privacy Policy does not apply to Third-Party Sites (as defined in the Terms of Use) that may be linked to or accessible from the Site. LHG is not responsible for the privacy practices of such Third-Party Sites.
For the avoidance of doubt, where you authorize a representative, agent, attorney-in-fact, or other third party (collectively, an “Authorized Representative“) to act on your behalf in connection with the Site, the Services, or the Program, you are responsible for ensuring that such Authorized Representative is aware of, understands, and complies with this Privacy Policy and all applicable laws. Any actions taken by an Authorized Representative on your behalf shall be deemed to be your actions for purposes of this Privacy Policy, and you remain responsible and liable for any breach of this Privacy Policy caused by such Authorized Representative.
2. Definitions
Capitalized terms used in this Privacy Policy and not otherwise defined herein shall have the meanings ascribed to them in the Terms of Use.
For purposes of this Privacy Policy:
(i) “Personal Information” means any information relating to an identified or identifiable natural person, as defined under applicable law;
(ii) “Processing” means any operation or set of operations performed on Personal Information, whether or not by automated means, including collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction;
(iii) “Sensitive Personal Information” means Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, data concerning health, sexual orientation, or other categories defined as sensitive or special category data under applicable law;
(iv) “Third-Party Sites” means websites, applications, or online services operated by unaffiliated entities; and
(v) “Anonymized Data” means data that has been modified so it can no longer reasonably be used to identify an individual, directly or indirectly.
3. Information We Collect
Depending on your relationship with LHG and your use of the Site and Services, we may collect the following categories of Personal Information:
A. Information You Provide Directly
(i) Identification and contact information, such as your name, telephone number and email address; and
(ii) Communications, such as messages sent through the Site’s secure messaging system, emails, SMS messages, or other correspondence with LHG, including communications exchanged with our support team or project staff.
B. Information Collected Automatically
(i) Device and usage information, including IP address, browser type, operating system, device identifiers, and activity logs related to your use of the Portal;
(ii) Log and analytics data, such as pages viewed, time spent on the Site, access times, and referring URLs; and
(iii) Cookies and similar technologies, as further described in Section 5 (Cookies and Tracking Technologies).
C. Information from Third Parties
We may receive Personal Information about you from:
(i) government authorities or agencies, for identity verification or compliance purposes;
(ii) financial institutions or payment processors, for payment facilitation and fraud prevention;
(iii) referral sources, authorized representatives, or other Program participants who provide information on your behalf; and
(iv) publicly available sources, where permitted by law.
4. Lawful Basis for Processing
LHG processes your Personal Information only where permitted by applicable law, including:
(i) Contractual necessity: to perform our obligations under the Terms of Use or other agreements with you;
(ii) Legal obligations: to comply with applicable laws, regulations, court orders, or law enforcement requests, including AML/CTF requirements;
(iii) Legitimate interests: to operate, maintain, and improve the Site and Services; prevent fraud and abuse; secure our systems; and protect our legal rights;
(iv) Consent: where you have given clear and informed consent to the Processing of your Personal Information for specific purposes; and
(v) Vital interests: to protect your safety or the safety of others.
5. Cookies and Tracking Technologies
A. Cookies and Tracking
The Site may use cookies, pixel tags, local storage, and other tracking technologies to:
(i) enable core functionality of the Site;
(ii) remember your preferences and settings;
(iii) analyze usage and performance;
(iv) deliver relevant content and communications; and
(v) detect and prevent fraudulent or unauthorized activities.
You may configure your browser to block or delete cookies, but doing so may impair the functionality of the Site or your ability to use certain features. Where required by applicable law, we will obtain your consent before placing non-essential cookies or similar technologies on your device.
B. Third-Party Cookies and Tracking by Partners
In addition to LHG’s use of cookies and similar technologies described in Section 5, certain third-party analytics, advertising, or content providers (“Third-Party Partners“) may place cookies, pixel tags, or similar tracking technologies on your device when you access or use the Site. These technologies may collect information about your online activities over time and across different websites, applications, or online services, including device identifiers, browsing history, and usage data.
Such Third-Party Partners may use this information to provide analytics services, deliver targeted content, measure the effectiveness of their content or advertising, and for other purposes described in their respective privacy policies. LHG does not control the tracking technologies used by these third parties, and their use is subject to their own terms and privacy policies.
Where required by applicable law, LHG will obtain your consent before allowing Third-Party Partners to place non-essential cookies or similar technologies on your device. You may also manage or disable such tracking through your browser settings or by using opt-out tools provided by the relevant third-party services.
LHG does not have access to or control over the information collected by these Third-Party Partners, and their activities are subject solely to their own terms and privacy policies.
6. Sensitive Personal Information
Where required by law or where necessary for the purposes of the Program, LHG may collect and process Sensitive Personal Information, including for:
(i) compliance with legal requirements;
(ii) conducting due diligence and background checks;
(iii) assessing eligibility for Program participation; and
(iv) fulfilling contractual obligations under the Program.
We will process Sensitive Personal Information only with your explicit consent or where otherwise permitted or required by applicable law and will apply enhanced safeguards to protect such data.
7. Your Privacy Rights
Depending on your jurisdiction, you may have the following rights in relation to your Personal Information:
(i) the right to access and obtain a copy of your Personal Information;
(ii) the right to correct inaccurate or incomplete Personal Information;
(iii) the right to delete your Personal Information (the “right to be forgotten”);
(iv) the right to restrict or object to certain Processing activities;
(v) the right to data portability, to receive your Personal Information in a structured, commonly used, and machine-readable format; and
(vi) the right to withdraw consent where Processing is based on consent, without affecting the lawfulness of Processing prior to such withdrawal.
Requests to exercise these rights should be submitted to privacy@littlehaitiglobal.com, and LHG will respond in accordance with applicable law. This includes the right to opt out of receiving direct marketing communications, as further described in Section 8(B).
A. Withdrawal of Consent and Service Impact
Where the Processing of your Personal Information is based on your consent, you may withdraw that consent at any time by contacting us at privacy@littlehaitiglobal.com or through any other method provided by LHG. Withdrawal of consent will not affect the lawfulness of any Processing carried out prior to such withdrawal.
You acknowledge that certain Processing activities are necessary for your participation in the Program and may be necessary for your access to and use of the Site and Services. If you withdraw consent for Processing that is essential to the provision of the Services, LHG may be unable to continue providing you with those Services, and your participation in the Program may be suspended or terminated, subject to applicable law and any applicable contractual obligations.
8. How We Use Personal Information
A. Use
We may use the Personal Information we collect for the following purposes:
(i) Program Administration: to receive, process, evaluate, and manage relocation and investment applications; maintain user accounts; and facilitate your participation in the Program;
(ii) Service Delivery: to operate, provide, maintain, and improve the Site, Portal and the Services, including providing secure access to personalized dashboards, case tracking, and secure communications;
(iii) Payment Processing: to process fees, contributions, and other payments; issue confirmations and receipts; manage billing; and address payment disputes;
(iv) Compliance and Risk Management: to conduct due diligence, background checks, sanctions screening, and other activities required under applicable laws, including anti-money laundering (AML) and counter-terrorist financing (CTF) obligations;
(v) Communications: to send notices, updates, alerts, decisions, required actions, and other messages related to the Program or the Services, whether through the Site, Portal, email, SMS, or other electronic means;
(vi) Security and Fraud Prevention: to monitor, detect, investigate, and prevent fraud, unauthorized access, or other malicious or unlawful activity; and to enhance the security and performance of the Site and Portal;
(vii) Legal and Regulatory Purposes: to comply with applicable laws, respond to lawful requests from public authorities, and protect our legal rights; and
(viii) Research and Analytics: to evaluate the performance of the Program and Services, conduct market and demographic research, and improve user experience, provided such use complies with applicable privacy laws.
B. Marketing and Opt-Out Rights
Where permitted by applicable law, LHG may use your Personal Information to send you promotional communications, including updates about the Program, related investment opportunities, community events, or other products and services that may be of interest to you (“Marketing Communications“). Such communications may be sent by email, SMS, secure Portal messaging, or other electronic means.
You may opt out of receiving Marketing Communications at any time by:
(i) clicking the “unsubscribe” link in any email we send;
(ii) replying “STOP” to any SMS message;
(iii) adjusting your preferences in your Account settings on the Portal; or
(iv) contacting us at privacy@littlehaitiglobal.com.
Please note that opting out of Marketing Communications will not affect your receipt of transactional or administrative messages that are necessary for your participation in the Program or the operation of your Account.
9. Sharing and Disclosure of Personal Information
We do not sell your Personal Information. We may share your Personal Information only as described below and in compliance with applicable law:
A. Internal Project Teams
We may share your Personal Information with LHG’s internal project teams, departments, and authorized personnel who require access to such information for operational, administrative, or program-related purposes. Such access will be limited to those with a legitimate need to know and will be subject to confidentiality obligations consistent with this Privacy Policy and applicable law.
B. With Your Consent
We may share your Personal Information with third parties when you have given clear, informed consent to such sharing.
C. Service Providers and Contractors
We may engage third-party service providers, contractors, and consultants to perform services on our behalf, including payment processing, data hosting, IT support, analytics, marketing, and compliance screening. These third parties are contractually required to process Personal Information only in accordance with our instructions and to protect its confidentiality and security.
D. Program Partners
We may share Personal Information with Program partners, including governmental agencies, investment entities, relocation service providers, and other authorized entities involved in the administration and execution of the Program.
E. Legal and Regulatory Disclosures
We may disclose Personal Information to courts, law enforcement authorities, regulators, or other government officials when we believe such disclosure is necessary to:
(i) comply with legal obligations;
(ii) respond to lawful requests;
(iii) protect the rights, property, or safety of LHG, our Users, or others; or
(iv) enforce our agreements.
F. Business Transfers
In the event of a merger, acquisition, corporate reorganization, sale of assets, or bankruptcy, your Personal Information may be transferred to a successor entity, subject to this Privacy Policy and applicable law.
10. International Data Transfers
Your Personal Information may be stored, processed, and transferred to servers and facilities located outside of your country of residence, including to the United States and other jurisdictions where privacy laws may not provide the same level of protection as those in your jurisdiction.
Where required by applicable law, we will implement appropriate safeguards for such transfers, which may include:
(i) executing the European Commission’s Standard Contractual Clauses or UK International Data Transfer Addendum;
(ii) verifying that the recipient is located in a jurisdiction deemed to provide adequate protection by the European Commission or UK authorities; or
(iii) relying on other lawful transfer mechanisms recognized under applicable law.
You may request further information about the safeguards applied to international transfers by contacting us at privacy@littlehaitiglobal.com.
11. Data Security
LHG implements and maintains commercially reasonable administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of Personal Information. These safeguards include, without limitation:
(i) encryption of data in transit (including secure HTTPS communications) and at rest;
(ii) role-based access controls;
(iii) two-factor authentication (2FA) for system and account access;
(iv) firewalls and intrusion detection and prevention systems;
(v) regular vulnerability assessments, system audits, and continuous monitoring; and
(vi) mandatory staff training on data protection obligations.
While LHG takes reasonable steps to protect your Personal Information, no method of transmission over the Internet or method of electronic storage is entirely secure, and absolute security cannot be guaranteed. You are responsible for maintaining the confidentiality of your Account credentials and for taking appropriate measures to secure your devices, networks, and any Personal Information in your control.
You agree to notify us promptly at security@littlehaitiglobal.com if you become aware of, or reasonably suspect, any unauthorized access to your Account, the Site, Portal, or the Services, or any other actual or suspected breach of security.
A. Breach Notification
In the event of a personal data breach affecting your Personal Information, LHG will provide notice to you and, where required, to the relevant supervisory or regulatory authorities without undue delay, in accordance with applicable law (including, where applicable, Articles 33–34 of the GDPR, the CCPA, and other data protection laws).
Such notification will include, to the extent reasonably available:
(i) a description of the nature of the breach;
(ii) the categories of Personal Information affected;
(iii) the likely consequences of the breach; and
(iv) the measures taken or proposed to address the breach and mitigate any potential adverse effects.
Where all such information cannot be provided at the same time, LHG may provide the information in phases as permitted by law.
12. Data Retention
A. Retention
We retain Personal Information only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, to resolve disputes, and to enforce our agreements.
When determining retention periods, we consider the following criteria:
(i) the nature and sensitivity of the Personal Information;
(ii) the potential risk of harm from unauthorized use or disclosure;
(iii) the purposes for which we process the Personal Information;
(iv) applicable legal requirements; and
(v) our operational needs.
Once the applicable retention period has expired, we will securely delete or anonymize Personal Information, unless we are required by law to retain it for a longer period.
B. Retention of Anonymized or Aggregated Data
Notwithstanding Section 12, LHG may create, use, and retain data that has been anonymized or aggregated in such a manner that it can no longer reasonably be used to identify an individual (“Anonymized Data“). LHG may use Anonymized Data for statistical analysis, research, program evaluation, or other legitimate business purposes. Anonymized Data may be retained indefinitely, provided it remains de-identified and cannot reasonably be re-identified in accordance with applicable law.
13. Third-Party Processors and Links
The Site may include integrations with, or links to, Third-Party Sites and services operated by unaffiliated entities. These third parties may process Personal Information in accordance with their own privacy policies, which we encourage you to review.
We are not responsible for the privacy, security, or information practices of such third parties, except to the extent required by applicable law.
14. Children’s Privacy and Age Verification
The Site and Services are not directed to children under the minimum digital consent age for their jurisdiction, as defined in the Terms of Use. We do not knowingly collect Personal Information from children without verifiable parental or legal guardian consent.
Where LHG is required by applicable law to obtain such consent before collecting, using, or disclosing Personal Information from a child, we will take reasonable steps to confirm it. Verification methods may include requiring the parent or guardian to: (i) provide a signed consent form; (ii) use a credit card, debit card, or other online payment system to confirm identity; (iii) communicate via a verified telephone call or video conference; or (iv) provide other reliable proof of identity acceptable under applicable law.
If we become aware that we have collected Personal Information from a child in violation of this policy, or if we cannot verify that appropriate consent has been obtained, we will promptly delete the information and restrict access to the Site, Portal, and Services until such verification is completed. Parents or legal guardians who believe their child has provided Personal Information should contact us at privacy@littlehaitiglobal.com.
15. Your Rights Under Specific Jurisdictions
Depending on your place of residence, you may have additional privacy rights under applicable law, including the rights described below. LHG will honor these rights to the extent required by applicable law.
A. California Residents (CCPA/CPRA)
If you are a California resident, you may have the right to:
(i) Know what categories and specific pieces of Personal Information we have collected about you, the sources from which the information was collected, the business or commercial purposes for collecting it, and the categories of third parties with whom we share it;
(ii) Request deletion of your Personal Information, subject to certain exceptions;
(iii) Request correction of inaccurate Personal Information;
(iv) Opt out of the “sale” or “sharing” of Personal Information, as those terms are defined under California law; and
(v) Not be discriminated against for exercising your privacy rights.
To exercise any of these rights, you may contact us at privacy@littlehaitiglobal.com. We will verify your request in accordance with California law, which may require proof of identity. You may also designate an authorized agent to make requests on your behalf, provided the agent’s authority is verified.
B. European Union and United Kingdom Residents (GDPR/UK GDPR)
If you are located in the EU or UK, you have the rights described in Section 7 of this Privacy Policy and additional rights to:
(i) Lodge a complaint with your local data protection authority if you believe our processing of your Personal Information violates applicable law; and
(ii) Request restriction of processing where you contest the accuracy of the Personal Information, the processing is unlawful, or you have objected to processing pending verification of legitimate grounds.
C. Canadian Residents (PIPEDA)
If you are a Canadian resident, you have the right to access the Personal Information we hold about you, to request corrections, and to challenge our compliance with the principles of the Personal Information Protection and Electronic Documents Act (PIPEDA).
D. Other Jurisdictions
Residents of other jurisdictions may have similar or additional rights under applicable local privacy laws. We will comply with such laws where they apply.
E. Jurisdiction-Specific Supplemental Notices
In addition to the rights described above, certain other jurisdictions may require LHG to provide you with additional privacy disclosures, notices, or terms that are specific to your place of residence. Where applicable, such jurisdiction-specific notices will be made available to you through the Site and/or Portal, appended to this Privacy Policy, or provided separately in writing, and are incorporated herein by this reference. In the event of any conflict between this Privacy Policy and an applicable jurisdiction-specific notice, the latter shall control to the extent required by applicable law.
16. Exercising Your Rights
To submit a request to exercise any of the rights described in this Privacy Policy, you may contact us using either of the following methods:
When submitting a request, you must:
(i) provide sufficient information to allow LHG to reasonably verify that you are the individual to whom the Personal Information relates, or an Authorized Representative with authority to act on that individual’s behalf; and
(ii) describe your request with sufficient clarity and detail to enable LHG to properly understand, evaluate, and respond to it.
If we are unable to verify your identity or authority, we may be unable to respond to your request or to provide access to the requested Personal Information, as permitted by applicable law.
A. Verification Standards
To protect the privacy and security of your Personal Information, LHG will take reasonable steps to verify your identity before fulfilling any request under Sections 7, 7A, or 15 of this Privacy Policy. Verification methods may include, without limitation:
(i) matching information you provide with information already in our records;
(ii) requesting additional identifying documentation; or
(iii) using secure verification tools or procedures.
If you designate an Authorized Representative to submit a request on your behalf, LHG may require:
(i) a written, signed authorization from you;
(ii) proof of the Authorized Representative’s identity; and
(iii) verification of your own identity.
Any identification or verification information collected for purposes of fulfilling a rights request will be used solely for that purpose and will be securely deleted or anonymized once verification is complete, unless retention is required by applicable law.
17. Changes to this Privacy Policy
We may update or modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors. If we make material changes, we will post the updated Privacy Policy on the Site and update the “Last Updated” date at the top of this page.
Where required by applicable law, we will provide additional notice or obtain your consent before material changes take effect. Your continued use of the Site or Services after any changes become effective constitutes your acceptance of the revised Privacy Policy.
18. Controlling Language
This Privacy Policy may be translated into other languages for convenience. In the event of any conflict or inconsistency between a translated version and the English version, the English version shall prevail and control in all respects.
19. Contact Information
If you have any questions, concerns, or complaints regarding this Privacy Policy, or if you wish to exercise your rights under applicable data protection laws, you may contact us using the following details:
Little Haiti Global Inc.
Attn: Privacy Officer
Email: privacy@littlehaitiglobal.com
Mail: 9841 Washingtonian Blvd, Suite #200 Gaithersburg, MD 20878
If you are located within the European Union or the United Kingdom, you may also contact our designated Data Protection Representative at:
privacy@littlehaitiglobal.com
A. Data Protection Officer
Where required by applicable law, LHG has appointed a Data Protection Officer (“DPO“) responsible for monitoring our compliance with data protection laws and this Privacy Policy. The DPO serves as a point of contact for inquiries, complaints, and requests relating to the Processing of Personal Information, including matters requiring confidential handling or communication with supervisory authorities.
Data Protection Officer Contact:
“Data Protection Officer“
Email: dpo@littlehaitiglobal.com
Mail: 9841 Washingtonian Blvd, Suite #200, Gaithersburg, MD 20878
20. Effective Date
This Privacy Policy is effective as of 09/09/2025 and remains in effect until amended or replaced.
