Privacy Policy

Last Updated: February 23, 2026
Effective Date: February 23, 2026

1. Overview

New Jerusalem Holdings, LLC ("we," "us," "our"), a Wyoming limited liability company, operates Wolf Shield HUD-Secure Pro ("the Service"). This Privacy Policy explains how we collect, use, store, and protect your information.

Our Role as Data Processor:

We act as a Data Processor on behalf of Property Managers (the "Data Controllers"). Tenant data is owned by the Property Manager, and we process it solely to provide the Service.

2. Information We Collect

A. Property Manager Information

  • Name, email address, phone number
  • Organization name and address
  • Payment information (processed by Stripe, not stored by us)
  • IP address and browser information

B. Tenant Information (PII)

SENSITIVE DATA WARNING:

The Service processes highly sensitive Personally Identifiable Information (PII):

  • Full name, address, phone number, email
  • Lease agreements and rental payment history
  • Income verification documents (paystubs, W-2s, bank statements)
  • Social Security Numbers (on HUD Form 50059)
  • Family composition and household income
  • Recertification status and compliance records

C. System Usage Data

  • Login timestamps and session duration
  • Features accessed and actions performed
  • Device type, operating system, browser type
  • Aggregate usage statistics (anonymized)

3. How We Use Your Information

We use the information we collect to:

  • Provide and maintain the Service
  • Process payments via Stripe
  • Send recertification alerts and system notifications
  • Generate compliance reports and ledger exports
  • Respond to support requests
  • Improve the Service (using anonymized data)
  • Comply with legal obligations (e.g., HUD audits, subpoenas)

We DO NOT sell, rent, or share tenant data with third parties for marketing purposes.

4. Data Storage & Security

A. Where Data is Stored

All data is stored on Supabase (PostgreSQL), a SOC 2 Type II certified cloud database provider. Data is hosted in secure, geographically distributed data centers.

B. Security Measures

  • Encryption at Rest: All data is encrypted using AES-256
  • Encryption in Transit: TLS 1.3 for all connections
  • Row-Level Security (RLS): Database policies ensure users only access their own data
  • Private Storage Buckets: Tenant documents are stored in private Supabase Storage with signed URLs
  • Immutable Ledger: Database triggers prevent unauthorized modification of audit logs
  • Role-Based Access Control: Super Admins, Property Managers, and Tenants have separate permission levels

C. Document Vault Security

CRITICAL SECURITY NOTICE:

The tenant-documents storage bucket is configured as PRIVATE. Documents are ONLY accessible via:

  • Authenticated users (tenant or property manager)
  • Short-lived signed URLs (expire after 1 hour)
  • RLS policies that verify user permissions

Public access is disabled. Documents cannot be accessed via direct URLs.

5. Data Retention

Active Accounts: Data is retained for the duration of your subscription plus 7 years (to comply with HUD audit retention requirements).

Canceled Accounts: After cancellation, you have 30 days to export your data. After 30 days, data is permanently deleted unless retention is required by law.

The immutable ledger cannot be deleted during the retention period, as it serves as the legal audit trail.

6. Third-Party Services

We use the following third-party services:

  • Stripe: Payment processing (does not store full credit card numbers)
  • Supabase: Database and file storage (SOC 2 Type II certified)
  • Vercel: Application hosting (SOC 2 Type II certified)

These providers have their own privacy policies. We recommend reviewing them:
Stripe Privacy Policy
Supabase Privacy Policy

7. Your Rights

Property Managers

  • Access your organization's data
  • Export ledger data (CSV format)
  • Request data deletion (after subscription cancellation)
  • Update account information

Tenants

  • Access your own documents and payment history
  • Request deletion of uploaded documents
  • Contact your Property Manager to exercise data rights (they are the Data Controller)

To exercise these rights, contact us at: privacy@wolfshield.app

8. Data Breach Notification

In the event of a data breach involving PII, we will:

  • Notify affected Property Managers within 72 hours
  • Provide details of the breach and steps being taken
  • Comply with all applicable breach notification laws

9. Children's Privacy

The Service is not intended for individuals under the age of 18. We do not knowingly collect information from children.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email at least 30 days in advance. Continued use of the Service after changes constitutes acceptance.

11. Contact Us

For privacy-related questions or concerns:
privacy@wolfshield.app
New Jerusalem Sovereign Holdings, LLC

SUMMARY

We take your privacy seriously. Tenant data is encrypted, stored securely, and never sold. We act as a Data Processor for Property Managers and comply with all applicable privacy laws.