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Privacy Policy

HOMELESS X MEDIA (HXM)

Privacy Policy & Data Protection Framework

Effective Date: April 6, 2026 Policy Version: 2.1 Registration No: 1045571202 Jurisdiction: Kampala, Uganda

1. Our Ethical Mandate and Scope

HOMELESS X MEDIA, founded and led by Tamale Enock, operates at the intersection of high-impact street-level journalism, IT services, and digital marketing. Unlike traditional media outlets, HXM frequently interacts with communities experiencing extreme housing instability, economic transition, and social marginalization.

This Privacy Policy is a foundational document governing our moral contract with our interview subjects, agency clients, and digital audience. It applies across all HXM platforms—including our primary web portal (homelessxmedia.store), digital channels, social distribution hubs (including TikTok, YouTube, and X), and our physical field reporting operations anchored along Gulu Highway, Kampala, Uganda.

2. Vulnerability-First Data Collection Framework

HXM acknowledges that informed consent can be complex for individuals facing crisis or displacement. Our data practices are governed by a Vulnerability-First Framework to prevent digital exploitation.

2.1 Field Reporting & Media Subject Data

  • Visual & Auditory Assets: High-definition video, raw photographic files, and ambient audio recordings gathered during street journalism and field interviews.
  • Contextual Background Data: Information regarding individual life stories, medical situations, or encounters with public systems.
  • Geographic Scrubbing: To protect subjects from harassment or displacement, we scrub precise GPS metadata from published media files unless explicit public advocacy requires location tagging.

2.2 Client, Subscriber & Platform User Data

  • Account & Intake Details: Names, email addresses, and contact numbers provided for IT service requests, marketing inquiries, or community membership.
  • Financial Transactions: Payments processed for IT retainers, web design, or sponsorships are handled via PCI-compliant gateways. Full card numbers are never stored on HXM servers.
  • Technical Telemetry: IP addresses, browser types, device IDs, and social profile identifiers gathered when interacting with our digital platforms.

3. Biometric Data Protection & Visual Redaction

HXM honors the digital privacy of individuals featured in our visual content:

  • Non-Tracking Hashing: We do not use facial recognition technology to track subjects across media stories. Internal cryptographic hashes are used solely to match signed release forms with media records securely.
  • Post-Publication Context Review: If an individual featured in past documentary content secures stable housing or employment and petitions our editorial desk, we review requests to blur images or archive video segments to support their reintegration.

4. Journalistic Exemptions & Legal Basis

While HXM adheres to global standards including the Uganda Data Protection and Privacy Act, GDPR, and CCPA principles, we operate under established Journalistic Exemptions for public interest reporting:

  • Public Interest Reporting: Processing narrative media without prior formal release when documenting matter of urgent public accountability or community awareness.
  • Legitimate Interest: Maintaining security protocols, preventing server attacks, and analyzing engagement trends across our content ecosystems.
  • Vital Interest Override: Sharing real-time location data with emergency services if an individual encounters life-threatening danger during field production.

5. Social Media Integrations & Digital Footprint

As part of the HOMELESS X MEDIA network, our social distribution relies on integrations across X, TikTok, YouTube, and messaging groups:

  • Platform APIs: Interaction data (retweets, shares, comments) is processed to gauge campaign reach and audience sentiment.
  • Third-Party Tracking: Links shared across external social platforms may invoke third-party analytics pixels governed by those respective platforms.
  • Zero Data Sale: HXM explicitly confirms: We do not sell, rent, or trade personal or client data to third-party data brokers.

6. Security Protocols & AI Safeguards

Defense-In-Depth Security
  • Encryption Standards: Data in transit is secured using TLS 1.3. Unedited video files and sensitive media archives are encrypted using AES-256.
  • Closed-Loop AI Tools: Automated AI transcription and editorial processing are conducted within closed environments. Raw interview footage is never submitted to public AI models for external training.
  • Data Shredding: Offline media drives are securely formatted, degaussed, or physically destroyed once legal retention periods (7–10 years) expire.

7. Data Subject Rights & Submissions

Users, clients, and community members have the right to request access, correction, or deletion of their personal data (Subject Access Requests).

DSAR Request Procedure

  1. Submit an email request to tamaleenock739@gmail.com with the subject line Data Subject Request.
  2. Include identity verification details (e.g., date/location of interview or service transaction reference).
  3. Requests are acknowledged within 10 business days and fulfilled within 30 days.

8. Official Legal & Compliance Contact

For privacy inquiries, media releases, IT data compliance, or editorial rights questions, contact our compliance team directly:

HOMELESS X MEDIA Legal Department

Attn: Privacy & Compliance Office

Founder & Lead: Tamale Enock

HQ Location: Gulu Highway, Kampala, Uganda (Reg. No. 1045571202)

Phone Contacts: +256 751 354 961 | +256 789 922 587

Email: tamaleenock739@gmail.com

Official Portal: https://homelessxmedia.store

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