Keep Safe Care Direct Privacy Policy

Keep Safe Care Direct (“Keep Safe Care Direct”) is committed to protecting your privacy. We have prepared this Privacy Policy to outline our practices regarding the Personal Data (as defined below) we collect from (i) users of our website (“Visitors”), located at www.keepsafecaredirect.com (“Site”) and (ii) Careseekers, Caregivers and Care Circle other third parties using our Services (collectively, “Members”). Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use located at www.keepsafecaredirect.com/terms-of-use.

1. User Consent

By submitting Personal Data through our Site or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

2. Note About Children

We do not intentionally gather Personal Data from visitors who are under the age of 18.

3. Note to Users Outside of the United States

Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.

4. Data Collection

Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

A. Information You Provide to Us

• If you are a Caregiver, when you create an account to log in to our Site, we may collect Personal Data from you, such as your first and last name, birth date, social security number, driver’s license number, criminal history, ethnicity, gender, religion, email and mailing address, phone number, work experience, salary/income, professional license numbers, education, interests, hobbies, professional and personal references, profile picture, professional skills and abilities, life style information, schedule availability, music preferences and bank information to facilitate direct deposit of earnings.
• If you are a Careseeker, when you create an account to log in to our Site, we may collect Personal Data from you, such as your first and last name, birth date, gender, religion, email and mailing address, phone number, care Services needed, health conditions, activities, profile picture, interests, music preferences and credit card information to facilitate payment processing.
• If you are a Member other than a Caregiver or Careseeker, such as a family member or healthcare provider, when you create an account to log in to our Site, we may collect Personal Data from you, such as your first and last name, birth date, social security number, driver’s license number, criminal history, ethnicity, gender, religion, email and mailing address, phone number, work experience, salary/income, professional license numbers, education, interests, hobbies, professional and personal references, profile picture, professional skills and abilities, life style information, schedule availability, music preferences, care Services needed and health conditions.
• We retain information on your behalf, such as files and messages that you store using your account.
• If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
• When you post messages or upload content within our Site (including in the Keep Safe Care Direct Messaging System), the information contained in your posting will be stored on our servers and other users to whom you provide access, will be able to see it.
• We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, and other requested information if you contact us via e-mail regarding support for the Services.
• We may also collect Personal Data, at such other points in our Site that state that Personal Data is being collected.
• Please note that you can choose not to provide us with certain information, but this may limit the features of the Site or Services you are able to use.

B. Information Collected via Technology

• To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
• We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web Site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Persistent Cookies can be removed by following Internet browser help file directions.>
• We may also use (i) third party tracking Services, such as Google Analytics, to track and analyze Anonymous Data from users of our Site and Services and (ii) location-enabled Services for Caregivers as a means to facilitate time card data. If you use the location- enabled Services, Keep Safe Care Direct may receive information about your actual location (such as GPS signals sent by a mobile device or via your web browser when on the Site).

C. Information Collected from You About Others

• Caregivers, Careseekers and visitors to our Site can invite other people to become Keep Safe Care Direct members by sending invitation emails via our Site. We store the email addresses that are provided to us and, if they are provided by a Keep Safe Care Direct member, we will associate those email addresses with such member’s account. People associated with a member’s account are considered in their “Care Circle.” We do not currently sell these email addresses or use them to send any other communication besides invitations (unless the email address is used in registration by a new Keep Safe Care Direct member) but we may do so in the future. Recipients of invitations may unsubscribe by contacting us at support@keepsafecaredirect.com to request that we refrain from sending them emails or to have us delete their information in accordance with this Privacy Policy.

D. Information Collected from Others About You

• Other Keep Safe Care Direct Members may provide us Personal and/or Anonymous Data about you through our Site or the Services. Examples include when a Careseeker posts feedback regarding a Caregiver or when another Keep Safe Care Direct Member (including a Careseeker’s healthcare provider) submits health information to the Keep Safe Care Direct system.

E. Information Collected from Third Party Companies

• We may receive Personal and/or Anonymous Data about you from companies that assist Keep Safe Care Direct in providing the Services, such as background checking companies, or companies that offer their products and/or Services on our Site. These third party companies may supply us with your Personal Data. We may add this information to the information we have already collected from you via our Site in order to provide and improve the Services.

5. Use of Your Personal Data

A. General Use

In general, Personal Data collected by us is used either to respond to requests that you make, or to aid us in serving you better. We may use your Personal Data in the following ways:

• to facilitate the creation of and secure your account on our network;
• identify you as a user in our system;
• to facilitate a background check and verify your credentials (if you are a Nurse);
• provide improved administration of our Site and Services;
• provide the Services and customer support you request;
• improve the quality of experience when you interact with our Site and Services;
• tailor the features, performance and support of the Site or Services to you;
• send you a welcome e-mail to verify ownership of the e-mail address provided when your account was created;
• send you administrative e-mail notifications, such as security or support and maintenance advisories;
• respond to your inquiries related to employment opportunities or other requests;
• respond to your requests, resolve disputes and/or troubleshoot problems;
• to make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback;
• to send newsletters, surveys, offers, and other promotional materials related to our Services and for other purposes of Keep Safe Care Direct;
• customize the advertising you may see on the Site or through our Services;
• collect and/or distribute money; and
• verify your compliance with your obligations in our Terms of Use or other Keep Safe Care Direct policies.

B. Creation of Anonymous Data

• We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. Keep Safe Care Direct reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.

6. Disclosure of Your Personal Data

We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

A. Other Keep Safe Care Direct Members

• We may share your Personal Data with third parties to whom you ask us to send Personal Information, including other Keep Safe Care Direct members. Unless you direct us to provide access to your Personal Data via your “Privacy Settings” or otherwise, we do not disclose the Personal Data of any Careseeker or Caregiver to any another Keep Safe Care Direct Member. We do, however, provide other Members with the opportunity to communicate with you through an anonymous in-browser messaging system.

B. Third Party Service Providers

• We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other Services to Keep Safe Care Direct. Examples of such third party service providers include companies that administer background checks of Caregivers and companies that process payments from both Caregivers and Careseekers. These third party service providers are required not to use your Personal Data other than to provide the Services requested by Keep Safe Care Direct.

C. Other Third Parties

• We may disclose your Personal Data to third parties so that such third parties may contact you for marketing purposes.

D. Affiliates and Acquisitions

• We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under common control with us (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, by way of any transaction including a merger or bankruptcy proceedings, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

E. Other Disclosures

• Regardless of any choices you make regarding your Personal Data (as described below), Keep Safe Care Direct may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Keep Safe Care Direct; (c) to protect or defend the rights or property of Keep Safe Care Direct or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy or Terms of Use.

7. Third Party Data Collection

A. Information Collected by Ad Networks

• We DO NOT use third-party advertising companies to serve ads when you visit our Site.

B. Information Collected by Other Third Parties

• This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you. If you disclose information to others, including to other Keep Safe Care Direct members, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. In addition, information made available through the Service by Members may be protected by applicable privacy laws, including the Health Insurance Portability and Accountability Act.
• Also, the Site may contain links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our Site and go to another Site. During this process, another entity may collect Personal Data or Anonymous Data from you. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

8. Your Choices Regarding Your Personal Data

A. Choices

We offer you choices regarding the collection, use, and sharing of your Personal Data.

• We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by hitting the ‘unsubscribe” link in the newsletter or contacting us directly (please see contact information below).
• Despite your indicated e-mail preferences, we may send you service related communication, including notices of any updates to our Terms of Use or Privacy Policy.

B. Changes to Personal Data

• You may change any of your Personal Data in your Account by editing your profile within your account or by contacting us directly. You may request deletion of your Personal Data by us, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your information for fraud or similar purposes. Please remember, however, if we have already disclosed some of your Personal Data to third parties, we cannot access that Personal Data any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

9. Security of Your Personal Data

A. Keep Safe Care Direct is committed to protecting the security of your Personal Data.

• We use a variety of industry-standard high level security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your account information. Please do not disclose your account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Keep Safe Care Direct uses reasonable efforts to protect your Personal Data, Keep Safe Care Direct cannot guarantee its absolute security.

Contact Information

Keep Safe Care Direct welcomes your comments or questions regarding this Privacy Policy. Please e-mail us at support@keepsafecaredirect.com or contact us at the following address or phone number:

10. Changes to This Privacy Policy

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Site. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Version 1.0, Last Revised: March 15, 2022.