Trusted Health

Privacy Policy

We treat your privacy just as seriously as you treat your patients. We know a thing or two about HIPAA and treat your privacy just as seriously as you treat your patients. We want to make it clear how we use your data. We’re not here to sell or share your personal information to recruiters or salespeople. We’re here to provide information, services, and opportunity to you. We will not disclose any personally identifiable information you provide to us to any third-party, except as follows:

1. If you give us explicit consent.
2. We use affiliated and unaffiliated service providers that help us deliver our service and run our business subject to strict confidentiality agreements. These services are for things like customer support, digital analytics, and marketing. These companies are authorized to use your personal information only as necessary to provide these services to us
3. If we believe in good faith that such disclosure is necessary to comply with relevant laws or to respond to subpoenas or warrants or legal process served on us.

If you have questions or want us to delete your personal data, please contact our support team.

Now, for the legal stuff.

Effective Date: January 1, 2020

We, Trusted, Inc. (and subsidiaries), a Delaware corporation with offices in California (“Trusted”) respect your privacy and are committed to protecting it through our compliance with this policy (“Privacy Policy”). We explain in this Privacy Policy how we collect, use, protect and disclose information and data when you use the Trusted website and Trusted services, including any software, mobile applications, or other services offered by Trusted from time to time, and other products or services offered by third parties using Trusted functionality (collectively, "Services"). This policy applies to information we collect:

• On our websites, including www.trustedhealth.com.
• In email, text, and other communication between you and Trusted.
• Through Trusted mobile applications you download or using Trusted functionality, which provide dedicated non-browser-based interaction between you and Trusted.
• When you interact with our advertising, content, and applications on third-party websites and services.

It does not apply to information collected by:

• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use Trusted Services. By accessing or using this website or Trusted Services, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

For purposes of this Agreement, the terms “we,” “us,” and “our” refer to Trusted.“You” refers to you, as a user of Service.

This Privacy Policy is effective immediately for unregistered users and users registering accounts on or after the effective date. For users who registered accounts before the effective date, it will become effective thirty (30) days after the effective date.

INFORMATION WE COLLECT AND HOW WE USE IT

Personal Information that You Provide Us Actively

When you fill out registration forms, submit your resume or provide us with other information actively, you will know what information we are collecting because you are actively submitting it. Because we change our offerings and features from time to time, the options you have to provide us with personal information also may change, but here are some examples of situations in which you may decide to provide personal information to us:
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1. Creating an account;
2. Signing up for email alerts;
3. Completing a form related to one of our products or services;
4. Uploading a resume; and
5. Contacting us for support or customer service.

If you connect to Trusted using Facebook or another social networking site (each a"Social Networking Site"), we will receive information that you authorize the Social Networking Site to share with us. Any information that we collect from your Social Networking Site account may depend on the privacy settings you have set with the Social Networking Site, so please consult the Social Networking Site’s privacy and data practices.

Information We Collect by Automated Means

When you use Trusted Services, your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means may vary, but generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect also may include usage information and statistics about your interaction with Trusted. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data, and other information about how you used Trusted.
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Information We Collect By Other Means

We may receive information about your activity on and off Trusted from our affiliates, advertisers, partners and other third parties we work with. For example: our employer clients and service providers working on their behalf may share with us information about the candidate status of job seekers who apply for positions with these employers (e.g. application status, completed stages of interview process, whether an offer was made, and whether the candidate was hired.)

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  
• • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

1. Identifiers.
   A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
   A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
   Some personal information included in this category may overlap with other categories.
3. Protected classification characteristics under California or federal law.
   Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
   
4. Commercial information.
   Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
5. Biometric Information.
   Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
6. Internet or other similar network activity.
   Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
7. Geolocation Data.
   Physical location or movements.
8. Sensory Data.
   Audio, electronic, visual, thermal, olfactory, or similar information.
9. Professional or employment-related information.
   Current or past job history or performance evaluations.
10. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
    Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
11. Inferences drawn from other personal information.
    Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

HOW WE USE INFORMATION

We may use the information we collect:

1. to provide you with personalized content and Services offered by Trusted;
2. to moderate and display the anonymous reviews, salary reports and other content you have submitted for the benefit of our other users;
3. to customize and improve the features, performance, and support of the site;
   
4. deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent);
   
5. for internal operations, including troubleshooting, data analysis, testing, research, and service improvement;
6. to help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business;
7. to communicate with you regarding our Services;
8. to analyze use of Trusted and improve Trusted;
9. to create aggregate and statistical data that does not identify you individually;
   
10. to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and
    
11. for other purposes that you separately authorize as you interact with Trusted.
    

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:

• Government and regulatory entities;
• Service providers; and
• Medical Facilities.
  

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category E: Biometric information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category H: Sensory data.
Category I: Professional or employment-related information.
Category J: Non-public education information.
Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Government and regulatory entities;
• Service providers; and
• Medical Facilities.
  

Sales of Personal Information
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We have not sold your personal information, nor do we intend to sell your personal information.

LINKS TO OTHER WEBSITES

As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through Trusted and the Service. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

HOW WE PROTECT INFORMATION

We implement security measures designed to protect your information from unauthorized access. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. We will be proactive about maintaining the security of our user’s data and ask that you help us by using a unique password, never disclosing your password, and not using your unique Trusted password for any other services or applications.
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OTHER IMPORTANT PRIVACY INFORMATION

Choices Regarding Your Personal Information

Upon request Trusted will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information. We will respond to your request within a reasonable timeframe. You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy. If you’d like to delete your Trusted account entirely, please contact us.
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Privacy of Minors

Trusted is not intended for minors. Minors must obtain parental consent to use Trusted. Minors (under 18 years of age) are expressly prohibited from using Trusted or providing any personal information. If you become aware that a child has provided us with personal information without parental consent, please contact us. If we become aware that a minor that has provided us with personal information, we remove such information and terminate the minor’s account.

CALIFORNIA RESIDENTS

Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
  
• The categories of third parties with whom we share that personal information.
  
• The specific pieces of personal information we collected about you (also called a data portability request).
  
• If we disclosed your personal information for a business purpose, two separate lists disclosing: disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  

We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
   
4. Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
   
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
   
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
   
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
   
8. Comply with a legal obligation.
   
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
   

We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us via the method most convenient to you detailed in Contact Us.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination
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We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Employment Exception

Employment-related personal information collected from employees, job applicants, contractors, or similar individual should be aware that an employment exception to the CCPA applies to personal information a business collects about natural persons acting as job applicants, employees, owners, directors, officers, medical staff members, or contractors for the business, but when collected and used either:

• Within the context of that individual's role.
• For that individual's emergency contact information.
• To administer that individual's benefits.

Other California Privacy Rights
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California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.

Data Controller

The information about you that we collect through Trusted is controlled by Trusted, Inc., San Francisco, California. This information is stored in the United States.

CHANGES TO OUR PRIVACY POLICY

Trusted reserves the right to change this policy and our Terms of Use at our discretion and at any time. We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or by placing a notice on our site. The revised Privacy Policy will be effective immediately for unregistered users and users registering accounts on or after the revision date. For users who registered accounts before the revision date, it will become effective thirty (30) days after the revision date. You should periodically check this privacy page for updates. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

CONTACT US

If you have any questions regarding this Privacy Policy, please contact us at:

1. Email: privacy@trustedhealth.com
2. Website: www.trustedhealth.com (via our website messaging platform)
3. Phone: +14154661466
4. Text: +14154661466
5. Postal Address: Trusted, Inc., 201 California St., Ste 950, San Francisco, CA 94111