INCREDIBLE HEALTH, INC. Privacy Policy

EFFECTIVE DATE: July 1, 2021

In this Privacy Policy (“Policy”), we describe how Incredible Health, Inc. (“Incredible Health,” “we,” “us,” or “our”) collects, uses, and discloses information that we obtain about visitors to our website https://www.incrediblehealth.com/ (the “Site”), users of our mobileautho Application (the “App”) and the services available through our Site and App (collectively, the “Services”).

By visiting the Site, using or downloading the App, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy, our Terms of Use, including its applicable limitations on damages and the resolution of disputes. The Company Terms of Service are incorporated by reference into this Policy. In addition, if you have executed a customer agreement with us, we will use your information in accordance with the terms of our agreement, and, as permitted by the agreement, and this Policy. If there is a conflict between your customer agreement and this Policy, then your customer agreement will govern.

The Information We Collect About You

We collect information about you directly from you, from third parties, and automatically through your use of our Site, App or Services.

Information We Collect Directly from You. The information we collect from you depends on how you use our Services. 

• We collect information from you when you register an account with the App. Registration with us is mandatory in order to be able to use the basic features of the App. When you register with us and use the App, you generally provide (a) your name, email address, age, user name, password and other registration information; (b) information you provide us when you contact us for help, and; (c) information you enter into our system when using the Application and its features, such as contact information, your resume, work experience, your licenses and certifications, and information about your job search.
• We collect information when you browse or complete continuing education courses. For example, we collect information about when you start and complete courses.
• If you are a hospital or employer, to create an account on the Site, we will collect your name, email address, age, user name, password and other registration information. 
• We collect information about you when you contact us through the Site. For example, if you request a demo or submit an inquiry, or engage in a chat, we will collect your name, contact information, information about your Company, and your communications with us.
• If you participate in our Healthcare Worker Community, we will collect information and content that you post to the community forum.

Information We Collect From Other Entities. We also may collect information about you from other organizations and sources.

• We may license or otherwise obtain information about our healthcare worker users from public records databases. This information may include licensure and certification records. 
• If you identify or include a reference in your user profile, we may collect information about you from the individuals you identify as a reference.
• If you are an employer user, we may collect information about you from your employer, such as your name and contact information to create your credentials for the Services.

Information that We Collect About You from Social Media Services. You also may log into our Services through your social media accounts. If you log into our Services using your social media account’s credentials, you must enter your social network login information. We then collect your name, email address, and phone number from your social media profile. If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public on your social media account.

We store the information that we receive from your social media account with other information that we collect from you or receive about you. Any third-party social media site controls the information it collects from you. For information about how a social media site may use and disclose your information, including any information you make public, please consult their respective privacy policies. We have no control over how any social media site uses or discloses the personal information it collects about you.

Information We Collect Automatically. We automatically collect information about your use of our Site and App through cookies, web beacons, and other technologies, including technologies designed for mobile applications. We also may use tools that allow us to monitor how you navigate the Site, App and Services, such as how you move your cursor or where you enter text (without seeing the actual text you enter) to help us improve the Site, App and Services and to identify and diagnose bugs.  To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information

Site:

• Domain name;
• Your browser type and operating system;
• Web pages you view on the Site; links you click on the Site; your IP address;
• The length of time you visit our Site and or use our Services;
• The referring URL, or the webpage that led you to our Site.

App:

• Device name and model; operating system type, name, and version;
• Device identifiers, your device’s IP address, and your device’s advertising ID.
• Device language settings.
• Activities within the App, the length of time that you are logged into our App, and links you click in the App.
• Camera and photos. With your permission, we will access your device’s camera and/or photos so you can upload your content to the Services, such as a profile picture.
• Device calendar information. With your permission, we will access your device’s calendar to help you schedule interviews with potential employers.
• Contact list information. With your permission, we will collect information from your device’s contact list, including your contacts’ names and contact information. We collect this information so you can send invites to your contacts to join the Services.

How We Use Your Information

We use your information, including your personal information, for the following purposes:

• Service Provisioning/Transactional Purposes:  
  • To provide our Site, App and Services to you.
  • To communicate with you about your use of our Site, App and Services; to fulfill your requests, to respond to your inquiries, and for other customer service purposes.
  • To tailor the content and information that we may send or display to you, to provide access to content you have signed up for or purchased or licensed from us, to provide personalized help and instructions, and to otherwise personalize your experiences while using the Site, App or the Services. For example, we use the information we collect about our healthcare worker job seekers to match them to potential employers.

• Marketing Communications: In accordance with applicable laws, we may use your information:
  • To send you marketing communications about our and our affiliates’ products and services. 
  • To send you news, newsletters, and event information.

• Advertising:
  • To assist us in determining relevant advertising content and media. 
  • To evaluate the success of our advertising campaigns (including our online and offline advertising campaigns).
  • To create Custom Audiences and lookalike audiences for our own advertising. 
  • See also the Ad Networks section discussed below for information about our own online advertising. 

• Services and Product Improvement/Research:  
  • To better understand how users access and use our Site, App and Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our App and Services are more (or least) used by users, and we will use this information to update or add new features to our App and Services. We may also use feedback provided by users to update our Services or develop new offerings.
  • To administer surveys and questionnaires, such as to evaluate user engagement, for market research or customer satisfaction purposes.
  • To create aggregated, anonymized, pseudonymized or de-identified data sets. We may use such data sets for research, product improvement and development, marketing, advertising, trend analysis and other purposes.

• Legal Purposes: 
  • To comply with legal obligations and act in accordance with legal authorizations, as part of our general business operations, and for other business administration purposes, including to comply with our legal and regulatory requirements, authenticating your identity, maintaining customer records, to monitor your compliance with your agreements with us, to collect debts owed to us, to safeguard our business interests, and to manage or transfer our assets or liabilities, for example in the case of an acquisition, disposition or ‎‎merger, as described below.
  • Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or property, or violations of this Policy, your customer agreement, and any applicable terms of use.
  • For other purposes we may inform you about from time to time. Where required by applicable laws and regulations, we will obtain your consent if we wish to use your personal information for purposes requiring such consent.

How We Share Your Information

We may share your information, including personal information, as follows:

• Employment Opportunities. The Incredible Health platform is a career marketplace that matches healthcare workers with potential employers. When a nurse or other healthcare worker creates an account on the Services, that healthcare worker directs Incredible Health to share their personal information with potential employers who we match to the worker’s skills, experience, and job preferences. If an employer expresses interest in a job candidate, we will facilitate scheduling an interview, which may include sharing the candidate’s and employer’s contact information.
• Healthcare Worker Community Users. When a user posts to our Healthcare Worker Community, their user name and post is shared with other Incredible Health users who are signed in to the Services. We also make Healthcare Worker Community posts publicly available, but do not disclose the poster’s username on the public forum. Users should be mindful of the content they post in the Healthcare Worker Community, as that information is publicly available.
• Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. 
• Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries.

We also disclose information in the following circumstances:

• Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, financed by or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company.  As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and advisors, including attorneys and consultants.
• In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, law enforcement request, or other legal process, such as in response to a subpoena.
• To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, customer agreement or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

Our Use of Cookies and Other Tracking Mechanisms

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site, App or Services. We may combine this information with other personal information we collect from you (and our service providers may do so on our behalf). 

Cookies.  Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.
• Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site, App and Services to, among other things, track the activities of Site visitors and App users, help us manage content, and compile statistics about Site and App usage. We and our service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Analytics. We use automated devices and applications, such as Google Analytics and Mixpanel, to evaluate usage of our Site, and to the extent permitted, our Apps. We also may use other analytic means to evaluate our Site and Apps. We use these tools to help us improve our Site’s and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Ad Network section.

Ad Networks

We use network advertisers to serve advertisements on unaffiliated websites and other media (e.g., social networking platforms). This enables us and these network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each entity’s specific privacy policy, not this one. We may provide these parties with information, including personal information, about you.

We may disclose certain information (such as your email address) to Facebook Custom Audiences (for more information on Facebook Custom Audience go here or to opt-out, go to the Facebook ad preferences page)—so that we can better target ads and content to you and others with similar interests on other websites or media (“Custom Audiences”). We may also work with other ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. You may also control how Facebook and other ad networks display certain ads to you, as explained further in their respective privacy policies or by using the opt-outs described below.

Users in the United States may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. App users may also download the AppChoices tool to manage interest-based advertising on their mobile device.Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or the AppChoices tool will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our App, Services, or on other websites or online media. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

User Generated Content

We invite you to post content on our Services, including your comments, pictures, and any other information that you would like to be available on our Services. If you post content to our Services, all of the information that you post will be available to all visitors to our Site, and your username will also be available to all registered users on our Services. If you post your own content on our Services, your posting may become public and we cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

Links

Our Site, App and Services may contain links to non-affiliated websites and online services, including links included in users’ posts. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those websites or online services. We are not responsible for the information practices of such websites or online services.

Security of My Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, device, and computer by, among other things, signing off after using a shared device, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Access to My Personal Information

You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Services for a period of time.

What Choices Do I Have Regarding Promotional Emails?

In accordance with applicable law, we will send periodic promotional communications to you. You may opt-out of such communications by following the opt-out instructions contained in the communication. We will process opt-out requests in accordance with applicable law. If you opt-out of receiving promotional communications, we may still send you communications about your account or any services you have requested or received from us. App users may enable or disable push notifications by adjusting their App or device settings.

Children Under 13

Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at [email protected].

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and App. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and App.

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Additional Information for California Residents 

In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.  

A. Categories of Personal Information Under the CCPA (Last Updated: July 1, 2021)

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months (from the Last Updated data above).  As further described in the Information We Collect About You section above, we may collect personal information from the following sources 

• directly from the individual  
• advertising networks
• data analytics providers
• social networks
• operating systems and platforms
• government entities
• business customers

The table below identifies the categories of personal information (as defined by the CCPA) we have collected about California consumers, as well as how we have disclosed for a business purpose such information. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the How We Use Your Information and the How We Share Your Information sections above.

B. California Residents’ Rights

CCPA Rights. In general, California residents have the following rights with respect to their personal information:

• Do-not-sell (opt-out): to opt-out of our sale of their personal information. While we may “sell” personal information as defined by the CCPA which specifically refers to advertising cookies that we use to deliver the service, we do not sell personal information about California consumers who we know are younger than 16 years old.] California residents may opt out of sales of their personal information by us, by submitting a request here: [email protected].
• Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.  
• Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
  • categories of personal information collected;
  • categories of sources of personal information;
  • categories of personal information about them we have disclosed for a business purpose or sold; 
  • categories of third parties to whom we have sold or disclosed for a business purpose their personal information; 
  • the business or commercial purposes for collecting or selling personal information; and
  • a copy of the specific pieces of personal information we have collected about them.
• Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA. 

Submitting CCPA Requests.  California residents may submit CCPA requests to opt out of sales, requests to know (access) and requests to delete their personal information through one of the following methods: 

• By emailing us at [email protected]

In addition, California residents may opt of “sales” of their personal information by us by emailing requests to [email protected] to opt out of “sales” via third party tags and cookies on our Sites, and provide evidence they identify as a California resident.

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must complete all required fields that we request which are required to verify your request.  In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.  Authorized agents may initiate a request on behalf of another individual by contacting us at [email protected]; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.    

For more information about our privacy practices, you may contact us as set forth in the Contact Us section above.