PRIVACY POLICY

Last Revised: November 1, 2024

Introduction

This Privacy Policy details how Carefam, Inc. and its affiliates (“us“, ”we”, ”our” or “Carefam“) process information of our clients’ employees or contractors who are registered users of our services, of individuals who wish to offer their services as caregivers or healthcare professionals to our clients via the Services or the Website (each, a “Care Talent“) or to any other user of our Website, as applicable (each of the above, “you“ or “User“) collected through our proprietary AI caregiving talent marketplace software solution, or through our website located at www.carefam.com (the “Services“ and “Website“, respectively).

Carefam’s details are as follows:

Carefam, Inc.
349 Metropolitan Ave, Apt 6E, Brooklyn, NY 11211
New York, NY 11211
United States
privacy@carefam.com

We may revise this policy from time to time, in our sole discretion, and the most current version will always be posted on our Website (as reflected in the “Last Revised” heading). We encourage you to visit this page regularly for any changes.

What Information We Collect

We may collect personal data about you, which means any information which are related to an identified or identifiable natural person, or “personal data” or “personal information” as otherwise defined under applicable privacy laws (“Personal Data“):

For Users of Our Website (Any)

We may collect information that you provide to us voluntarily such as your email address, for instance when you communicate with us via the ‘contact us’ option on the Website. In those cases, we will use such information to contact you in connection with your submission to us. Such information may also include Personal Data that is shared with us by third parties, based on your consent to be contacted for marketing purposes.
We may collect specific types of connection details and information with regard to your device, software or hardware that may identify you. Such information may include your browser type, OS version, device model, IP address, device location, network information, etc.
Information regarding User’s activity on the Website such as your clicks, actions and browsing on the Website.

For Users of Our Services (Care Talent)

Information which you provide us with when signing-up or registering to our Services, which may include the following information: your name, account name and email address.
Information you provide via the Website or Services in order to enter into engagements with our clients, including education records such as student records and directory information, and professional details and history including work history and CV.
We also collect information about your use of the Services, either on an identified basis, in connection with our Services to the applicable customer, or on an anonymized basis, for statistical purposes or to train and improve the Services’ performance, to improve our Website and to develop new products and services.

Client Users

Information which we receive from our clients when signing-up or registering to our Services, which may include the following information: your name, account name and email address.
We also collect information about your use of the Services, either on an identified basis, in connection with our Services to the applicable customer, or on an anonymized basis, for statistical purposes or to train and improve the Services’ performance, to improve our Website and to develop new products and services.

Excluded Personal Data

Unless expressly agreed between you and Carefam, including in a separate agreement, we do not process sensitive Personal Data or protected health information. Furthermore, we do not knowingly process the information of persons under 18 years old.

Legal Basis for Our Personal Data Processing

Depending on the type of use, Carefam processes Personal Data based on the following legal basis:

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
Processing is necessary for our legitimate interests and those of third parties in the purposes identified below
Processing is necessary to comply with our legal obligations
Consent (with regards to marketing communications)

How We Use the Information

We use the information in the manner described in this Privacy Policy. In addition to those purposes listed herein, the information we collect, which may include your Personal Data, is used for the following purposes:

To respond to inquiries and requests from our Users, to provide you with further information about our products and services;
If you are a Care Talent, to share such information with our clients and allow you to enter into engagements with them;
To provide our clients with the Services, including support in connection therewith;
To investigate and resolve disputes in connection with your use of the Services;
To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
To improve the performance of our Website.

With Whom We Share the Information and For What Purpose

We do not rent or sell any Personal Data. We may share Personal Data with the following recipients:

Our third-party vendors engaged in providing services in connection with the Services, the Website or sending marketing communications (the latter, with your consent);
Our subsidiaries and affiliated companies;
tors or advisers of our business processes; and
Any potential purchasers or investors in Carefam, in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, including a spin-off transaction.

We may share Personal Data with our recipients for any of the following purposes: (i) storing or processing Personal Data on our behalf (e.g., cloud computing service providers); (ii) assisting us with our business operations (e.g., verifying and processing transactions); (iii) performing research, technical diagnostics, personalization and analytics that will enable us to train and improve the Services and Website’s performance, and develop new products and services; or (iv) business transaction with the aforementioned purchasers or investors, of the type set out above.

We may also disclose Personal Data, or any information you submitted via the Services or Website (as applicable) if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our agreements), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

Cookies and Related Technologies

We and our service providers may use cookies because they:

help us optimize, personalize and/or otherwise improve your experience and/or the performance of the Services and our service and marketing-related communications with you; and
enable advertising delivered to you to be more relevant.

Most web browsers allow you to erase cookies on your computer, block cookies from your computer, or notify you when a cookie is stored on your computer. If you choose to disable or otherwise block certain cookies, you may be unable to use, or experience decreased functionality with, parts of the Services.

We use Google Analytics to collect information about your use of the Services. This third party service collects and shares information about your use of the Services in accordance with the following terms. You can opt-out of this tracking technology here.

International Data Transfers

Since we operate globally, it may be necessary to transfer data, including Personal Data, to other countries than the country in which the information was collected. In these instances, we will transfer your data only based on standard data protection clauses adopted by the European Commission.

For How Long We Retain Personal Data

We retain the Personal Data that we collect from our Users for as long as it is relevant based on the purpose it was collected for (for Website Users), and/or for long as we are providing the Services to the applicable customer (for Users of our Services). Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we may keep records containing Users’ Personal Data, account opening documents, communications and anything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Your Privacy Rights

Certain jurisdictions and states provide Users with certain statutory rights to their Personal Data. Subject to exemptions provided by law, and with proper identification, you may have the right to certain actions to your Personal Data such as:

Right to verify your Personal Data (to access, delete, change or update any Personal Data relating to you. For example, if you believe that your Personal Data is incorrect, you may ask to have it corrected or deleted);
Right to see what Personal Data about you we have;
Right to request that we erase Personal Data about you (subject to any other legal obligation that may require us to keep that information);
Right to restrict us from processing Personal Data pertaining to you (for example, you may request that we will stop using or sharing your Personal Data with third-parties); and
Right to export Personal Data in a portable format.

In addition to the above, Users located in specific jurisdictions and states, such as California and Virginia, may be entitled specific rights, in accordance with their applicable privacy laws.

If you wish to exercise any of your privacy rights under this policy or applicable law, please contact us at: privacy@carefam.com. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Data). However, please note that if you choose not to allow us to process certain Personal Data, it may affect the provision of Services that require the processing of that specific data or access to certain parts and features of the Website, including your complete access to the Services.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to raise a complaint on how we have handled your Personal Data, please contact us directly at: privacy@carefam.com.

If you are not satisfied with our response or believe we are collecting or processing your Personal Data not in accordance with the laws, you can file a complaint to the applicable data protection authority.