Medely Privacy Policy

Last Updated: June 7, 2023

Medely, Inc. (“Medely”) respects your concerns about privacy. This Privacy Policy describes the types of personal information we obtain about you when you visit our websites or our mobile applications (“collectively, “Sites”), how we use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to safeguard the personal information and how you can contact us about our privacy practices. If you are a California resident, please also see our California Consumer Privacy Statement.

Information We Obtain

We may obtain certain personal information that you choose to submit to us our Sites, including:

• Contact information, such as name, email and postal address, and phone number;
• Login credentials when you create an account on our Sites;
• Information you provide in the course of applying for a job with us, such as your resume information, legal work eligibility status, salary requirements, publicly-accessible social media profiles, background check information, and other information about you; and
• Other information you choose to provide, such as through communications with us.

In addition, if you are an independent provider of medical services (e.g., a nurse or medical technician) who uses our Sites (a “Professional”), we also may obtain:

• Information about your job preferences;
• Information about your work experience, professional credentials, education, health-care related licensure, and information in your resume;
• The geolocation of your mobile device with your permission when you enable this feature;
• Bank account information (e.g., account number and routing number) and payment card information (e.g., card number and expiration date), which may be collected on our behalf by our third-party payment processor; and
• Photos, images or videos.

When you visit our Sites, we may obtain certain information by automated means, such as cookies, web beacons, web server logs and other technologies. A “cookie” is a text file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, location information, referring URLs, pages visited, clickstream data, and dates and times of visits.

We may use these automated technologies on our Sites to collect information about your equipment, browsing actions, and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Sites; (3) tailor the Sites around your preferences; (4) measure the usability of our Sites and the effectiveness of our communications and marketing efforts; and (5) otherwise manage and enhance our products and services, and help ensure they are working properly.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Note, that without cookies you may not be able to use all of the features of our Sites. For mobile devices, you can manage how your device and browser share location data and certain device data by adjusting the privacy and security settings on your mobile device. Our Sites are not designed to respond to “do not track” signals from browsers.

How We Use The Information We Obtain

We may use the personal information we obtain about you to:

• Provide our products and services, including the Sites;
• Establish and manage your account with us;
• Verify your identity;
• Process and fulfill transactions in connection with our products and services;
• Communicate with you (including administrative notices and promotional communications about our products and services) and respond to your inquiries;
• Manage and administer our marketing and promotional efforts, including special events and contests;
• Establish and manage our business relationships;
• Personalize your experience on our Sites;
• Manage career opportunities at Medely, including for recruitment purposes, candidate screening and evaluation, and employee onboarding;
• Manage current and prospective business relationships;
• Protect against and prevent fraud, unauthorized transactions, claims and other liabilities;
• Perform analytics (including market research, trend analysis, financial analysis, and anonymization of personal information);
• Operate, evaluate, develop and improve our business (including managing our Sites, products and services; developing new products and services; enhancing and improving our Sites, products and services; managing and evaluating our communications; analyzing our Sites, products and services; and performing accounting, auditing and other internal functions);
• Maintain and enhance the safety and security of our Sites, products and services, and prevent misuse; and
• Comply with and enforce applicable legal requirements, industry standards and Medely policies and terms, including our Terms of Service.

We also may use the information in other ways for which we provide specific notice at the time of collection.

Third-Party Analytics

We also use third party web analytics services on the Sites, such Google Analytics. The service providers that administer these services use technologies such as cookies, web beacons and web server logs to help us analyze how visitors use our Sites. The information we obtain through our Sites may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit https://policies.google.com/technologies/partner-sites.

How We Share The Information We Obtain

We may share the information we obtain about you with our affiliates and subsidiaries. We also may share the information we obtain about you with our service providers. We do not authorize these service providers to retain, use or disclose the personal information except as necessary to perform services on our behalf or comply with legal requirements.

If you are a Professional, we may share your information with third parties seeking to engage the services of Professionals (i.e., independent third-party medical facilities). We also may share information we obtain with insurance providers or our business partners.

In addition, we may disclose personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.

We reserve the right to transfer any personal information we have about you in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business or assets (including in the event of a merger, acquisition, joint venture, divestiture, restructuring, reorganization, dissolution or liquidation).

Your Rights and Choices

We offer you certain choices in connection with the personal information we collect from you. If you have an account with us, you can update your profile information or the types of communications you wish to receive from us by logging into your account. You also can unsubscribe from our marketing emails by clicking the “Unsubscribe” link in the emails.

If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement.”

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Children's Privacy

Our Sites are intended for a general audience and are not directed to children. We do not knowingly collect personal information online from children under the age of 13, or such other age as may be stipulated by applicable law.

Third-Party Links And Features

For your convenience and information, our Sites may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Medely, we are not responsible for these third parties' information practices.

Updates To Our Privacy Policy

This Privacy Policy may be updated periodically and to reflect changes in our personal information practices. We will post a notice on our Sites to notify you of significant changes to our Privacy Policy and indicate at the top of the Privacy Policy when it was most recently updated.

How To Contact Us

If you have any questions about this Privacy Policy, please contact us at [email protected].

California Consumer Privacy Statement

Last Updated: January 1, 2023

This California Consumer Privacy Statement (“Statement”) supplements the Medely Privacy Policy (“Privacy Policy”) and applies solely to personal information collected about California consumers, such as Professionals, visitors to our Sites, job applicants, and representatives of medical facilities, vendors and business partners. This Statement does not apply to personal information collected about Medely personnel.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the Last Updated date of this Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), date of birth, online identifier, IP address, email address, account name, Social Security number, driver's license number, passport number, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, bank account number, credit card number, debit card number, or other financial information, education information, medical information and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, age, sex, gender, gender expression, marital status, medical condition, disability, and citizenship status
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information: audio, electronic, visual, and similar information
• Employment Information: professional or employment-related information such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the Last Updated date of this Statement) your personal information for the purposes described in the Privacy Policy and for the following business purposes:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
• Providing advertising and marketing services;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Short-term, transient use, such as nonpersonalized advertising shown as part of your current interaction with us;
• Helping to ensure security and integrity;
• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them;
• Debugging to identify and repair errors;
• Undertaking internal research for technological development and demonstration;

We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in the Privacy Policy and this Statement, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

Sources of Personal Information

During the 12-month period prior to the Last Updated date of this Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you contact us
• Your devices, such as when you use our Sites
• Our affiliates and subsidiaries
• Vendors who provide services on our behalf
• Medical facilities and business partners
• Your employer, if you are a representative of a vendor, medical facility or business partner
• Data analytics providers
• Social networks
• Recruiting and talent agencies
• Job references, such as your employers
• Data brokers, such as background check services

Disclosure of Personal Information

During the 12-month period prior to the Last Updated date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this Statement, we may have disclosed personal information about you to government entities and third parties in connection with actual or proposed corporate transactions, such as mergers, acquisitions or divestitures.

We do not sell, or share for cross-context behavioral advertising purposes, personal information about California consumers covered by this Statement.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold or shared about you.
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request. To submit an access, correction, or deletion request, please email [email protected]. To submit a request as an authorized agent on behalf of a consumer, please email [email protected]. For questions or concerns about our privacy policies and practices, please contact us as described in our Privacy Policy.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your deletion or correction request. If you have an online account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an online account with us and you request access to, correction of or deletion of your personal information, we may require you to verify certain of your information in our records, such as your email address, mailing address and phone number. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.