SAFEQUAL PRIVACY POLICY

Last Updated April 10, 2025

Contents

Introduction

The purpose of this Privacy Policy (the “Policy”) is to describe how we collect, use, store, protect, and disclose personal data online and offline either via our websites or related applications. This Policy applies to personal data we collect or use and applications owned or controlled by SafeQual Health, L.P. and mobile app(s) (collectively referred to as the “Services”), or affiliated companies (collectively referred to as “SafeQual”, “we”, “us”, or “our”).

By using any part of the Services you agree that you have read this Policy, your personal data will be processed as described herein, and you agree to be bound by this Policy. This Policy is incorporated into our Terms of Use. Definitions not explicitly defined herein shall retain the meaning as prescribed in the Terms of Use. Any dispute related to privacy is subject to the Terms of Use and this Policy, including limitations on liability.

This Policy does not apply to (1) personal data controlled by our Customers (employers that utilize our Services, described further below), which is governed by our separate agreements and related data processing agreements with such Customers; (2) personal data collected by unaffiliated sites that link to or are accessible from our Services; (3) personal data our partners may collect directly from you and control; (4) personal data collected and processed by us about our employees or job applicants responding to our job offers; and, (5) non-personal data derived from personal data, including any data that is aggregated, de-identified, or anonymized, statistical data, insights, or other predictive data that is sufficiently different from your personal data that it cannot be reversed engineered through reasonable means, or otherwise identified from analysis or further processing of the derived data (collectively referred to as the “De-Identified Platform Data”). We use De-Identified Platform Data to provide Customers with useful and relevant insights, build features and data services, and improve our Services. Because De-Identified Platform Data does not identify you personally, we can use and disclose it at our discretion.

We are the controller for the personal data discussed in this Policy, except as noted in the “Where We Are a Service Provider” section below.

Where We Are a Service Provider

Our Customers are organizations such as private, federal, state, local, tribal, or other healthcare agencies (including administrative agencies, departments, and offices thereof), private businesses, and educational institutions (including without limitation K-12 schools, colleges, universities, and vocational schools), who use our Services to improve employee safety, patient safety, clinical quality, compliance, and risk management or otherwise improve operations of their healthcare systems. When we provide our Services to our Customers, the Customer generally controls and manages the personal data of patients, providers, staff, employees, vendors, volunteers, and others (which may include sensitive personal data, precise geolocation information, health information, and demographic information like race and ethnicity), and we process personal data as a "data processor" or "service provider" (as these terms are defined in applicable data protection laws). Our legal obligations as a processor and service provider are set out in our Customer contracts and policies. Our Customers, and not us, decide what types of personal data to collect to manage their relationships with you.

For instance, if you provide information about your vaccinations to your employer that utilizes our Services to manage their relationship with you, the personal data collected about you is generally controlled by the employer (our Customer). This Policy does not describe the processing of your personal data by our Customers, and we encourage you to visit the Customer’s privacy policy for information about their privacy practices.

Where we serve as a data processor or service provider, our Customer contracts and policies require us to either instruct you to contact our Customer, or redirect your inquiry to our Customer.

Personal Data We Collect About You and Why

In this Section we set out general categories of personal data we may collect and the purpose for using your personal data. We collect and process personal data to provide you the Services, fulfill our contractual responsibility to deliver the Services to our Customers, fulfill your requests, and pursue our legitimate interests and our business and commercial purposes. We also automatically collect data during your usage of the Services and collect other personal data about you from other sources. Your personal data will only be collected and used for purposes stated herein and/or within Agreements with our Customers, where you provide additional consent, or as required by law or regulation - including national security or law enforcement requirements.

Information Provided By You

We collect personal data from you directly when you visit our Services from either your computer, mobile phone, or other device, attend our events, or communicate with our personnel. The categories of personal data we collect from you, involve the following:

Types of Personal Data

Why the Personal Data is collected

Identification, account, and contact data, including your name, username and password, professional or personal email address, professional or personal telephone phone number, and account preferences.

  • Create your account, perform and manage our relationship with you and our Customers, and facilitate the relationship between you and our Customers for their hiring and employment purposes.
  • Communicate with you and send you information as part of the Services regarding your questions, comments, requests for information, contests you entered into, upcoming events, newsletters and surveys, technical notices, security alerts, statements and invoices, support and administrative messages, significant updates to the Services or policies, as well as relevant notifications regarding your account.
  • Notify you about our Services and events that we believe will interest you, for our legitimate interests in conducting direct marketing, or to the extent you’ve provided your consent. If you purchased or sent us an inquiry regarding our Services, we may send you information about similar Service you may be interested in. To learn how to manage these communications, see the “Your Data Rights and Choices” section of this Policy.
  • Provide support services, answer your requests, comments, and questions, troubleshoot, and diagnose problems with our Services.
  • Verify your identity, respond to legal requests, enforce our legal agreements where applicable, prevent fraud or potentially illegal activities, maintain security, and screen for and prevent undesirable or abusive activity.

Profile and employment data including your name, professional or personal postal address, professional or personal e-mail or telephone number, employer name and general location, job title or area of expertise, work experience and performance data, search history, job interest cards, education history, skills, certificates, and licenses.

  • Perform and manage our relationship with you and our Customers, and facilitate the relationship between you and our Customers for their hiring and employment purposes.
  • Provide you personalized recommendations of content, features, and Services, including to enable you to search and apply for jobs, match you with employers and job listings, help our Customers find and contact you, and display targeted notices and messages from our Customers.
  • Make improvements, enhancements, or modifications to the Services through data analysis and research of usage trends, and feedback sessions.
  • Provide support services, answer your requests, comments, and questions, troubleshoot, and diagnose problems with our Services.
  • Verify your identity, respond to legal requests, enforce our legal agreements where applicable, prevent fraud or potentially illegal activities, maintain security, and screen for and prevent undesirable or abusive activity.

Communications and publication data including communication content within emails, phone and other voice recordings, online forms, chats, forums including our Customer Community, date and time of the communication, and the communication method.

  • Make improvements, enhancements, or modifications to the Services based on your feedback collected through feedback sessions or content you post within our Services or the Customer Community about your experience using our Services.
  • Determine Services, events, newsletters, or contests that we believe will interest you and notify you.
  • Provide support services, answer your requests, comments, and questions, troubleshoot, and diagnose problems with our Services.
  • Verify your identity, respond to legal requests, enforce our legal agreements where applicable, prevent fraud or potentially illegal activities, maintain security, and screen for and prevent undesirable or abusive activity.

Contact preferences data including marketing content preferences, and the status of whether you opted-out of our marketing notices.

  • Manage and track your preferences for communications you receive from us, identify trends in the interactions with our Services, and measure the performance of our communications.

Personal Health Information and Personal Information data

  • To facilitate the processing of data, completion of processes, and are otherwise necessary for our Customers to benefit from the Services.
  • To facilitate the relationship between you and our Customers for their regulatory compliance, hiring, and employment purposes.

 

 

Submit Personal Health Information Only When Required

Only submit personal health information of a patient, yourself, another employee, or other person in a data field of our Services that is specifically designated exactly to receive such personal health information.

Do not submit anywhere else. Doing otherwise is a misuse of the Services.

For example, do not place personal health information such as a patient name or medical record number in a data field designated for something else. Do not attach an image or video with such information either without first redacting that information.

Submit Social Security Numbers Only When Required

Only submit social security number of a patient, yourself, another employee, or other person in a data field of our Services that is specifically designated exactly to receive such social security number.

Do not store anywhere else. Doing otherwise is a misuse of the Services.

For example, do not place social security number in a data field designated for something else. Do not attach an image or video with such information either without first redacting that information.

Do Not Submit Credit Card Numbers

You may not submit credit card numbers in our Services. Doing so is considered a misuse of the Services. Do not attach an image or video with such information either without first redacting that information.

Information Collected Automatically

With the help of our Service Providers, we may also automatically collect personal data about you and your device and how you interact with our Services. Categories of personal data collected automatically include the following:

Types of Personal Data

Why the Personal Data is collected

Usage data including Services you purchase, IP address, webpages visited, what you click on, features you use, how often and when you use the Services (including the date and time of your access or use), general location of usage, jobs performed, Service configurations, browser type and version, browser language, internet service provider, domain name, error logs, e-mails you view, and the subject of the ads you click or scroll over; and,

Device data including device address or other unique device identifying numbers, type of device, software and hardware attributes, your operating system, system and performance data, and mobile application permissions including cellular data, general geolocation, access to photos, camera, calendars, and reminders.

  • To facilitate the processing of data, completion of processes, and are otherwise necessary for our Customers to benefit from the Services.
  • To facilitate the relationship between you and our Customers for their regulatory compliance, hiring, and employment purposes.
  • Track your preferences and provide you personalized recommendations of content, features, and Services.
  • Make improvements, enhancements, or modifications to the Services.
  • Produce De-Identified Platform Data and conduct research on social, economic, and sectoral employment and hiring trends.
  • Verify your identity, respond to legal requests, enforce our legal agreements where applicable, prevent fraud or potentially illegal activities, maintain security, and screen for and prevent undesirable or abusive activity.

General Location data including your device’s location through data that indicates a country, state, city or postal code, and in certain instances, by tracking the latitude and longitude of your IP address, Wi-Fi address, or device.

  • To facilitate the processing of data, completion of processes, and are otherwise necessary for our Customers to benefit from the Services.
  • To facilitate the relationship between you and our Customers for their regulatory compliance, hiring, and employment purposes.
  • Verify your identity, respond to legal requests, enforce our legal agreements where applicable, prevent fraud or potentially illegal activities, maintain security, and screen for and prevent undesirable or abusive activity.

Log and other automatic data collection including data about the nature of each access, IP address, ISP, files viewed, content changes in certain cases, operating systems, device type and timestamps, pages you view, links you click, touch stream data, movement, scroll, keystroke activity, browser type, access times, and third-party sites and services you were using before and after interacting with our Services.

  • Track your preferences and provide you personalized recommendations of content, features, and Services.
  • Make improvements, enhancements, or modifications to the Services.
  • Ensure you can use our Services in conjunction with other services and facilitate your use of integrations.
  • Produce De-Identified Platform Data and conduct research on social, economic, and sectoral employment and hiring trends.
  • Verify your identity, respond to legal requests, enforce our legal agreements where applicable, prevent fraud or potentially illegal activities, maintain security, and screen for and prevent undesirable or abusive activity.

Cookies, pixel tags (“web beacons”), HTML Storage Objects, web tags, and embedded scripts within our communications and on our Services to collect data related to usage, location, device and logs.

  • Among other reasons, we use various cookies and other tracking technologies to provide our Services, authenticate users when visiting our Services, for security purposes (e.g., to prevent fraudulent use of the Services and protect our Services generally), track your preferences, provide personalized recommendations of content, features, and Services, deliver more relevant ads to you as you browse the web, including ads on websites and applications other than on our Services, and help us understand how our websites and communications are being used. For more information on Cookies see the “Cookies and similar Tracking Technologies; “Do Not Track” section immediately below.

 

Cookies and Similar Tracking Technologies

We and our service providers may use a variety of technologies to collect information about your device and use of our Services as discussed immediately above. Most web browsers can be programmed to accept or reject the use of some or all of these technologies, although you must take additional steps to disable or control other technologies. Among these technologies include:

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Microsoft EdgeGoogle ChromeMozilla Firefox, or Apple Safari). By blocking any or all cookies, you may not have access to certain features or offerings of the Services.

Online Analytics and Advertising

Online Analytics

We may use third-party web analytics services on our Services, such as those from Amazon AWS, Google Analytics, and others. These service providers use the sort of technology previously described in the “Personal Data We Collect About You and Why” section to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Tailored Online Advertising

We may personalize the content and advertising that you see when using the Services through the use of third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as other websites you visit and other applications you use. These third-party advertising technologies may include Google Ads, DoubleClick, Twitter, AddThis, ShareThis, and others. The ads may be based on various factors such as the content of the page you are visiting, information you provide such as your age and gender, your searches, demographic data, and other information we collect from you. These ads may be based on your current activity or your activity over time and may be tailored to your interests.

We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs. You can also use the options below in the "Rights Regarding Your Information" section below.

Please note that you may still receive advertisements even if you opt out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Information From Other Sources

We also receive your personal data described in this Policy from third party sources, including from your employer (our Customer), third party companies from which our Customer or we purchase personal data, accreditation agencies, and co-organizers and sponsors for our events and webinars.

Partners. We collect and use personal data originally collected by partners for joint product and marketing opportunities. If you sign into our Services with Facebook or other single sign on services, we import the requested data from your account.

Information We Disclose

We disclose personal data with other parties for the purposes stated herein or as required by law. The following lists the categories of entities we’ve disclosed personal data with, including over the past year.

To Customers

We disclose personal data to our Customers (your current or potential employer) that utilize our services. For instance, if you are a provider or staff member, we will disclose your personal data to the employer in order to manage compliance activities, such as vaccinations. If your current or former employer uses one of our Services, personal data you input into those Services is accessible by that employer’s end users - subject to the security and access controls set up by the employer.

To Service Providers

We disclose personal data to services providers to provide services on our behalf. For instance, we use service providers to facilitate our support services, data security, email, web hosting, research and analytics, data enrichment services, deliver and help us track our marketing and advertising content, coordinate our customer conferences, and manage our sales and customer relations.

Research and Event Partners/Sponsors

We work with other entities to perform research, under controls that are designed to protect your privacy. We publish or allow others to publish insights, presented as either aggregated, anonymized, de-identified, or non-personal data.

If you download or access content on our Services or attend an event or webinar we host or co-host, we may disclose your personal data to sponsors of the event or webinar. The sponsor may also be a controller of your personal data in this instance, and processing of your personal data will be subject to the sponsors’ privacy statements as well.

To Advertising Partners

As explained in detail above in the "Online Analytics and Advertising" section, we may disclose your information to third parties that assist in tailoring and serving advertisements that are relevant to you. We may also allow third-party advertising technologies (e.g., ad networks and ad servers) to use cookies and similar technologies on the Services to deliver relevant and targeted content and advertising to you on the Services and other websites you visit and applications you use.

To Other Parties When You Give Your Consent

We may also disclose personal data where you provide your consent or post your personal data publicly. Where required by law, additional consent is obtained before personal data is transferred to us or forwarded to other parties.

During your use of the Services, you may have the opportunity to visit or link to other websites, including websites by third parties unaffiliated with us. We have no relationship or control over unaffiliated websites. These websites might collect personal data about you, and you should review the privacy policies of such other websites to see how they treat your personal data.

To Other Third Parties Where Required By Law

We also disclose personal data or data in order to meet any applicable law, regulation, legal process or enforceable governmental request, investigate violations and enforce policies (including our Terms of Service, this Policy and other contracts with you), detect, prevent, or otherwise address fraud, protect against harm to the rights, property or safety of our users or the public, protect your vital interests or the vital interests of another natural person; and where disclosure is necessary for establishment, exercise or defense of legal claims or where there is reasonable belief that disclosure is required by law or regulations

Mergers, Acquisitions, Dissolutions, Affiliates

We may transfer or disclose personal data to another entity who acquires or may acquire any or all of our business units, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets, or bankruptcy. We disclose personal data to our affiliates with our Customers’ consent in order to facilitate any Service transition or implementation services.

International Users

Please be aware that we are based in the United States and the information we collect will be transferred to, processed, and stored on our servers in the United States in accordance with this Privacy Policy and applicable laws. The data protection laws and regulations applicable to your information transferred to the United States may be different from the laws in your country of residence. We take appropriate steps to protect, process, and transfer your information only in accordance with this Privacy Policy and applicable law, which may include using standard contractual clauses or other transfer mechanisms.

Your Data Rights and Choices

Marketing Communications

In accordance with applicable law, we may send you marketing and promotional emails. If you would like to opt out of email marketing, notify us at [email protected] or follow the unsubscribe instructions in the email. Please note that even though you may opt-out of receiving marketing-related communications from us, we may still send you important administrative and transactional messages (e.g., notifications regarding updates to our legal terms).

Rights Regarding Your Information

Depending on your jurisdiction, you may have the right, in accordance with applicable data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the Services to you or our Customer.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify your identity, we may be unable to respond to your requests.

To exercise any of these rights, you can contact us at [email protected] with your name and type of request you are making.

You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes

If you are a resident of certain U.S. states, you may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”

As explained in the “When We Disclose Your Information” and "Online Analytics and Advertising" sections above, we sometimes disclose information to third-party advertising providers for targeted advertising purposes or use advertising analytics partners to assist us in analyzing use of our services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the processing/sharing of personal information for targeted advertising purposes.

Please note that we do not knowingly sell the personal information of minors under 16 years of age.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Except as otherwise described herein with respect to legally required browser based opt outs, we do not recognize or respond to browser-initiated DNT signals, as there is no industry-wide framework for DNT signals. To learn more about Do Not Track, you can do so here.

Your Rights and Control Under EU GDPR

Data Controllers and Processors.

Our Customers use our Services to manage their human resource activities, and train their workforce. In conducting these activities, the Customer maintains control over what personal data is collected, how it is used, how long it is retained, and who it is disclosed to. For purposes of the EU GDPR, the Customer is considered a data controller in these respects and we are a data processor. In other instances, such as when we use cookies or contact you about our Services, we will determine the means and purpose of processing.

Lawful Basis for Processing

For personal data subject to the European Union General Data Protection Regulation and ePrivacy Directive, we rely on multiple legal bases for processing, including:

Consent. In certain cases, we ask you for your consent to process your personal data, for instance, for certain marketing purposes. You can withdraw your consent at any time; however, this will not affect the lawfulness of the processing before your consent was withdrawn. You can withdraw your consent by using the prompts within the messages you receive, the settings within your account, or by contacting our support using any of the privacy support emails listed at the end of this Policy.

Legitimate Interest. We process certain personal data for our legitimate interests. These legitimate interests include contacting you to provide support or sending you marketing information (subject to applicable law); detecting, preventing, and investigating illegal activities and potential security issues; and maintaining and improving our Services. We will balance our interests, the purpose and necessity of processing, and the rights and risks to you before we process for legitimate interests.

Performance of a Contract. We process personal data to perform our obligations under an agreement with you or our Customers.

Other Legal Bases. In some cases, we may have a legal obligation to process your personal data, such as in response to a court or regulator order. We also may need to process your personal data to protect vital interests, or to exercise, establish, or defend legal claims.

Automated Decision Making and Profiling

We use an automated chat bot within some of our Services to screen your requests and questions. The purpose of the automated chat bot is to fulfill frequently asked questions provided by our users, tag the requests and questions to route to our most appropriate contact, and improve our responses and Services. The chat bot is not fully automated and will not have a legal or significant impact on you.

Data Security and Integrity

We implement physical, technical, and administrative safeguards designed to maintain data accuracy, integrity, and security, prevent unauthorized access, and facilitate correct use of personal data. Our security measures take into account the risk of harm to you and Customers, as well as the availability of technology, industry common practices, effectiveness of mitigation controls, and the sustainability of those controls by us.

Although we maintain the controls listed herein, transmission of data is not without risk and the complete security of your personal data cannot be guaranteed. Please note, you are responsible for keeping your login credentials secret at all times, including your username and password.

Retention and Removal

For personal data we determine the purposes for and means by which it is processed, such personal data will not be kept for longer than necessary for the original purpose of collection, when no longer relevant, or upon permissible request. When the original purpose no longer exists, we will either delete or de-identify it (subject to applicable law) or, if this is not possible, we will securely store your personal data until deletion is possible. Your personal data will be appropriately disposed in a manner designed to ensure it cannot be reconstructed or read. If you are a job applicant, after your account has been closed, we may retain De-Identified Platform Data as permitted by law.

Where our Customer is the controller of your personal data, our retention policies and procedures are designed to allow Customers to comply with their own record retention requirements.

Right to Revise

We reserve the right to revise our Policy to reflect changes in our online information practices or to comply with the law by publishing a new version on our website. In circumstances where we materially change this Policy, we will provide you with appropriate notice in accordance with legal requirements. By continuing to access and use the Services, you are confirming that you have read and understood the latest version of this Policy.

Contact Details

This website is owned and operated by SafeQual Health, L.P. Our principal place of business is at 101 Sunnyside Blvd, Suite 201, Plainview, NY 11803. You can contact us by email, telephone 516 576-8000, or regular mail using the contact information listed herein.

Privacy Contacts

If at any time you have questions or concerns about this Policy, please feel free to call us at (516) 576-8000 or e-mail us at [email protected].