Clipboard Health Privacy Policy

Updated September 26, 2022

Welcome! This Privacy Policy explains how Twomagnets Inc. dba Clipboard Health (“CBH,” “Clipboard Health,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes Personal Information (as defined below) in connection with our CBH websites (the “Site”), the CBH desktop/mobile applications (the “Apps”), and the related content, products, services, and other functionality offered on or through the online services (collectively, the “Services”). It does not address our privacy practices relating to individuals  employed directly by CBH.

A user of the Services is hereinafter referred to as a “User,” or collectively, the “Users.” Users can include individuals such as website visitors, healthcare professionals seeking shifts (“Healthcare Professionals” or “HCPs”) and representatives of facilities or agencies seeking healthcare talent (“Facilities”).

In certain instances, when Facilities or other healthcare agencies use our Services to submit, manage, or otherwise process protected health information, we have contractually agreed to act as a “Business Associate” and only process such information on behalf of and under the instruction of the respective Facility or agency, who is the “Covered Entity”. This Privacy Policy does not apply to such processing, and we recommend you contact the Covered Entity with any questions regarding the processing of your protected health information.

What Is Personal Information?

When we use the term “Personal Information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

CBH’s Collection of Personal Information

Sometimes we collect Personal Information automatically when an individual interacts with our Services, and sometimes we collect the Personal Information directly from an individual. At times, we may collect Personal Information about an individual from other sources, even before our first direct interaction with that individual.

Personal Information Collected from You Directly

We may collect the following Personal Information from you directly:

        Contact Information, including your name, your employer’s name (if applicable), address, phone number, email address, and communications preferences.

        Inquiry Information, including information provided in custom messages sent through our Site. We also may collect your information when you sign up to receive information or notifications from us.

        Healthcare Professional Information, including name, email address, address, zip code, phone number,  licensing information, Social Security Number, date of birth, gender, driver’s license number and information, background check (including criminal history-related) information, physical and health-related information, COVID-19 screening and vaccination information, profile information including but not limited to preferences relating to shifts and facilities, professional information including prior roles, videotape, film, record, photograph, voice, or all related instrumental, musical, or other sound effects, information you provide on boards or in chats, and any other information provided to us during your account sign-up process or through our Services. Please note we utilize the third-party provider Stripe to process payments on our behalf. Although you provide your personally identifiable financial information in connection with payments, such as your credit and debit card numbers, directly to Stripe, we may store or view your Stripe account data which may include your Stripe account number, and the last four digits of your credit card, debit card and/or bank account number. To view Stripe’s privacy policy, please visit: https://stripe.com/privacy.

        Facility Information, including facility/company name, related entities’ names, names of facility representatives, those representatives’ positions, address, email address, phone number, profile information, billing and payment information, and any other information provided to us during your account sign-up process or through the Services.

        Survey and Testimonial Information, including information provided in any questions submitted through surveys, or content of any testimonials.

        Any Other Personal Information You Choose to Provide.

CBH may also collect and store certain data about your use of the Services on an aggregate and/or de-identified basis.

Personal Information Automatically Collected

General. As is true of many websites, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, such as the list below and in the sub-sections here:

        Device Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services). Device Data may overlap with the other categories of data below.

        Analytics Data, including the path taken to our Services, through our Services, and when exiting our Services, usage and activity on or in connection with our Services, metrics on how many emails we send are actually opened and which attachments or links are opened, clicked, or viewed (such as via pixels, as described further below).

        Location Data of Healthcare Professional Users, such as precise or coarse geographic location we or our third-party providers may collect, including via permissions within the app operating system or browser functionality. With your permission, we may collect precise geographic location (including GPS and WiFi data) from your mobile device. For example, we may collect such information when you have an upcoming shift or when you are otherwise active in the Clipboard Health App if you have set your device’s location permissions to “Always Allow” or “Allow all the time.” We will use that information to track your location up to two hours before a booked shift in order to predict whether you will be on time for that shift and provide you with an “Attendance Confirmation Required” notification if it appears you will not be on time (and cancel your shift and enable booking of that shift on an “Urgent Shift” basis by another healthcare professional user of the marketplace if you fail to confirm attendance), and to allow you to access Urgent Shifts in your area. As another example, we may collect precise geographic location if you have set your device’s location permissions to “Allow Once” or “Allow While Using the App,” and will use such information to confirm shift attendance and the timing of any break once at the Facility in order to facilitate InstantPay, if you have opted into InstantPay.  You may change the Services’ access to your device information and your location at any time through your “Settings” app on your device.  For more information, please see the “Control Over Your Information” section of our Privacy Policy. Please note that certain aspects of the Services, including InstantPay and access to Urgent Shifts, may not be available if you do not grant the relevant level of location sharing permissions in the Clipboard Health App.

        Advertising/Advertising Measurement Data, including data associated with your view of, or click on, advertisements served on our Services, cookie IDs or other digital or proprietary identifier (e.g., iOS IDFA, Google AAID) assigned to such device, and device metadata, analytics data, and location data described above, in each case, for purposes of serving advertising (personalized or otherwise) or facilitating advertising measurement/attribution to better optimize or otherwise understand the effectiveness of ad campaigns.

For more information on our and third-party partners’ data collection and online advertising practices, please see the “Third-Party Data Collection and Online Advertising” section of this Privacy Policy.

        Cookies and Other Technologies. Like many websites, we and our third-party providers may use “cookies” that our Services use to collect and store information about Users. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We and our third-party service providers may also use other tracking technologies, such as “pixel tags,” “web beacons,” “clear GIFs,” SDKs, location-identifying technologies, or similar means in connection with the Services and HTML-formatted email messages to, among other things, track the actions of Users and email recipients and to automatically collect the personal information described in this section (and otherwise expanded upon in other sections). See the “Control Over Your Information” section below to learn more about how you may limit or disable cookies or certain other tracking technologies on your device.

Note that we and our third-party partners may combine information that each of us collects automatically with other information about you, including information you choose to provide.

Personal Information Collected Through Other Sources

We also obtain Personal Information from third parties, which we often combine with Personal Information we collect either automatically or directly from you. For example, we may receive the same categories of Personal Information as described above from the following third parties:

        Your Employer / Company: When an individual interacts with our Services as an employee or representative of their company, we may receive their information from their employer or other employees at their company.

        Other Users: When you interact with other Users on the Services we may receive information you choose to share with them. For example, if you send a direct message to another User, we may receive the information in the message. We also may receive ratings and comments from other Users. For example, we receive HCP ratings from Facilities after shifts are completed.

        CBH Marketplace Sign-Up-Related Third Parties: When you sign up for a Healthcare Professional account to access CBH’s marketplace or seek a shift through CBH’s marketplace, we may receive personal information from related third parties, such as websites and platforms containing information about CBH and opportunities to find shifts through our marketplace, references, background check providers, and recruiters.

        Licensing and Certifications: We may receive information from third parties in order to verify your licenses or certifications.

        Referrals: We may receive your information through our Refer a Coworker Program. For example, when a User refers you to CBH, we receive your contact information.

        Social Media: When you interact with our Services through various social media networks, such as when you log in through a social network, “Like” us on Facebook or follow us or share our content on Google, Facebook, Twitter, or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.

        Service Providers: Our service providers that perform services solely on our behalf, such as payment processors or survey and certain advertising/marketing providers, collect personal information and may share some or all of this information with us.

        Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement personal information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual or obtain demographic information (e.g., preferences).

        Other Sources: We may also collect Personal Information about you that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.

Only authorized CBH staff have access to your Personal Information in its entirety. Other staff may have access to portions of this information if it pertains to their job duties.

CBH's Use of Personal Information

CBH uses Personal Information for the following general purposes:

    •       to fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to provide our products and the Services, and to process transactions,
    •       to manage our organization and its day-to-day operations,
    •       to determine whether you may sign up for an account to access CBH’s marketplace as a Healthcare Professional or Facility,
    •       to request individuals to complete surveys about our organization, organizations we partner with, Facilities, and the Services,
    •       to facilitate promotions, contests and sweepstakes,
    •       to offer incentives to Users in the marketplace,
    •       to determine whether Healthcare Professionals will arrive on time to booked shifts, and whether they are at the Facilities during shifts,
    •       to suggest and display nearby available shifts,
    •       for billing, payment, identification and authentication, and fraud prevention,
    •       to identify and analyze how individuals use our Site and Services and to conduct research and analytics on our User base and our Services,
    •       to improve and customize our products and the Services to address the needs and interests of our Userbase and other individuals we interact with,
    •       to communicate with you, including via email, text message, social media and/or telephone calls, and to deliver administrative notices and communications relevant to your use of our products and the Services,
    •       to market our Services to individuals, including through email, direct mail, phone or text message,
    •       to administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Site,
    •       to facilitate User benefits and services, including customer support through our command center services,
    •       for internal market research,
    •       to test, enhance, update and monitor the Services, or diagnose, fix or troubleshoot technology problems,
    •       to help maintain the safety, security and integrity of our property and Services, technology assets and business,
    •       to detect, investigate, provide notice of or protect against error, fraud or other unlawful or criminal activity,
    •       for distribution to third-party contractors that provide services to CBH and partners of CBH,
    •       to comply with legal obligations,
    •       to defend, protect or enforce our rights or applicable contracts and agreements, including our Terms of Service, and
    •       as otherwise set forth in this Privacy Policy.

Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry/request and/or Personal Information we require fall outside the scope of this Privacy Policy. In that case, the additional privacy disclosures will govern how we may process the information provided at that time.

CBH’s Disclosure of Personal Information

We disclose Personal Information in the following ways:

        Affiliates. We may share Personal Information with other companies owned or controlled by CBH, and other companies owned by or under common ownership as CBH, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.

        Healthcare Facilities. In limited circumstances, we may share your personal information, including your social security number and the results of your background check, with Healthcare Facilities with whom you have booked a shift. Background check information will be provided to Facilities with whom you book a shift as a matter of course. Sharing of social security numbers with Facilities will be limited to instances where required by the Healthcare Facilities reporting requirements (i.e., the Healthcare Facility is required to report an allegation against a Healthcare Professional for alleged instances of abuse, narcotics theft, patient neglect, patient abandonment, or workplace violence) or pursuant to a legal obligation.      

        Survey, Contest and Sweepstakes Providers, Sponsors and Partners. We may share Personal Information with third parties who assist us in delivering our survey offerings and processing the responses. We also may share information with our contest, sweepstakes and other promotional providers and partners. Some CBH content is “sponsored by” or “presented by” other companies. CBH shares market research data (how the sponsorship performed, names of contest winners, etc.) collected on this Site, the Services, or via email surveys with these partners. This information is usually in aggregate form. Partners may sponsor promotions, contests and sweepstakes that require you to reveal details such as your name, address or phone number. Always check their privacy policy before revealing information about yourself. If you don’t want these sponsors to have your Personal Information, you can choose to not participate.

        Your Employer / Company: When an individual interacts with our Services as an employee or representative of their company, we share their information with their employer or other employees at their company.

        Other Users: We may share your Personal Information with other Users. For example, if you are a Healthcare Professional who signs up for a shift at a Facility, we may share your information with that Facility.

        Marketing Providers: We coordinate and share Personal Information with our marketing providers in order to communicate with individuals about the Services we make available.

        Customer Service and Communication Providers: We share Personal Information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.

        Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as payment processing, website hosting, infrastructure provisioning, IT services, analytics services, administrative services.

        Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Information may also be disclosed in the event of insolvency, bankruptcy or receivership.

        Legal Obligations and Rights: We may disclose Personal Information to third parties, such as legal advisors and law enforcement:

o   if required by law or if we are given reason to believe, in our sole discretion, that someone is causing injury to or interference with the rights of Users, the general public, or CBH,

o   to comply with a judicial proceeding, court order, legal process, or required response to a regulator,

o   in connection with the establishment, exercise, or defense of legal claims,

o   to protect our rights and property and the rights and property of others, including to enforce our agreements and policies,

o   to detect, suppress, or prevent fraud,

o   to protect the health and safety of us and others, or

o   as otherwise required by applicable law.

        Otherwise With Consent or Direction: We may disclose Personal Information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Site or service-related publications.

Except as otherwise required by applicable law, we will not disclose to non-partner third parties any Personal Information specifying your medical or health condition, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership without your consent.

Third-Party Data Collection and Online Advertising

General. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on Personal Information and to measure the effectiveness of those ads. We permit third-party online advertising networks or exchanges (or other entities, such as demand-side or sell-side platforms or ad servers), measurement/attribution companies, ad fraud companies, social media companies, and other third-party services to collect information about your use of our online services so that they may display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including clickstream information, browser type, time and date you visited the Sites, mobile ad ID or other digital identifier (e.g., iOS IDFA, Google AAID, cookie ID, click ID, other proprietary IDs such as open source “universal IDs” or other ID solutions) precise or coarse geolocation, and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, analytics, market research, and measurement/attribution. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. For example, we may do this by providing your email address (typically in hashed format) or other information (such as phone number, which also is typically provided in hashed format) to the platform provider, such as via API, direct file upload, server-to-server transfer, or integrating the tracking technologies of those platform providers (e.g., pixel). Please see the “Control Over Your Information” section below to learn how you can opt out of interest-based advertising.

Social Media Platforms and Advertising.  Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter, or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media forums. For example, these companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. As mentioned in the section above, we may share a unique identifier, such as a user ID or hashed email address or phone number, with these platform providers or they may collect information from our website visitors through a pixel (or other mechanism, such as API, direct file upload, or server-to-server integration), in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.

Control Over Your Information

You may control your information in the following ways:

Choice/Opt-Out of Communications

General. You may opt-out of receiving communications from us and our partners, remove your information from our database, and choose to not receive future communications unrelated to the Services.

During the account sign-up process you will be automatically subscribed to receive correspondence from either CBH or its partners, but will be provided with the option to opt out of receiving such correspondence. This information remains on your profile.  You may contact CBH customer support (support@clipboardhealth.com or 408-837-0116) at any time to update your contact information and notification preferences.  If you enroll with CBH, we may occasionally contact you with information about special events, activities, promotions, contests, submission opportunities and programs. You always have the option to ask CBH not to contact you with this information again.

Email Communications Preferences. If you no longer wish to receive marketing or promotional emails from us, you can click the “unsubscribe” link in the latest email you receive from us.

Telephone Calls and SMS Text Messaging. We may use personal information we collect to communicate with you via text message and telephone calls, including (with your consent) to market to you or offer you information and updates on products or services we think you may be interested in. You can unsubscribe from marketing calls or text messages at any time by replying STOP or clicking the unsubscribe link (where available) in one of our messages. For more information, please see our Terms of Service.

Edit Your Information

We want to give you the ability to edit your Personal Information. To update your Personal Information, please do so in the CBH app. You may also contact our support team at support@clipboardhealth.com and we will assist you.

So that we can protect the integrity of sensitive data, there are certain pieces of information, such as your age, that you cannot alter yourself. Please contact us at support@clipboardhealth.com to find out how to change information you cannot access through your account.

Our databases automatically update any Personal Information you edit in your profile, or that you request we edit. Information transmitted through boards, chats, polls or through any other means remains in our databases and becomes the property of CBH upon submission.

Access to Your Device Information

You may control the Services’ access to your device information through your “Settings” app on your device.  For instance, you can withdraw permission for the Services to access your network devices and geolocation and to integrate with your other applications. Withdrawing access to certain device information may affect the features and functionality of the Services, and may inhibit our ability to provide you with the Services you have requested.

Deleting Your Account or Information

If you are a Healthcare Professional and would like to delete your account and/or delete your record in our system, you may submit your request by signing into your account on the mobile app or at https://hcp.clipboard.healthclipboard.health, navigating to ‘My Account,’ clicking on ‘Profile,’ and following the instructions to ‘Delete My Account’ at the bottom of the page. We may ask you to verify your identity before we process your request. In certain circumstances, we may not be able to respond to your request if we are not able to verify your identity or authority to make the request.

When you close your account, your deactivated status will be reflected promptly in our user databases and you may no longer be able to access your information. Please note that in some instances we may retain certain information to the extent required or permitted by law.

Cookies and Tracking Technologies

If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit.  Disabling cookies will usually result in also disabling certain functionalities and features of the Services.

Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Online Ads

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising (to the extent the advertising partner or other entity participates in such industry opt-out pages), you may wish to visit the Digital Advertising Alliance’s (DAA) resources or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services.  It means that the online ads that you do see from these self-regulatory program participants should not be based on your interests.  We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs, or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under those self-regulatory programs.

Children’s Personal Information

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any Personal Information either directly or by other means. If a child under the age of 13 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Information from our systems. If we learn that any Personal Information we collect has been provided by a child under the age of 13, we will promptly delete that Personal Information.

Links to Third-Party Websites or Services

Our Site and Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy policies.

Updates to this Privacy Policy

CBH’s security and privacy policy are periodically reviewed and enhanced as necessary. This policy might change as CBH updates and expands the Service. CBH will endeavor to notify you of these changes by email, but will not be liable for any failure to do so. CBH also encourages you to review this privacy policy periodically. If you do not understand any of the terms or conditions of any of CBH’s policies, you may inquire regarding the same via email at support@clipboardhealth.com.

State-Specific Disclosures

We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

        Nevada: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Please contact us at support@clipboardhealth.com to submit such a request.

        California: If you are a resident of the State of California in the U.S., please see our CA Notice for additional California-specific privacy information.

Users From Outside the United States

CBH and its Services are based in the United States. Please be aware that your information may be processed and transferred to the U.S. and be subject to U.S. law. The privacy and data protection laws in the U.S. may not be equivalent to such laws in your country of residence. By using the Site, participating in any of the Services, or by providing CBH with your information, you understand your Personal Information may be transferred to, stored in, and processed in the U.S.

How to Reach the CBH Team

If you have technical problems, questions or other issues related to your use of CBH, please click the link Contact Us on the home at the bottom of any page of this website. You can also contact us at support@clipboardhealth.com.

CBH’s team will respond to all requests sent through mail or email from Users and partners interested in knowing more about what personal information is stored on the CBH database, or if they want their personal information nullified, or have additional questions regarding privacy.

Contacting Us

If you have any questions about this privacy statement, the practices of this site, or your dealings with this website, you may contact us at support@clipboardhealth.com.