The family of companies comprised of Ingenovis Health; Fastaff, LLC; Stella.ai; Trustaff Management, LLC; U.S. Nursing Corporation, CardioSolution, LLC, and their subsidiaries and affiliates (collectively, the “Company” or “we” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (“Policy”).

This Policy describes the types of information we may collect from you or that you may provide when you visit the Company’s websites, including: IngenovisHealth.com, Trustaff.com, My.trustaff.com, Estaff365.com, mobile.er.trustaff.com, Fastaff.com, usnursing.com, myportal.fastaff.com, cardiosolution.com, and fastaff.erecruitcloud.com (collectively, the “Websites”), or when you download and use one of our mobile applications (the Websites and mobile applications are, collectively, the “Online Services”). This Policy further describes our practices for collecting, using, maintaining, protecting, and disclosing that information. Employees, independent contractors, and job applicants should review the separate privacy notices we provide to you, or make available to you, when you submit an application, regarding our collection and use of personal information in the employment/contracting/applicant context. If there are any conflicts between this Policy and the separate privacy notice, the separate notice controls.

By accessing or using the Online Services, you consent to the collection and use of your personal information by the Company in accordance with this Policy. If you do not agree to the terms of this Policy, please do not use the Online Services.

If we change this Policy, we will advise you of material changes through postings on our Websites, and/or email to the primary email address you provide to us (if any) or push notifications through our mobile applications. Your continued access to or use of the Online Services after we provide notice will mean that you accept the changes. You are responsible for ensuring we have an up-to-date active and deliverable email address for you if you wish to receive change notices via email, and for periodically visiting our Websites and this Policy to check for any changes.

In accordance with all applicable laws, this Policy applies to all personal information we collect about you from any source, including:

• Through the Online Services or any of your other interactions with the Company;
• In email, text, and other electronic messages between you and us, including through communications made through the Online Services;
• Through mobile and desktop applications you download from the Websites or online application platforms (such as Google Play or the App Store), which provide dedicated non-browser-based interaction between you and the Online Services; and
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

This Policy does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Online Services. As permitted by law, this Policy does not apply to personal information pertaining to employees, independent contractors, job applicants and individuals communicating with us in the business-to-business context, and collected in those contexts.

Please read this Policy carefully to understand our practices regarding your personal information. If you do not agree with our practices, your choice is not to use our Online Services. By accessing or using the Online Services, you agree to this Policy. The Company reserves all rights.

Information We Collect and Share or Disclose, and Sources of the Information

We collect several types of personal information from and about users of our Online Services. For purposes of this Policy, personal information is broadly defined to include, among other things, all information that can be directly or indirectly linked to an individual or household. In all cases, personal information does not include de-identified information, aggregate information that cannot be linked to a particular individual or household, or pseudonymized information.

Currently and for the 12-month period prior to the Effective Date of this Policy (except as specified below), we have collected and shared the categories of information listed below. This listing does not apply to employees, contractors, job applicants or business contacts:

• Identifiers, e.g. name, email address, postal address, phone number, online identifiers (such as user name), passwords when you set up an account, or internet protocol address. We collect this information when you provide it to us and automatically when you use our Online Services.

We may share this information with affiliates, subsidiaries, agents or service providers.

• Internet and other online activity, and device information, such as IP address; device ID; browser information and history; cookie information; operating systems; time stamps; the pages you request; the path you take on the Online Services; user settings; your use of our Online Services; search queries conducted on the Online Services; details of your use of the Online Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Online Services. We collect this information automatically when you use our Online Services.

We may share this information with affiliates, subsidiaries, agents or service providers.

• Geolocation data is collected when you provide it to us, or may be collected automatically by third party analytics companies.

We may share this information with affiliates, subsidiaries, agents or service providers.

• Information you provide to us, including if you use any of the services available through our Online Services, records and copies of your correspondence, and information and documentation you choose to upload using our document repository.

We may share this information with affiliates, subsidiaries, agents or service providers.

• Inferences drawn from information provided to us by you or third parties, and information that we collect automatically when you use our Online Services.

We may share this information with affiliates, subsidiaries, agents or service providers.

In addition, we have collected personal information from our employees, independent contractors and job applicants in the course of those individuals’ acting in their capacity as an employee, contractor or job applicant, as specified in notices provided or made available to them and any agreements with them, including in connection with registration to use the Nurse Portal login. We also have collected information from individuals who interact with us on behalf of a business, non-profit organization or governmental agency solely in the context of conducting business or providing or receiving a service, including information provided to us at the time such individuals register to use our services if the individual represents a hospital.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Websites, or transmitted to other users of the Websites or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Websites with whom you may choose to share your User Contributions. We cannot guarantee that third party vendors engaged by us who have access to User Contributions in connection with the services they perform will not provide access to User Contributions without authorization. We are not responsible for the actions or omissions of third party vendors. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automated Data Collection Technologies

We may use automatic data collection technologies to collect information about your online activities over time and across third-party websites or other online services. The information we collect automatically is statistical data and does not include personal information. It helps us to improve our Online Services and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Websites according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Websites.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies) A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites.

• Flash Cookies Certain features of our Online Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Online Services. Flash cookies are not managed by the same browser settings as are used for browser cookies.

• Web Beacons Pages of the Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Online Services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website, and that allows for tracking over time and across websites.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information – Our Business Purpose for Collecting the Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Services and their contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any purpose for which you provide it.
• To provide you with notices about your relationship with any of us.
• To notify you about changes to our Services or any products or services we offer or provide through it.
• To allow you to participate in interactive features on our Services.
• To provide you with information about job placements or assignments.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

The listing above regarding our use of personal information does not apply to personal information collected from our employees, applicants for employment, contractors or business contacts in the context of those relationships. We encourage employees, independent contractors and job applicants to review the separate privacy notices provided to them.

Additional Disclosures of Your Personal Information

In addition to the disclosures described above, we may disclose personal information that we collect or that you provide to us as follows:

• To comply with any court order, law, subpoenas, search warrants, judicial proceedings, legal process or law enforcement measures, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements.
• To establish or exercise our legal rights, or to defend against legal claims.
• To investigate, prevent, or take action regarding alleged or actual illegal activities, or as otherwise required by law.
• To comply with applicable laws, including laws pertaining to taxes.
• To administer a promotion, survey or other feature of our Services.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
• We may also share information about you for any other purposes disclosed to you at the time we collect your information or with your consent.
• To a prospective buyer or buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company is among the assets transferred, including in connection with any due diligence conducted in anticipation of such a transaction.

We may disclose aggregated information about our users and information that does not identify any individual, without restriction.

No Sales of Personal Information

We have not sold personal information to third parties during the 12 months prior to the Effective Date of this Policy, and do not plan to do so without further notice (with the exception of a sale in connection with the sale or transfer of the business or our assets, as noted in the section above about Additional Disclosures).

Security Measures

We have implemented measures designed to secure your personal information and information you upload to the Repository from accidental loss and from unauthorized access, use, alteration, and disclosure. No security measures are perfect or impenetrable. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to a part of one of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we work hard to protect your personal information and information in the Repository from unauthorized access, alteration, disclosure, and loss, we cannot guarantee the security of your personal information transmitted to or stored through our Websites or that information will not be altered or lost. Any transmission, storage or loss of personal or other information is at your own risk. You should keep backup copies of all information stored on the Repository and check that materials on the Repository are accurate. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.

Your Rights With Respect to Personal Information We Collect

If you are a California resident, you have certain rights with respect to your information under the California Consumer Privacy Act (“CCPA”). Those rights and how you may exercise them are described below. Those rights are not absolute and the Company reserves all available rights in this regard. For example, the rights described below do not extend to personal information collected in the employment/independent contracting context (including job applicants) or business-to-business context. We are, however, pleased to extend these rights to all individuals regardless of state of residence, subject to the same exclusions that pertain to California residents.

• Non-Discrimination You have the right to be free from discrimination for exercising your rights to know or delete.
• Right to Know You may request that we provide you a list of the categories of personal information we have collected about you over the last 12 months, the categories of sources from which it was collected, the business or commercial purpose for collecting or selling the information, and the categories of third parties to whom we disclosed or sold that information. You may also request that we provide you a copy of the specific pieces of personal information we have collected about you in the past 12 months. You may make a request to know up to two times in a 12-month period, subject to limitations described in the law. For a list of general categories of information that we have collected and shared in the past 12 months, see the listing above under “Information We Collect and Share or Disclose, and Sources of the Information.”
• Right to Delete You may request that we delete any personal information that we have collected from you, with the exception of information that the law allows us to keep. When we respond to your request to delete, we will explain what (if any) information we have kept and why.
• How to Make a Request to Know or Delete You may make a request to know or delete by emailing [email protected], [email protected], [email protected], or submitting your request online on our Website at https://response.fastaff.com/Privacy, https://www.trustaff.com/privacy-request, or by calling our toll-free number at 1-800-736-8773 or 877-880-3046. When you make a request, we will take steps to verify your identity before responding. This is to protect your information. We will ask you to provide us your email and physical address. If you maintain an account with us, these must match the addresses connected to your account. We will then send you a physical letter to this address with a one-time code. You must email us this code from the email address you provided to us. Once you do, we will respond to your request.
• Authorized Agent You may designate an authorized agent to make requests on your behalf. We will require verification that you did, in fact, authorize the agent. Unless the law requires otherwise, your authorized agent must provide contact details for you. We will contact you to confirm that you authorized the agent. Once you confirm, we will promptly respond to the rights request.

As permitted by law, the rights described above do not apply to all personal information that we collect. For example, we collect information from our employees, independent contractors and job applicants in the course of those individuals’ acting in those capacities, consistent with notices provided to them and any agreements with them. We also collect information from individuals who interact with us on behalf of a business, non-profit organization or governmental agency solely in the context of conducting business or providing or receiving a service. These and other categories of information are excluded from the rights described above. the Company reserves its right to rely upon all exclusions and other provisions allowed by law.

Minors Under Age 18 and Children Under Age 13

Minors under 18 years of age may have the personal information and content that they have posted on the Websites removed by sending an email to [email protected], [email protected], or [email protected], requesting removal. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that content or information from all sites, services or systems.

Our Online Services are not intended for children under 13 years of age or any minors. No one under age 13 may provide any information to or through the Online Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on any of the Online Services or on or through any of its features/register on any of the Online Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.

“Do not track” Signals

Some Internet browsers include the ability to transmit “Do Not Track” signals. We do not process or respond to “Do Not Track” signals.

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us at:

LEGAL DEPARTMENT
Ingenovis Health
5700 South Quebec Street
Suite 300
Greenwood Village, CO 80111
[email protected] / 800-736-8773
[email protected] / 800-736-8773
[email protected] / 877-880-3046

Updated effective date: 9-15-2021