TANDEM – PRIVACY POLICY

Last Updated: January 1, 2024

Welcome to our Privacy Policy. This Privacy Policy explains how we collect, use, disclose, and secure Personal Information about our users (“you” or “your”) of our website located at https://www.tandem.care, our associated online service and mobile applications, and other related non-medical caregiver support services (collectively the “Service”).  This Policy also applies to the Personal Information we may collect about the subscribers of our Services (“Members”) and our caregivers (“Caregivers”).  The terms “Tandem Care”, “Tandem”, “we”, “us”, and “our” include Tandem Care Inc., a Delaware Corporation and all of our affiliates and subsidiaries. This Privacy Policy is incorporated by reference into our Terms of Use. If you do not agree with this Privacy Policy, please do not use the Service or provide us with any Personal Information. Any capitalized terms used and not defined in this Privacy Policy shall have the meaning(s) given to them in our Terms of Use.

When referred to in this Privacy Policy, the term “Personal Information” includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including any information that is subject to applicable data protection laws.

PERSONAL INFORMATION TANDEM COLLECTS

Personal and Contact Information. When you engage with us or use the Service, we may collect Personal Information about you, such as name, address, telephone number, email address, birth date, gender, and household information (e.g., spouse and child name and contact information). If you are a Caregiver, we may collect your social security number and other potential identifiers.

Professional Information about Caregivers. Caregivers who apply for employment with us may be asked to provide certain professional and employment information such as professional experience, credentials, education, performance history, job title, training records, income/salary/compensation, biography, and driver’s license information, and background check information. Specifically, if you are a Caregiver, we may verify your professional registration with your state regulator, and with your permission, we may review a background investigation report provided to us by you or on your behalf.

Financial/Payment Information. If you are a Caregiver, you may need to provide bank account information to our service providers. If you are a Member or his/her associate, relative, friend, or another individual responsible for a Member (“Associate”), you may need to provide a bank account, credit card information, and billing address to us or our service provider in order to submit payment for the Service.

Health Information about Members. If you are a Member or Associate, to request or use the Service, we may collect Member health information, such as physical or psychological state of health, medical history, medical treatment or diagnosis, health care provider information, caregiver preferences, and other similar information about care needs or that may be necessary for us to provide the Service.

Registration and Account Information. You may provide other information, such as your account login credentials (i.e., username and password).

Communications. If you submit any questions or comments, complete surveys, or otherwise contact our support teams or us, we may collect and save a record of your communication and any Personal Information provided during the communication.

Device Content, Internet, and Electronic Network Activity Information. With your permission, the Service may access and collect information you select from your device’s contact list and photo storage so you can store contact information and photos on the Service. If you are a Caregiver, we may coordinate with third-party mobile application providers that will collect your geo-location, working time, and other information, and we receive such information for timekeeping, payment, and other business purposes. We may be able to infer a Member’s location from the Caregiver’s geo-location (e.g., if we are monitoring a Caregiver who is providing you with a service). Additionally, when using the Service, we may collect your browser characteristics, IP address or other device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of the Service.

Activity and Utility Usage Data.  Depending on the Services you subscribe to, we may collect your activity and utility usage data.  This data is collected using passive monitoring devices offered by us. Depending on your agreement and configuration of the services, we may collect utility data such as electricity, water, gas, and other similar utility usage data. We may also collect certain activity data such as door opening and closing and other similar data indicating your activity level. This is a customizable service, and the above are examples of data we may collect, and actual collection may vary depending on the amount and placement of monitors in your home.

If you are part of a service that allows for the collection of this type of data, you will be provided with notice of this at the time you join the service.

HOW TANDEM COLLECTS PERSONAL INFORMATION

We may obtain Personal Information when you provide it directly to us, including but not limited to the following:

• Using the Services. We may collect the Personal Information you provide when you use the Service.

• Creating an Account with Us. We may collect Personal Information (such as name, contact information, and login credentials) when you register or create an account to use the Services.

• Surveys. We may invite you to participate in surveys, and we receive any Personal Information you provide when participating in those surveys.

• Referrals. You may submit information, such as an email address, about others to us so that you can recommend the Service or content available on the Service to them. We use the information (including Personal Information) to send a communication to the individual. The recipient of an invitation to use the Service will see your name and email address as the referrer.

• Communicating with Us. We may collect Personal Information about you through your communications with our customer-support team or through other communications with us, including through social media, our online chat features, and by telephone. This information you provide to us may include questions, feedback, comments, suggestions, and other information submitted through the Service or via email.

• Applying to Work for Us. We may collect Personal Information about you (including contact information and professional and educational background information), when you submit an application for employment as a Caregiver or other position at Tandem.

• Using our Passive Monitoring Devices. When you subscribe to our services, you will be provided with our proprietary monitoring devices to be installed at your home. We use those devices to collect a variety of usage and activity data.

We may obtain Personal Information from third parties including but not limited to the following:

• Service Providers. We may coordinate with third-party service providers for Caregiver management, timekeeping, and compensation, as well as other business or employment purposes. We may also partner and work with third-party service providers in order to provide the Services to you, including service providers that help us receive, process, or analyze data.

• Payment Processors. While we do not process any payments, when you make payments for the Service, or if you are a Caregiver and receive earnings from us, from time to time we may receive applicable payment information and other Personal Information from our payment processors or back-office vendor.

• Your Associates. If you are a Member, your health care providers or your Associates may provide us with your Personal Information, including health and care-related information to assist with your care and its coordination and updating our records.

• Members. If you are a Caregiver, we may receive Personal Information from or about your assigned Member to fulfill our legal obligations and as necessary to handle employment and professional-related issues and complaints.

• Other Third Parties. We may receive contact information from other third parties for potential outreach related to employment or marketing purposes.

• Publicly Available Information.  We may receive Personal Information from publicly available sources, including websites, social media accounts, and other public records.

We may combine Personal Information from different sources. For example, we may combine Personal Information that we have collected offline with Personal Information we collect online, or we may combine Personal Information we get from a third party with Personal Information we already have.

If you submit any Personal Information about other people to us (for example, if you are an Associate and you provide Personal Information about a Member for whom you have responsibility), you represent that you have the authority to do so and to permit us to use the Personal Information in accordance with this Privacy Policy.

COOKIES

Additionally, when you visit or use the Service or open our emails, we and our third-party partners, such as advertising networks and analytics providers, collect certain Personal Information (including from your computer system or mobile device) by automated means, such as cookies, web beacons, web server logs, and other tracking software. By using the Service, you consent to the placement of cookies, beacons, and other similar technology in your browser and on emails in accordance with this Privacy Policy. We may use this information, for example, to improve the Service, determine how many users have visited certain pages or opened messages or newsletters, or to prevent fraud. We may link this data to your profile.

Some cookies we use are essential for parts of the Service to function, while we use others to collect statistical information to make the Service more convenient and useful for you. Some cookies are temporary and will disappear when you close your browser, others are persistent and will stay on your computer for some time.

Some of the cookies are strictly necessary for the functionality of the Service, particularly our website, while others are used to enhance your user experience.

• Strictly Necessary Cookies. Strictly necessary cookies are used to enable you to move around the Service and use its features. Without these cookies, a Service you have requested, such as remembering your login details or submitted information, cannot be provided.

• Functional Cookies. Functional cookies are used to remember choices you make (e.g., your log-in details), make sure you are secure when logged-in, and make sure that the website looks consistent. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

• Performance Cookies. Performance cookies are used to collect anonymous information on how people use our website and enhance the performance of the website and the user experience.

• Targeting/Advertising Cookies. Targeting cookies or advertising cookies are used to collect Personal Information about your browsing habits in order to make advertising more relevant to you and your interests and send such information to other websites to customize their advertisements.

You can refuse or accept cookies from the Service at any time by activating the settings on your browser. You are always free to decline our cookies if your browser permits, but some parts of the Service may not work properly if you do. Check the “Help” menu of your browser to learn how to change your cookie preferences. If you would like more information about opting out of advertising cookies on the particular device on which you are accessing this Privacy Policy, please go to http://optout.aboutads.info/. The Network Advertising Initiative also offers a means to opt out of a number of advertising cookies. Please visit http://www.networkadvertising.org to learn more. Note that opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.

Our partners also may collect and combine Personal Information about your online activities over time, on other devices, and on other websites or online services, if those websites and online services also use the same partners. We currently use Google Analytics to collect and process certain website usage data. To learn more about Google Analytics and how to opt out, please visit www.google.com/policies/privacy/partners/.

DO NOT TRACK

At this time, our Site does not recognize automated browser signals regarding tracking mechanisms, which may include Do-Not-Track instructions.

HOW TANDEM USES PERSONAL INFORMATION

Internal and Service-Related Usage. We use Personal Information to provide and improve our Services. For example, we may analyze the Personal Information collected through the Service and use the analysis to try to improve the Service. Additionally, we may use Personal Information for Caregiver management, timekeeping, and compensation purposes.

If you subscribe to certain of our services, we may collect additional data, such as utility usage and activity data. We use this data to develop a baseline activity level and utility usage data. We then continue to collect and monitor your ongoing usage and activity data and compare that data to the established baseline. If we detect a variation or an anomaly, we will then contact you and/or your authorized contacts or our Caregiver to ensure your wellbeing. We may also use this data to aggregate activity and usage tracking to study and discover usage patterns to improve our services.

Communications. We may send emails to the email address you provide to us, push notifications to your mobile device if you have downloaded our app and enabled notifications and send text messages to any mobile number you provided to us, to verify your account and for informational and operational purposes, such as account management, customer service, system maintenance, and other Service-related purposes.

Employment. We may use Personal Information you provide when you apply for employment with us to process your employment application, including to conduct background checks and education and employment verification, as applicable. Please note that if you accept an offer from us, we may transfer the Personal Information we collected about you during the recruiting and job application process to your personnel file.

Marketing. We may use Personal Information about you for marketing purposes, such as providing online advertising on the Service and on other websites or online services and sending you information we think may be useful or relevant to you. You may opt-out of email marketing by using the unsubscribe link in a marketing email.

Legal Obligations. We may use Personal Information to protect our and others’ interests, rights, and property (such as to protect our copyrighted materials). We may also use Personal Information to comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts, and law enforcement requests.

Aggregate Data. We anonymize or aggregate data collected through the Service into aggregate data from which individual consumer identities have been removed so that the data is not linked or reasonably linkable to any consumer or household and may use and disclose this data for any purpose.

WHO WE SHARE YOUR PERSONAL INFORMATION WITH

Vendors and Service Providers. We share Personal Information with vendors and service providers that perform services on our behalf. For example, we will share Personal Information (e.g., name, address, email address, telephone number, and bank account information) with our back-office vendor to facilitate the receipt and payment of funds. We will share Personal Information with the vendor that provides the Caregiver time-keeping mobile application to create Caregiver accounts.  We may share your Personal Information with other service providers that facilitate the provision of the Services, such as a call center or emergency medical services.  We also partner with service providers to access, process, and analyze data to detect anomalies and alert us of changes in your activity and usage levels.  Service providers have limited access to the data and may only use it for the purpose for which it was shared with them and we retain the ownership of data shared with service providers.

Your Associates and Other Authorized Parties. We may share your Personal Information with your Associates or other parties that you have authorized to be contacted by us regarding the Services.  For example we may contact your next of kin or emergency services on your behalf and provide them with your Personal Information, such as your name, address, and other relevant information.

Marketing and Advertising Partners. We may allow access to your Personal Information to enable the delivery of online advertising to you and others on the Service and other websites and online services from our third-party advertising partners and us, or to send you information we think may be useful or relevant to you.

Legal and Similar Disclosures. We may access, preserve, and disclose Personal Information, if we believe doing so is required or appropriate to comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; comply with the law; or protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. If we are involved in a (potential or actual) merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of Tandem assets, or transition of service to another provider, Personal Information may be disclosed in connection with the negotiation of such transaction, and/or sold or transferred as part of such a transaction as permitted by law and/or contract.

With Your Permission. We may disclose Personal Information as described in this Privacy Policy or with your permission.

INFORMATION SECURITY

We take steps in an effort to treat Personal Information securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any Personal Information provided to us.

RETENTION

Except to the extent prohibited by law, and subject to this Privacy Policy, we will retain and use Personal Information for as long as it is needed to access our Services or to provide you with the Service you have requested, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us by calling at 1-800-955-4497 or by sending an email to [email protected]. If we learn that we have collected any Personal Information from children under 13, we will take the necessary steps to delete such Personal Information and terminate the child’s account.

INTERNATIONAL USERS

If you are visiting or using the Service from other jurisdictions, please be advised that you are transferring Personal Information to us in the United States where data protection and privacy laws may be less stringent than the laws of your jurisdiction. If you are using the Service, you agree to the transfer of the Personal Information you provide to the United States and processing globally. By providing Personal Information, you consent to any transfer and processing in accordance with this Privacy Policy.

Additionally, the Service is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.

PRIVACY RIGHTS

California Shine the Light Law. California Civil Code Section 1798.83 permits California residents to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain Personal Information for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request you should send a letter to Tandem Care Inc., 324 S Beverly Dr #171 Beverly Hills, CA 90212. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.

THIRD-PARTY SERVICES AND LINKED WEBSITES

The Service may also contain links to third-party websites or services. This Privacy Policy does not apply to the information (including Personal Information) collected on any third-party service or website over which we have no influence or control. We are not responsible for the privacy practices of these third-party services or websites. Accordingly, we recommend that you review the privacy notice and related policies posted on any third-party website.

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

If you would like to request that we update or correct any Personal Information that you have provided to us through your use of the Service or otherwise, or if you have suggestions for improving this Privacy Policy, please send an email to [email protected].

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

Posting of a Revised Privacy Policy. We may make changes to this Privacy Policy from time to time, and the revised version will be effective when it is posted and the last updated date will be listed on the top of this Privacy Policy. If we make any material changes, we will let you know through the Service, by email, or other communication. We encourage you to read this Privacy Policy periodically to stay up-to-date about our privacy practices. As long as you use the Service, you are agreeing to this Privacy Policy and any updates we make to it.

Contact Information

Tandem Care Inc.

324 S Beverly Dr #171 Beverly Hills, CA 90212

[email protected]