Privacy Notice

Effective Date: May 5, 2025
Last updated on: May 5, 2025

Homecare Software Solutions, LLC d/b/a HHAeXchange and its subsidiaries (“Company”, “we” or “us”) has created this privacy notice (“Privacy Notice”) in order to demonstrate our commitment to protecting the privacy of users of our products, which include (i) our websites, www.hhaeXchange.com, www.sandata.com, www.cashesoftware.com, and www.homecaresoftware.com including online job applications; (ii) our mobile application(s); and (iii) our web-based application(s) or portal(s) (collectively, the “Products”), in accordance with applicable privacy laws in the jurisdictions in which we operate.

For users of our Products, this Privacy Notice explains the information we collect via our Products, how that information is collected via our Products, and how that information is disseminated, used, and with whom it is shared. For our online job applicants, the purpose of this Privacy Notice is to inform you about how we collect, use, and disclose your personal information throughout the application process.

By using our Products, you represent and warrant that you have thoroughly read, understand and agree to all terms and conditions stated in this Privacy Notice and our Terms of Use. If you do not agree with our policies and practices as set forth herein, your choice is not to use our Products. This Privacy Notice may change from time to time. Your continued use of the Products after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.

Please note that the privacy practices set forth in this Privacy Notice are for our Products only and we are not responsible for the privacy practices of any third party, including any other application, website, or product that may be linked to, accessible from, or that you may use in connection with the Products. If you, the user, elect to link to other applications, websites, or products, please review the privacy policies posted for those products.

This Privacy Notice also does not apply to:

• information we may collect offline or through any other means,
• personal health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or similar state privacy laws,
• personal financial information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), or
• employee information.

Information We Collect About You

We collect several types of information from and about users of our Products, including:

• Contact Information: This includes your name, postal address, e-mail address, telephone number, employer, employer size, and any other identifier by which you may be contacted online or offline; and
• Other Identifiers: This includes your username, password, IP address, and online identifiers.
• Product Usage Information: This includes your visits to and use of our Products, including the equipment you use to access our Products and usage details as further described in the Computer and Internet/Network Information section below.
• Computer and Internet/Network Information: This includes the IP address of your device, the type of device you are using, its operating system, browser used, and device identifiers; Internet or mobile service provider; general geolocation of your device via IP address; website browsing activities and history (pages you visit, date and time of use, length of visit, browsing and search history, referring URL or exit pages); search history; and analytics data, statistical information, and information regarding your interaction with our Products or advertisements.
• Personal Characteristics or Traits: This includes demographic data, including those regarding characteristics protected by law, gender, and physical characteristics or description.
• Inferences Derived from Personal Information: This includes information about your characteristics, behavior, attitudes, aptitudes, interests or preferences, which may include inferences derived from your use of connected devices, or from combining multiple sources or categories of information. We may also supplement certain information we collect from you with outside records. External parties may provide us with information about you in connection with a co-marketing agreement or in connection with tracking technology.
• Geolocation Data: This includes your approximate geolocation, as well as your precise geolocation when you use our mobile applications as a provider of care. Please note that use of our mobile application for electronic visit verification requires you to enable location data for your visit to be verified in accordance with Section 12006 of the 21st Century Cures Act (and any similar and/or relevant state regulations).

Customer Feedback: Any data you voluntarily provide to us as part of a survey or other feedback mechanism. When you use our Products as a healthcare provider, we also collect:

• employment information;
• payroll information; and
• other information as required by your employer.

How We Collect Information

We collect this information directly from you, from other parties, or from you indirectly through cookies and other technologies, including when you:

• register to use our Products or request further services;
• use our Products;
• report a problem with our Products;
• contact us;
• respond to surveys that we might ask you to complete for research purposes or you otherwise provide us feedback.

Use of Information

We may use the information we collect about you as follows:

• to provide you with the Products and manage your account
• to provide you with customer support;
• to communicate with you regarding Products and services that you may be interested in;
• to research and analyze your use of and interest in our Products;
• to enforce our Terms of Use and Privacy Notice;
• to manage Company business;
• to diagnose problems with our server and to manage the Products;
• to personalize and improve our Products, including by enabling us to estimate our audience size and usage patterns; store information about your preferences, allowing us to customize our Products according to your individual interests; speed up your searches; and recognize you when you return to our Products;
• in connection with any other functions described at the time the information is collected;
• in the case of precise geolocation data collected through our mobile app for providers of care, to conduct Electronic Visit Verification for purposes relating to compliance with the 21st Century Cures Act and any similar and/or related state regulation(s); and
• to fulfill any other purpose for which you provide such information.

Any information submitted to us through our Products in connection with an online job application for a position with our Company will be used for the purpose of considering and moving forward with your application. We may also retain personal information from your application for the purpose of considering your application for future employment needs with our Company. Such information may be shared with third-party service providers whom we retain to gather, maintain, and evaluate candidate applications for job postings. All such information may also be shared to conduct and report equal opportunity and diversity monitoring where required by law or regulation.

With Whom We Share Information

We may share your personal information as follows:

• Provide the Products: We may share information to provide the Products to you or otherwise fulfill the purpose for which you provide the information to us.
• Service Providers: Third parties who perform services on behalf of the Company may require some personal information from users to provide their services. We may disclose personal information to contractors, business partners, marketing partners, analytics providers, and other vendors to provide, improve, and personalize Services or where we have your permission to do so. Our vendors may engage subcontractors to perform Services for us. For example, these services may include customer service, marketing assistance, Product support, business analysis, and member screening.
• Business Partners: Some of our services are offered in conjunction with partner companies and we may share some of your user data with such partners.
• Affiliates: We may share information with our affiliates.
• Significant Corporate Transaction: In the event of a significant corporate transaction which may include, but is not limited to, a sale, merger, consolidation of our business, or the sale of all or substantially all of the Company’s assets;
• Legal: We may also disclose your personal information as follows:
  • in response to a subpoena or similar legal requirement;
  • to comply with applicable law or cooperate with law enforcement or other government agencies;
  • to establish or exercise our legal rights including enforcing our Product’s terms and conditions or other agreements and policies;
  • to defend against legal claims;
  • to aid with efforts to investigate, prevent, or take action regarding suspected illegal activity such as fraud or other wrongdoing;
  • to conduct equal opportunity and diversity monitoring where required by law or regulation in the case of online job applicants;
  • to protect and defend our company, users, employees, and others; and
  • as otherwise required by law.
• Protection: We may share information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others.
• Consent: We may share information with your consent.

In any situation, we reserve the right to raise or waive any legal objection or rights available to us.

Your Choices Regarding Collection and Use of Your Information

You, as a user, have the following choices regarding information provided to the Products:

• Changing Account Information: Upon the creation of your account, your personal settings will be automatically set to a default position by your provider of care, agency, employer or the Company’s customer. To make any changes to your account, you must request such changes directly from your provider of care, agency, employer or the Company’s customer. We do not control the procedures of third parties and thus are not responsible for any changes to your account.
• Closing Your Account: To close your account, you must contact your provider of care and request they close your account. Upon the removal of your account, we will remove all of your personal information from public view within the applicable Product(s). We expressly disclaim any liability arising from the retention and/or deletion of information. We do not control the procedures of third parties and thus are not responsible for any information remaining in the public domain after removal from the Products.
• Opting Out of Marketing Emails: You may unsubscribe from marketing and advertising emails at any time by clicking the unsubscribe link in emails you receive from us and following the instructions provided.

Information Retention

We will retain the personal information that you share with us via the Products for as long as may be required or permitted under applicable law. If you are a California resident, please see our Privacy Notice for California Residents and Notice of Collection of Personal Information for California Applicants below for further information about our retention of California Personal Information (as defined below).

Children’s Data

Our Products are restricted to use by individuals fourteen (14) years of age and older. No one under the age of fourteen (14) may access or use the Products. We do not knowingly collect information from children under the age of fourteen (14). Should you have knowledge that a user of our Products is under the age of fourteen (14), please contact us immediately.

Visiting the Product from outside the U.S.

This Privacy Notice is intended to primarily cover the collection of information via the Products from United States residents. However, we recognize that some users may access our Products from Canada. In such cases, we handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA). If you are utilizing the Products outside the United States, please know that by using the Products, you understand and agree that your information may be transferred to and processed in the United States where our servers are located and our central database is operated and such information may also be transferred to our third parties with whom we share such information as described in this Privacy Notice. If you reside in Canada, you have the right to request how we use your personal information and the recipients to which it has been disclosed, as well as the right to access and correct your personal information. If you reside in Canada and would like to exercise your rights noted above, please submit your request to us by either:

• Calling us at 855.400.4429
• Emailing us at privacy@hhaexchange.com

Only you, or someone legally authorized to act on your behalf, may make a request to know or correct your Canadian personal information. You may also make a request to know or correct on behalf of your child.

Security

All information provided by users will be protected in accordance with industry standard security protocols and technology. We have physical, electronic and procedural security measures in place to prevent misuse and modification of your information under our control and to prevent any loss thereof. Unfortunately, the internet, mobile networks, and other networks our Products rely on are not completely secure and thus we cannot 100% guarantee the security of any information provided to us by our users. Please also note that email and other communication methods may not be secure, and you should avoid sending any personal information via such channels.

Cookies and Tracking Technologies

Depending on the Product being used, we may use cookies, pixels, web beacons, mobile analytics and advertising IDs, and similar online tracking technologies (collectively “cookies” or “tracking technologies”) managed by us or our third party vendors to provide, personalize, secure, support and improve our Products, to deliver advertisements and marketing, and to provide a better Product experience. For example, use of cookies allows us to customize our Products according to your individual interests; speed up your searches; and recognize you when you return to our Products.

Tracking technologies can generally be categorized as follows:

• Necessary or essential. These tracking technologies are used for core functionality, for example, for security and to enforce your privacy preferences. Without these cookies, some functionality on our Products will not work.
• Functional or analytics. These tracking technologies help to improve our Products by allowing us to understand how the Products are used and how they perform. We may also use location-aware technologies to locate you, including as determined by your IP address, for purposes such as verifying your location and delivering content based on your location.
• Advertising. These tracking technologies help personalize and measure ads that are shown to you on our Products, as well as on other parties’ online services. If enabled, these tracking technologies will allow other parties to engage in advertising based on your use of online services across platforms and over time.

In certain circumstances, we may combine tracking technology information with other personal information about you. We or external parties, on our behalf and pursuant to contract, may collect personal information about your online activities over time and across different online services when you use our Products.

We may use Google Analytics or other providers (such as Google Tag Manager and 6Sense) to help us understand how users interact with our Products and for other analytics services. We may also implement Google Analytics Advertising Features such as remarketing with analytics and interest-based ads. We may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to deliver advertisements, measure your interests, and/or personalize content.

For more information on how certain of these providers use data collected through our Products or to opt-out, visit:

• Google Analytics
  • For more information, please visit http://www.google.com/policies/privacy/partners, or any other URL that Google may provide from time to time.
  • To opt out of Google Analytics cookies, visit https://tools.google.com/dlpage/gaoptout or download the Google Analytics Opt-Out Browser Add-On.
• Google Tag Manager
  • For more information, please visit https://www.google.com/policies/privacy/partners, or any other URL that Google may provide from time to time.

You may also opt out of certain tracking technologies by visiting the opt-out services by the Digital Advertising Alliance in the U.S. and the Canadian Digital Advertising Alliance in Canada. You can visit Ad Choices (U.S.) or Your Ad Choices (Canada). Opting out through these services does not mean you will no longer receive advertising from us, or when you use the internet.

Depending on your device settings, you may also opt out of certain interest-based advertising through the device’s “Limit Ad Tracking” or equivalent feature. Refer to your device for more information on what this opt out affects. For instance, you can generally adjust or reset the advertising identifiers on your mobile device in the device settings. In addition, iOS and Android operating systems provide options to limit tracking and/or reset advertising IDs.
You can set your browser to refuse cookies from websites, but if you do so, you may not be able to access or use portions of our Products and certain portions of our Products may not function as intended or as well.

To control web beacons, most email providers have settings which allow you to prevent the automatic downloading of images, which will disable web beacons in the email messages you read.

We are not responsible for opt-out processes provided by external parties.

Interactive Features

We may engage third party service providers to provide certain interactive features on our Products. Your use of these interactive features is voluntary, and we and our third party service providers may monitor, record, use, share and retain the information that you submit through these features. For example, we may offer interactive chat or voice assistance features on or in our Products to (a) answer questions and for other customer support purposes and (b) help identify your product needs and for other sales and marketing purposes. When you participate in the interactive features, either with a virtual or live agent, the contents of the communication may be captured, recorded, kept as a transcript and stored by our third-party service providers. By using these features, you understand that our service providers may receive and process the information obtained through the feature to provide the service on our behalf.

Polls and Surveys

You may occasionally be invited to participate in polls and surveys by us and our affiliates, either directly or via a third-party service provider. Such invitation may be random or may be based on information gathered by us or the third party. Your participation is completely voluntary, and you may be asked to provide personally identifiable information in order to participate. Information gathered in connection with surveys or polls will be used only in connection with that survey or poll and will not be disclosed with any third parties other than the affiliate or third-party service provider conducting that survey or poll.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS AND NOTICE OF COLLECTION OF PERSONAL INFORMATION FOR CALIFORNIA APPLICANTS

This Privacy Notice for California Residents and Notice of Collection of Personal Information for California Applicants supplements the information contained in our Privacy Notice and applies solely to all visitors to and users of our Products who reside in the State of California (“consumers” or “you”) and California online job applicants (“California Applicants”). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice. Unless otherwise noted, the disclosures in this Privacy Notice for California residents cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.

Information We Collect

We collect California Consumer Personal Information from California users of our Products and California Applicant Personal Information from California Applicants (collectively, “California Personal Information”).

As used herein, the term “California Applicant Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California Applicants. California Applicant Personal Information does not include information that is publicly available, de-identified, or aggregated.

As used herein, “California Consumer Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

California Consumer Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

How and Why We Collect, Use, and Disclose Your Personal Information

We may collect, use, and disclose California Personal Information for business purposes consistent with applicable laws as identified below. Where we transfer applicable California Personal Information to recipients, such as our service providers, we do so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.

Category of Consumer Personal Information	Categories of Sources from which Collected	Business Purposes for Collection, Use, or Disclosure	Categories of Recipients to Whom Consumer Personal Information May be Disclosed for a Business Purpose
Identifiers (such as name, alias, title, postal address, unique personal identifier, online identifier, internet protocol address, email address, telephone number, account name, social security number, driver’s license number, professional license number, or other similar identifiers).	Directly from you Automatically when you use our Products including our online job application From service providers that help us to run our business	Provide the Products Open and maintain your job application records Confirm eligibility and conduct qualification and background checks Communicate with you Maintain business records Provide personalized advertising and marketing Comply with applicable state and federal law	Examples include service providers, data analytics providers, security providers, background check vendors, information technology vendors, advertisers, and state or federal governmental agencies
Internet or other electronic network activity information (including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with our websites, applications, social media pages, and advertisements).	Directly from you Automatically when you use our Products including our online job application From service providers that help us to run our business	Provide the Products, including analyzing usage patterns and behaviors Investigate security breaches and misuse of computer equipment and systems Protect the safety of employees and third parties Communicate with you Provide personalized advertising and marketing	Examples include data analytics providers, security providers, information technology vendors, advertisers, outside counsel, and state or federal governmental agencies.
Any personal information described in subdivision (e) of Section 1798.80 of the California Civil Code, such as name, physical and electronic signature, address, telephone number, physical characteristics, education, employment, and employment history	Directly from you Automatically when you use our Products including our online job application From service providers that help us to run our business	Provide the Products Open and maintain your job application records Confirm eligibility and conduct qualification and background checks Communicate with you Maintain business records Comply with applicable state and federal law	Examples include service providers, data analytics providers, security providers, background check vendors, information technology vendors, and state and federal government agencies.
Approximate geolocation data such as your geographic location inferred from your device IP address.	Automatically when you use our Products or our online job application From service providers that help us to run our business	Provide the Products Communicate with you Maintain business records Provide personalized advertising and marketing Comply with applicable state and federal law
Commercial information, including records of personal property, products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Directly from you Automatically when you use our Products including our online job application From service providers that help us to run our business	Provide the Products Communicate with you Maintain business records Provide personalized advertising and marketing Comply with applicable state and federal law	Examples include service providers data analytics providers, and advertisers.
Professional or employment-related information such as skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter. Answers to behavioral or other screening questions in an application or interview. Information contained in any websites or documents you choose to share with us. Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations. Information relating to membership in civic organizations.	Directly from you From service providers that help us to run our business	Open and maintain your job application records Confirm eligibility and conduct qualification and background checks Provide reasonable accommodation as required by law Maintain business records Comply with applicable state and federal law	Examples include background check vendors, outside counsel, and state or federal governmental agencies
Protected classification characteristics such as age race, color, national origin, religion or creed, marital status, disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.	Directly from you	Open and maintain your job application records Confirm eligibility and conduct qualification and background checks Conduct equal opportunity and diversity monitoring where permitted or required by law Provide reasonable accommodation as required by law. Comply with applicable state and federal law Maintain business records
Inferences drawn from other personal information (profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.)	Automatically when you use our Products including our online job application From service providers that help us to run our business	Provide personalized advertising and marketing	Examples include advertisers and data analytics providers.
Sensory data such as photographs, to the extent contained on documents you provide.	Directly from you From service providers that help us to run our business	Open and maintain your job application records Maintain business records Comply with applicable state and federal law	Examples include data analytics providers, security providers, information technology vendors, outside legal counsel, and state or federal governmental agencies.
Other California Applicant Personal Information that does not directly fall within the categories listed in the CCPA such as driving record, criminal records, background check information, drug and alcohol screening information.	Directly from you From service providers that help us to run our business	Open and maintain your job application records Confirm eligibility and conduct qualification and background checks Conduct equal opportunity and diversity monitoring where required by law Provide reasonable accommodation as required by law. For security and fraud detection/prevention Maintain business records Comply with applicable state and federal law or as required by company policy.	Examples include service providers, security providers, background check vendors, information technology vendors, outside legal counsel, and state or federal governmental agencies.

We may also collect publicly available information about you, including information that is lawfully made available to the general public from federal, state, or local government records.

We may disclose each of the categories of California Personal Information identified above to the identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the California Personal Information was collected, including, but not limited to:

• To personalize, our Products.
• To create, maintain, customize, and secure your account with us.
• To provide you with Product support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of your California Personal Information, our Products, our databases and other technology assets, and our business.
• For testing, research, analysis, and product development, including to develop and improve our Products.
• Auditing our ads;
• Performing services on our behalf.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.
• Short-term, transient use;
• As described to you when collecting your personal information or as otherwise set forth in the CCPA

In addition to the other purposes for collection, use, and disclosure of California Personal Information described in this Privacy Notice for California Residents and Notice of Collection of Personal Information for California Applicants, we may collect, use, and disclose California Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use and disclose California Personal Information to other parties in connection with the sale, assignment, merger, or reorganization of the Company.

Selling or Sharing of Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes for such disclosures, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart above.

We may also sell or share the following categories of California Personal Information with third parties for the purposes of cross-context behavioral advertising: identifiers, internet or other electronic network activity, and approximate geolocation data. We sell and/or share this California Personal Information with third parties for advertising purposes. The third parties to whom this personal information was sold and/or shared are advertisers and analytics vendors. When we use the terms sell, sold, or sale, we mean for valuable consideration and not monetary value.

We offer you the ability to opt out of sales and sharing of your California Personal Information as set forth below.

We do not have actual knowledge that we sell or share the California Personal Information of consumers under sixteen (16) years of age.

Data Retention

We will store your California Personal Information for as long as necessary for the performance of our obligations or to achieve the purposes for which the California Personal Information was collected, or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove California Personal Information from our systems and records or take appropriate steps to properly anonymize, deidentify, or aggregate it, where legally applicable.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your California Personal Information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Correct), we will disclose to you:

• The categories of California Personal Information we collected about you.
• The categories of sources for the California Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that California Personal Information.
• The categories of third parties with whom we share that California Personal Information.
• If we sold or disclosed your California Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the California Personal Information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the California Personal Information categories that each category of recipient obtained.
• The specific pieces of California Personal Information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your California Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Correct), we will review and respond to your request.
We will delete or deidentify personal information not subject to an exception from our records and will direct our service providers to take similar action.

Right to Correct

You have the right to correct California Personal Information that we hold about you (the “right to correct”).

Right to Limit Use and Disclosure of Sensitive California Personal Information.

We do not use or disclose sensitive California Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

Exercising Your Rights to Know, Delete, or Correct

To exercise your rights to know or delete described above, please submit a request by either:

• Calling us at 855.400.4429
• Emailing us at privacy@hhaexchange.com

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct your California Personal Information.

You may also make a request to know, delete, or correct on behalf of your child.

You may only submit a request to know twice within a 12-month period. Your request to know, delete, or correct must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.

You do not need to create an account with us to submit a request to know, delete, or correct. However, we do consider requests made through your password protected account sufficiently verified when the request relates to California Personal Information associated with that specific account.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@hhaexchange.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your California Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will only use California Personal Information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Changes to the Privacy Notice

We occasionally update this Privacy Notice and will post the date of the last update at the top of this Privacy Notice. Please check back periodically so as to inform yourself of any changes to this Privacy Notice. Any changes will become effective upon the posting of the revised Privacy Notice on our website. Each time that you use our Products, you agree to all terms set forth in this Privacy Notice, the Terms of Use and any other policies published by Company on the Product being utilized. In the event that you object to any changes, please promptly close your account. Please email us at privacy@hhaexchange.com with any questions regarding the terms or conditions of any of our policies.

Contact Information

If you have any questions regarding this Privacy Notice, please do not hesitate to contact us via email or postal mail as follows:
HHAeXchange
130 West 42nd Street, 2nd Floor
New York, NY 10036
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