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PRIVACY POLICY




Effective Date: March 11, 2021

This Privacy Policy applies to the following websites: www.nextshifthealth.com and www.nextshift.com (collectively, the "Site") owned and operated by NextShift LLC, a Pennsylvania limited liability company ("NextShift", "we" or "us"). This Privacy Policy describes how NextShift collects, uses, shares and secures the personal information you provide when you visit the Site. It also describes your choices regarding use, access, correction and deletion of your personal information.

1. How We Collect Information

We collect the following personal information from you:

1.1 Information that you provide to us about yourself

When you contact us by completing a form on the Site, we ask you for your name, telephone number and email address. If you do not provide this information, we may not be able to respond to your request.

1.2 Information collected automatically

When you visit the Site, we may use cookies and similar technologies to collect information about your location, and your activities on the Site, information about your device and log information. This is described in more detail below. These cookies and similar technologies collect anonymized Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. NextShift allows Google Analytics to use these technologies to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our visitors for the purpose of analytics. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the Site.

Google Analytics:

As noted above, we use a tool called "Google Analytics" to collect some information about your use of the Site. We use the information we get from Google Analytics to improve the Site and to understand how visitors use the Site. In order to collect this information, Google Analytics may set cookies on your browser or mobile device, or read cookies that are already there. Google Analytics may also receive information about you from apps you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google's ability to use and share information collected by Google Analytics about your visits to the Services to another application which partners with Google, is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Please review those and see http://www.google.com/policies/privacy/partners/ for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here.

2. Purpose and Legal Basis of the Processing

To the extent EU data protection law applies to our processing of personal information about you, we act as the "data controller".To perform the Services: We use your information to identify you and communicate with you about our products and services. The legal basis for these uses in the performance of a contract with you.To Optimize or improve the Services: We use your information to authenticate you, prevent fraud and abuse and perform research. The legal basis for these uses is our legitimate interest in the improvement and optimization of our offerings and in ensuring the security of our Site, and we apply appropriate safeguards to protect your personal information (see Section 4 below).

3. How We Share Your Information

We share personal information with service providers, as required by law and in connection with the protection and enforcement of our legal and contractual rights.

With Service Providers: We share your personal information with third parties who provide services on our behalf to help with our business activities. This includes: providing customer service, sending marketing communications, conducting research and analysis and providing cloud computing infrastructure. The legal basis for sharing this information is our legitimate interest in providing our products and services efficiently, and we implement measure to safeguard your personal information.

With Public Authorities or Law Enforcement:
In certain situations, NextShift may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law (such as to comply with a subpoena or other legal process), when we believe in good faith that disclosure is necessary to protect our rights, when we believe there is a violation to our Terms of Use, to protect your safety or the safety of others, to investigate fraud, to respond to a government request, if we are involved in a merger, acquisition or sale of all or a portion of our business or assets, or if we are involved in a bankruptcy or liquidation proceeding. The legal basis for this is our legitimate interest in protecting our legal rights and those of others, compliance with legal obligations and our legitimate interest in fulfilling legal obligations imposed by legal authorities outside of the EU.

Prevent fraud and abuse of the Services: We will share personal information to prevent or detect fraud or to address technical issues and if we believe it is necessary to investigate, prevent or take action regarding situations that involve abuse of the Site infrastructure. The legal basis for this is our legitimate interest in the maintaining the security of our Site.We also process and share information in an aggregated, de-identified manner where the information is shared as part of a statistical report and does not contain personal information.

4. Security

The security of your personal information is important to us. We implement adequate measures to protect the personal information submitted to us, both during transmission and once it is received. NextShift takes steps to ensure that all personal information remain private and confidential. We restrict access to personal information to NextShift employees, contractors and agents who need to know that information in order to operate, develop or improve our Site or offerings. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. If you have any questions about the security of your personal information, you can contact us at the contact information below.

5. Rights with respect to your information

Upon request, NextShift will provide you with information about whether we hold any of your personal information. You may access, correct, obtain a copy of or request deletion of your personal information by contacting us at the contact information below. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or we may need to retain your personal information in order to continue providing a service. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

6. Your Choices with Respect to Personal Information

We use and disclose personal information in ways that are consistent with your expectations and choices. Accordingly, we will provide you with the opportunity to choose (opt out) whether your personal information is to be (a) disclosed to a third party or (b) used for a purpose that is materially different from the purpose(s) for which it was collected or subsequently authorized. You will be provided with clear, conspicuous and readily available mechanisms to exercise your choices. To do so, please email us your request any time at [email protected], and we will respond to your request within a reasonable timeframe.

Promotional Email communication: You may have the option to sign-up to receive email or newsletters or other communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the "Unsubscribe" link found in emails we send to you or by contacting us at the contact information below.

7. Data Retention

We may retain your information for as long as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. In certain circumstances we may be required by law to retain your personal information, or we may need to retain your personal information in order to continue providing a service.

8. Policy Regarding Children

The Site is not directed to children under the age of 16. We do not knowingly collect personal information from children under 16. If you are under 16, please do not use the Site and do not provide any personal information to us. If you become aware that a child under 16 has provided us with personal information without the consent of a parent or legal guardian, please contact us at [email protected].

9. Transfers of Personal Information Not from the EEA, the UK or Switzerland

To the extent that personal information is transferred to the United States from countries other than countries within the European Economic Area, the United Kingdom or Switzerland, including personal information that is transferred from Canada, we employ similar safeguards such as selecting third party vendors carefully, ensuring personal information will be used and disclosed only as set out in this Privacy Policy and ensuring that it is protected by appropriate security safeguards.

However, in connection with these transfers of personal information, your personal information may be subject to privacy laws that may not provide the same protection as your country of residence. For example, government entities in such other countries may have certain rights to access your personal information. By using this Site, you are consenting to this transfer of your personal information.

10. Privacy Notice for California Residents

This Privacy Notice for California Residents applies solely to the personal data of individuals who reside in the State of California. We have provided this Privacy Notice for California Residents to comply with the California Consumer Privacy Act of 2018 and its implementing regulations (the "CCPA"), and any terms defined in the CCPA have the same meaning when used in this notice.

Your Rights and Choices: California residents have certain specific rights regarding their personal information. This section describes those rights and how California residents may exercise them.

Access to Specific Information; Data Portability Rights. California residents have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: (a) the categories of personal information we collected about you; (b) the categories of sources for the personal information we collected about you; (c) our business or commercial purpose for collecting or selling that personal information; (d) the categories of third parties with whom we share that personal information, if any; (e) the specific pieces of personal information we collected about you (also called a data portability request); (f) if we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.

Deletion Request Rights
. California residents have the right to request that we delete any personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, if any, to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (a) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (b) detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities; (c) debug products to identify and repair errors that impair existing intended functionality; (d) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (e) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (f) engage in public or peer-reviewed research in accordance with Section 1798.105 (d)(6) of the CCPA; (g) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (h) comply with a legal obligation; or (i) make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights
. To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by email at [email protected].

Only a California resident, or a person registered with the California Secretary of State that a California resident authorizes to act on the California resident's behalf, may make a verifiable consumer request related to that California resident's personal information.

You may only make a verifiable consumer request for access or data portability twice within any 12-month period. The verifiable consumer request must: (a) provide sufficient information that allows us to reasonably verify that you are the individual about whom we collected personal information or that you are an authorized representative of that individual; and (b) describe your request with sufficient detail to allows us to properly understand, evaluate and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable consumer request. 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 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.

Non-Discrimination
. We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; (d) 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.

Contact Information: If you have any questions or comments about this Privacy Notice for California Residents, the ways in which we collect and use your information described in this notice, your choices and rights regarding such use or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: [email protected]
Phone: 800-399-0690
Postal Address: NextShift LLC, 116 Research Drive, Bethlehem, PA 18015

11. Browser Do Not Track

We honor and enforce Do Not Track preferences. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit donottrack.us.

12. Changes to This Privacy PolicyWe may need to update this policy from time to time. Unless otherwise required by law, we will notify of such changes by updating the Effective Date at the top of this Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices. By continuing to use the Site, you are agreeing to and accepting the then-current version of this Privacy Policy.

13. Privacy Questions / Feedback
If you have questions or concerns about NextShift's Privacy Policy please contact us at [email protected] or NextShift LLC, 116 Research Drive, Bethlehem, PA 18015.