INTERPOSE LLC (dba Zelderly) Privacy Policy
Last Updated: September, 2023
Zelderly offers various services to help its users find, coordinate, and maintain quality care. Zelderly's Privacy Policy ("Privacy Policy") is designed to explain the information we collect and how we use it to provide our services and give users a better experience. It applies to any users of www.Zelderly.com and any web pages, mobile applications and mobile websites operated by Zelderly (collectively, the "Site"), including those who are seeking to find an individual through Zelderly ("Care Seekers") as well as those who are looking to promote their services through Zelderly ("Care Providers"), and any users of any of the various services that Zelderly provides through the Site or any other channels, including over the telephone (collectively, "Services").
For purposes of this Privacy Policy, the terms "Zelderly," "we," "us," and "our" refer to INTERPOSE LLC., and "You" refers to you, as a visitor or user or the Site or the Services. Other capitalized terms that are not expressly defined in this Privacy Policy have the same meaning as set forth in the Zelderly Terms of Use.
By using the Site and/or the Services, you consent to our collection, storage, use and disclosure of your information as described in this Privacy Policy.
Information We Collect and their Sources
Information you provide
Information provided by others
Information you expressly authorize us to collect
Automatically collected information
Purposes For Which We Use Information
How We Share and Categories of Third Parties With Whom We Share Information
Your Choices Regarding the Sharing of your Information
Your Communication Choices
Changing or Removing your Information and Closing your Account
Collection of Information from Children
How We Protect Information
Links to other Websites
Changes to our Privacy Policy
Collection of location data while using the Zelderly application
Contact Us
1. Information We Collect and their Sources
Visitors who access and browse the Site are "Site Visitors." In order to utilize the Services offered by Zelderly, you must register with Zelderly. All users who register with Zelderly are "Registered Users."
1.1 Information you provide
Regardless of whether you are a Site Visitor or a Registered User, all information that you provide to us when registering, posting a profile, communicating through the Site, discussing care options over the phone, utilizing our mobile applications or that you otherwise provide on the Site or by phone, email, postal mail or otherwise, will be stored by us. You represent and warrant to us that you have the right and authority to provide us all information you provide about yourself or others. You may provide us with information in various ways, including:
1.1.2 When registering
When you register directly through Zelderly, we will collect and store the information that you provide to us on our online registration forms. This may include, among other information, your:
first and last name
email address
home address
gender
birthday
phone number
If you register for a Service that requires you to pay a fee, Zelderly will also collect your payment method details, such as account number, expiration date, and security code, as well as your billing address, for payment purposes and your birthday, if not previously provided.
1.1.3 When posting a Care Seeker Profile
If you are a Care Seeker, we collect and store all of the additional information that you provide to us on your Zelderly Profile or that is otherwise included in an auto-generated care request. This may include, among other information:
the type of care you are looking for, your requested hours, location, pets (if applicable), narrative job description, requirements for a Care Provider (such as ability to drive)
pictures you choose to provide
your phone numbers
your email address
health information, if you choose to provide it
any other information you choose to include in your patient or admin profile settings
1.1.4 When posting a Care Provider profile
If you are a Care Provider, we collect and store all of the additional information that you provide to us in your profile. This may include, among other information:
details on the care you offer, including for example the type of care you provide, your availability, your location, languages you speak, your ability to drive
related services you provide
pictures you choose to post
your phone numbers
your email address
references, if you choose to provide them
any other information you choose to include in your profile
1.1.5 Otherwise through the Site or by telephone, email, postal mail or chat
Certain Registered Users may provide additional information on the Site through other Site features and offerings such as our payment platforms and mobile application. In some cases, Site Visitors may have the ability to provide us information through the Site, such as contact information. In addition, both Registered Users and Site Visitors may choose to provide information by phone, email, postal mail, or chat. We collect and store all of the information you provide us through these channels. Moreover, if you provide information about someone other than yourself through any of these channels, you represent that you have authority to do so.
1.2 Information provided by others
1.2.1 By Site Visitors, Registered Users and others
Zelderly also captures and collects information that Site Visitors, Registered Users and others provide about one another. For example, Care Providers may invite Site Visitors, Registered Users or others to rate and indicate their relationship to the Care Provider on the Site. Additionally, certain Registered Users may post reviews about individual Care Providers. In addition, certain Registered Users may communicate directly with one another through Zelderly platforms. Site Visitors, Registered Users and others also may provide us information about Registered Users by phone, email or postal mail. Zelderly captures and stores all information it receives from Site Visitors, Registered Users and others about other Registered Users and Site Visitors.
1.2.2 By third parties to verify your information and representations
In order to promote the safety and integrity of the Site and Service, you authorize Zelderly, as provided in the Terms of Use, to utilize third party service providers to check your information on an ongoing basis against a variety of sources, which may include, but are not limited to, national criminal databases, sex offender registries, certain media streams, terrorist watch lists, criminal and fugitive watch lists, fraud watch lists, law enforcement reports, and other data to assist us in verifying the information you provide us (such as your name, address, email address, etc.) and the representations and warranties you make in the Terms of Use and on the Site (such as representations regarding your criminal background) ("Preliminary Membership Screens"). The results of any Preliminary Membership Screens will be made available to Zelderly.
1.2.3 By other sources
In addition, we may obtain information about you from other sources (e.g., partners, researchers, marketers, etc.), such as demographic data, and other information to enable us to comply with regulatory requirements, ensure the accuracy of data, better understand your likely interests, prevent fraud, etc. We may combine information that we collect from you with information about you from such other sources and use it in accordance with this Privacy Policy.
1.3 Information you expressly authorize us to collect
We may from time to time request permission to collect certain information from or about you. For example, if you use a Zelderly mobile application, we may request permission to access information about the contacts listed in your mobile device phone book when you initiate an address book search for friends who have downloaded the application. We may also request permission to access and store your location (e.g., your precise GPS-based functionality on the mobile devices used to access the Site and Services). If you grant your permission, we will access and/or store such information unless you subsequently opt out by adjusting the settings in your mobile device. See your device manufacturer's instructions for further details.
1.4 Automatically collected information
We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Site and Services as described in this section below.
1.4.1 Log files, IP addresses and information about your computer and mobile device
When you visit the Site, Zelderly receives the internet protocol ("IP") address of your computer (or the proxy server you use to access the internet), your computer operating system, the type of web browser you are using, and browser language. If you are using a mobile device, Zelderly may also receive unique device identifiers and other information about your mobile or other device(s), and mobile operating system. We may correlate this information with other information we have about you. We may also automatically collect information related to the ways in which you interact with the Site and the Services, such as referring and exit pages, URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed (including ads viewed) and the order of such views, the amount of time spent on particular pages, the date and time you use the Services, error logs, and other similar information.
1.4.2 Cookies and other technologies
A cookie is a tiny data file that resides on your computer, mobile phone, or other device, and allows us to recognize you when you return to the Site using the same computer (or mobile device) and web browser. Like most websites, we and our service providers use cookies, and tracking pixels to track Site usage and trends, evaluate the effectiveness of our ads both on and off our Site, customize your experience on the Site and improve the quality of our Services. For example, using these technologies we can determine, among other things, which pages of our Site you visit and which ads you click on. Most browsers automatically accept cookies, but you can modify your browser settings to decline cookies. In some cases, however, doing so may impact your ability to use Zelderly. Tracking pixels do not identify individual users, and the analysis of data obtained by tracking pixels is performed on an aggregate basis.
1.4.3 Online analytics and advertising
When you visit our Site or open one of our emails, we may allow authorized third parties, such as ad servers, ad agencies, ad exchanges, ad technology vendors, and research firms, to place or recognize a unique cookie, pixel, and/or similar technologies on your browser in order to provide you relevant Zelderly advertisements as you surf the Internet. These advertisements may be targeted to you based on information these authorized third parties know or infer about you and include in the cookies placed on your browser, and/or on information about your Internet browsing activities gathered through your browser. In order for the opt-out to work, your browser must be set to accept third party cookies. Furthermore, if you buy a new computer or mobile device, change web browsers or delete the opt-out cookie, you will need to perform the opt-out task again. Please note that if you opt-out you may continue to receive Zelderly advertisements as you surf the Internet, including contextual ads based on the content on a webpage you are visiting. However, these advertisements will not be displayed based on information contained in, or collected by, cookies or other technologies placed on your browser when you visit our Site or open our emails.
We also use Google Analytics to measure Site usage and improve our visitor experience. The relevant data is provided to us by Google in the aggregate (i.e., individual users are not identified) and allows us to better understand our Site audience. The Google Analytics features implemented by us allow us (i) to evaluate and generate reports on certain demographic, behavioral, and interest metrics of users collected by Google, and (ii) to create advertising remarketing audiences and campaigns based on such metrics, which may be segmented into aggregated groups.
Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings form at https://www.google.com/settings/ads.
Do Not Track Notice. Some browsers used to access the Internet may give you the option through "Do Not Track" settings associated with such browsers to request that a website operator not track your information across its website or other websites. We engage in such tracking in order to optimize and/or customize our Services, detect and respond to allegations of fraud, and to otherwise ensure the safety of our Registered Users and Site Visitors. While we do not currently honor such browser requests, we will not use your information in a manner that violates this Privacy Policy. In addition, you retain the ability to opt out of certain online analytics and advertising activities as discussed in this section above.
1.4.4 Social media features and widgets
Our Site includes social media features and widgets, such as the Facebook "Like" button and the Facebook "Share" button. These features may collect your IP address, the URL of the page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
2. Purposes For Which We Use Information
In general, the information we collect is used for our business purposes: (1) to improve our Services and enhance your experience with Zelderly, (2) to enable us to provide a safer community for all of our Registered Users, and (3) to help us communicate with you. For example, we may use your information to:
register and service your account;
include in Care Seeker profiles, and Care Provider profiles;
contact you in response to questions and solicit feedback and input from you;
notify you about new features of the Services, special events, or products, services, and special offers, or other information that we believe will be of interest to you via email, SMS messages, or other media or networks;
administer referral bonuses and payments;
enable Care Seekers with each other and with Care Providers to search based on the information the other has made available on the Site, and information others have provided about them;
connect Care Seekers with Care Providers that appear to meet their needs and preferences;
enable Registered Users to search for, find, interact, connect and share information with other Registered Users they may have an interest in interacting with;
enable Registered Users who connect to Zelderly through Facebook to see which of their Facebook friends who have connected to Zelderly through Facebook are Registered Users or friends with other Registered Users who have connected to Zelderly through Facebook;
verify information you provide us as well as the representations and warranties you make to us in the Terms of Use or on the Site;
perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of the Services;
generate and review reports and data about our user base and usage patterns, including to improve the content and features of the Services or develop new Services;
otherwise help protect the safety and integrity of the Site and Zelderly users; and
personalize promotional messages or content on the Site, via email or other ads on Zelderly or third party sites.
We may aggregate and/or de-identify information collected by the Site, the Services, or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.
3. How We Share and Categories of Third Parties With Whom We Share Information
In addition to using the information collected by Zelderly for the purposes described above, we may also share your information with various third parties, as described below. Please review our sharing policy closely. By using our Site or our Services, you agree to allow us to share the information you provide to us in the ways described below. Your ability to make changes to what information is shared is described below in Section IV.
3.1 With All Site Visitors and Registered Users
If you are a Care Seeker or a Care Provider, in order to increase your chances of finding a job or finding the care you need, we share with Site Visitors and Registered Users the information that is included in your profile. With certain exceptions, you choose how much detail you want to include in your profile. We may also share on your profile any company reviews you have posted on our Site, whether you have connected to Zelderly through Facebook, and any connections you have with other Zelderly members, including the nature of those connections. If you are a Care Provider and have elected to verify certain information with Zelderly or to have a background check performed, we may also disclose that information in your profile as a Registered User in addition to your response rate and any payment or payroll preferences you have indicated.
If you post information in a Zelderly online group forum, that information may be viewed by any Site Visitor or Registered User who accesses the forum.
We may display personal testimonials of Registered Users and other endorsements on our Site or in other marketing materials. These testimonials or endorsements may include information such as the Registered User's first and last name.
3.2 With other Registered Users
In addition to the information that is provided to all Registered Users and Site Visitors, Care Provider reviews and references are made available to certain Registered Users. If you are a Care Provider, your phone number may be visible to certain Registered Users if you elect to share it in your profile. In addition, your approximate residential location (through Google map plotting) is made available to certain Registered Users and Site Visitors unless you elect to keep that information confidential.
If you are a Care Provider, you will appear in search result listings if you match the search criteria used by a Care Seeker, as applicable.
If we terminate your registration for any reason, we reserve the right to send a notice of your termination to other Registered Users with whom we believe you have corresponded.
3.2.1 With vendors/service providers
We also share information with vendors with whom we have a contractual relationship and who perform services for Zelderly including, without limitation, vendors who provide email, demographic information, or geo-location information services, vendors who perform background checks or Preliminary Membership Screens, vendors who process or accept credit card payments, vendors who run classified advertising businesses, vendors who send SMS messages to Registered Users' mobile phone numbers, vendors who provide services that enable us and other third parties to detect and prevent fraud, in each case to the extent applicable. In certain cases (such as for vendors who help facilitate our online communication services or provide fraud detection and prevention services), the information we share may include the contents of written and audio messages you send through our online communication platforms.
3.2.2 With listings in and through Google and other public search engines, social media sites (e.g. Facebook, Google+), and on other third party websites)
In an effort to further facilitate the ability of Care Seekers or Care Providers to find a caregiver or job, selected information contained in Care Seeker job postings and Care Provider profiles, which may include photo, first name, first name, last name, city, state, may also be shared with third party search engines, social media sites, and other third party websites or vendors who run classified advertising and other businesses, and thus may be listed in third party web site search results and on third party websites, which would make that information available to the public and allow them to link to your Zelderly posting. If you post information in a Zelderly online group forum, your content, including your name as the contributor, may be displayed in third party search engine results and available to the public.
3.2.3 As required by law or for reasons of safety
We may disclose your information when we believe in good faith that such disclosure is appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the health or physical safety of any person, violations of this Privacy Policy, the Terms of Use, and/or to protect the rights and property of Zelderly, our employees, users, and the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.
3.2.4 With our affiliates
You acknowledge and agree that we may disclose any of the information we've collected about you to any of our affiliates or subsidiaries for the purposes of providing you with the Services, operating the Site, soliciting you for potential employment opportunities with those affiliates or subsidiaries, and our other commercial purposes, including those of our affiliates and subsidiaries.
3.2.5 With Your Consent
We also may share your information with a third party if you consent to the sharing.
3.2.6 Business transactions
In the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of ours or that acquirer's affiliates may continue to process your information as set forth in this Privacy Policy.
4. Your Choices Regarding the Sharing of your Personal Information
Registered Users have control over what optional information they choose to share with us when utilizing our Services (such as pictures, certain details in a job description or profile, etc.).
In addition, Registered Users have the following opt out choices with respect to the sharing of their information, which they can manage via their account settings:
Care Providers can opt out of having their approximate residential location (through Google map plotting) visible to Registered Users.
Users of a Zelderly mobile application, who have given Zelderly permission to access certain information from their mobile device such as their location or contacts, may subsequently opt out of that information sharing by adjusting the settings in their mobile device.
Your opt out preferences will take effect within 10 days of receipt of your request.
5. Your Communication Choices
By becoming a Registered User, you are consenting to receive certain email communications from us, such as special offers, tips and advice, notifications of new Care Seekers or Care Providers in your area, customer surveys and administrative notices.
If you are a Care Seeker, certain Care Providers may initiate contact with you directly using the messaging features of the Zelderly Site. You have an option at any time to stop permitting Care Providers from initiating contact with you by adjusting your settings in your account settings.
6. Changing or Removing your Personal Information and Closing your Account
You can update certain of your information by logging into your account and accessing your account settings. If you would like to remove some of the information you have posted on the Site, such as information you posted in profiles, you may do so by editing or deleting that item in your account settings.
If you no longer wish to participate in our Services, you may close and delete your account directly through your account settings.
If you close your Zelderly account, we will remove your name and other contact and identifiable information from our publicly viewable database. If you close your account, we have no obligation to retain your information, and may delete any or all of your account information without liability. However, we may retain information related to you if we believe it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, de-identified information, account recovery, auditing our records, enforcing our rights and obligations under our agreements, or if required by law. Zelderly may also retain and use your information if necessary to provide the Services to other Registered Users.
7. Collection of Information from Children
Zelderly's Site and Services are not intended for individuals under the age of 18. Moreover, if we become aware that we have collected personal information (as defined by the Children's Online Privacy Protection Act) from children under the age of 18, we will take reasonable steps to delete it as soon as practicable.
8. How We Protect Information
We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction, or alteration of your information. These safeguards vary based on the sensitivity of information that we collect, process, and store and the current state of technology.
Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.
9. Links to Other Websites
The Site and Services may contain links to third-party websites and services. However, we are not responsible for the privacy practices employed by those web sites or services, nor are we responsible for the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and Services; thus when you use a link to go from the Site or Services to a third-party web site or service, this policy is no longer in effect and the privacy policy of such third-party site or service will govern.
10. Changes to Our Privacy Policy
Zelderly reserves the right to change this Privacy Policy and our Terms of Use at any time. We will notify you about and provide you with choice about material changes to this Privacy Policy or in our practices as required by applicable law. Material changes will go into effect 30 days after we notify. Non-material changes or clarifications will take effect immediately upon posting of the updated policy on our Site. You should periodically check www.Zelderly.com/privacy for updates. Your use of the Site or the Services after such effective date will constitute acceptance by you of such changes.
11. Collection of location data while using the Zelderly application
Zelderly collects location data to enable logging of caregiver movements while checked in for confirmed shifts using the Zelderly application. The GPS tracking feature is only enabled when the Caregiver is checked in and then disabled once the Caregiver checks out for each individual shift. This data is used to provide validation that a Caregiver is providing services where and when they are confirmed to do so. This data is also captured in the History section of the application in the form of receipt once a Caregiver shift is complete and processed for payment.
12. Contact Us
If you have any questions on our Privacy Policy, you can contact us via privacy@zelderly.com or at:
INTERPOSE LLC
Attn: Legal Department
admin@zelderly.com
admin@zelderly.com
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