Privacy Policy

HEALTHPRO INNOVATION WORKFORCE SOLUTIONS, LLC

PRIVACY POLICY

Effective Date: January 1, 2026

Last Updated: December 27, 2025

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INTRODUCTION

HealthPro Innovation Workforce Solutions, LLC ("HealthPro Innovation," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (www.healthproinnovation.com), apply for employment opportunities, participate in our referral program, or otherwise interact with our services.

Please read this Privacy Policy carefully. By accessing or using our website or services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access our website or use our services.

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TABLE OF CONTENTS

1. Information We Collect

2. How We Use Your Information

3. How We Share Your Information

4. Cookies and Tracking Technologies

5. Data Retention

6. Data Security

7. Your Privacy Rights

8. Children's Privacy

9. Third-Party Websites

10. Healthcare Information and HIPAA Compliance

11. State-Specific Privacy Rights

12. International Data Transfers

13. Changes to This Privacy Policy

14. Contact Information

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1. INFORMATION WE COLLECT

We collect information that you provide directly to us, information we obtain automatically when you use our services, and information from third-party sources.

1.1 Information You Provide to Us

**Job Applicants and Employees:**

When you apply for a position or work with HealthPro Innovation, we may collect:

• **Personal Identification Information:**

- Full legal name

- Date of birth

- Social Security number

- Government-issued identification numbers

- Contact information (address, phone number, email)

- Emergency contact information

• **Professional Information:**

- Resume/CV and work history

- Educational background and transcripts

- Professional licenses and certifications

- References and recommendations

- Skills and qualifications

- Salary history and expectations (where permitted by law)

• **Background and Screening Information:**

- Criminal history records

- Employment verification

- Education verification

- Credit history (where job-related and permitted by law)

- Motor vehicle records (for positions requiring driving)

- Drug and alcohol screening results

- Health screening and immunization records

• **Financial Information:**

- Bank account information for direct deposit

- Tax withholding information (W-4, W-9)

- Payment and compensation records

• **Sensitive Personal Information:**

- Information about disabilities (for accommodation purposes)

- Race, ethnicity, gender (for EEO reporting, voluntary)

- Veteran status (for compliance and preference programs)

- Medical information (for benefits and accommodation)

**Referral Program Participants:**

• Name and contact information

• Relationship to referred candidate

• Tax information (SSN or EIN for bonus payments)

• Payment method details

**Website Visitors:**

• Name and email address (if you contact us)

• Any information you choose to provide in forms or communications

1.2 Information We Collect Automatically

When you access our website, we automatically collect:

• **Device and Usage Information:**

- IP address

- Browser type and version

- Operating system

- Device identifiers

- Pages visited and time spent

- Referring website addresses

- Click data and navigation patterns

• **Location Information:**

- General geographic location based on IP address

• **Cookies and Similar Technologies:**

- Session cookies

- Persistent cookies

- Web beacons

- Analytics data

1.3 Information from Third Parties

We may receive information from:

• **Background Check Providers:**

- Criminal records

- Employment verification

- Education verification

- Professional license verification

• **Professional Licensing Boards:**

- License status and history

- Disciplinary actions

- Continuing education compliance

• **References and Former Employers:**

- Performance information

- Employment dates and titles

- Reason for separation

• **Healthcare Facilities (Client Sites):**

- Performance evaluations

- Attendance records

- Incident reports

- Skills assessments

• **Government Databases:**

- OIG Exclusion Lists

- GSA Debarment Lists

- Sex offender registries

- Professional sanctions databases

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2. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

2.1 Recruitment and Employment

• Processing job applications and evaluating qualifications

• Conducting background checks and verifications

• Making hiring decisions

• Credentialing and privileging for healthcare placements

• Matching candidates with appropriate job opportunities

• Communicating about employment opportunities

• Facilitating interviews and assessments

• Onboarding new employees and contractors

2.2 Payroll and Benefits Administration

• Processing payroll and issuing payments

• Administering employee benefits

• Tax reporting and compliance (W-2, 1099 forms)

• Maintaining employment records

• Processing time and attendance

2.3 Referral Program Administration

• Processing referral submissions

• Verifying referral eligibility

• Calculating and paying referral bonuses

• Tax reporting for referral payments

• Communicating program updates

2.4 Compliance and Legal Obligations

• Complying with federal, state, and local employment laws

• Meeting healthcare industry regulatory requirements

• Responding to legal process (subpoenas, court orders)

• Conducting internal investigations

• Maintaining EEO-1 and other compliance reports

• Verifying work authorization (I-9 compliance)

• Meeting client contractual requirements

2.5 Business Operations

• Providing customer service and support

• Improving our services and website

• Conducting business analytics and research

• Protecting against fraud and security threats

• Enforcing our terms and policies

• Managing relationships with healthcare facilities

2.6 Marketing and Communications

• Sending newsletters and job alerts (with consent)

• Promoting our referral program

• Sharing company updates and announcements

• Conducting surveys and feedback requests

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3. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We may share your information in the following circumstances:

3.1 Healthcare Facilities and Client Sites

We share applicant and employee information with healthcare facilities where you may be placed, including:

• Professional qualifications and credentials

• Background check results

• Immunization and health screening records

• Performance evaluations and work history

• Skills assessments and competency verifications

3.2 Service Providers and Business Partners

We share information with third-party service providers who perform services on our behalf:

• **Background Screening Companies:**

- Criminal history checks

- Employment and education verification

- Professional license verification

- Drug testing services

• **Technology Providers:**

- Applicant tracking system vendors

- Payroll and HRIS systems

- Website hosting and maintenance

- Email service providers

- Cloud storage providers

• **Professional Services:**

- Legal counsel

- Accounting and tax professionals

- Insurance providers

- Credentialing organizations

3.3 Regulatory and Government Agencies

We may disclose information to government agencies as required by law:

• Department of Labor (DOL)

• Equal Employment Opportunity Commission (EEOC)

• Immigration and Customs Enforcement (ICE)

• State licensing boards

• Centers for Medicare & Medicaid Services (CMS)

• State departments of public health

• Tax authorities (IRS, state revenue departments)

3.4 Legal Compliance and Protection

We may disclose information when we believe it is necessary to:

• Comply with legal obligations or legal process

• Protect the rights, property, or safety of HealthPro Innovation, our employees, or others

• Enforce our agreements and policies

• Respond to lawful requests from public authorities

• Detect, prevent, or address fraud or security issues

3.5 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred to the successor entity.

3.6 With Your Consent

We may share information for other purposes with your explicit consent.

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4. COOKIES AND TRACKING TECHNOLOGIES

4.1 What Are Cookies

Cookies are small text files placed on your device when you visit our website. We use cookies and similar technologies to enhance your experience and understand how our website is used.

4.2 Types of Cookies We Use

**Essential Cookies:**

• Required for website functionality

• Enable navigation and access to secure areas

• Cannot be disabled without affecting website performance

**Analytics Cookies:**

• Help us understand how visitors use our website

• Collect information about pages visited and time spent

• Used to improve website performance

• Examples: Google Analytics

**Functional Cookies:**

• Remember your preferences and settings

• Provide enhanced features and personalization

• Store language preferences and location

**Marketing Cookies:**

• Track your activity across websites

• Used to deliver relevant advertisements

• Measure advertising campaign effectiveness

4.3 Managing Cookies

You can control cookie settings through your browser:

• Most browsers allow you to refuse or delete cookies

• You can set your browser to notify you when cookies are being used

• Blocking cookies may affect website functionality

To opt out of Google Analytics: https://tools.google.com/dlpage/gaoptout

4.4 Do Not Track Signals

Our website does not currently respond to "Do Not Track" browser signals. We will update this policy if our practices change.

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5. DATA RETENTION

5.1 How Long We Keep Your Information

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

**Job Applicants (Not Hired):**

• Application materials: 1-2 years from application date

• Allows us to consider you for future opportunities

• You may request earlier deletion

**Employees and Contractors:**

• Employment records: 7 years after termination (or longer as required by law)

• Payroll records: 7 years (IRS requirement)

• Medical records: 30 years (OSHA requirement)

• I-9 forms: 3 years after hire or 1 year after termination, whichever is later

• Benefits records: Duration required by specific benefit plan

**Referral Program:**

• Referral submissions: 2 years from referral date

• Payment records: 7 years (tax requirements)

**Website Data:**

• Analytics data: 26 months

• Cookie data: Varies by cookie type (see Section 4)

5.2 Factors Affecting Retention

We consider the following when determining retention periods:

• Legal and regulatory requirements

• Potential litigation or investigation needs

• Business operational needs

• Contractual obligations

• Industry best practices

5.3 Secure Disposal

When we no longer need your information, we securely destroy or anonymize it according to our data retention and disposal policies.

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6. DATA SECURITY

6.1 Security Measures

We implement reasonable administrative, technical, and physical safeguards to protect your personal information, including:

**Technical Safeguards:**

• Encryption of data in transit (SSL/TLS)

• Encryption of sensitive data at rest

• Secure servers and databases

• Firewall protection

• Regular security assessments

• Anti-malware and intrusion detection systems

**Administrative Safeguards:**

• Access controls and authentication

• Employee training on data protection

• Confidentiality agreements

• Background checks for employees with data access

• Incident response procedures

• Regular policy reviews and updates

**Physical Safeguards:**

• Secure office facilities

• Restricted access to data storage areas

• Secure disposal of physical records

• Video surveillance (where appropriate)

6.2 Limitations

While we use reasonable efforts to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security. You acknowledge and accept these inherent risks when providing information to us.

6.3 Data Breach Notification

In the event of a data breach affecting your personal information, we will:

• Investigate the incident promptly

• Notify affected individuals as required by law

• Notify relevant regulatory authorities

• Take steps to mitigate harm and prevent recurrence

• Cooperate with law enforcement if applicable

6.4 Your Role in Security

You can help protect your information by:

• Using strong, unique passwords

• Not sharing login credentials

• Logging out after using shared computers

• Keeping contact information current

• Reporting suspicious activity immediately

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7. YOUR PRIVACY RIGHTS

7.1 General Rights

Depending on your location, you may have the following rights:

**Right to Access:**

• Request access to your personal information

• Obtain a copy of the data we hold about you

• Understand how your information is used

**Right to Correction:**

• Request correction of inaccurate information

• Update outdated information

• Complete incomplete records

**Right to Deletion:**

• Request deletion of your personal information

• Subject to legal retention requirements

• May affect your eligibility for employment

**Right to Restrict Processing:**

• Request that we limit how we use your information

• Object to certain types of processing

**Right to Data Portability:**

• Request your data in a structured, machine-readable format

• Transfer data to another service provider

**Right to Opt-Out:**

• Unsubscribe from marketing communications

• Opt out of certain data sharing (where applicable)

• Manage cookie preferences

**Right to Non-Discrimination:**

• We will not discriminate against you for exercising your privacy rights

7.2 How to Exercise Your Rights

To exercise your privacy rights, contact us at:

Email: privacy@healthproinnovation.com

Phone: 630-613-7454

Mail: HealthPro Innovation Workforce Solutions, LLC

Attn: Privacy Officer

18W140 Butterfield Road, 15th Floor

Oakbrook Terrace, IL 60181

**Verification Process:**

To protect your privacy, we will verify your identity before responding to requests. We may ask for:

• Government-issued identification

• Matching information in our records

• Additional verification for sensitive requests

**Response Timeline:**

• We will respond to requests within 45 days (or as required by applicable law)

• We may extend this period by an additional 45 days if necessary

• We will notify you of any extension and the reason

7.3 Limitations on Rights

Certain rights may be limited when:

• Required by law to retain information

• Necessary for legal claims or defense

• Needed for employment law compliance

• Protected by attorney-client privilege

• Necessary for legitimate business interests

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8. CHILDREN'S PRIVACY

Our website and services are not directed to children under the age of 18. We do not knowingly collect personal information from children under 18.

If you are under 18, do not:

• Use or provide any information on this website

• Submit any employment application

• Participate in our referral program

• Make any purchases or provide payment information

If we learn we have collected personal information from a child under 18, we will delete that information immediately. If you believe we might have information from or about a child under 18, please contact us at privacy@healthproinnovation.com.

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9. THIRD-PARTY WEBSITES

Our website may contain links to third-party websites, including:

• Client healthcare facility websites

• Professional licensing board websites

• Background check provider portals

• Social media platforms

• Job boards and career sites

**Important:**

• We are not responsible for the privacy practices of third-party websites

• This Privacy Policy does not apply to third-party sites

• We encourage you to read the privacy policies of any third-party sites you visit

• Clicking on third-party links is at your own risk

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10. HEALTHCARE INFORMATION AND HIPAA COMPLIANCE

10.1 Protected Health Information (PHI)

HealthPro Innovation may have limited access to Protected Health Information (PHI) in certain circumstances, such as:

• Workers' compensation claims

• Return-to-work medical clearances

• Accommodation requests under the ADA

• Occupational health and safety matters

10.2 HIPAA Business Associates

When we act as a Business Associate under HIPAA:

• We enter into Business Associate Agreements (BAAs) with covered entities

• We implement HIPAA-compliant safeguards for PHI

• We limit use and disclosure of PHI as required by law

• We report breaches of PHI as required

10.3 Employment Health Information

Health information collected for employment purposes (immunizations, drug tests, health screenings) is generally not subject to HIPAA but is protected under:

• Americans with Disabilities Act (ADA)

• Genetic Information Nondiscrimination Act (GINA)

• State privacy laws

• Our internal confidentiality policies

We maintain employment health records separately from general personnel files with restricted access.

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11. STATE-SPECIFIC PRIVACY RIGHTS

Depending on your state of residence, you may have additional privacy rights:

11.1 California Residents (CCPA/CPRA)

**Your California Rights:**

• Right to know what personal information is collected

• Right to know whether personal information is sold or shared

• Right to opt out of sale/sharing of personal information

• Right to delete personal information (with exceptions)

• Right to correct inaccurate personal information

• Right to limit use of sensitive personal information

• Right to non-discrimination for exercising rights

**Notice:**

We do not "sell" personal information as defined by California law.

**Categories of Information:**

See Section 1 for detailed categories of information we collect.

**Shine the Light:**

California residents may request information about disclosure of personal information to third parties for direct marketing purposes.

**California Privacy Rights Request:**

Email: privacy@healthproinnovation.com

Submit Request: privacy@healthproinnovation.com

11.2 Illinois Residents (BIPA)

**Biometric Information Privacy Act:**

• We do not currently collect biometric information

• If we collect fingerprints or other biometric data in the future, we will:

- Obtain written consent

- Provide retention and destruction schedules

- Comply with BIPA storage and protection requirements

11.3 Virginia, Colorado, Connecticut, Utah Residents

If you reside in states with comprehensive privacy laws, you have rights including:

• Right to access personal information

• Right to correct inaccuracies

• Right to delete personal information

• Right to data portability

• Right to opt out of targeted advertising and sales

• Right to appeal our decision regarding your request

11.4 Other States

If your state has enacted privacy legislation, you may have additional rights. Contact us to learn more about rights specific to your state.

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12. INTERNATIONAL DATA TRANSFERS

12.1 United States-Based Operations

HealthPro Innovation is based in the United States. Your information will be processed and stored in the United States, which may have different data protection laws than your country of residence.

12.2 Data Transfers

If you are accessing our services from outside the United States:

• Your information will be transferred to and processed in the United States

• By using our services, you consent to this transfer

• We implement appropriate safeguards for international transfers

• We comply with applicable data transfer regulations

12.3 European Economic Area (EEA) and United Kingdom

If you are located in the EEA or UK, we rely on the following legal bases for data transfers:

• Standard Contractual Clauses approved by the European Commission

• Your explicit consent

• Necessity for contract performance

• Compliance with legal obligations

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13. CHANGES TO THIS PRIVACY POLICY

13.1 Right to Modify

We reserve the right to modify this Privacy Policy at any time to reflect:

• Changes in our practices

• Legal or regulatory requirements

• Technological developments

• Business changes

13.2 Notice of Changes

When we make material changes:

• We will update the "Last Updated" date at the top of this policy

• We may notify you via email (if we have your email address)

• We may post a notice on our website

• Continued use of our services constitutes acceptance of changes

13.3 Review Responsibility

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

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14. CONTACT INFORMATION

14.1 Privacy Questions and Requests

For questions about this Privacy Policy or to exercise your privacy rights:

**Privacy Officer:**

HealthPro Innovation Workforce Solutions, LLC

Attn: Privacy Officer

18W140 Butterfield Road, 15th Floor

Oakbrook Terrace, IL 60181

**Email:** privacy@healthproinnovation.com

14.2 General Inquiries

For general questions about our services:

**Email:** info@healthproinnovation.com

**Phone:** 630-613-7454

14.3 Complaints

If you believe your privacy rights have been violated, you may:

• File a complaint with us using the contact information above

• File a complaint with your state Attorney General

• File a complaint with the Federal Trade Commission (FTC)

• File a complaint with your data protection authority (if located outside the U.S.)

We will investigate all complaints and respond appropriately.

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ACKNOWLEDGMENT

By using our website or services, you acknowledge that you have read and understood this Privacy Policy and agree to our collection, use, and disclosure of your information as described herein.

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Document Version: 1.0

Effective Date: January 1, 2026

Last Updated: December 27, 2025

© 2025 HealthPro Innovation Workforce Solutions, LLC. All rights reserved.