Privacy Policy

1. Who this Policy applies to

This Policy explains how Carelynk handles personal information collected through Carelynk Go, the facility-facing mobile application of the Carelynk platform. It applies to Authorized Users at facilities and organizations that use Carelynk Go (“Facility users”).

Carelynk is based in Canada and handles personal information in accordance with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws. Carelynk is not a clinical system and does not collect or process patient clinical records.

2. Personal information we collect

Information you provide

• identity and contact details of Authorized Users (name, work email, phone number);
• job title or role and the organization you represent;
• account credentials and preferences;
• billing and organizational contact information used for invoicing and account administration.

Information collected automatically

• device and usage information (device type, app or browser activity, log data, and IP address);
• approximate or precise location (GPS), where you grant permission, to support location-based features;
• information tied to device permissions you grant (see below).

3. Worker information accessed through the Service

Through the Service, Facility users access personal information about Workers (such as names, contact details, credentials, and shift history) in order to evaluate, schedule, and engage them. Carelynk makes this information available for that purpose. Facility users must handle Worker personal information in accordance with the Terms of Service and applicable privacy law. Carelynk’s own handling of Worker personal information is described in the Carelynk Privacy Policy for Workers.

4. How we collect personal information

We collect personal information directly from you and your organization, automatically through your use of the Service, and, where relevant, from service providers that support account setup, billing, and security.

5. Why we collect and use personal information

We use personal information to:

• create and administer your organization’s account and Authorized Users;
• operate the Platform, including posting shifts, scheduling, and communications;
• process billing, invoicing, and payments and meet tax obligations;
• provide support and send service-related and, where permitted, optional communications;
• maintain safety and security and detect and prevent fraud and misuse;
• meet legal, regulatory, and tax obligations.

Service improvement, analytics, and predictive features

We analyze operational data generated through use of the Platform — such as shifts, postings, scheduling, attendance and fill outcomes, response times, and ratings — to operate, evaluate, and improve the Service and to develop new features, including analytics dashboards and predictive staffing tools. This analysis is carried out on Carelynk’s own data within our Canadian environment.

Research use of non-identifiable data. Where this operational data is used for research purposes, it is first rendered non-identifiable before being made available to the research team. Where your non-identifiable data are used for research purposes, the limitation of liability and indemnity clauses contained within the Carelynk Terms of Service are waived with respect to any harms suffered or liabilities incurred as a result of any research activities, as set out in Section 12 of the Terms of Service. This waiver remains in effect until any such dataset is destroyed.

Use of artificial intelligence

Where we use artificial intelligence or automated tools to assist Service features, we do so under appropriate controls. We do not send identity documents, credential files, financial details, or other sensitive personal information to third-party generative-AI or large-language-model providers. Where such tools are used, we require providers to offer appropriate protections, including no use of our data to train their models and no retention beyond what is necessary to deliver the service. Significant decisions affecting individuals are subject to human review.

6. Consent

We collect, use, and disclose personal information with consent, which may be express or implied depending on the context and sensitivity. By using the Service you consent to the practices described in this Policy. Consent may be withdrawn subject to legal and contractual limits and reasonable notice; withdrawing consent may limit our ability to provide parts of the Service.

7. How we disclose personal information

We disclose personal information only as needed to operate the Service. We do not sell your personal information, and we do not share it with advertisers or advertising networks.

• Service providers: trusted providers that host our systems, process payments, and help us operate the Service, under contracts requiring them to protect the information and use it only for those purposes.
• Legal and safety: where required by law, regulation, court order, or to protect the rights, safety, or property of users, the public, or Carelynk.
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.

8. Where your information is processed

Carelynk primarily stores and processes personal information on servers located in Canada (Amazon Web Services, Canada (Central) Region). In limited cases, a service provider may process information outside Canada; where this occurs, the information remains subject to this Policy and to contractual safeguards requiring a comparable level of protection, and it may be accessible to courts or authorities in that jurisdiction. We can provide information about such transfers on request.

9. How long we keep information

We retain personal information only as long as needed for the purposes in this Policy and to meet legal, regulatory, and tax obligations. Account information is generally retained while the organization’s account is active; financial and tax records are retained for the period required by law. When no longer needed, information is securely deleted or anonymized.

10. How we protect information

We use administrative, technical, and physical safeguards, including encryption in transit, access controls, and secure handling of payment data through certified providers. No system is completely secure; while we work to protect information, we cannot guarantee absolute security and will respond to any incident in accordance with applicable law, including breach-notification requirements.

11. Your privacy rights

Subject to applicable law, you may:

• access the personal information we hold about you and request a copy;
• request correction of inaccurate or incomplete information;
• withdraw consent or change communication preferences;
• request deletion, subject to legal and contractual retention requirements.

To exercise these rights, contact our Privacy Officer at privacy@carelynk.ca. We may verify your identity before responding. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.

12. Device permissions

With your consent, the App may request the following device permissions, each used only for its related feature and declinable in your device settings:

• Push notifications — to send real-time updates about shifts, schedules, and account activity;
• Camera — to capture and upload documents or images within the App;
• Photos / files — to upload documents or images required for shifts and account administration;
• Location — to support location-based features such as nearby shift management.

13. Children’s privacy

The Service is intended for organizational and professional use by adults and is not directed to children. We do not knowingly collect personal information from minors.

14. Changes to this Policy

We may update this Policy to reflect changes to the Service or legal requirements. Unless otherwise required by law, we will provide notice before material changes take effect and update the effective date above. Continued use of the Service after a change takes effect means you accept the updated Policy.

15. Contact us

For questions about this Policy or our handling of personal information, contact our Privacy Officer:

• Email: privacy@carelynk.ca (general enquiries: info@carelynk.ca)
• Mail: Carelynk Inc., 208 Charles Road, Timberlea, Nova Scotia, B3T 1N4, Canada

You may also contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.