Privacy Policy

1. Who this Policy applies to

This Policy applies to (a) healthcare professionals who register to find and accept work (“Workers”), (b) authorized users at facilities and organizations that use the Service (“Facility users”), and (c) visitors to our website and applications.

2. Personal information we collect

Depending on how you use the Service, we may collect:

Information you provide

• identity and contact details (name, username, email, phone number, mailing/billing address);
• date of birth, gender (where you choose to provide it), and job title or role;
• professional information (licences, certifications, credentials, education, work history, work-eligibility status, and work-permit details where applicable);
• Social Insurance Number (SIN) and banking/payment details, where required for payment and tax reporting;
• documents you upload (for example, identification, resume, and credential documents).

Information collected automatically

• device and usage information (device type, app/usage activity, log data, and IP address);
• approximate or precise location (GPS), where you grant permission, to show relevant nearby shifts;
• cookies and similar technologies (see the Cookies section).

Information from third parties

• regulatory or registry information used to verify professional credentials;
• fraud-prevention and identity-verification information from service providers;
• information you choose to make available to us (for example, from a social login).

Optional device permissions (camera, photo/file access, push notifications, location) are used only for the related feature and can be declined or changed in your device settings.

3. Why we collect and use personal information

We use personal information for the following purposes:

• to create and manage your account and operate the Platform;
• to match Workers with shifts, manage scheduling, attendance, and communications;
• to process payments and prepare tax documentation (such as T4A);
• to verify credentials and support credential and compliance requirements;
• to provide customer support and send service-related and, where permitted, optional communications;
• to maintain safety and security and to detect and prevent fraud and misuse;
• to 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, job postings, applications, 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. We use operational data for this purpose; we do not need, and do not rely on, the content of identity or credential documents for predictive modelling.

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, banking 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 you are subject to human review.

4. Consent

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

5. How we disclose personal information

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

• Facilities: we share the Worker information reasonably necessary for a Facility to evaluate, schedule, and engage a Worker (for example, name, relevant credentials, and shift details).
• Service providers: we share information with trusted providers that host our systems, process payments, support credential and identity verification, and help us operate the Service, under contracts that require them to protect the information and use it only for those purposes.
• Legal and safety: we may disclose information where required by law, regulation, court order, or to protect the rights, safety, or property of users, the public, or Carelynk.
• Business transfers: if Carelynk is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this Policy.

6. 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 in accordance with that jurisdiction’s laws. We can provide information about such transfers on request.

7. How long we keep information

We retain personal information only as long as needed for the purposes described in this Policy and to meet our legal, regulatory, and tax obligations. Account and profile information is generally retained while your account is active. Financial and tax records are retained for the period required by applicable law (generally several years). When information is no longer needed, we securely delete it or anonymize it so that it can no longer identify you.

8. How we protect information

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

9. Your privacy rights

Subject to applicable law, you have the right to:

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

To exercise these rights, contact our Privacy Officer at privacy@carelynk.ca. We may need to verify your identity before responding. If you are a Worker or Facility user, some requests may also be handled through your account settings. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.

10. Cookies and tracking technologies

We use cookies and similar technologies to keep you signed in, remember preferences, and understand how the Service is used so we can improve it. Most browsers let you block or delete cookies; if you do, some features may not work properly. We do not place information that directly identifies you in cookies.

Mapping services

We use the Google Maps API to provide location-based features such as showing nearby shifts. Google may collect information in accordance with its own privacy policy.

11. Children’s privacy

The Service is intended for adults and is not directed to children. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, please contact us and we will take appropriate steps to remove it.

12. Changes to this Policy

We may update this Policy to reflect changes to the Service or to legal requirements. Unless otherwise required by law, we will provide notice (for example, through the Service) 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.

13. 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 regarding the handling of your personal information.