A user of the Services is hereinafter referred to as a “User,” or collectively, the “Users.” Users can include individuals such as website visitors, professionals seeking shifts (“Professionals”) and representatives of facilities or agencies seeking talent (“Facilities”).
What Is Personal Information?
Clipboard’s Collection of Personal Information
Sometimes we collect Personal Information automatically when an individual interacts with our Services, and sometimes we collect the Personal Information directly from an individual. At times, we may collect Personal Information about an individual from other sources, even before our first direct interaction with that individual.
Personal Information Collected from You Directly
We may collect the following Personal Information from you directly:
- Contact Information, including your name, your employer’s name (if applicable), address, phone number, email address, and communications preferences.
- Inquiry Information, including information provided in custom messages sent through our Site. We also may collect your information when you sign up to receive information or notifications from us.
- Facility Information, including facility/company name, related entities’ names, names of facility representatives, those representatives’ positions, address, email address, phone number, profile information, billing and payment information, and any other information provided to us during your account sign-up process or through the Services.
- Survey and Testimonial Information, including information provided in any questions submitted through surveys, or content of any testimonials.
- Any Other Personal Information You Choose to Provide.
Clipboard may also collect and store certain data about your use of the Services on an aggregate and/or de-identified basis.
Personal Information Automatically Collected
As is true of many websites, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, such as the list below and in the sub-sections here:
- Device Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services). Device Data may overlap with the other categories of data below.
- Analytics Data, including the path taken to our Services, through our Services, and when exiting our Services, usage and activity on or in connection with our Services, metrics on how many emails we send are actually opened and which attachments or links are opened, clicked, or viewed (such as via pixels, as described further below).
- Location Data of Professionals, including precise and coarse geographic location information, which we and/or our third-party providers collect, once enabled by the permissions setting on your device, leading up to the start of shifts you book, when you arrive at and leave those shifts, and when you search for “Urgent Shifts” near you. During the two-hour period before a booked shift, Clipboard actively tracks your location every few minutes in order to predict whether you will be on time for that shift. We share our prediction, as well as a map showing your geographic location up to one hour before your shift, with the Facility with which you booked the shift, and will also notify the Facility if/when it appears that you are on your way to the Facility, are nearby the Facility, and have arrived at the Facility. We will provide you with an “Attendance Confirmation Required” notification if it appears you will not be on time. If you fail to confirm your attendance in response to that notification, we will enable booking of that shift on an Urgent Shift basis by another Professional and cancel your shift as soon as another Professional successfully books the Urgent Shift. Additionally, up to 24 hours before a booked shift, if you open the Clipboard App, we initiate passive tracking, which may provide us with location information as frequently as every two hours. Passive tracking helps us ensure that active tracking is able to start on time, i.e. two hours before your booked shift. We use location data gathered when you arrive at and leave your shifts to verify the completion of those shifts in order to distribute your earnings via InstantPay. We also use location data from your device in order to show you nearby Urgent Shifts when you search for them. You may change the Clipboard App’s access to your location information at any time through your “Settings” app on your device. However, if you do not enable “Always” and “Precise Location” permissions, many important features of the Clipboard App will be unavailable to you, including your ability to access the marketplace, book shifts, receive payments through InstantPay, and see nearby Urgent Shifts. For more information, please see the Control Over Your Information section below.
- Advertising/Advertising Measurement Data, including data associated with your view of, or click on, advertisements served on our Services, cookie IDs or other digital or proprietary identifier (e.g., iOS IDFA, Google AAID) assigned to such device, and device metadata, analytics data, and location data described above, in each case, for purposes of serving advertising (personalized or otherwise) or facilitating advertising measurement/attribution to better optimize or otherwise understand the effectiveness of ad campaigns. For more information on our and third-party partners’ data collection and online advertising practices, please see the Third-Party Data Collection and Online Advertising section below.
- Cookies and Other Technologies. Like many websites, we and our third-party providers may use “cookies” that our Services use to collect and store information about Users. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We and our third-party service providers may also use other tracking technologies, such as “pixel tags,” “web beacons,” “clear GIFs,” SDKs, location-identifying technologies, or similar means in connection with the Services and HTML-formatted email messages to, among other things, track the actions of Users and email recipients and to automatically collect the Personal Information described in this section (and otherwise expanded upon in other sections). See the Control Over Your Information section below to learn more about how you may limit or disable cookies or certain other tracking technologies on your device.
- UXCam. We use UXCam, which is an analytics solution. While you are using the Clibpoard App, UXCam may record: screens that you visit in the Clipboard App, interaction patterns in the Clipboard App (such as screen actions, gestures: taps, scrolls), and your device’s details (type, version, model, operating system). We use the information collected by UXCam to improve the Clipboard App and the Services. UXCam stores and processes this information on our behalf and may contain personally identifiable information although UXCam proactively removes it where possible. UXCam will not record or otherwise track your device usage outside of the Clipboard App.
- Near-Field Communication (“NFC”) Tag Interactions. When certain facilities request this service, we provide them with NFC tags, which those facilities may require you to tap with your device when starting and ending a shift or break. When you tap one of our NFC tags, we collect a unique identifier associated with that NFC tag, which allows us to infer the location of your device based on the known location of the NFC tag. Like geolocation data collected directly from your device, we use data from NFC tag interactions to verify your completion of shifts in order to distribute your earnings via InstantPay.
Note that we and our third-party partners may combine information that each of us collects automatically with other information about you, including information you choose to provide.
Personal Information Collected Through Other Sources
We also obtain Personal Information from third parties, which we often combine with Personal Information we collect either automatically or directly from you. For example, we may receive the same categories of Personal Information as described above from the following third parties:
- Your Employer / Company: When an individual interacts with our Services as an employee or representative of their company, we may receive their information from their employer or other employees at their company.
- Other Users: When you interact with other Users on the Services we may receive information you choose to share with them. For example, if you send a direct message to another User, we may receive the information in the message. We also may receive ratings and comments from other Users. For example, we receive Professional ratings from Facilities after shifts are completed.
- Clipboard Marketplace Sign-Up-Related Third Parties: When you sign up for a Professional account to access Clipboard’s marketplace or seek a shift through Clipboard’s marketplace, we may receive Personal Information from related third parties, such as websites and platforms containing information about Clipboard and opportunities to find shifts through our marketplace, references, background check providers, and recruiters.
- Licensing and Certifications: We may receive information from third parties in order to verify your licenses or certifications.
- Referrals: We may receive your information through our Refer a Coworker Program. For example, when a User refers you to Clipboard, we receive your contact information.
- Social Media: When you interact with our Services through various social media networks, such as when you log in through a social network, “Like” us on Facebook or follow us or share our content on Google, Facebook, Twitter, or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
- Service Providers: Our service providers that perform services solely on our behalf, such as payment processors or survey and certain advertising/marketing providers, collect Personal Information and may share some or all of this information with us.
- Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement Personal Information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual or obtain demographic information (e.g., preferences).
- Other Sources: We may also collect Personal Information about you that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.
Only authorized Clipboard staff have access to your Personal Information in its entirety. Other staff may have access to portions of this information if it pertains to their job duties.
Clipboard's Use of Personal Information
Clipboard uses Personal Information for the following general purposes:
- to fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to provide our products and the Services, and to process transactions,
- to manage our organization and its day-to-day operations,
- to determine whether you may sign up for an account to access Clipboard’s marketplace as a Professional or Facility,
- to request individuals to complete surveys about our organization, organizations we partner with, Facilities, and the Services,
- to facilitate promotions, contests and sweepstakes,
- to offer incentives to Users in the marketplace,
- to determine whether Professionals will arrive on time to booked shifts, and whether they are at the Facilities during shifts,
- to suggest and display nearby available shifts,
- for billing, payment, identification and authentication, and fraud prevention,
- to identify and analyze how individuals use our Site and Services and to conduct research and analytics on our User base and our Services,
- to improve and customize our products and the Services to address the needs and interests of our Userbase and other individuals we interact with,
- to communicate with you, including via email, text message, social media and/or telephone calls, and to deliver administrative notices and communications relevant to your use of our products and the Services,
- to market our Services to individuals, including through email, direct mail, phone or text message,
- to administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Site,
- to facilitate User benefits and services, including customer support through our command center services,
- for internal market research,
- to test, enhance, update and monitor the Services, or diagnose, fix or troubleshoot technology problems,
- to help maintain the safety, security and integrity of our property and Services, technology assets and business,
- to detect, investigate, provide notice of or protect against error, fraud or other unlawful or criminal activity,
- for distribution to third-party contractors that provide services to Clipboard and partners of Clipboard,
- to comply with legal obligations,
- to defend, protect or enforce our rights or applicable contracts and agreements, including our Terms of Service, and
Clipboard’s Disclosure of Personal Information
We disclose Personal Information in the following ways:
- Affiliates: We may share Personal Information with other companies owned or controlled by Clipboard, and other companies owned by or under common ownership as Clipboard, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
- Facilities with which You Book a Shift: We may share information about your geographic location with Facilities in the manner described under “Location Data of Professionals,” above. Additionally, your name, licensure and qualifications, contact information, and background check results will be provided to Facilities with which you have booked a shift as a matter of course. In limited circumstances, we may share other Personal Information of yours, including your social security number, with Facilities with which you have booked a shift. Sharing of social security numbers with Facilities will be limited to instances where the information is reasonably related to a reporting requirement or other legal obligation of the Facilities, including, but not limited to, required staffing reports, regulatory audits, and investigations and/or reports regarding allegations of Professional misconduct.
- Facilities in General: We may share the following Personal Information with facilities in general, even if you have not booked a shift with them: your name, your profile photo, any worker video clips you have chosen to provide us with, your total number of completed shifts, your attendance rate (which we calculate based on your numbers of booked and cancelled shifts), and the average rating you have received from Facilities.
- Your Employer / Company: When an individual interacts with our Services as an employee or representative of their company, we share their information with their employer or other employees at their company.
- Other Users: We may share your Personal Information with other Users. For example, if you are a Professional who signs up for a shift at a Facility, we may share your information with that Facility. Additionally, we may share the Personal Information and shift booking activity of Professionals with other Professionals, including via our Work with Friends feature. For more information about how to disable sharing with other Professionals, please see the Control Over Your Information section below.
- Marketing Providers: We coordinate and share Personal Information with our marketing providers in order to communicate with individuals about the Services we make available.
- Customer Service and Communication Providers: We share Personal Information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
- Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as payment processing, website hosting, infrastructure provisioning, IT services, analytics services, administrative services.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Information may also be disclosed in the event of insolvency, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose Personal Information to third parties, such as legal advisors and law enforcement:
- if required by law or if we are given reason to believe, in our sole discretion, that someone is causing injury to or interference with the rights of Users, the general public, or Clipboard,
- to comply with a judicial proceeding, court order, legal process, or required response to a regulator,
- in connection with the establishment, exercise, or defense of legal claims,
- to protect our rights and property and the rights and property of others, including to enforce our agreements and policies,
- to detect, suppress, or prevent fraud,
- to protect the health and safety of us and others, or
- as otherwise required by applicable law.
- Otherwise With Consent or Direction: We may disclose Personal Information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Site or service-related publications.
Except as otherwise required by applicable law, we will not disclose to non-partner third parties any Personal Information specifying your medical or health condition, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership without your consent.
Third-Party Data Collection and Online Advertising
General. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on Personal Information and to measure the effectiveness of those ads. We permit third-party online advertising networks or exchanges (or other entities, such as demand-side or sell-side platforms or ad servers), measurement/attribution companies, ad fraud companies, social media companies, and other third-party services to collect information about your use of our online services so that they may display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including clickstream information, browser type, time and date you visited the Sites, mobile ad ID or other digital identifier (e.g., iOS IDFA, Google AAID, cookie ID, click ID, other proprietary IDs such as open source “universal IDs” or other ID solutions) precise or coarse geolocation, and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, analytics, market research, and measurement/attribution. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. For example, we may do this by providing your email address (typically in hashed format) or other information (such as phone number, which also is typically provided in hashed format) to the platform provider, such as via API, direct file upload, server-to-server transfer, or integrating the tracking technologies of those platform providers (e.g., pixel). Please see the Control Over Your Information section below to learn how you can opt out of interest-based advertising.
Social Media Platforms and Advertising. Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter, or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media forums. For example, these companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. As mentioned in the section above, we may share a unique identifier, such as a user ID or hashed email address or phone number, with these platform providers or they may collect information from our website visitors through a pixel (or other mechanism, such as API, direct file upload, or server-to-server integration), in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
Control Over Your Information
You may control your information in the following ways:
Choice/Opt-Out of Communications
General. You may opt-out of receiving communications from us and our partners, remove your information from our database, and choose to not receive future communications unrelated to the Services.
During the account sign-up process you will be automatically subscribed to receive correspondence from either Clipboard or its partners, but will be provided with the option to opt out of receiving such correspondence. This information remains on your profile. You may contact Clipboard customer support (email@example.com or 408-837-0116) at any time to update your contact information and notification preferences. If you enroll with Clipboard, we may occasionally contact you with information about special events, activities, promotions, contests, submission opportunities and programs. You always have the option to ask Clipboard not to contact you with this information again.
Email Communications Preferences. If you no longer wish to receive marketing or promotional emails from us, you can click the “unsubscribe” link in the latest email you receive from us.
Telephone Calls and SMS Text Messaging. We may use Personal Information we collect to communicate with you via text message and telephone calls, including (with your consent) to market to you or offer you information and updates on products or services we think you may be interested in. You can unsubscribe from marketing calls or text messages at any time by replying STOP or clicking the unsubscribe link (where available) in one of our messages. For more information, please see our Terms of Service.
Edit Your Information
You have the ability to edit your Personal Information. To update your Personal Information, please do so in the Clipboard App. So that we can protect the integrity of sensitive data, there are certain pieces of information, such as your age, that you cannot alter yourself. Please contact us at firstname.lastname@example.org to find out how to change information you cannot access through your account, or if you have any other questions. Our databases automatically update any Personal Information you edit in your profile, or that you request we edit. Information transmitted through boards, chats, polls or through any other means remains in our databases and becomes the property of Clipboard upon submission.
Access to Your Device Information
You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your network devices and geolocation and to integrate with your other applications. Withdrawing access to certain device information will affect the features and functionality of the Services, and may inhibit our ability to provide you with the Services you have requested. For example, if you do not grant the Clipboard App “Always” and “Precise Location” permissions with respect to your device’s location data, many important features will be unavailable to you, including the ability to access the marketplace, book shifts, receive payments through InstantPay, and see nearby Urgent Shifts.
Deleting Your Account or Information
If you are a Professional and would like to delete your account and/or delete your record in our system, you may submit your request by signing into your account on the mobile app, navigating to “My Account,” clicking on “Profile,” and following the instructions to “Delete My Account” at the bottom of the page. We may ask you to verify your identity before we process your request. In certain circumstances, we may not be able to respond to your request if we are not able to verify your identity or authority to make the request.
When you close your account, your deactivated status will be reflected promptly in our user databases and you may no longer be able to access your information. Please note that in some instances we may retain certain information to the extent required or permitted by law.
Cookies and Tracking Technologies
If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services.
Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Sharing with Other Healthcare Professionals
If you are a Professional and do not want your Personal Information and shift booking activity shared with other Professionals, including via our Work with Friends feature, you may disable such sharing by opening the Clipboard App, then tapping “My Account” in the bottom right corner, then tapping “Profile,” then turning on “Hide me as a colleague on shifts.”
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising (to the extent the advertising partner or other entity participates in such industry opt-out pages), you may wish to visit the Digital Advertising Alliance’s (DAA) resources or the Network Advertising Initiative’s (NAI) online resources, at https://optout.aboutads.info or https://optout.networkadvertising.org. You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting https://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Children’s Personal Information
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any Personal Information either directly or by other means. If a child under the age of 13 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Information from our systems. If we learn that any Personal Information we collect has been provided by a child under the age of 13, we will promptly delete that Personal Information.
Links to Third-Party Websites or Services
We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:
- Nevada: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Please contact us at email@example.com to submit such a request.
- California: If you are a resident of the State of California in the U.S., please see our Privacy Notice for California Residents for additional California-specific privacy information.
Users From Outside the United States
Clipboard and its Services are based in the United States. Please be aware that your information may be processed and transferred to the U.S. and be subject to U.S. law. The privacy and data protection laws in the U.S. may not be equivalent to such laws in your country of residence. By using the Site, participating in any of the Services, or by providing Clipboard with your information, you understand your Personal Information may be transferred to, stored in, and processed in the U.S.
How to Reach the Clipboard Team
If you have technical problems, questions, or other issues related to Clipboard, or the Services, please click “Contact Us” at the bottom of any page of this website. You can also send us an e-mail at firstname.lastname@example.org.