Dwell at Home™ Privacy Policy

Last Revised: February 25, 2020

DwellAtHome.com offers various services to help its users find, coordinate, and maintain quality care. DwellAtHome.com’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.DwellAtHome.com and any web pages, mobile applications and mobile websites operated by DwellAtHome.com (collectively, the “Site”), including those who are seeking to find an individual or shared service provider through DwellAtHome.com (“Care Seekers”) as well as those who are looking to promote their services through DwellAtHome.com (“Care Givers”), and any users of any of the various services that DwellAtHome.com provides through the Site or any other channels, including over the telephone (collectively, “Services”).

For purposes of this Privacy Policy, the terms “DwellAtHome.com,” “we,” “us,” and “our” refer to DwellAtHome.com, Inc. “You” refers to you, as a visitor or user or the Site or the Services. This Privacy Policy does not apply to third party entities that may use the Site or Services. Such entities’ use of the Site and Services are subject to separate terms that they agreed to when they registered or otherwise contracted with DwellAtHome.com. Other capitalized terms that are not expressly defined in this Privacy Policy have the same meaning as set forth in the DwellAtHome.com 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.

I. Information We Collect and their Sources

1. Information you provide
2. Information provided by others
3. Information you expressly authorize us to collect
4. Automatically collected information

II. Purposes For Which We Use Information

III. How We Share and Categories of Third Parties With Whom We Share Information

IV. Your Choices Regarding the Sharing of your Information

V. Your Communication Choices

VI. Changing or Removing your Information and Closing your Account

VII. Collection of Information from Children

VIII. How We Protect Information

IX. Links to other Websites

X. Changes to our Privacy Policy

XI. Contact Us

I. Information We Collect and their Sources

How we collect and store information depends on the Services you use and the activities in which you participate. You can use some of the Site and Services without providing any information other than that automatically collected as described below.

Visitors who access and browse the Site without registering are “Site Visitors.” In order to utilize some of the Services offered by DwellAtHome.com, you must register with DwellAtHome.com. All users who register with DwellAtHome.com are “Registered Users.”

A. 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 job, 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. When registering

When you register directly through DwellAtHome.com, 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

DwellAtHome.com 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.

2. When posting a job

If you are a Care Seeker, we collect and store all of the additional information that you provide to us on your job posting or that is otherwise included in an auto-generated job posting. This may include, among other information:

• the type of care you are looking for, your schedule, location, hourly rate, number and ages of children, family members, or pets (if applicable), narrative job description, requirements for a Care Giver (such as ability to drive)
• pictures you choose to provide
• health information, if you choose to provide it
• any other information you choose to include in your job posting

 

3. When posting a profile

If you are a Care Giver, 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, your level of education, languages you speak, your ability to drive
• related services you provide
• pictures you choose to post
• your phone numbers
• references, if you choose to provide them
• any other information you choose to include in your profile
  

 

4. By telephone

Both Site Visitors and Registered Users may provide information to DwellAtHome.com when they contact Us or utilize certain Services DwellAtHome.com may offer by telephone. For example, if you call DwellAtHome.com to discuss care options over the phone, we will collect and store all of the information you chose to provide to us, including but not limited to financial information, information about the care you or your loved one needs, health information about you or the loved one you seek care for, your contact information, etc. If you provide information about someone other than yourself, you represent that you have authority to do so.

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 online communication platforms, groups and payment platforms and our senior care offerings. 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.

B. Information provided by others

1. By Site Visitors, Registered Users and others

DwellAtHome.com also captures and collects information that Site Visitors, Registered Users and others provide about one another. For example, Care Givers may invite Site Visitors, Registered Users or others to rate and indicate their relationship to the Care Giver on the Site. Additionally, certain Registered Users may post reviews about individual Care Givers. In addition, certain Registered Users may communicate directly with one another through DwellAtHome.com platforms. Site Visitors, Registered Users and others also may provide us information about Registered Users by phone, email or postal mail.

DwellAtHome.com captures and stores all information it receives from Site Visitors, Registered Users and others about other Registered Users and Site Visitors.

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 DwellAtHome.com, 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 DwellAtHome.com.

3. By third parties that perform background checks

As provided in the Terms of Use, we may provide some or all Registered Users with the ability to request from a third-party consumer reporting agency that a background check be run on themselves using information that they provide. Any such background checks will be subject to the terms we establish for such checks on the Site pages where they are requested or authorized, the terms of this Privacy Policy, and our Terms of Use. DwellAtHome.com may receive a copy of, or otherwise have access to, any such background check, unless otherwise specified in this Privacy Policy or the Terms of Use.

4. By service providers you use in connection with our Services

If you engage a service provider through DwellAtHome.com, such as a home care agency or a payments processor, that service provider may provide us with information about you or your loved ones, such as information relating to your transactions with the service provider.

5. 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.

C. 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 DwellAtHome.com 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.

D. 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. Log files, IP addresses and information about your computer and mobile device

When you visit the Site, DwellAtHome.com 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, DwellAtHome.com 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.

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 DwellAtHome.com. Tracking pixels do not identify individual users, and the analysis of data obtained by tracking pixels is performed on an aggregate basis.

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 DwellAtHome.com 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. If you prefer not to receive these online behavioral advertisements, you may

opt-out here or here. 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 DwellAtHome.com 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.

II. 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 DwellAtHome.com, (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:

1. register and service your account;
2. include in Care Seeker profiles, job postings and Care Giver profiles;
3. contact you in response to questions and solicit feedback and input from you;
4. 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;
5. enable Care Seekers with each other and with Care Givers to search based on the information the other has made available on the Site, and information others have provided about them;
6. connect Care Seekers with Care Givers that appear to meet their needs and preferences;
7. 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;
8. perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of the Services;
9. 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;
10. otherwise help protect the safety and integrity of the Site and DwellAtHome.com users; and
    
11. personalize promotional messages or content on the Site, via email or other ads on DwellAtHome.com 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.

III. How We Share and Categories of Third Parties With Whom We Share Information

In addition to using the information collected by DwellAtHome.com 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.

A. With All Site Visitors and Registered Users

If you are a Care Seeker or a Care Giver, 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 job posting or profile, aside from your contact information, as well as the following registration information, which we may include in your job posting or profile: your first name, first initial of your last name, city, state, profile picture, and if you are a Care Giver, your gender and, unless you opt-out, your age. With certain exceptions, you choose how much detail you want to include in either your job posting or your profile. We may also share on your profile or job posting any company reviews you have posted on our Site. If you are a Care Giver and have elected to verify certain information with DwellAtHome.com 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.

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 name, first initial of last name, town and state. With a Registered User’s consent, we may include their full name.

B. With other Registered Users and corporate providers

In addition to the information that is provided to all Registered Users and Site Visitors, Care Giver reviews and references are made available to certain Registered Users. If you are a Care Giver, 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 Seeker or a Care Giver, you will appear in search result listings if you match the search criteria used by a Care Giver or Care Seeker, as applicable. Similarly, you may appear in emails sent to Care Givers or Care Seekers in your area.

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.

C. With vendors/service providers

We also share information with vendors with whom we have a contractual relationship and who perform services for DwellAtHome.com including, without limitation, vendors who provide email, demographic information, or geo-location information services, vendors who perform background checks, 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.

D. 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 or the Terms of Use, and/or to protect the rights and property of DwellAtHome.com, our employees, users, and the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.

E. 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.

F. With Your Consent

We also may share your information with a third party if you consent to the sharing.

G. Background Checks

DwellAtHome.com offers various background check services from consumer reporting agencies. A Care Giver can authorize a background check at their own discretion or in response to a request by a Care Seeker who is considering hiring him or her. If you are a Registered User who has requested a background check through DwellAtHome.com, you may or may not share the results of that background check on your profile. The service provider who completes the background check may also send the results to you by email or postal mail. You acknowledge that sensitive material may be included in your background check, and that you are responsible for providing us and our service provider (if applicable) with correct information.

If you are a Registered User of the Site and have requested such a background check you may post the results of the background check but are not required to do so. We will not share the check or results with any other Site Visitor or Registered User unless you specifically consent. The service provider who completes the background check may send the results to you by email or postal mail.

H. 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.

IV. 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:

• Care Givers who have chosen to have their phone number made available to other Registered Users can later change their election so that their number is no longer visible.
• Users of a DwellAtHome.com mobile application, who have given DwellAtHome.com 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.

 

Except as otherwise provided above, you may call Member Care at 205.259.8388 or adjust your account settings to opt out of any of the above information sharing that is applicable to your account. Your opt out preferences will take effect within 10 days of receipt of your request.

V. 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 Givers in your area, customer surveys and administrative notices.

You have a choice at any time to stop us from sending you emails for marketing purposes by adjusting your settings in your account settings. Go to your account settings for a complete list of the email types you may opt out of receiving. You can also opt out of commercial email messages by following the “unsubscribe” link included in these messages. Please note that despite any indicated email marketing preferences, we may continue to send you administrative emails regarding DwellAtHome.com, including, for example, notices of updates to our Privacy Policy, notifications of new Care Seekers or Care Givers in your area, responses to job postings from Care Givers, and responses to job applications from Care Givers, if we choose to provide such notices to you in this manner

You may also opt-out of receiving unsolicited marketing calls from us regarding your DwellAtHome.com account by adjusting your settings in your account settings.

VI. 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 and job postings, you may do so by editing or deleting that item in your My Profile & Setting area or your My Jobs area. To request removal of other information you have voluntarily posted on our Site, such as information you may have posted in online group forums, contact support@dwellathome.com. In some cases, we may not be able to reasonably accommodate your request to remove your information, in which case we will let you know if we are unable to do so and why.

If you no longer wish to participate in our Services, you may close your account directly through your account settings.

If you close your DwellAtHome.com 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. DwellAtHome.com may also retain and use your information if necessary to provide the Services to other Registered Users. For example, just as an email you may send to another person through an email service provider resides in that person’s inbox even after you delete it from your sent files or close your account, emails you send through DwellAtHome.com to other

Users, as well as your contributions to DwellAtHome.com groups, may remain visible to others after you have closed your account. Similarly, other information you have shared with others, or that others have copied, may also remain visible. DwellAtHome.com disclaims any liability in relation to the deletion or retention (subject to the terms herein) of information, or any obligation not to delete the information.

DwellAtHome.com does not control when search engines update their search index or cache, which may contain certain job posts, profiles or other information that have since been removed from DwellAtHome.com’s Site.

VII. Collection of Information from Children

DwellAtHome.com’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 13, we will take reasonable steps to delete it as soon as practicable.

VIII. 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.

IX. 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.

X. Changes to Our Privacy Policy

DwellAtHome.com reserves the right to change this Privacy Policy and our Terms of Use at any time. We may 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.DwellAtHome.com/privacy for updates. for updates. Your use of the Site or the Services after such effective date will constitute acceptance by you of such changes.

XI. Contact Us

If you have any questions on our Privacy Policy, you can contact us via email at contact@dwellathome.com

or at:

Legal Department DwellAtHome.com, Inc. 1500 First Avenue North

Suite M141

Birmingham, Alabama 35203