The details in this Privacy Notice will tell you about how Kiwi Healthcare LLC and its affiliates and subsidiary entities (referred to collectively herein as, “Kiwi Healthcare” “our” “us” or “we”) handle personal information.
This Privacy Notice applies to any individuals who are (1) Kiwi Healthcare job applicants, (2) current Kiwi Healthcare employees and/or independent contractors, (3) former Kiwi Healthcare employees and/or independent contractors, (4) dependents or beneficiaries of current Kiwi Healthcare employees, and/or (5) dependents or beneficiaries of former Kiwi Healthcare employees, (6) visitors of Kiwi Healthcare’s locations, and/or (7) visitors to Kiwi Healthcare websites. Where you provide Kiwi Healthcare with the personal information of third parties (i.e., dependents, beneficiaries and/or emergency contacts) for employment purposes, it is your responsibility to notify such third party of the limited purpose for which you provided Kiwi Healthcare their personal information and inform them of this Privacy Notice as applicable. This Privacy Notice does not cover how Kiwi Healthcare’ clients or subcontractors will handle your personal information; they will have separate notices regarding their personal information handling practices, and who can refer to their websites or policies for more details.
In this Privacy Notice, we will tell you how we handle your personal information—both online and offline—when you apply for a job, through the course of your employment, or if you visit our website or are one of Kiwi Healthcare’ clients. We want to be clear with you about the following:
Your privacy is important to us. This section will describe the “who, what, when, and why” of the personal information we collect about you.
Pre-Employment Communication
Travel
Payroll and Benefits
Licenses, Credentials, Certifications and Education History
Background and Qualification Checks
Providing Client Services
Audits
Website
Technology Monitoring
Marketing
When we use your personal information for marketing purposes, you can withdraw your consent at any time using the unsubscribe link in our emails, or by phone, email, or regular mail.
Security
Sensitive Personal Information
Improving and Developing the Services and Our Systems
Artificial Intelligence Analytics
This section gives you more specific details about the information we collect automatically from your device(s) online. We’ll tell you about cookies and different online technologies that automatically collect information, what types of information we collect automatically, and how we use online information we collect automatically from you.
Here, have a cookie! A “cookie” is a small text file that websites send to your computer, device, or other Internet-connected device you are using. We use cookies to identify your browser or to store information or settings in the browser to improve your experience with our website(s).
Web beacons. A “web beacon” links web pages to web servers and the cookies and may be used to transmit information collected through cookies back to a web server. You might have heard of a web beacon that was called something else, like an Internet tag, pixel tag or clear GIF.
What information do our websites collect from you? Our sites use cookies, web beacons, java scripts, and similar technologies to collect certain information about your activity relating to our websites. These technologies collect your Internet Protocol (IP) address, device type, age or age range, network location, and information about how you interact with our websites.
How do we use cookies and other automatically collected information? We use data collected automatically through our website to analyze trends, administer our sites, track visitors’ movements through our websites, and gather demographic information about our visitors as a whole. We may receive reports based on these technologies on an aggregated basis.
We use cookies to keep track of advertisements and compile aggregate data about website traffic and website interaction, so we can offer better website experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our website visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. We also use third-party analytics services on our websites, including Google Analytics. To learn more about Google Analytics, visit: https://policies.google.com/technologies/partner-sites.
What you can do about cookies. Your Internet browser may let you restrict or disable certain types of cookies. Without cookies, you may not be able to use all of the options on our websites.
We may also use JavaScript to help our websites, especially pictures, function better. You can turn JavaScript on or off in your browser functions, but if you turn it off, you may not be able to use all of the options on our websites.
Sometimes we use technology to collect the information that your browser uses to auto-fill your personal information, such as you name, contact information or other information that you may enter. We use this to tell you if there is a mistake in registration or if the registration cannot be submitted. You can stop this technology by turning it off in your browser, and you will still be able to use all of the options on our websites.
Where we share personal information with third parties about our visitors of our website, we only do so for the purposes outlined in Section 1 and based on your third party permissions. For more information on who we share personal information with, see Section 4, “SHARING YOUR PERSONAL INFORMATION.” Below are links to our third parties opt out pages for your convenience:
Do Not Track Signals. Some web browsers allow you to turn on Do Not Track (“DNT”), which sends signals to websites you visit, telling those sites that you do not want your online activities to be tracked. Our websites currently are not designed to respond to DNT signals received from web browsers.
The law requires us to tell you about the personal information we collect about you in a certain way – specifically, we need to tie it back to “legal categories” of personal information that are listed in the law. To do this, we bundled up the information we gave you in Section 1 of this Privacy Notice and matched the different types of personal information we collect about you with the legal category. To make things easier to understand, we’ve put this information in a chart that shows you four things:
We’ve included the chart at the end of this Privacy Notice as Appendix A. At the end of the Personal Information Privacy Chart, we also included a list of Information We Disclose for a Business Purpose.
This section tells you about the rights and choices you have for your personal information under California law, as well as how to make a request to exercise your rights.
Employees in California may have these rights:
These rights may be subject to certain limitations or exceptions under California Law and the purpose for which we process personal information about you.
Where applicable and technically feasible, we will accommodate your valid request to exercise your privacy rights and choices. You may also designate an authorized agent to make a request on your behalf.
How to Make a Request: If you would like to make a request, please email us at privacy@kiwihealthcare.com. You will need to provide your first and last name, phone number, the relationship you have or had with us (whether you are an internal employee or a clinician), request details, and the type of request you want to make.
We will make good faith efforts to make requested changes in our then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information. Further, we reserve the right to retain data (a) as required by applicable law; and (b) as long as we need it or as long as the law allows or requires.
Responding to Requests:
Your request will be evaluated to determine whether the requested change meets legal regulatory requirements. If we aren’t able to honor any part of your request, we will tell you that in our response, as well as the reason(s) we cannot do so.
Verifying Your Identity:
In order for us to look into your request, we first need to verify your identity, meaning that we need to make sure that you are the individual whose personal information we collected, or that you are a person who has been duly authorized to make the request on behalf of another person. For example, if you make a request, we will ask you to confirm your email address and phone number. For certain requests, we will use a combination of your email address, phone number, zip code, and/or birth date to verify your identity, so that we can help protect your information. If you designate an authorized agent to make a request on your behalf, we will require you to verify your identity and provide the information outlined in “How to Make a Request” above.
Requests by Authorized Agents:
You may have the right to designate an authorized agent to make a request on your behalf. Authorized agents may make a request by emailing privacy@kiwihealthcare.com. As permitted by California Privacy Law, we will still verify your identity, the agent’s identity, and confirm that you have given the agent the authority to make a request on your behalf. When we confirm an agent’s authority, this may include attestation under penalty of perjury. Absent a power of attorney, we will also require you to verify your own identity. We may verify identity based on matching information you provided with data we have maintained on you in our systems. This data could include, but is not limited to, first and last name, phone number, the relationship you have or had with us, request details, and the type of request you want to make.
This section will tell you about how we share your personal information with others. First, we will tell you how we use and share your personal information for marketing purposes. Then, you’ll learn about how we share your personal information for business purposes. We’ll take the “legal categories” of information from Appendix A and match them up with what we share and who we share it with.
Follow-Up Marketing. We will use information you have shared with us, including your name, phone number, and email address, to contact you in order to provide our services. You will have an opportunity to opt-in to receive text messages. We may use both text messages if you opt-in and/or email to share information about potential opportunities with you. We will not sell, trade, disclose, or otherwise share your name, telephone number, or other personal information to any other companies or individuals, except as described in this Privacy Notice unless you authorize us to do so or except where needed to deliver a service to you. If you don’t want to receive follow-up marketing from us, you can opt out at any time. To opt out of receiving text messages, you simply need to respond with the word “Stop.”
Sharing for Business Purposes. Except for follow-up marketing, we only share your personal information for our business purposes. Put another way, we only share your personal information to operate our business and for the purposes we’ve described for you in this Privacy Notice (to accomplish the “why” in Section 1).
Clients, Facilities, Potential Employers: We may share your personal information with our clients, facilities, and potential employers to present you for employment opportunities and to manage your employment relationship.
Our “Family” Companies: We may share your personal information with any company that is owned by or affiliated with Kiwi Healthcare or our parent companies. If we share your personal information, we will take reasonable steps to make sure that our companies take prudent steps to protect your personal information. We may share not just information that you provide to us, but also information we obtain from third parties (all of which may be combined or comingled).
Service Providers: Other companies sometimes provide certain services to us or on our behalf (e.g., payroll services, leave and absence management services, maintenance or IT support, audits, analysis, and benefits). Unless we tell you differently or as described elsewhere in this Privacy Notice, our service providers are not permitted to use your personal information except to assist us.
Artificial Intelligence Analytics: One of the services we use includes artificial intelligence analytics. To understand which opportunities might be particularly relevant to you or for which you may be an exceptionally good fit, we may use any of the information you provide to us in the course of your employment. It is important to note that while we may use this information with artificial intelligence to assist in the determination of whether you are or are not qualified for a particular placement or whether you will be placed or offered a position with a certain clinic or location, our employees working in conjunction with our clients and their requests will make those ultimate decisions.
Third Parties with Whom You Direct Us to Share Your Personal Information: If you direct us to share your personal information with a third party, we will share only the information that is needed to complete your request.
Other Third Parties, such as consumer reporting agencies when we perform employee background checks.
Compliance with Legal Obligations: We may need to disclose certain information to auditors, government authorities, law enforcement, regulatory agencies, our legal counsel, third party litigants and their counsel, or other authorized individuals to comply with laws that apply to us, subpoenas, discovery requests, or other legal obligations such as contractual requirements.
Changes in Business Structure/Ownership: We may disclose or transfer your personal information to a third party in the event of any reorganization, merger, sale, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of Kiwi Healthcare’s business, assets, or ownership interest (including through bankruptcy or similar proceedings).
We’ve provided a list of all the legal categories of information we share for a business purpose after the chart in Appendix A.
Kiwi Healthcare does not sell applicants’ or employees’ personal information to anyone and Kiwi Healthcare does not share applicants’ or employees’ personal information with third parties for those parties’ commercial use. The law also requires us to explicitly state that we do not sell the personal information of minors under 16 years old.
In certain circumstances, we may chose to or may be required to provide additional or different disclosures to residents of different countries or states. Below are the disclosures that may be applicable to you.
Privacy Rights: Some privacy laws require that we disclose to you the privacy rights that you have regarding personal information. We have defined the various privacy rights below. to see which rights apply to you, refer to the “Privacy Rights Chart” immediately following this subsection.
These rights may be subject to certain limitations or exceptions depending on your state of residency and the purpose for which we process personal information about you. For example, if you are engaging with Kiwi Healthcare as part of a future, current or past employment relationship, your privacy rights may not apply.
If you would like to make a request or have any questions or concerns about this Privacy Notice, you can contact us via phone, email, and regular mail. Alternative formats of this Privacy Notice are available to individuals with a disability. Please contact us for assistance.
Your privacy is important to us, and we strive to take appropriate security measures to help safeguard your personal information from unauthorized access, disclosure, alteration, or destruction. For example, only authorized employees are allowed to access personal information, and they may only access it for permitted business functions. We also use technology to protect your personal information, including encrypting confidential personal information that is transferred to or from our systems and implementing physical security measures to protect electronic and hard copy information.
While we cannot guarantee that loss, misuse, or alteration will never occur, we use reasonable efforts to prevent it. When you send your personal information to us over the internet, please keep in mind that no method of storage or transmission over the Internet is completely secure, so your provision of information to us is at your own risk.
In general, we keep your information for as long as we need it to carry out the purposes described in this policy, and as necessary to comply with our records-management policies and laws that apply to us. We also keep your information when we need to comply with other legal obligations we might have, such as in connection with a lawsuit, complaint, or investigation. Retention of information and destruction is more fully described in the Employee Handbook.
Types of Information Collected: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, video or pictures or other similar identifiers.
Source: Directly from you; From Third Parties; Automatically from your devices
Purpose for Collection and Use: Pre-employment communication; Job Applications; Employment; Travel; Payroll and Benefits; Licenses, Credentials, and Certifications; Background, and Qualification Checks; Providing Client Services; Audits; Website; Technology Monitoring; Marketing; Security; Improving and Developing the Services and Our Systems; Artificial Intelligence Analytics
Sharing of Information for Business Purposes: Clients, Facilities, Potential Employers; Our “Family” Companies; Service Providers; Third Parties with Whom You Direct Us to Share Your Personal Information; Other Third Parties; Compliance with Legal Obligations; Changes in Business Structure/Ownership; Improving and Developing the Services and Our Systems; Artificial Intelligence Analytics
Types of Information Collected: Name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, images and videos or any other financial information. Some personal information included in this category may overlap with other categories.
Source: Directly from you; From Third Parties
Purpose for Collection and Use: Pre-employment communication; Job Applications; Employment; Travel; Payroll and Benefits; Licenses, Credentials, and Certifications; Background, and Qualification Checks; Providing Client Services; Audits; Website; Technology Monitoring; Marketing; Security; Improving and Developing the Services and Our Systems; Artificial Intelligence Analytics
Sharing of Information for Business Purposes: Clients, Facilities, Potential Employers; Our “Family” Companies; Service Providers; Third Parties with Whom You Direct Us to Share Your Personal Information; Other Third Parties; Compliance with Legal Obligations; Changes in Business Structure/Ownership; Improving and Developing the Services and Our Systems; Artificial Intelligence
Types of Information Collected: Age (40 years or older), national origin, citizenship, marital status, and veteran or military status.
Source: Directly from you; From Third Parties
Purpose for Collection and Use: Pre-employment communication; Job Applications; Employment; Travel; Payroll and Benefits; Licenses, Credentials, and Certifications; Background, and Qualification Checks; Providing Client Services; Audits; Website; Technology Monitoring; Marketing; Security; Improving and Developing the Services and Our Systems; Artificial Intelligence Analytics
Sharing of Information for Business Purposes: Clients, Facilities, Potential Employers; Our “Family” Companies; Service Providers; Third Parties with Whom You Direct Us to Share Your Personal Information; Other Third Parties; Compliance with Legal Obligations; Changes in Business Structure/Ownership; Improving and Developing the Services and Our Systems; Artificial Intelligence
Types of Information Collected: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, device type.
Source: Automatically from your device(s)
Purpose for Collection and Use: Pre-employment communication; Audits; Website; Technology Monitoring; Marketing; Improving and Developing the Services and Our Systems; Artificial Intelligence Analytics
Sharing of Information for Business Purposes: Our “Family” Companies; Service Providers; Third Parties with Whom You Direct Us to Share Your Personal Information; Compliance with Legal Obligations; Changes in Business Structure/Ownership; Improving and Developing the Services and Our Systems; Artificial Intelligence
Types of Information Collected: Physical location or movements.
Source: Automatically from your device(s)
Purpose for Collection and Use: Audits; Website; Technology Monitoring; Marketing; Improving and Developing the Services and Our Systems; Artificial Intelligence Analytics
Sharing of Information for Business Purposes: Our “Family” Companies; Service Providers; Third Parties with Whom You Direct Us to Share Your Personal Information; Compliance with Legal Obligations; Changes in Business Structure/Ownership; Improving and Developing the Services and Our Systems; Artificial Intelligence
Types of Information Collected: Current or past job history or performance evaluations.
Source: Directly from you; From Third Parties.
Purpose for Collection and Use: Pre-employment communication; Job Applications; Employment; Licenses, Credentials, and Certifications; Background and Qualification Checks; Audits; Improving and Developing the Services and Our Systems; Artificial Intelligence Analytics
Sharing of Information for Business Purposes: Clients, Facilities, Potential Employers; Our “Family” Companies; Service Providers; Third Parties with Whom You Direct Us to Share Your Personal Information; Other Third Parties; Compliance with Legal Obligations; Changes in Business Structure/Ownership; Improving and Developing the Services and Our Systems; Artificial Intelligence
Types of Information Collected: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Source: Directly from you; From Third Parties (including but not limited to Nursys)
Purpose for Collection and Use: Job Applications; Employment; Licenses, Credentials, and Certifications; Background and Qualification Checks; Audits
Sharing of Information for Business Purposes: Clients, Facilities, Potential Employers; Our “Family” Companies; Service Providers; Third Parties with Whom You Direct Us to Share Your Personal Information; Compliance with Legal Obligations; Changes in Business Structure/Ownership
Types of Information Collected: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Source: Directly from you; Automatically from your device(s)
Purpose for Collection and Use: Pre-employment communication; Audits; Website; Improving and Developing the Services and Our Systems; Artificial Intelligence
Sharing of Information for Business Purposes: Our “Family” Companies; Service Providers; Third Parties with Whom You Direct Us to Share Your Personal Information; Other Third Parties; Compliance with Legal Obligations; Changes in Business Structure/Ownership; Improving and Developing the Services and Our Systems; Artificial Intelligence
Types of Information Collected: Social Security number, driver’s license, state ID card, passport number, account login, financial account, debit/credit card number (w/access code), credentials allowing access to an account, precise geolocation, race or ethnic origin, religious or philosophical beliefs, or union membership, contents of personal communications, genetic data, biometric data health data, and sex life or sexual orientation.
Source: Directly from you; From Third Parties
Purpose for Collection and Use: Job Applications; Employment; Travel; Payroll and Benefits; Licenses, Credentials, and Certifications; Background, and Qualification Checks; Providing Client Services; Audits; Website; Technology Monitoring; Marketing; Security; Improving and Developing the Services and Our Systems; Artificial Intelligence
Sharing of Information for Business Purposes: Affiliates; Clients; Service Providers; Suppliers; Compliance with Legal Obligations; Changes in Business Structure/Ownership; Improving and Developing the Services and Our Systems; Artificial Intelligence
We may need to adapt to changes to continue to protect your personal information, so we may make changes to our privacy practices at any time, and we will review our practices at least every 12 months. If we make a change to the privacy practices, we will update this Privacy Notice on our website and the clinician portal.