Trio VMS Privacy Policy
Updated May 1, 2023
TRIO VMS PRIVACY POLICY
American Health Technology Group, LLC (“we,” “us,” and “our”) is committed to taking reasonable steps to protect your privacy and manage your information responsibly. This privacy policy (the “Privacy Policy”) explains how we collect, use, and share your information obtained through Trio. Importantly, this Privacy Policy explains the choices you can make regarding the use of your information.
Scope of this Policy
This Privacy Policy applies to your use of Trio, our proprietary, cloud-based, vendor management system, and the services made available through same (collectively, the “Software”).
Consent
By using our Software, you agree to the terms of this Privacy Policy and the accompanying Trio Terms of Use, available at www.triowfs.com/trio-vms-user-terms-of-service. You also consent to our use of the information we collect through the Software as described in this Privacy Policy.
1. The Information We Collect. While using the Software, we will collect, and you authorize us, to collect the following types of information:
a. Personal Information. When you signup to use the Software, you provide us with personal information about yourself or your employees, such as name, physical address, email address, phone number, and other contact information, and in some cases payment information and tax information (such as tax exemption information and W9 forms). If you are an Agency partner user of the Software, you will provide us with information related to your clinicians and other employees that you submit for consideration for job orders posted in the Software by our Client or Managed Service Provider (“MSP”) partners. In some instances, the information provided regarding your clinicians and other employees may be considered “Sensitive Personal Information”, which is personal information that reveals a person’s social security number, health information, and payment information. (collectively, the “Personal Information”).
b. Other Information. We may automatically collect or receive additional information regarding you and your use of the Software (“Other Information”). Such Other Information may include:
i. Information Required to Provide Services. This includes contracts, term sheets, codes of conduct, and other documents Clients and Agency partners provide that govern the performance of services and submissions by Agencies to Clients.
ii. User Submitted Information. We collect information you submit to the Software, such documents you upload to the Software and messages to us, our Clients, Agencies, and MSP partners.
iii. From Your Activity. We may collect or receive information regarding:
· IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable mobile device;
· date and time;
· details regarding your activity on the Software, such as job orders viewed by you, your search queries, and other performance and usage data.
· Logs and session data when you access the Software.
iv. About Your Device. We may collect or receive information regarding the following:
· type of device used to access the Software;
· operating system and version;
2. How Information is Collected.
a. User Submitted. We collect information from you when you submit it to the Software. Sometimes the Software actively asks you for it, sometimes you upload it of your own volition, and other times we or our Client, Agency, or MSP partners may ask for it.
b. Cookies. The Software requires you to use cookies when accessing and using the Software. A cookie is a small text file placed on your browser or device by a web server to store data that can be used to recall your device and individualize your experience. We use cookies to collect information about you, to tell us whether you have previously visited the Software, and to help personalize your experience when using Software. We also use cookies that enable us to obtain analytics information about your use of the Software and provide feedback and analysis on how our Software and applications perform.
3. Why We Collect Information. We collect information to help us maintain and improve the Software and to create, maintain, and improve other products and services. We collect information to provide services and administer your account. We collect information to comply with our legal and regulatory obligations and for our legitimate business interests.
4. How We Use Your Information.
a. Your Personal Information is shared with our Client, Agency, and/or MSP partners as applicable and necessary for submission and placement of Agency candidates for job orders, and for the management of assignments of Agency personnel on assignment with our Clients. However, Agency Personal Information and Other Information is not shared with other Agency users of the Software.
b. We use Personal Information and Other Information (collectively, “Information”) to operate, manage, maintain, improve, and evaluate the Software and its usage.
c. We use Information in an anonymized and aggregated form (that does not reveal your Personal Information) to provide data analytics and other metrics for lawful purposes to ourselves and our affiliates, parent companies, Clients, MSPs, licensees, and other third parties.
d. We may share Information with our affiliates, parent companies, investors, lenders, and insurers on an as-needed basis for business and other lawful purposes.
e. We may use Information to create, improve, and enhance our services and products.
f. We use Information to communicate with you and respond to requests from you.
g. We sometimes engage third-party companies and individuals to perform services involving the Software. Sometimes these third-party companies may have access to Information as necessary to perform their services and to the extent permitted by law. Examples of these third-party services include technical assistance, consultative advice, and administrative support.
h. If we or our parent companies are involved in a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transaction and transferred to a third party as part of the transaction.
i. To the extent permitted by law, we may also disclose the Information: (1) when required by law, court order, subpoena, or other government or law enforcement authority or regulatory agency; (2) whenever we believe disclosing such Information is necessary or advisable to protect the rights, property, or safety of us or others, including you.
5. How We Protect Your Information. We take commercially reasonable steps to protect Information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, because no security system is impenetrable, we cannot guarantee the security of our databases or the databases of the third parties with which we may share Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet.
6. Third-Party Links. This Privacy Policy only addresses the use and disclosure of Information we collect through your interaction with the Software. We are not responsible for the privacy practices of any third parties. The Software may link to or embed content from third-party websites. When we link to other websites or embed their content, our privacy practices no longer apply. You should refer to the privacy policy of that third party for information about their privacy policies and cookie practices.
7. No Out-of-Country Use. You cannot use the Software outside of the United States.
8. Do Not Track Requests. We do not honor do not track requests. We cannot adequately provide the Software if a ‘Do Not Track’ flag is enabled on your device.
10. Children’s Privacy. The Software is not directed to or intended for children and individuals under the age of 18. Minors should not use the Software. We will not knowingly collect Personal Information from any child under the age of 16. If a child under the age of 16 has provided us with Personal Information, a parent or guardian of that child may contact us and request that we delete the child’s Personal Information from our records.
11. Changes to this Privacy Policy. This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. These changes may include material changes. Any changes will be posted on the Software. By accessing the Software after we make any such changes to this Privacy Policy, you consent to those changes. Please refer back to this Privacy Policy on a regular basis.
12. How to Contact Us. If you have questions about this Privacy Policy, please email us at support@triovms.com with “Trio Privacy Policy” in the subject line or mail us at the following address: AHTG, 3051 Willowood Rd, Edmond, OK 73034, Attn: Privacy Policy.
13. Retention of Information. We generally store your Personal Information for as long as you remain a user of the Software and as long as necessary to fulfill the purposes for which it was collected while considering the amount, nature, and sensitivity of the information. We may also store your Personal Information for as long as necessary to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. The criteria that we use to define the periods for storing your data have been established in accordance with the requirements of applicable laws, in addition to our own operating requirements. At the appropriate time, we will take reasonable steps to destroy your Personal Information or ensure that your personal information is de-identified.
14. California Addendum. If you are a California user of the Software, this California Addendum applies to our processing of Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (collectively, “California Personal Information”). For California users of the Software, the provisions of this California Addendum prevail over any conflicting provisions in other sections of this Privacy Policy.
(a) We do not sell, and in the past 12 months, we have not sold California Personal Information.
(b) If you are a California user, you have certain rights related to your California Personal Information under the California Consumer Privacy Act and California Privacy Rights Act. For example, you have:
(i) The right to know:
(A) What California Personal Information we have collected about you, including categories of personal information? Please see Section 1 (Information We Collect) for the types of information we collect about you.
(B) The categories of sources from which the California Personal Information is collected. We collect information that you submit to us on the Software and from your usage of the Software, as described in Section 1 (Information We Collect).
(C) The business or commercial purpose for collecting, selling, or sharing California Personal Information. We use California Personal Information as described in Section 4 (How We Use Your Information),.
(D) The categories of third parties to whom we disclose California Personal Information, and the specific pieces of California Personal Information we have collected about you. We disclose your California Personal Information to Client, Agency, and/or MSP partners as applicable and necessary for submission and placement of Agency candidates for job orders, and for the management of assignments of Agency personnel on assignment with our Clients or MSP partners. However, Agency California Personal Information is not shared with other Agency users of the Software.
(ii) The right to correct inaccurate California Personal Information that we have collected about you. Please contact us as described in Section 14(h) if you believe we have inaccurate California Personal Information about you.
(iii) The right to delete California Personal Information we collected from you, subject to certain exceptions. These exceptions include when required to be retained by law or for our essential business purposes, such as providing services or products to you. These exceptions also include record retention schedules and other requirements mandated by law that prohibit or restrict the deletion of certain personal information. Once we receive and verify your consumer request, we will delete your personal information from our records unless an exception applies.
(iv) If you would like for us to delete the California Personal Information we collected from you, please contact us as described in Section 14(h). Please note that we will not delete California Personal Information that we are required to maintain in accordance with applicable law.
(v) The right to opt out of the sale or the sharing of California Personal Information. We do not sell California Personal Information.
(vi) The right to opt out of the sharing of California Personal Information with third parties for cross-contextual behavioral advertising.
(vii) The right to limit the use or disclosure of your sensitive personal information. We may use your Sensitive Personal Information for purposes of providing the Software, creating and managing assignments of Agency personnel on assignment with our Clients, verifying user information, managing payments, and activities relating to quality, safety control, and improvement of the Software.
(viii) The right to opt-out of the use of automated decision-making technology. We do not use automated decision-making technology.
(ix) Right to know about data retention policy.
(x) The right not to receive discriminatory treatment by the business for exercising privacy rights conferred by applicable law, including the right not to be retaliated against for exercising your rights. We will not discriminate against you for exercising your rights under this Privacy Policy or applicable law.
(c) If you contact us regarding your California Personal Information, we will take steps to verify your identity before granting you access to your California Personal Information or acting on a request from you regarding your California Personal Information. We may require you to provide your first name, last name, email address, and shifts worked to verify your identity. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. When you submit a request regarding your California Personal Information, we will use the information you provide to process your request and to maintain a record of your request. However, we may partially or wholly deny your request as allowed by applicable law, as permitted under applicable law.
(d) You may only make a verifiable consumer request for access or data portability twice within a 12-month period. You may also make a verifiable consumer request on behalf of your minor child.
(e) Under California law, you may designate an authorized agent to make a request regarding your California Personal Information on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. To the extent permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent.
(f) Within ten business days of receiving a verified consumer request, we will provide confirmed receipt of your requests along with information about how We will process your request. We will respond to a verified consumer request for personal information within 45 days of receipt. If we require more time (up to 45 additional days), we will notify you of the reason and extension period in writing. We will deliver our written response through a secure link. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response will also explain the reasons we cannot comply with a request, if applicable.
(g) For data portability requests, we will select a format to provide your personal information that is readily useable and in a format that allows you to transmit this information to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
(h) To exercise the access, data portability, and deletion rights described above, please submit a request using one of the following methods:
· Emailing us at support@triovms.com
· Calling us at 1-800-536-3001