Privacy Policy

Sincere Care Residential Ltd. (“Sincere Residential Services”, “us”, “we”, or “our”) is committed to respecting your privacy and protecting your personal data. Sincere Residential is a healthcare company that is innovating and revolutionizing the way home care is delivered. We bring dignity and support to patients needing care in their homes and to the caregivers who care for them.

This Privacy Policy explains the types of personal data we may collect from visitors to and users of our websites, including www.Sincere-Res.com and all related websites (the “Sites”), and web-based services (collectively with Sites and Apps, our “Services”), including our employees and prospective employees. This Privacy Policy also describes how we use personal data, the purpose for sharing and recipients of personal data, and your available choices associated with that information.

We may collect or receive certain personal data and other data about you that is governed by federal law, such as the Health Insurance Portability and Accountability Act (“HIPAA”). Please review our Notice of Privacy Practices, which governs our use, disclosure and access to information protected by HIPAA. This Privacy Policy does not apply to information about how we handle HIPAA-regulated personal health information (“PHI”).

This Privacy Policy also does not apply to third-party websites, mobile applications, products, or services, even if they may link to our Services or our Services may link to them. We recommend you review the privacy practices of those third parties before accessing third party websites and sharing any personal data.

For the purposes of this Privacy Policy, “personal data” means any information that relates to an identified or identifiable individual, and does not include PHI. The types of personal data we may collect will vary depending on how you interact with our Services. Personal data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified, or aggregate consumer information. “Publicly available information” includes information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the individual; and information that is made available by a person to whom the individual has disclosed the information if the individual has not restricted the information to a specific audience.

For information on Sincere Residential’s privacy practices specific to PHI, please see our Notice of Privacy Practices.

Personal data you provide to us.
We may collect the following personal data about you that you provide us when you use our Services, become a Sincere Residential employee, or apply for employment with us, including:

• Application information When you apply for employment, including to be a home health aid (“HHA”), Direct Support Professional (“DSP”), or caregiver, you may be asked to provide certain personal data, including first and last name, email address, phone number, education information (including your education history, records maintained by an educational institution, as well as information about any training or certification programs), and professional or employment-related information (including your employment history).
• Employment-related information If you work for Sincere Residential, we may collect certain information such as information relating to your compensation and benefits, information relating to your performance evaluations, information concerning time worked (clock ins/outs), your signature (for timesheets), and travel history.
• Registration and account information If you work for Sincere Residential or are in process of joining as a personal assistant (“PA”) and create an account on our Apps or through other means, you may be asked to provide certain personal data including full name, address, email address, phone number, date of birth. Through the use of your account on our Apps, we may also invite you to provide additional information about yourself, such as social security number, gender, work eligibility, emergency contact information, clothing and/or shoe sizes, prior work history, employer references, health information/history, and potential patient information.
• Financial information If you work for Sincere Residential, we also collect information such as bank account numbers, credit or debit card numbers, and other financial information relating to your financial institution required to administer payroll and reimburse business expenses.
• Medical and health insurance information If you work for Sincere Residential, we may also collect insurance policy numbers; medical conditions; workplace accommodations and related documentation; FMLA calculations and related leave records; signature; physical characteristics or description; worker’s compensation claim information; and other medical and health insurance information.
• Biometric information When you use our Apps, we may collect data via facial recognition or similar technology from an image (such as a selfie) to identify caregivers, and to verify caregiver time entries.
• Consumer health data We may also collect consumer health data from patients or prospective patients. “Consumer health data” means personal data that is linked or reasonably linkable to you and that identifies your past, present, or future health status or mental health status, as may be applicable.
• Audio, electronic, visual, or similar information We may collect on-premises video surveillance information; audio recordings of phone calls when you contact us; or any photo, video, or audio information you submit through our access portals, interfaces, and properties.
• Communications information When you communicate with us through our Services, we may collect your first and last name, phone number, email address, and any personal data that you choose to provide in the content of your message.

Information that we automatically collect
Our Services may use cookies and other tracking technologies such as web beacons, embedded scripts, and tags, which collect information from you automatically as you use our Services, including:

• Browser and device data When you use our Services, we may automatically collect information such as IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Sites you are visiting.
• Usage data When you use our Services, we may automatically collect information such as browsing history, time spent on the Sites, pages visited, links clicked, language preferences, patterns of use, and the pages that led or referred you to our Site. We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. For example, we use Google Analytics on our Sites to help us analyze your use of our Sites and diagnose technical issues. Please review Cookies & Other Tracking Technologies below for more information about our use of these technologies.
• Geolocation data We may request access or permission to and gather location-based information from your mobile device, either continuously or while you are using our Apps, to allow you to clock in and out, and provide location-based services.

Information we collect from others
We may collect personal data about you from the following entities or individuals:

• Our service providers We may collect personal data from our service providers, including providers of background checks and credit checks, recruiters, communications and analytics providers, customer and technical support providers (such as when caregivers use the Sincere Residential mobile app’s chatbot, Alice), internet service providers, operating systems and platforms, data brokers, fraud solutions, health and risk insurance brokers, and healthcare carriers.
• Social media and other content platforms We may collect personal data from platforms such as Meta, X, YouTube, LinkedIn, or Google if you interact with us on these platforms to use the Sites or Services.
• Government entities We may collect personal data about you from government entities to assist in providing employee benefits and services.
• Other individuals We may collect personal data about you from employees, contractors, patients, or other users of our Services.

Aggregated, anonymized, and deidentified information
We may create aggregated, anonymous, or de-identified data from personal data by removing data components that make the data personally identifiable to you or through obfuscation or other means. Our use of aggregated, anonymized and de-identified data is not subject to this Privacy Policy and may be further controlled by federal health privacy law, as described in our Notice of Privacy Practices.

Use of Personal data
We use the personal data we collect for the following purposes:

• Communicating with you.
• Applying for employment (including screenings, processing employment applications, interviews, and performing background checks).
• Workforce management and planning (such as performance reviews, evaluations, and internal investigations).
• Administering payroll, employee benefits, and health insurance.
• Providing you with customer service and support, and to facilitate other communications that you request or that are required to render Services to you.
• Providing you with information about new Services and other opportunities that we believe may be of interest to you, and to personalize, measure, and improve such offers.
• Performing analytics for new and existing Services, such as our user accounts and related features.
• For internal business purposes.
• Maintaining and improving the effectiveness and quality of our Services.
• For targeted advertising and marketing
• Growing our business, including performing research and development, understanding our user trends, and understanding the effectiveness of our marketing.
• Protecting the legal rights, safety, privacy, and property of us, you, and others.
• Preventing fraud; and creating and maintaining a trusted, secure, and reliable online environment.
• Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about the users of our Sites or Services is among the assets transferred.
• Complying with our legal obligations; respond to subpoenas, court orders, or legal process; or to establish or exercise our legal rights or defense against legal claims.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Disclosure of Personal Data
We may disclose personal data to the following categories of third parties:

• Our affiliates We may share personal data with our affiliates, in which case, we will require such affiliates to comply with the terms of this Privacy Policy.
• Service providers We share personal data with our service providers to provide services on our behalf, such as payment processing, analytics, advertising, hosting, marketing, customer and technical support, and other services. For example, when caregivers interact with Alice, the chatbot on the Sincere Residential mobile app, the information provided may be recorded and stored by our provider Azure, in order for us to provide customer and technical support.
• Third-party platform advertising We may share your information with third-party platform providers who assist us in serving advertising regarding the Sites and Services to others who may be interested. We also partner with third parties such as Google and Adobe, who use cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location, and/or interests.
• Compliance and harm prevention Under certain circumstances, we may share personal data as we believe necessary (i) to comply with applicable law, rules and regulations; (ii) to enforce our contractual rights; (iii) to investigate possible wrongdoing in connection with the Site and Services; (iv) to protect and defend the rights, privacy, safety and property of Sincere Residential, you or others; and (v) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
• Affiliate and business transfers and transactions If we or our subsidiaries are involved in a merger, acquisition, asset sale, or other corporate combination, your personal data may be transferred to the acquiring or surviving entity.

We will retain your personal data for as long as necessary for the purposes outlined in this Privacy Policy. This information will be used and retained to the extent necessary to comply with any legal obligations or policies, to resolve disputes, and/or enforce legal agreements. Personal data may also be retained for internal analytic purposes. This information is retained for a shorter period of time, unless it used to enhance security features or improve the functionality of our Services. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you (such as whether you are a current employee or contractor) (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position, including regard to applicable statutes of limitations, litigation or regulatory investigations.

Our Services are operated exclusively in the United States and intended for users located in the United States. We may transfer, store, and use information we collect and maintain about you, including personal data outside of your state, province, country, or other governmental jurisdiction. For such transfers, we take the necessary measures to ensure that your personal information receives an adequate level of protection. Please note that the data protection laws in the jurisdiction in which we process personal data may differ from those of your jurisdiction, and in certain circumstances, your personal data may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions.

You may have rights and choices regarding our use and disclosure of your personal data. To exercise these rights and choices, please Contact Us. Please note that you may have further rights and choices as may be described in our Notice of Privacy Practices.

Opting out of promotional emails from us. If you give us your email address, postal address, or telephone number, you are authorizing us to use that information to communicate with you regarding the status of any pending order as well as for marketing purposes. If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails, or by contacting us at admin@sincere-res.com. When you contact us, please provide us with your name, address, and phone number. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required in order to provide you with the Services or for other reasons disclosed in this Privacy Policy.

Opting out of SMS messages. As further detailed in our SMS Terms Notification, we may send you SMS messages to inform caregivers when visits are and to ensure that you are clocking in and out for each of your visits, inform you of upcoming seminars, document requirements, and provide other notifications. To cancel the SMS service at any time, text “STOP” to any text message you receive or contact us at admin@sincere-res.com. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have unsubscribed. After this, you will no longer receive SMS messages from us. If you are experiencing issues with the messaging program you can text “HELP” for more assistance, or you can get help directly at admin@sincere-res.com.

View or change your account data. If you have an account with us through our Apps, you are able to add and edit your account information, such as phone number, email address, address, date of birth, gender, work eligibility, emergency contact information, pay information, clothing and/or shoe sizes in MySteps and phone number, email address and W4 information for our mobile application.

Account deletion requests. You have the right to request the deletion of your account with Sincere Residential. If you would like to request that your account be deleted, please contact us at admin@sincere-res.com.