Privacy Policy

1. Introduction

This Privacy Policy explains how Prosperity Medical, LLC d/b/a Kinwell ("we," "us," or "our") collects, uses, discloses, and safeguards your information. This Privacy Policy applies to information we collect in the course of providing our services, including through our website kinwellaid.com, any related webpages, mobile and web applications, and any other online or offline services we offer (collectively, our "Services"), which are intended for caregivers or prospective caregivers of individuals enrolled in or eligible for Michigan Medicaid who have not previously received services under the Michigan Home Help Program. This Privacy Policy incorporates our website Terms of Service, which we encourage you to review.

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

This Privacy Policy does also not apply to third-party websites and platforms, even if our Services link to them or vice versa. We recommend that you review the privacy policies for third-party websites and platforms to understand how your personal data is used and stored by those third parties.

Please note that we are providing the following disclosures in this Privacy Policy in the interest of transparency. Such disclosures are not intended to waive any applicable exemptions under state and federal law.

2. Information We Collect

"Personal data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. Personal data includes "personal information" and "personally identifiable information" as such terms are defined under various privacy laws.

Personal data does not include publicly available information, which includes information that is made available from federal, state, or local government records; information that we have 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.

We may collect the following personal data:

a. Personal data you provide us

We collect personal data when you visit our website, contact us, work with us to apply for the Michigan Home Help Program, or otherwise interact with us, including:

• Contact & Identity Information: Name, phone number, email address, date of birth, home address, and gender.
• Eligibility Information: General, non-clinical information about care needs and living situation used to pre-screen eligibility for the Michigan Home Help Program. This information does not include medical records, diagnoses, treatments, prescriptions, or any other Protected Health Information (PHI).
• Caregiver Information: Relationship to the care recipient and caregiver contact details.
• Employment-related information: If you work for us as a caregiver, 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.
• Account information: If you work for us as a caregiver and create an account on our mobile or web applications 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, we may also invite you to provide additional information about yourself.
• Financial information: If you work for us as a caregiver, 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 us, 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.
• Audio, electronic, visual, or similar information: We may collect 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.

b. Personal data collected automatically

We may use cookies and other tracking technologies such as web beacons, embedded scripts, and tags (collectively, "Cookies") which collect information from you automatically as you use our Services, including: (i) browser and device data, 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 Services you are visiting; and (ii) usage data, such as geolocation data, browsing history, time spent on the Services, pages visited, links clicked, language preferences, and patterns of use. Please review Section 7 below for more information about our use of these technologies.

c. Personal data we collect from others

We may also collect information from the following sources:

• Service providers — including hosting, analytics, customer and technical support, email services, and other services.
• Corporate affiliates — including our current and future parent companies, affiliates, subsidiaries, and other companies under common control and ownership.
• Other third parties — including business and marketing partners, ad network providers, advertisers, and analytics companies.
• Government entities — including to provide employee benefits and services.
• Other individuals — including employees, contractors, and patients.

We may combine the personal data we receive from these sources with personal data we otherwise collect about you through your use of our Services.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To process and submit your Michigan Home Help Program application;
• To communicate with you about your application status and to provide you with updates and other information relating to our Services;
• To provide customer support;
• To provide, operate, maintain, improve, and expand our Services;
• For internal business purposes;
• To perform internal analytics;
• To market our Services, including through targeted advertising initiatives;
• To prevent unauthorized, improper, or illegal activities on our Services;
• For systems and data security;
• For workforce management and planning (such as performance reviews, evaluations, and internal investigations);
• For administering payroll, employee benefits, and health insurance;
• To comply with legal obligations, including responding to subpoenas, court orders, or legal process; and to establish or exercise our legal rights or defenses against legal claims;
• To evaluate or conduct 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 our customers is among the assets transferred; and
• For purposes disclosed at the time we collect the information, or as otherwise set forth in this Privacy Policy, or for any other legal purpose not inconsistent with this Privacy Policy.

4. Disclosure of Information

We may disclose your information to the following:

• Government agencies — as necessary to process your Michigan Home Help Program application.
• Service providers — who provide services on our behalf, such as hosting, customer and technical support, analytics, marketing, and other services, and who are subject to confidentiality obligations.
• Corporate affiliates — including our current and future parent companies, affiliates, subsidiaries, and other companies under common control and ownership, in order to provide our Services and for internal business purposes.
• Third-party platform providers — including advertising, social media, and analytics companies, who assist us in serving advertising regarding the Services to others who may be interested. For example, if you visit the Services while logged into social media or other third-party platform accounts, the platforms may collect information about your interactions with the Services, such as browser/device data and usage data, including through Cookies on our Services. We may also partner with third parties 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.
• Authorities for compliance and harm prevention — when required by law, regulation, or legal process, and/or in response to a threat of harm involving an individual's health and/or safety.
• Professional advisors — including lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us.
• Business transferees — if we or our affiliates are involved in a merger, acquisition, asset sale, or other corporate combination, personal data may be transferred to the acquiring or surviving entity.
• Other parties — with your consent.

5. Data Security

We use industry-standard security measures to protect your information, including encryption, secure servers, and access controls. However, no method of transmission over the Internet is completely secure, and we cannot guarantee absolute security.

6. Data Retention

We retain your information for as long as necessary to provide our Services, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Our determination of precise retention periods will be based on: (a) the length of time we have an ongoing relationship with you; (b) whether there is a legal obligation to which we are subject; and (c) whether retention is advisable given our legal position, including regard to applicable statutes of limitations, litigation, or regulatory investigations.

7. Cookies

As mentioned above, we use Cookies to collect and track information, improve and analyze our website, and promote content and services that relate to your interests. You can manage cookie preferences through your browser settings. Cookies that we use generally fall into the following categories:

• Strictly Necessary Cookies: These are required for the operation of our website.
• Functional Cookies: These improve the functional performance of our website and make it easier for you to use.
• Performance/Analytics: We may use Cookies that are useful to assess the performance of our website, including as part of our analytic practices or otherwise to improve our Services. For example, we may use PostHog or other service providers for analytics services. These analytics services may use Cookies to help us evaluate your use of the website, compile statistic reports on the website's activity, and to provide us other services relating to the website's activity and other Internet usage.
• Targeting/Advertising: We may use Cookies placed by third-party advertising platforms or networks to deliver ads and track ad performance, enabling advertising networks to deliver ads that may be relevant to you based upon your activities (sometimes called "targeted advertising") on the website.

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer's online activities over time and across third-party websites or online services (e.g., browser "Do Not Track" signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms, unless otherwise required by applicable law.

8. Children's Privacy

Our Services are not intended for children, and we do not knowingly collect any personal data from children under the age of 18. If you are a parent or guardian and you are aware that a child has provided us with personal data, please contact us, and we will take steps to remove that information from our servers.

9. International Transfers

Your personal data may be transferred and maintained outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Our Services are operated in, and are intended only for individuals in, the United States. If you are located outside of the United States and choose to provide information to us, please note that we transfer personal data to the United States and process it there. For such transfers, we take the necessary measures to ensure that your personal data receives an adequate level of protection.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices or relevant laws. We will let you know of material changes consistent with applicable law, and will update the "last updated" date at the top of this Privacy Policy. Changes will be effective upon posting with an updated date. We encourage you to review this policy periodically.

11. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact: