Privacy Policy

Welcome! This Privacy Policy explains how Twomagnets LLC dba Clipboard Health (“Clipboard,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes Personal Information (as defined below) in connection with our Clipboard websites (the “Site”), the Clipboard desktop/mobile applications (collectively, the “Clipboard App”), and the related content, products, services, and other functionality offered on or through the online services (collectively, the “Services”). It does not address our privacy practices relating to individuals employed directly by Clipboard or applicants for employment with Clipboard.

A user of the Services is hereinafter referred to as a “User,” or collectively, the “Users.” Users can include individuals such as website visitors, professionals seeking shifts (“Professionals”) and representatives of facilities or agencies seeking talent (“Facilities”). Professionals are independent contractors who use the Clipboard marketplace to find and book shifts of their own choosing. Professionals are not employed by Clipboard.

In certain instances, when medical Facilities or healthcare agencies use our Services to submit, manage, or otherwise process protected health information, we have contractually agreed to act as a “Business Associate” under the Health Insurance Portability and Accountability Act and only process such information on behalf of and under the instruction of the respective Facility or agency, who is the “Covered Entity”. This Privacy Policy does not apply to such processing, and we recommend you contact the Covered Entity with any questions regarding the processing of your protected health information.

What Is Personal Information?

When we use the term “Personal Information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Clipboard’s Collection of Personal Information

Sometimes we collect Personal Information automatically when an individual interacts with our Services, and sometimes we collect the Personal Information directly from an individual. At times, we may collect Personal Information about an individual from other sources, even before our first direct interaction with that individual.

Personal Information Collected from You Directly

We may collect the following Personal Information from you directly:

• Contact Information, including your name, your employer’s name (if applicable), address, phone number, email address, and communications preferences.
• Inquiry Information, including information provided in custom messages sent through our Site. We also may collect your information when you sign up to receive information or notifications from us.
• Professional Information, including name, email address, address, zip code, phone number, licensing information, Social Security Number, date of birth, gender, driver’s license number and information, other government-issued identification documents and numbers, taxpayer identification number, background check (including criminal history-related) information, the results of federal and state exclusion list screening (such as the OIG List of Excluded Individuals/Entities and the System for Award Management), physical and health-related information, COVID-19 screening and vaccination information, immunization records, tuberculosis screening results and other health screening records Facilities require, records verifying skills and competencies Facilities require, profile information including but not limited to preferences relating to shifts and facilities, professional information including prior roles, videotape, film, record, photograph, voice, or all related instrumental, musical, or other sound effects, selfie images and facial geometry derived from those images that we use to verify your identity and detect impersonation, account login credentials, bank account and payout information, records of the agreements and disclosures you have accepted, information you provide on boards or in chats, and any other information provided to us during your account sign-up process or through our Services. You may also choose to provide race, ethnicity and place of birth; we do not use this information to infer characteristics about you. Please note we utilize the third-party providers, including but not limited to Stripe, Invoiced, and Fazeshift, to process payments on our behalf. We also use third-party accounts-receivable, collections, billing and enterprise resource planning providers, and the payment processors they rely on, in connection with Facility billing. These vendors may collect and store personally identifiable financial information on our behalf. In addition, we may store or view data associated with your account stored by these vendors, which may include the last four digits of your credit card, debit card and/or bank account number. To view Stripe’s privacy policy, please visit: https://stripe.com/privacy. To view Invoiced’s privacy policy, please visit: https://www.invoiced.com/legal/privacy. To view Fazeshift’s privacy policy, please visit: https://www.fazeshift.com/privacy-policy.
• Facility Information, including facility/company name, related entities’ names, names of facility representatives, those representatives’ positions, address, email address, phone number, profile information, billing and payment information, in app chats, information about the Facility’s own personnel and schedules that the Facility chooses to upload to or maintain in the Services, and any other information provided to us during your account sign-up process or through the Services.
• Survey and Testimonial Information, including information provided in any questions submitted through surveys, or content of any testimonials. This includes responses to screening questionnaires about your experience and qualifications, which may be used to determine eligibility for certain types of shifts.
• Emergency Contact Information, including the name, relationship to you, and phone number of a person you designate to be contacted if you experience an emergency during or in connection with a shift. Providing this is your choice. We use it only for that purpose and, as described below, may share it in an emergency.
• Content You Share with Other Professionals, including reviews you write about workplaces, posts, photographs, videos, comments and profile content you submit to community features of the Clipboard App, pay information you choose to report for the benefit of other Professionals, and the rates you submit when bidding on a shift.
• Any Other Personal Information You Choose to Provide.

Clipboard may also collect and store certain data about your use of the Services on an aggregate and/or de-identified basis.

Personal Information Automatically Collected

As is true of many websites, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, such as the list below and in the sub-sections here:

• Device Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services). Device Data may overlap with the other categories of data below.
• Analytics Data, including the path taken to our Services, through our Services, and when exiting our Services, usage and activity on or in connection with our Services, metrics on how many emails we send are actually opened and which attachments or links are opened, clicked, or viewed (such as via pixels, as described further below).
• Location Data of Professionals, including precise and coarse geographic location information, which we and/or our third-party providers collect, once enabled by the permissions setting on your device. This includes location information leading up to the start of shifts you book, between when you arrive at and leave those shifts, shortly after the shift ends, and when you search for shifts near you. During the two-hour period before a booked shift, Clipboard actively tracks your location in order to predict when you will arrive, whether you will be on time for that shift, and to detect no shows. We share our prediction, as well as a map showing your geographic location up to two hours before your shift, with the Facility with which you booked the shift, including the Facility’s employees and independent contractors, and will also notify the Facility if/when it appears that you are on your way to the Facility, are nearby the Facility, and have arrived at the Facility. We will provide you with an “Update ETA” notification if it appears you will not be on time. If you fail to confirm your attendance in response to that notification, we will enable booking of that shift on an Urgent Shift basis by another Professional and cancel your shift as soon as another Professional successfully books the Urgent Shift. Additionally, based on this location data and other information, we may decide you cannot make the shift or are running too late, and will give up your shift. Further, up to 24 hours before a booked shift, if you open the Clipboard App, we initiate passive tracking, which may provide us with location information as frequently as every two hours. Passive tracking helps us ensure that active tracking is able to start on time, i.e. two hours before your booked shift. We also use location data gathered when you arrive at and leave your shifts to verify the completion of those shifts in order to distribute your earnings via InstantPay. Even if you are unassigned from the shift during your commute, Clipboard may keep collecting your location information, for up to four more hours or up until the end of the shift or shortly thereafter, to make sure any arrivals to the workplace are still recorded. This helps protect your account in case you were wrongly unassigned from the shift. We also use location data from your device in order to show you nearby shifts. We may also use location information to generate mileage summaries that you may use for your own tax purposes. We may share your location information with third party service providers in order to provide these services. You may change the Clipboard App’s access to your location information at any time through your “Settings” app on your device. However, if you do not enable “Always” and “Precise Location” permissions, many important features of the Clipboard App will be unavailable to you, including your ability to access the marketplace, book shifts, receive payments through InstantPay, and see nearby Urgent Shifts. For more information, please see the Control Over Your Information section below.
• Advertising/Advertising Measurement Data, including data associated with your view of, or click on, advertisements served on our Services, cookie IDs or other digital or proprietary identifier (e.g., iOS IDFA, Google AAID) assigned to such device, and device metadata, analytics data, and location data described above, in each case, for purposes of serving advertising (personalized or otherwise) or facilitating advertising measurement/attribution to better optimize or otherwise understand the effectiveness of ad campaigns. For more information on our and third-party partners’ data collection and online advertising practices, please see the Third-Party Data Collection and Online Advertising section below.
• Cookies and Other Technologies. Like many websites, we and our third-party providers may use “cookies” that our Services use to collect and store information about Users. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We and our third-party service providers may also use other tracking technologies, such as “pixel tags,” “web beacons,” “clear GIFs,” SDKs, location-identifying technologies, or similar means in connection with the Services and HTML-formatted email messages to, among other things, track the actions of Users and email recipients and to automatically collect the Personal Information described in this section (and otherwise expanded upon in other sections). See the Control Over Your Information section below to learn more about how you may limit or disable cookies or certain other tracking technologies on your device.
• Analytics Tools. We use analytics tools, including Datadog, which may record screens that you visit in the Clipboard Applications and pages you visit on our Site, your interaction patterns with the Clipboard Applications (such as screen actions, gestures, taps, and scrolls), errors, and your device’s details (such as type, version, model, operating system). We use this information to improve the Clipboard Applications and Services. The analytics tools store and process the information on our behalf, which may include personally identifiable information. The analytics tools will not record or otherwise track your device usage outside of the Clipboard Applications or our Site.
• Near-Field Communication (“NFC”) Tag Interactions. When certain facilities request this service, we provide them with NFC tags, which those facilities may require you to tap with your device when starting and ending a shift or break. When you tap one of our NFC tags, we collect a unique identifier associated with that NFC tag, which allows us to infer the location of your device based on the known location of the NFC tag. Like geolocation data collected directly from your device, we use data from NFC tag interactions to verify your completion of shifts in order to distribute your earnings via InstantPay.
• Timekeeping Data, including the times you record starting and ending a shift or break, records generated when you check in through a kiosk or scan a code at a Facility, the hours reflected on timesheets, and, where a Facility requires it, short video you record of yourself clocking in or out. We use this information to verify shift completion, to distribute your earnings, and to produce the records Facilities need for their own timekeeping and reporting.
• Communications Content, including the content of messages you exchange with Facilities and with our support teams through the Clipboard App, text messages, and calls with our support teams. Calls with our support teams may be monitored or recorded where permitted by applicable law. We review message content to provide support, to identify shift cancellations and scheduling changes, to make credential information you send us usable in your account, and to maintain the safety and security of the marketplace.

Note that we and our third-party partners may combine information that each of us collects automatically with other information about you, including information you choose to provide.

Personal Information Collected Through Other Sources

We also obtain Personal Information from third parties, which we often combine with Personal Information we collect either automatically or directly from you. For example, we may receive the same categories of Personal Information as described above from the following third parties:

• Your Employer / Company: When an individual interacts with our Services as an employee or representative of their company, we may receive their information from their employer or other employees at their company.
• Other Users: When you interact with other Users on the Services we may receive information you choose to share with them. For example, if you send a direct message to another User, we may receive the information in the message. We also may receive ratings and comments from other Users. For example, we receive Professional ratings from Facilities after shifts are completed.
• Facilities: Facilities provide us information about Professionals, including ratings, written endorsements and warnings, designations indicating that a Professional should not return to that Facility, assessments of skills and competencies the Facility requires, and reports of safety or conduct incidents the Facility says occurred at its site.
• Government and Regulatory Sources: We receive information from federal and state government sources, including licensing boards and federal and state exclusion lists such as the OIG List of Excluded Individuals/Entities and the System for Award Management.
• Clipboard Marketplace Sign-Up-Related Third Parties: When you sign up for a Professional account to access Clipboard’s marketplace or seek a shift through Clipboard’s marketplace, we may receive Personal Information from related third parties, such as websites and platforms containing information about Clipboard and opportunities to find shifts through our marketplace, references, background check providers, and recruiters.
• Licensing and Certifications: We may receive information from third parties in order to verify your licenses or certifications.
• Referrals: We may receive your information through our Refer a Coworker Program. For example, when a User refers you to Clipboard, we receive your contact information.
• Social Media: When you interact with our Services through various social media networks, such as when you log in through a social network, “Like” us on Facebook or follow us or share our content on Google, Facebook, Twitter, or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
• Service Providers: Our service providers that perform services solely on our behalf, such as payment processors, background check and credentialing vendors, or surveys and certain advertising/marketing providers, collect Personal Information and may share some or all of this information with us.
• Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement Personal Information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual or obtain demographic information (e.g., preferences).
• Other Sources: We may also collect Personal Information about you that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.

Only authorized Clipboard staff have access to your Personal Information in its entirety. Other staff may have access to portions of this information if it pertains to their job duties.

Clipboard’s Use of Personal Information

Clipboard uses Personal Information for the following general purposes:

• to fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to provide our products and the Services, and to process transactions,
• to manage our organization and its day-to-day operations,
• to determine whether you may sign up for an account to access Clipboard’s marketplace as a Professional or Facility,
• to verify your identity, including through biometric identity verification where you have consented to it, and to detect impersonation,
• to verify the licenses, certifications, screenings, skills and competencies Facilities require of Professionals who book their shifts,
• to request individuals to complete surveys about our organization, organizations we partner with, Facilities, and the Services,
• to facilitate promotions, contests and sweepstakes,
• to offer incentives to Users in the marketplace,
• to determine whether Professionals will arrive on time to booked shifts, and whether they are at the Facilities during shifts,
• to suggest and display nearby available shifts,
• for billing, payment, identification and authentication, and fraud prevention,
• to prepare and file tax information returns, and to make tax records available to you,
• to identify and analyze how individuals use our Site and Services and to conduct research and analytics on our User base and our Services,
• to improve and customize our products and the Services to address the needs and interests of our Userbase and other individuals we interact with,
• to develop, test, monitor and improve the automated processes,
• to communicate with you, including via email, text message, social media and/or telephone calls, and to deliver administrative notices and communications relevant to your use of our products and the Services,
• to market our Services to individuals, including through email, direct mail, phone or text message,
• to administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Site,
• to facilitate User benefits and services, including customer support through our command center services,
• for internal market research,
• to test, enhance, update and monitor the Services, or diagnose, fix or troubleshoot technology problems,
• to help maintain the safety, security and integrity of our property and Services, technology assets and business,
• to receive, route and investigate reports of safety or conduct incidents,
• to contact, or enable a Facility, emergency responders or medical personnel to contact, the emergency contact you have designated, if you experience an emergency during or in connection with a shift,
• to detect, investigate, provide notice of or protect against error, fraud or other unlawful or criminal activity,
• for distribution to third-party contractors that provide services to Clipboard and partners of Clipboard,
• to comply with legal obligations,
• to retain records where a law, regulation, licensing requirement or registration obligation applicable to us requires us to keep them,
• to defend, protect or enforce our rights or applicable contracts and agreements, including our Terms of Service, and
• as otherwise set forth in this Privacy Policy.

Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry/request and/or Personal Information we require fall outside the scope of this Privacy Policy. In that case, the additional privacy disclosures will govern how we may process the information provided at that time.

Clipboard’s Disclosure of Personal Information

We disclose Personal Information in the following ways:

• Affiliates: We may share Personal Information with other companies owned or controlled by Clipboard, and other companies owned by or under common ownership as Clipboard, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
• Facilities with which You Book a Shift: We may share information about your geographic location with Facilities in the manner described under “Location Data of Professionals,” above. In addition, we may share the following with a Facility at which you have booked a shift:
  • identity and contact information, including your name, profile photo, any worker video clips you have provided, postal address, email address, phone number, gender, and date of birth;
  • government-issued identification documents and identification numbers, including images of those documents where a Facility requires them;
  • your professional licenses, certifications and qualifications, badges indicating that your credentials and screenings have been verified, and the status of skills and competency verifications the Facility requires;
  • your background check results and the results of federal and state exclusion list screening;
  • health and screening records the Facility requires, including physical examination results, tuberculosis screening and chest X-ray results, immunization records, and COVID-19 screening and vaccination information;
  • your prior professional roles and work history, and your shift and facility preferences and availability;
  • do not return history and related information;
  • records of your activity in connection with that Facility, including shifts booked, transferred and cancelled, arrival and departure times, timekeeping punches, kiosk and NFC check-ins, timesheets, and any timeclock video the Facility requires;
  • the rate applicable to a shift and the amounts payable for it;
  • messages you exchange with that Facility through the Clipboard App, and reports of safety or conduct incidents relating to your shifts at that Facility;
  • credentials so that you can use charting or electronic health record systems the Facility uses; and
  • in limited circumstances, your Social Security number or taxpayer identification number.

The categories above describe what we may share; what is actually shared depends on the Facility, the shift, and what the Facility is required to collect.

We limit sharing of Social Security numbers and taxpayer identification numbers with Facilities to circumstances where the Facility reasonably needs the information to identify you, or to meet a reporting requirement or other legal obligation that applies to it. Where the Facility does not need the full number, we mask all but the last four digits, and where the number is not needed at all we mask it entirely.

If you have provided emergency contact information, we may share your emergency contact’s name, relationship to you and phone number with a Facility, with emergency responders, or with medical personnel, where you experience a medical emergency, injury or other health event during or in connection with a shift, or where doing so is otherwise necessary to protect your health or safety.

• Facilities in General: We may share the following Personal Information with facilities in general, even if you have not booked a shift with them: your name, your profile photo, any worker video clips you have chosen to provide us with, your total number of completed shifts, your licensure, qualifications, and other information provided at sign-up, your background check results, your attendance rate (which we calculate based on your numbers of booked and canceled shifts), and the average rating you have received from Facilities. We may also share the following with Facilities in general: your date of birth; badges indicating that your credentials, licenses and screenings have been verified, and the status of skills and competency verifications; your prior professional roles and work history; your shift and facility preferences and your general availability; your approximate location, or your distance from the Facility; do not return history and related information; written endorsements or warnings that other Facilities have submitted about you, which may include the number of Facilities that have endorsed you and the text of those endorsements; and reviews you have written about workplaces.
• Timekeeping and Workforce Management Platforms: Where a Facility uses a third-party timekeeping, scheduling or payroll platform, or asks us to transmit labor files to a recipient it designates, we may disclose Professional identity, shift, hours-worked and rate information to that platform or recipient so the Facility can maintain its own records and satisfy reporting obligations that apply to it.
• Insurance Providers: We may disclose Professional information and shift information to providers of per-shift occupational insurance coverage that Facilities require.
• Tax Authorities: We disclose taxpayer identification numbers and earnings information to the Internal Revenue Service and to state tax authorities, and to the providers that prepare and file information returns on our behalf, as required for tax information reporting.
• Survey, Contest and Sweepstakes Providers, Sponsors and Partners: We may share Personal Information with third parties who assist us in delivering our survey offerings and processing the responses. We also may share information with our contest, sweepstakes and other promotional providers and partners. Some Clipboard content is “sponsored by” or “presented by” other companies. Clipboard shares market research data (how the sponsorship performed, names of contest winners, etc.) collected on this Site, the Services, or via email surveys with these partners. This information is usually in aggregate form. Partners may sponsor promotions, contests and sweepstakes that require you to reveal details such as your name, address or phone number. Always check their privacy policy before revealing information about yourself. If you don’t want these sponsors to have your Personal Information, you can choose to not participate.
• Your Employer / Company: When an individual interacts with our Services as an employee or representative of their company, we share their information with their employer or other employees at their company.
• Other Users: We may share your Personal Information with other Users. For example, if you are a Professional who signs up for a shift at a Facility, we may share your information with that Facility, or with other Professionals who booked shifts at that Facility. Additionally, we may share the Personal Information and shift booking activity of Professionals with other Professionals, including via our Work with Friends feature. Where you choose to use community features of the Clipboard App, the content you post, including reviews you write about workplaces, posts, photographs, videos and comments, and pay information you choose to report, may be visible to other Professionals. For more information about how to disable sharing with other Professionals via Work with Friends feature, please see the Control Over Your Information section below.
• Marketing Providers: We coordinate and share Personal Information with our marketing providers in order to communicate with individuals about the Services we make available. Phone numbers collected with SMS consent, will not be sold, rented, or shared with third parties or affiliates other than the aggregators and providers necessary to deliver our text message services.
• Customer Service and Communication Providers: We share Personal Information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
• Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as payment processing, website hosting, infrastructure provisioning, IT services, analytics services, administrative services, and background check and credentialing vendors. We use third-party technology providers, including automated services, to process documents, images, video and message content in connection with identity verification, credential and document review, content review, safety and customer support.
• Advertising and Analytics Partners: We may share certain information, including disclose online identifiers, device and advertising identifiers, IP address, information about your activity on our Site and apps, and inferences drawn from that information to advertising publishers, advertising networks and analytics and measurement providers, so that they can deliver advertising to you on and off our Services and measure how that advertising performs.
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Information may also be disclosed in the event of insolvency, bankruptcy or receivership.
• Legal Obligations and Rights: We may disclose Personal Information to third parties, such as legal advisors and law enforcement:
  • if required by law or if we are given reason to believe, in our sole discretion, that someone is causing injury to or interference with the rights of Users, the general public, or Clipboard,
  • to comply with a judicial proceeding, court order, legal process, or response to a regulator,
  • in connection with the establishment, exercise, or defense of legal claims,
  • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies,
  • to detect, suppress, or prevent fraud,
  • to protect the health and safety of us and others, or
  • as otherwise required by applicable law.
• Otherwise With Consent or Direction: We may disclose Personal Information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Site or service-related publications.

Notwithstanding the categories of disclosure listed above, text messaging originator opt-in data and consent will not be shared with any third parties, excluding the aggregators and providers necessary to deliver our text message services.

Other than as described in this Privacy Policy, we will not disclose Personal Information specifying your health condition, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership without your consent or unless required by applicable law.

Third-Party Data Collection and Online Advertising

General

We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on Personal Information and to measure the effectiveness of those ads. We permit third-party online advertising networks or exchanges (or other entities, such as demand-side or sell-side platforms or ad servers), measurement/attribution companies, ad fraud companies, social media companies, and other third-party services to collect information about your use of our online services so that they may display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including clickstream information, browser type, time and date you visited the Sites, mobile ad ID or other digital identifier (e.g., iOS IDFA, Google AAID, cookie ID, click ID, other proprietary IDs such as open source “universal IDs” or other ID solutions) precise or coarse geolocation, and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, analytics, market research, and measurement/attribution. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. For example, we may do this by providing your email address (typically in hashed format) or other information (such as phone number, which also is typically provided in hashed format) to the platform provider, such as via API, direct file upload, server-to-server transfer, or integrating the tracking technologies of those platform providers (e.g., pixel). Please see the Control Over Your Information section below to learn how you can opt out of interest-based advertising.

Social Media Platforms and Advertising

Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter, or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media forums. For example, these companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. As mentioned in the section above, we may share a unique identifier, such as a user ID or hashed email address or phone number, with these platform providers or they may collect information from our website visitors through a pixel (or other mechanism, such as API, direct file upload, or server-to-server integration), in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.

Control Over Your Information

You may control your information in the following ways:

Choice/Opt-Out of Communications

General

You may opt-out of receiving communications from us and our partners, remove your information from our database, and choose to not receive future communications unrelated to the Services.

During the account sign-up process you will be automatically subscribed to receive correspondence from either Clipboard or its partners, but will be provided with the option to opt out of receiving such correspondence. This information remains on your profile. You can reach out to Clipboard Support anytime through the Support page to update your contact information and notification preferences. If you enroll with Clipboard, we may occasionally contact you with information about special events, activities, promotions, contests, submission opportunities and programs. You always have the option to ask Clipboard not to contact you with this information again.

Email Communications Preferences

If you no longer wish to receive marketing or promotional emails from us, you can click the “unsubscribe” link in the latest email you receive from us.

Telephone Calls and SMS Text Messaging

We may use Personal Information we collect to communicate with you via text message and telephone calls, including (with your consent) to market to you or offer you information and updates on products or services we think you may be interested in. You can unsubscribe from marketing calls or text messages at any time by replying STOP or clicking the unsubscribe link (where available) in one of our messages. Any information obtained as part of SMS consent will not be shared with third parties or affiliates. For more information, please see our Terms of Service.

Edit Your Information

You have the ability to edit your Personal Information. To update your Personal Information, please do so in the Clipboard App. So that we can protect the integrity of sensitive data, there are certain pieces of information, such as your age, that you cannot alter yourself. Please contact us through the Support chat in the Clipboard App, or through our Support page, to find out how to change information you cannot access through your account, or if you have any other questions. If you are a Professional, you may request a correction directly in the Clipboard App through Support chat, and we will correct the information or explain why we cannot. Our databases automatically update any Personal Information you edit in your profile, or that you request we edit. Information transmitted through boards, chats, polls or through any other means remains in our databases and becomes the property of Clipboard upon submission.

Access to Your Device Information

You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your network devices and geolocation and to integrate with your other applications. Withdrawing access to certain device information will affect the features and functionality of the Services, and may inhibit our ability to provide you with the Services you have requested. For example, if you do not grant the Clipboard App “Always” and “Precise Location” permissions with respect to your device’s location data, many important features will be unavailable to you, including the ability to access the marketplace, book shifts, receive payments through InstantPay, and see nearby Urgent Shifts.

Deleting Your Account or Information

If you are a Professional and would like to delete your account and/or delete your record in our system, you may submit your request by signing into your account on the mobile app, navigating to “Account,” and following the instructions to “Delete My Account” at the bottom of the page. We may ask you to verify your identity before we process your request. In certain circumstances, we may not be able to respond to your request if we are not able to verify your identity or authority to make the request.

When you close your account, your deactivated status will be reflected promptly in our user databases and you may no longer be able to access your information. For approximately 30 days after you ask us to delete your account, we deactivate it and hold it in a suspended state before deletion is completed. This gives you a window to restore the account if you change your mind or if the request was made in error. During that period your account cannot be used to book shifts. When the window closes, we delete or deidentify your Personal Information except for the categories described below.

After the deletion window closes, we may retain certain Personal Information where permitted or required by law, including where retention is reasonably necessary for one of the following purposes: fraud prevention and identity resolution; legal claims and litigation holds; insurance; tax and information reporting; consumer reports; state licensing and registration; contract obligations; completing transactions or providing requested services; health record requirements; trust and safety; and/or security purposes.

Cookies and Tracking Technologies

If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. You can also manage your cookie preferences using the cookie banner preference tool available on our Site. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services.

Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Sharing with Other Healthcare Professionals

If you are a Professional and do not want your Personal Information and shift booking activity shared with other Professionals via our Work with Friends feature, you may disable such sharing by opening the Clipboard App, then tapping “My Account” in the bottom right corner, then tapping “Profile,” then turning on “Hide me as a colleague on shifts.”

Online Ads

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising (to the extent the advertising partner or other entity participates in such industry opt-out pages), you may wish to visit the Digital Advertising Alliance’s (DAA) resources or the Network Advertising Initiative’s (NAI) online resources, at https://optout.aboutads.info or https://optout.networkadvertising.org. You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting https://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from these self-regulatory program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs, or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under those self-regulatory programs.

How Long We Keep Personal Information

We keep Personal Information for as long as it is reasonably necessary for the purposes described in this Privacy Policy, and then delete it or maintain it in deidentified form.

Children’s Personal Information

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any Personal Information either directly or by other means. If a child under the age of 13 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Information from our systems. If we learn that any Personal Information we collect has been provided by a child under the age of 13, we will promptly delete that Personal Information. We also don’t knowingly sell or share personal information of children under the age of 16.

Links to Third-Party Websites or Services

Our Site and Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy policies.

Updates to this Privacy Policy

This Privacy Policy may be periodically reviewed and updated at Clipboard’s discretion, including as Clipboard expands and/or modifies the Service. We review this Privacy Policy at least once every twelve months. Clipboard will endeavor to notify you of these changes by email, but will not be liable for any failure to do so. Use of our Service after an update to this Privacy Policy constitutes consent to the updated terms to the extent permitted by law. Clipboard encourages you to review this Privacy Policy regularly, and if you do not understand any of its terms or conditions, you may inquire regarding the same via email at privacy@clipboardworks.com.

State-Specific Disclosures

We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

• Nevada: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Please contact us at privacy@clipboardworks.com to submit such a request.
• California: If you are a resident of the State of California in the U.S., please see the California Privacy Supplement at the end of this Privacy Policy for additional California-specific privacy information.

Users From Outside the United States

Clipboard and its Services are based in the United States. Please be aware that your information may be processed and transferred to the U.S. and be subject to U.S. law. The privacy and data protection laws in the U.S. may not be equivalent to such laws in your country of residence. By using the Site, participating in any of the Services, or by providing Clipboard with your information, you understand your Personal Information may be transferred to, stored in, and processed in the U.S.

How to Reach the Clipboard Team

If you have technical problems, questions, or other issues related to Clipboard, or the Services, please click “Contact Us” at the bottom of any page of this website.

If you have any questions about this Privacy Policy or the privacy practices of Clipboard, you may contact us at privacy@clipboardworks.com or by telephone at (408) 837-0116.

California Privacy Supplement

Effective Date and Scope

Last Updated August 31, 2026. This California Privacy Supplement forms part of, and supplements, the Privacy Policy above. It applies solely to residents of the State of California and describes how Twomagnets LLC dba Clipboard Health collects, uses, discloses and otherwise processes Personal Information within the scope of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (the “CCPA”). Unless otherwise stated, terms used here have the meaning given in the Privacy Policy above or in the CCPA.

This Supplement does not apply to protected health information that Clipboard processes as a “Business Associate” on behalf of a Facility or healthcare agency acting as a “Covered Entity”.

Categories of Personal Information We Collect and Disclose

The table below shows the categories of Personal Information we may have collected about California residents in the preceding twelve months, and the categories of recipients to whom we may have disclosed each category for a business or commercial purpose. The sources we collect each category from are described under “Clipboard’s Collection of Personal Information” above, and the purposes are described under “Clipboard’s Use of Personal Information” above. The examples given are illustrative and not exhaustive.

Each category above is described further, with examples of the specific data elements it includes, in the “Clipboard’s Collection of Personal Information” section of the Privacy Policy above.

For the purposes of the table above:

• “Other Professionals and Facility users” includes, for example, Facilities at which you have booked a shift, Facilities browsing the marketplace, and other Professionals who work at the same Facility or with whom you have chosen to share information.
• “Our service providers and contractors” includes, for example, providers of hosting and infrastructure, payment processing, identity verification, background screening, credential review, communications, customer support, analytics and document processing.
• “Our advertising and analytics partners” includes, for example, advertising publishers, advertising networks, social media platforms and providers of measurement and attribution services.
• “Other third parties” includes, for example, Facilities and the timekeeping, scheduling and payroll platforms they use, occupational insurance providers, tax authorities, government agencies and regulators, professional advisors, and parties to whom you direct us to disclose information.

“Professional or employment-related information” is a statutory category name in California law. In Clipboard’s case it refers to the professional licensing, certification and credentialing information of independent contractors who use the marketplace, and to the business contact information of Facility representatives. It does not indicate that any Professional is employed by Clipboard.

Categories of Personal Information Sold or Shared, and the Third Parties Receiving It

In the preceding twelve months we may have “sold” or “shared” the following categories of Personal Information with third parties for the purpose of cross-context behavioral advertising or analytics:

• Identifiers;
• Commercial information;
• Internet or other electronic network activity information; and
• Geolocation information.

We may have sold or shared each of those categories with the following categories of third parties:

• Advertising publishers that place advertisements on our behalf;
• Advertising networks and partners that place advertisements on behalf of other advertisers; and
• Providers of statistical, analytics and measurement information regarding the effectiveness of our marketing and advertising.

In the preceding twelve months we may have disclosed each of the categories of Personal Information described in the table above to the categories of recipients identified in that table for a business purpose.

Children’s Data

Our services are not directed at children under the age of 13, and we do not knowingly collect personal information from such children. We also do not knowingly sell or share the Personal Information of children under 16 years of age.

Sensitive Personal Information

To the extent that we use or disclose sensitive Personal Information as defined by California law, we do so only in order to provide the Services and for other purposes permitted by California law, including to verify identity and detect impersonation, to meet the credentialing and eligibility requirements Facilities impose, to process payments, to prevent and detect security incidents and fraudulent or illegal activity, to verify shift completion, to perform research and analysis, and to maintain the safety and quality of the marketplace. We do not sell or share sensitive Personal Information for the purpose of cross-context behavioral advertising.

Retention

We keep Personal Information for as long as it is reasonably necessary for the purposes described in this Privacy Policy, and then delete it or maintain it in deidentified form.

Your California Privacy Rights

Subject to certain limits at law, California residents have the following rights:

• Right to know and access. You have the right to know what Personal Information we have collected about you, including the categories and sources it came from, the business or commercial purposes for collecting or sharing it, the categories of third parties to whom we disclosed it, and the specific pieces of Personal Information we hold about you.
• Right to correct. You may request that we correct inaccurate Personal Information we hold about you.
• Right to delete. You may request that we delete Personal Information we collected from you, and direct our service providers and contractors to do the same. Certain information may be retained after deletion as further described under the “Deleting Your Account or Information” section above.
• Right to opt out of sale or sharing. You may direct us not to sell or share your Personal Information for cross-context behavioral advertising.
• Right to non-discrimination. We will not discriminate or retaliate against you for exercising any of these rights.

Please note that if exercising a right limits our ability to process Personal Information, for example, if you ask us to delete it, we may no longer be able to provide you the Services or engage with you in the same way.

How to Exercise Your Rights

To exercise your right to know, access, delete or correct your Personal Information, you may:

• If you are a Professional, message us through the Support chat in the Clipboard App;
• Submit a request through our Support page; or
• Call us at (408) 837-0116.

Professionals may also update or correct much of their Personal Information directly in the Clipboard App, and may delete an account in the app as described under “Deleting Your Account or Information” above. You may opt out of the “sale” or “sharing” of your Personal Information for cross-context behavioral advertising through the Do Not Sell My Personal Information opt out mechanism. If you enable a browser-based opt-out preference signal that complies with California law, such as the Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sharing of personal information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each one that you use.

Only you, or someone legally authorized to act on your behalf, may make a request relating to your Personal Information. Before we act on a request to know, delete or correct, we need to verify your identity and confirm you are a California resident. We will generally do this by authenticating your account, or by matching information you give us against information we already hold. This may mean asking you for additional information, such as your email address, phone number, or the date of your last transaction on the Services. If we cannot verify your identity or authority, we may be unable to respond to your request.

An authorized agent may submit a request on your behalf. For requests to know, delete or correct, we require either a power of attorney valid under California law, or evidence that you gave the agent signed permission to act for you together with verification of your own identity directly with us. For a request to opt out of sale or sharing, we may ask the agent to show that you gave permission to submit the request.

Financial Incentives

We may offer financial incentives for the collection, retention, sale or use of Personal Information as permitted by the CCPA, which can result in different prices, rates or quality levels. The material terms of any incentive will be described in that program’s terms. Participation is entirely optional, you must affirmatively opt in, and you can withdraw prospectively by following the instructions in the program terms. Any financial incentive or price or service difference is based on our reasonable, good-faith estimate of the value of the information to our business, calculated using the expense of the offer and the revenue we anticipate from rewarding loyalty.

“Shine the Light”

California residents who have an established business relationship with us may request information about how we disclose Personal Information to third parties for those third parties’ direct marketing purposes, under California Civil Code section 1798.83. You may make this request once a year, free of charge, by emailing privacy@clipboardworks.com.

Contact and Changes

We may amend this Supplement at any time. When we do, we will post the updated Supplement and update its effective date. If you have questions about this Supplement or our California privacy practices, contact us at privacy@clipboardworks.com, by telephone at (408) 837-0116, or through https://www.clipboardworks.com.