National Datacare Privacy Notice  

Last Updated: April 25, 2024  

National Datacare Corporation (“National Datacare,” “NDC” “we,” “us,” or “our”), is an industry leader  in providing resident trust fund services and Medicaid billing services for the skilled care, assisted living,  developmentally disabled and representative payee markets. This Privacy Notice is designed to help you  understand how we collect, use, process, and share your personal information, and to help you understand  and exercise your privacy rights.  

As used in this Privacy Notice, “personal information” has the meaning given to it under the law where you  live, but typically refers to information that can be used to identify you as an individual; meanwhile our  activities taken with respect to your personal information are referred to as “processing.” For residents of  California and other US states with special privacy rights, additional disclosures are available below.  

1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE  

2. PERSONAL INFORMATION WE COLLECT  

3. HOW WE USE YOUR PERSONAL INFORMATION  

4. HOW WE SHARE YOUR PERSONAL INFORMATION  

5. YOUR PRIVACY CHOICES AND RIGHTS  

6. SECURITY OF YOUR INFORMATION  

7. RETENTION OF PERSONAL INFORMATION  

8. NOTICE AT COLLECTION AND SUPPLEMENTAL NOTICE FOR RESIDENTS OF  CERTAIN U.S. STATES  

9. CHILDREN’S INFORMATION  

10. OTHER PROVISIONS  

11. CONTACT US  

1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE  

This Privacy Notice applies to personal information processed by us, including on our websites, mobile  applications (e.g., RFMS Mobile), online platforms (e.g., RFMS Online) and other online or offline  offerings. To make this Privacy Notice easier to read, our websites, mobile applications, and other offerings  are collectively called the “Services.”  

An Important Note: This Privacy Notice does not apply to any of the personal information that we  process on behalf of our customers through their use of our Services (“Customer Data”). Our customers’  respective privacy policies govern their collection and use of Customer Data. Our processing of Customer  Data is governed by the contracts that we have in place with our customers, not this Privacy Notice. Any  questions or requests relating to Customer Data should be directed to our customer. This Privacy Notice  describes the personal information we collect and process independently as a data controller.  

Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion.  If there are any material changes to this Privacy Notice, we will notify you as required by applicable law, 

such as by sending you an email. If you continue to use our Services after the new Privacy Notice takes  effect, we will assume you have read and acknowledged the new notice. 

2. PERSONAL INFORMATION WE COLLECT  

The categories of personal information we collect depend on how you interact with us, our Services, and  the requirements of applicable law. We collect information that you provide to us, information we obtain  automatically when you use our Services, and information from other sources such as third-party services  and organizations, as described below.  

A. Personal Information You Provide to Us Directly 

We may collect personal information that you provide to us.  

Account Creation. We may collect personal information when you create an account, such as  name, email address, username, profile picture, etc. 

Payments. We may collect personal information and details associated with your payments,  including financial information. Any payments made via our Services are processed by third-party  payment processors. We do not directly collect or store any payment card information entered  through our Services, but we may receive information associated with your payment card  information (e.g., your billing details). 

Your Communications with Us. We may collect personal information, such as email address,  phone number, or mailing address when you request information about our Services, register for  our newsletter, request customer or technical support, or otherwise communicate with us. 

Healthcare Professionals. If you are a healthcare professional, we may collect personal  information such as your professional contact information, credential and institutional affiliations  information, information about our programs and activities in which you have participated,  information about our interactions with you, information about your published papers, your  photograph, information about your prescribing of our products and services, and information  contained in agreements executed with us. 

Regulatory Information. We may collect personal information where required to comply with  regulatory requirements. 

Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect  personal information from you in connection with the survey. 

Interactive Features. We and others who use our Services may collect personal information that  you submit or make available through our interactive features (e.g., messaging and chat features,  commenting functionalities, forums, blogs, and social media pages). Any information you provide  using the public sharing features of the Services will be considered “public,” unless otherwise  required by applicable law, and is not subject to the privacy protections referenced herein.  

Conferences, Trade Shows, and Other Events. We may collect personal information from  individuals when we attend or host conferences, trade shows, and other events.  

Business Development and Strategic Partnerships. We may collect personal information from  individuals and third parties to assess and pursue potential business opportunities.  

Job Applications. We may post job openings and opportunities on our Services. If you respond to  one of these postings, we may collect your personal information, such as your application, CV,  cover letter, and/or any other information you provide to us. 

B. Personal Information Collected Automatically  

We may collect personal information automatically when you use our Services.  

• Automatic Collection of Personal Information. We may collect certain information  automatically when you use our Services, such as your Internet protocol (IP) address, user settings,  cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device  information, location information, and Internet service provider. We may also automatically collect  information regarding your use of our Services, such as pages that you visit before, during and after  using our Services, information about the links you click, the types of content you interact with,  the frequency and duration of your activities, and other information about how you use our  Services. If you provide crash reports, we may collect personal information related to such crash  reports, including detailed diagnostic information about your device and the activities that led to  the crash.  

• Cookie Policy (and Other Technologies). We, as well as third parties that provide content,  advertising, or other functionality on our Services, may use cookies, pixel tags, and other  technologies (“Technologies”) to automatically collect information through your use of our  Services.  

o Cookies. Cookies are small text files placed in device browsers that store preferences and  facilitate and enhance your experience.  

o Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code  embedded in our Services that collects information about engagement on our Services. The  use of a pixel tag allows us to record, for example, that a user has visited a particular web  page or clicked on a particular advertisement. We may also include web beacons in e-mails  to understand whether messages have been opened, acted on, or forwarded.  

o APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software  development kits (“SDKs”) as part of the functionality of our Services. For more  information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.  

Our uses of these Technologies fall into the following general categories:  

o Operationally Necessary. This includes Technologies that allow you access to our  Services, applications, and tools that are required to identify irregular website behavior,  prevent fraudulent activity, improve security, or allow you to make use of our functionality;  

o Performance-Related. We may use Technologies to assess the performance of our  Services, including as part of our analytic practices to help us understand how individuals  use our Services (see Analytics below);  

o Functionality-Related. We may use Technologies that allow us to offer you enhanced  functionality when accessing or using our Services. This may include identifying you when  you sign into our Services or keeping track of your specified preferences, interests, or past  items viewed;  

o Advertising or Targeting-Related. We may use first party or third-party Technologies,  including cross-device tracking, to deliver content, including ads relevant to your interests,  on our Services or on third-party digital properties. Some of the advertising Technologies  we use include: 

•Google Advertising. For more information about how Google uses your personal information  (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google  Advertising’s Privacy Notice. To learn more about how to opt-out of Google Analytics’ use of your  information, please click here 

•Analytics. We may use Technologies and other third-party tools to process analytics information  on our Services. These Technologies allow us to better understand how our digital Services are  used and to continually improve and personalize our Services. Some of our analytics partners  include:  

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies. C. Personal Information Collected from Other Sources  

Third-Party Services and Sources. We may obtain personal information about you from other sources,  including through third-party services and organizations. For example, if you access our Services through  a third-party application, such as an app store, a third-party login service, or a social networking site, we  may collect personal information about you from that third-party application that you have made available  via your privacy settings.  

3. HOW WE USE YOUR PERSONAL INFORMATION  

We use your personal information for a variety of business purposes, including to provide our Services, for  administrative purposes, and to market our products and Services, as described below.  

A. Provide Our Services 

We use your information to fulfil our contract with you and provide you with our Services, such as:  

• Managing your information and accounts;  

• Providing access to certain areas, functionalities, and features of our Services;   Answering requests for customer or technical support;  

• Communicating with you about your account, activities on our Services, and policy changes;   Processing your financial information and other payment methods for products or Services  purchased;  

• Processing applications if you apply for a job we post on our Services; and  

• Allowing you to register for events.  

B. Administrative Purposes 

We use your information for various administrative purposes, such as: 

• Pursuing our legitimate interests such as direct marketing, research and development (including  marketing research), network and information security, and fraud prevention;  

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity,  and prosecuting those responsible for that activity;  

• Measuring interest and engagement in our Services; 

• Short-term, transient use, such as contextual customization of ads;  

• Improving, upgrading, or enhancing our Services;  

• Developing new products and services;  

• Ensuring internal quality control and safety;  

• Authenticating and verifying individual identities, including requests to exercise your rights under  this Privacy Notice;  

• Debugging to identify and repair errors with our Services;  

• Auditing relating to interactions, transactions, and other compliance activities;   Sharing personal information with third parties as needed to provide the Services;   Enforcing our agreements and policies; and  

• Carrying out activities that are required to comply with our legal obligations.   We may use your information for other legitimate business purposes as permitted by law.  

C. Marketing and Advertising our Products and Services 

We may use personal information to tailor and provide you with content and advertisements. We may  provide you with these materials as permitted by applicable law.  

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest based” or “personalized advertising,” including through cross-device tracking. 

If you have any questions about our marketing practices, you may contact us at any time as set forth in  “Contact Us” below.  

D. De-identified and Aggregated Information.  

We may use personal information to create de-identified and/or aggregated information, such as  demographic information, information about the device from which you access our Services, or other  analyses we create.  

E. With Your Consent 

We may use personal information for other purposes that are clearly disclosed to you at the time you  provide personal information or with your consent.  

F. Other Purposes 

We also use your personal information for other purposes as requested by you or as permitted by applicable  law. 

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION  

We share your personal information with third parties for a variety of business purposes, including to  provide our Services, to protect us or others, or in the event of a major business transaction such as a merger,  sale, or asset transfer, as described below.  

A. Disclosures to Provide our Services 

The categories of third parties with whom we may share your personal information are described below.  

• Service Providers. We may share your personal information with our third-party service providers and  vendors that assist us with the provision of our Services. This includes service providers and vendors  that provide us with IT support, hosting, payment processing, customer service, and related services.  

• Business Partners. We may share your personal information with business partners to provide you  with a product or service you have requested. We may also share your personal information with  business partners with whom we jointly offer products or services.  

• Affiliates. We may share your personal information with our company affiliates for example: for our  administrative purposes, IT management, or for them to provide services to you or support and  supplement the Services we provide.  

• Advertising Partners. Through our Services, we may share your personal information with third-party  advertising partners. These third-party advertising partners may set Technologies and other tracking  tools on our Services to collect information regarding your activities and your device (e.g., your IP  address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use  this information (and similar information collected from other services) for purposes of delivering  personalized advertisements to you when you visit digital properties within their networks. This  practice is commonly referred to as “interest-based advertising,” “cross-context behavioral  advertising,” or “personalized advertising.”  

The privacy choices you may have about your personal information are determined by applicable law and  are described in “Your Privacy Choices and Rights” below.  

B. Disclosures to Protect Us or Others 

We may access, preserve, and disclose any information we store associated with you to external parties if  we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national  security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights,  property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an  

investigation or prosecution of suspected or actual illegal activity.  

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers 

If we are involved in an actual or proposed merger, acquisition, financing due diligence, reorganization,  bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your  information may be disclosed, sold or transferred as part of such a transaction, as permitted by law and/or  contract. 

5. YOUR PRIVACY CHOICES AND RIGHTS  

Your Privacy Choices. The privacy choices you may have about your personal information are determined  by applicable law and are described below.  

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe  link found at the bottom of the email to opt out of receiving future emails. Note that you will  continue to receive transaction-related emails regarding products or Services you have requested.  We may also send you certain non-promotional communications regarding us and our Services,  and you will not be able to opt out of those communications (e.g., communications regarding our  Services or updates to our Terms or this Privacy Notice).  

• Mobile Devices. We may send you push notifications through our mobile application. You may  opt out from receiving these push notifications by changing the settings on your mobile device.  With your consent, we may also collect precise location-based information via our mobile  application. You may opt out of this collection by changing the settings on your mobile device.  

• “Do Not Track” / “Global Privacy Control.” Do Not Track (“DNT”) is a privacy preference that  users can set in certain web browsers. Additionally, some browsers or plug-ins use a “Global  Privacy Control” (“GPC”), which you can learn more about at https://globalprivacycontrol.org/.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by  web browsers. However, if our site detects a GPC signal from your device, we will interpret it as  either a Do Not Sell request or a request to limit the sale or sharing of personal information for  targeted advertising depending on the law applicable to your jurisdiction.  

• Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies  on your device or remove them by using the controls we make available in our cookie banner, or  adjusting your preferences as your browser or device permits. However, if you adjust your  preferences, our Services may not work properly. Please note that cookie-based opt-outs are not  effective on mobile applications. However, you may opt-out of personalized advertisements on  some mobile applications by following the instructions for Android, iOS, and others.  

The online advertising industry also provides websites from which you may opt out of receiving  targeted ads from data partners and other advertising partners that participate in self-regulatory  programs. You can access these and learn more about targeted advertising and consumer choice  and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the  European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.  

Please note you must separately opt out in each browser and on each device.  

Your Privacy Rights. In accordance with applicable law, you may have the right to:  

• Obtain Access to and Portability of Your Personal Information, including: (i) confirming  whether we are processing your personal information; (ii) obtaining access to or a copy of your  personal information; and (iii) receiving an electronic copy of personal information that you have  provided to us, or asking us to send that information to another company in a structured, commonly  used, and machine readable format (also known as the “right of data portability”);  

• Request Correction of your personal information where it is inaccurate or incomplete. In some  cases, we may provide self-service tools that enable you to update your personal information;  

• Request Deletion of your personal information;  

• Request Restriction of or Object to our processing of your personal information depending on  the legal rights of your jurisdiction. For example, depending on where you live, you might have the 

right to opt out of (i) the sale or sharing of your personal information, (ii) our use or disclosure of  your sensitive personal information, and/or (iii) the processing of your personal information for  purposes of (a) targeted advertising, and (b) profiling in furtherance of decisions that produce legal  or similarly significant effects concerning you; and  

• Withdraw your Consent to our processing of your personal information. Please note that your  withdrawal will only take effect for future processing and will not affect the lawfulness of  processing before the withdrawal.  

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below or as  otherwise instructed in any additional privacy notices provided at the time we collect your personal  information. We will process such requests in accordance with applicable laws.  

For additional rights applicable to residents of certain US states, please see here. 

6. SECURITY OF YOUR INFORMATION  

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information  you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for  unauthorized access, use, disclosure, or loss of your personal information.  

By using our Services or providing personal information to us, you agree that we may communicate with  you electronically regarding security, privacy, and administrative issues relating to your use of our Services.  If we learn of a security system’s breach, we may attempt to notify you electronically, for example by  posting a notice on our Services, by mail, or by sending an email to you.  

7. RETENTION OF PERSONAL INFORMATION  

We store the personal information we collect as described in this Privacy Notice for as long as you use our  Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve  disputes, establish legal defenses, conduct audits, enforce our agreements, and comply with applicable laws,  or based upon other criteria, including, but not limited to, the sensitivity and volume of such data.  Additionally, we endeavor to retain all such personal information in accordance with legal requirements.  

8. NOTICE AT COLLECTION AND SUPPLEMENTAL NOTICE  FOR RESIDENTS OF CERTAIN U.S. STATES  

This Notice at Collection and Supplemental Notice is for residents of states that have adopted  comprehensive privacy legislation and others that may come into effect from time to time, including, but  not limited to, California (collectively, “Applicable State Laws”).  

A. Personal Information We Collect and Share  

As more fully described in the section titled Personal Information We Collect, the sources from which we  collect personal information include directly from you when you interact with us, automatically from you  when you use our sites and Services (for example through cookies and other Technologies), from third  parties (for example, from third-party referrals).  

Depending on how you use our Services, the information we may have collected about you, as well as the  categories of third parties with whom we have shared this information, are described in the table below. 

B. Use of Personal Information
We may use or disclose the personal information we collect for the purposes outlined in Use of
Information above. These purposes include:
To provide our Services to you;
• For our administrative purposes (including security, fraud detection and protection, and improve
our Services);
• To process your requests, orders, and transactions (including provide customer service to you);
• To Advertise and market our products and Services to you;
• With your consent; and,
• To comply with law and enforce our rights and the rights of others.

Where required under applicable law, we will not collect additional categories of personal information or  use the personal information we have collected for materially different, unrelated, or incompatible  purposes without first providing you notice.  

C. Sales/Sharing of Personal Information 

For purposes of certain state law, National Datacare does not “sell” personal information, nor do we have  actual knowledge of any “sale” of personal information of minors under 16 years of age as the term “sell”  is commonly understood. That said, for users over 16 years of age, we may share information with third party advertising partners for the purpose of promoting our Services as described above, such as for cross context behavioral advertising. You may limit such sharing as described in “Your Privacy Choices and  Rights”, or by contacting us as set forth in “Contact Us” below. 

D. Retention of Personal Information  

We store the personal information we collect as described in our Privacy Notice for as long as you use our  Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve  disputes, establish legal defenses, conduct audits, enforce our agreements, and comply with applicable laws,  or based upon other criteria, including, but not limited to, the sensitivity and volume of such data.  Additionally, we endeavor to retain all such personal information in accordance with legal requirements.  

E. Additional Privacy Rights for Residents of Certain States  

• Non-Discrimination. Residents of certain states have the right not to receive discriminatory  treatment by us for the exercise of their rights conferred by applicable law.  

• Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a  verifiable consumer request related to your personal information. You may also make a verifiable  consumer request on behalf of your minor child. To authorize an agent, provide written authorization  signed by you and your designated agent and contact us as set forth in “Contact Us” below for  additional instructions.  

• Verification. To protect your privacy, we will take steps to reasonably verify your identity before  fulfilling your request. These steps may involve asking you to provide sufficient information that allows  us to reasonably verify you are the person about whom we collected personal information or an  authorized representative, or to answer questions regarding your account and use of our Services.  

• De-Identified Information. If we create or receive de-identified information, we will not attempt to  reidentify such information, except to comply with applicable law.  

• California Shine the Light. The California “Shine the Light” law permits users who are California  residents to request and obtain from us once a year, free of charge, a list of the third parties to whom  we have disclosed their personal information (if any) for their direct marketing purposes in the prior  calendar year, as well as the type of personal information disclosed to those parties. To make such a  request, you may contact us as set forth in “Contact Us” below.  

9. CHILDREN’S INFORMATION  

The Services are not directed to children under 13 (or other age as required by local law), and we do not  knowingly collect personal information from children.  

If you are a parent or guardian and believe your child has uploaded personal information to our site without  your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has  provided us with personal information in violation of applicable law, we will delete any personal  information we have collected, unless we have a legal obligation to keep it.  

10. OTHER PROVISIONS  

• Third-Party Websites/Applications. The Services may contain links to other websites/applications  and other websites/applications may reference or link to our Services. These third-party services are  not controlled by us. We encourage our users to read the privacy policies of each website and  application with which they interact. We do not endorse, screen, or approve, and are not responsible  for, the privacy practices or content of such other websites or applications. Providing personal  information to third-party websites or applications is at your own risk. 

11. CONTACT US  

National Datacare is the controller of the personal information we process under this Privacy Notice.  

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as  detailed in this Privacy Notice, please contact us at:  

National Datacare Corporation  

Legal Department  

14155 Newbrook Drive Suite 200  

Chantilly, Virginia 20151  

800-632-7367  

privacy@nationaldatacare.com