Effective Date: December 20, 2024 

Last Updated: December 20, 2024 

  1. Introduction 

Elite365 Healthcare Workforce Solutions is a brand of Staffing Management, LLC, (“Elite365,” “we,” “us,” or “our”), which oversees this website, elite365.com (“Site”) and all related services (collectively, our “Services”). We have developed this Privacy Policy to inform all users (“user(s),” “you,” or “your”) about how we collect information in the course of conducting our business, including on the Site, how we use the collected information, and a user’s rights with respect to the collected information. 

Please read this Privacy Policy carefully.  If you do not agree to be bound by this Privacy Policy, then do not access or use the Services.  By accessing and/or using the Services, you accept and agree to be bound by this Privacy Policy.  This Privacy Policy is incorporated into our Terms of Use [TERMS OF USE HYPERLINK]. Your use of our Services and any Personal Information (as hereafter defined) you provide through the Services are subject to this Privacy Policy at all times. 

You must be at least EIGHTEEN (18) years old to access the Site and use our services.  If you are under eighteen (18) years old, you are not permitted to use any part of the Services for any reason.  

If you have any questions about this Privacy Policy, please contact us at privacy@elite365.com or at the contact information at the bottom of this page. 

  1. Information We Collect  

When you use the Site, we process certain types of Information, as described below. 

  1. Personal Information 

“Personal Information” means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.   

Personal Information that we collect on the Site includes, but is not limited to, first and last names, phone number, residential address, email address, and payment information.  

When you access or use the Services, you may provide Personal Information to us, such as when you request to receive information or support; complete online forms and surveys; communicate with us or our representatives, whether through standard mail, email, or telephone.  Over the course of communicating with us and using the Services, you may also provide more sensitive information, including but not limited to your social security number, NPI number, banking info for direct deposit, certifications, driver’s license, health records, and educational and employment background.  

  1. Non-Personal Information 

“Non-Personal Information” means information that does not identify you, but provides insights regarding your use of the Site. For example, we collect information about your use of the Site, including but not limited to Internet connections, computer equipment, browser information, websites visited before entering and after leaving the Site, IP addresses, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data, and other information about your use of the Services that does not identify you as a user. 

Personal Information and Non-Personal Information are collectively referenced as “Information.” Information we collect about you may be aggregated with other users’ Information. It may also be combined with associated Personal Information that you provide to us or that we receive from third parties. If we combine or associate information from other sources with Personal Information that we collect through the Site, we will treat the combined Information as Personal Information in accordance with this Policy. 

  1. Geolocation Information 

You may choose to allow us to access your location by granting the Site access to your location when prompted or through your device’s location services settings. You may change these settings on your device, but this will impact your use of and access to the Services. 

  1. Third-Party Social Networking Service(s) 

If you choose to access, visit, and/or use any third-party social networking service(s) (such as Google, Facebook, Instagram, TikTok, WhatsApp, Indeed, and/or LinkedIn) that may be integrated with our Site, we may receive your Personal Information and other Information about you and your computer, mobile, or other device that you have made available to those social networking services, including information about your contacts through those services.  For example, some social networking services allow you to push content from our Site to your contacts or to pull information about your contacts so you can connect with them on or through our Site.  Some social networking services also will facilitate registration or enhance or personalize your experience on our Site.  Your decision to use a social networking service in connection with our Site is voluntary.  However, you should make sure you are comfortable with the information your third-party social networking services may make available by reviewing privacy policies of those providers and/or modifying your privacy settings directly with those networking sites/services. 

  1. Use of Information 

We use Non-Personal Information collected by cookies, web beacons, and other Internet tracking technology to store your preferences, improve website navigation, make personalized features and other services available to you, to generate statistical information, monitor and analyze user traffic and usage patterns, monitor and prevent fraud, investigate complaints and potential violations of our policies, to improve the products, services, materials, and other content that we describe or make available through the Services, and otherwise help administer and improve the Services.  For more information about our use of tracking technology, please see our Cookie Policy.  

We may identify you from your Personal Information and merge or co-mingle Personal Information and Non-Personal Information.  Except as otherwise stated, we may use Information we collect from you for the legitimate business purpose of providing our Services to you, including, but not limited to: 

  • To fulfill or meet the reason you provided the Personal Information.  For example, if you share your name and contact information to ask a question about our Services, we will use that Personal Information to respond to your inquiry.   
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses. 
  • To provide, support, personalize, and develop our Services, including without limitation, to conduct aggregate or research analysis and develop business intelligence that helps us to enhance, improve, evaluate, operate, protect, make informed decisions about, and report on the performance of our Services. 
  • To communicate information and promotional materials to you, where you have not expressed a preference otherwise, and to send you information and updates about the Services. 
  • To notify you of any changes to relevant agreements, policies, or other terms, and to enforce such terms. 
  • To work with our service providers, who perform certain business functions or services on our behalf and who are bound by contractual obligations consistent with this Privacy Policy. 
  • To prevent or investigate fraud, or for risk management purposes, and to help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business. 
  • To comply with legal obligations, court orders, or in order to exercise any legal claim or to defend against any legal claim. 
  • 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 Information held by us about our consumers is among the assets transferred. 
  • As otherwise described to you when collecting your Personal Information. 

In addition, we may use third‐party e‐mail providers to deliver communications to you.  This is an opt-in e-mail program.  If you no longer want to receive these e-mail communications, you may opt-out of receiving e-mail communications through the “unsubscribe” link or by contacting us at privacy@elite365.com.

  1. How We Share Information 

We may share Personal Information with the following parties:  

  • Corporate affiliates, including corporate parents, subsidiaries, other affiliated entities, and associated entities for the purposes described in this Policy which are required to treat the information in accordance with this Privacy Policy;  
  • Service providers that help us administer and provide the Services (for example, a web hosting company whose services we use to host our platform).  These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf.  We have entered into contractual relationships with these service providers and require them to comply with all applicable information privacy laws and regulations and to use the Information only for the purposes for which it was disclosed.  We require that any third-party service providers limit their use of your Information solely to providing services to us and that they maintain the confidentiality, security, and integrity of your Information and not make unauthorized use or disclosure of the Information;  
  • Authorized third parties, who are parties directly authorized by you to receive the applicable Information, such as when you authorize a third-party application provider to access your account.  The use of your Information by an authorized third party is subject to the third party’s privacy policy; 
  • Advertising and marketing partners and service providers, who create or distribute advertising materials and campaigns and with whom we may share your Personal Information for purposes of serving interest-based or targeted advertisements; 
  • Third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), in which case we will require the recipient to use such information in accordance with this Privacy Policy;  
  • As we believe necessary: (i) under applicable law; (ii) to enforce applicable terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment and (vi) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence; and 
  • Pursuant to your express consent. 
  1. Information Security 

We take reasonable steps online and offline to safeguard the Personal Information that you provide to us. 

It is common knowledge that transmission of information via the Internet is not wholly secure, and we cannot guarantee or warrant the security of your Personal Information, or any other information, transmitted to or through our Site or Services or otherwise provided to us.  We are not responsible for the theft, destruction, or inadvertent disclosure of such information.  It is your responsibility to safeguard any passwords, ID numbers, or other special access features associated with your use of the Service(s).  Any transmission of information is at your own risk. 

If you have any questions about security on our Services, or if you become aware of or suspect a security breach, notify us immediately via privacy@elite365.com.  If our security system is breached, we will notify you of the breach to the extent required under applicable law. 

  1. Information Retention 

We retain the Personal Information we receive as described in this Privacy Policy for as long as you use our Site or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.  

  1. Links to Third-Party Sites 

The Site may contain links to other sites that are not operated by us.  If you click on a link to another site, you will be directed to that third party’s site.  Such links do not constitute an endorsement by us of those other websites, their content or services, or the persons or entities associated with those websites.  This Privacy Policy does not apply to third-party websites.  We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.  We encourage you to review the privacy policies and terms of all third-party websites or services that you may visit. 

  1. Communication Preferences 

Our Communications Preferences are located here: Elite365 | Communication Preferences. 

  1. Google Analytics 

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. 

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. 

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy  

  1. Children’s Privacy 

We do not sell products or services for purchase by anyone under the age of thirteen (13).   In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit Personal Information from anyone under the age of thirteen (13) without verifiable parental consent.  In the event that we receive actual knowledge that we have collected such Personal Information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical.  We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Service(s).  

  1. Your California Privacy Rights 

California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.  Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to privacy@elite365.com.  For more information regarding your privacy rights as a California resident, please see our Privacy Notice for California Residents.  

  1. Additional Information for certain U.S. Residents and their Consumer Data Privacy Rights 

Depending on where you live, you may have certain rights related to your personal information. These rights may include the below. Please be aware that these rights are not absolute and may apply only in certain circumstances. In certain cases, we may decline your request as permitted by law. 

  • Right to Access / Know. You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information, subject to certain privacy and other limitations. 
  • Right to Delete. You may have a right to request that we delete personal information we maintain about you, subject to certain exceptions under applicable law. 
  • Right to Correct. You may have a right to request that we correct inaccurate personal information that we maintain about you. 
  • Right of Portability. You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions. 
  • Right to Opt Out of Sale or Targeted Advertising. You may have a right to opt out of the sale of your personal information or the processing of your personal information for purposes considered to be “targeted advertising”, as defined in applicable privacy laws.  
  • Right to Opt Out of Profiling. You may have a right to opt out of the use of your personal information for purposes of profiling with a legal or similar significance.  
  • Right to Limit Use and Disclosure of Sensitive Personal Information. We will not process or use your sensitive personal information without your consent.  
  • Right Not to Be Discriminated Against. You may have the right not to be discriminated against for exercising any of your rights under applicable law. Please note, however, that we may be permitted to offer certain benefits in connection with your voluntary participation in certain incentives and loyalty, rewards, or similar programs. If we choose to do so, we will provide additional information about such incentives and programs.   
  • Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information. 
  • Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent. 
  • Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial. 
  • Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account, subscriptions, or other purchases that you have made. 

You may exercise these rights where indicated on our Site or by contacting us using the contact details provided below. Note that we may choose not to honor requests where we are not legally obligated to do so, and we may choose to honor requests even where we are not legally obligated to do so, in each case in our sole and absolute discretion. By honoring such requests, however, we do not assume, and hereby expressly disclaim, any obligation to honor such requests in the future.    

We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, You may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law. 

  1. Additional Information for UK, EEA, and certain other individuals residing outside of the United States  

Residents of certain jurisdictions outside of the United States, whose Personal Information we have collected (“Data Subjects”), may have additional rights respecting their Personal Information, including rights to specific disclosures and rights to control their Personal Information. Please see below for more information. 

  1. Legal Bases for Processing Your Information 

We process your Personal Information for the purposes set forth in Section 4, above, on the bases further described below.  

  • For Legitimate Interests. We may use your Personal Information for the legitimate business purpose of providing our Services to you. For example, we use your Personal Information to administer the Services, help diagnose problems with our Services and provide support, to communicate information to you, to improve our Services and customize our Services to your preferences, to work with our service providers, to show you content and sponsored messaging, to prevent or investigate fraud or to comply with legal obligations, and for other purposes identified to you and as requested by you.  
  • Performance of a Contract. If you have agreed to our terms of use, or other terms of service, and you have created an account, signed up for a subscription, or entered into a contest or sweepstakes, we may also use your information to establish your account to use the Services, validate your account credentials, respond to your requests, provide you with merchandise or services you have requested, notify you of contest or sweepstakes results, and to notify you of any changes to relevant agreements or policies.  
  • Consent. If we have obtained your consent, we may also share your information with our corporate parents, subsidiaries, other affiliated entities, and associated entities for the purposes described in this Privacy Policy or use and use your Personal Information to process any request or transaction you make, send email and postal mail to provide you with updates and news, and to otherwise process your Personal Information and Non-Personal Information as described throughout this Privacy Policy and as consented to by you.  
  1. Your Choices, Access, and Rights to Your Personal Information 

Data Subjects may have the following rights and options with regard to accessing, reviewing, correcting, and updating their Personal Information:  

  • Right to Access.  We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your Personal Information.  
  • How to Access Your Personally Identifiable Information. You may choose to access or update Personal Information, by logging into the account you have created with our Service(s), if applicable. 
  • Access to Personal Information.  You may choose to access your Personal Information by contacting us and requesting access, a process which shall include our identity verification procedures.  Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law). 
  • Updating Communications Preferences (Opt-Out) and Unsubscribing.  You may choose to receive promotional offers, newsletters, and similar communications from us regarding our products and services and the products and services of our affiliated organizations.  You may opt out of receiving such communications from us by communicating your preferences to us at privacy@elite365.com, or in the case of e-mails, by following the unsubscribe instructions contained in the applicable e-mail.  
  • Right to Rectify — Correction and Deletion.  Citizens of some jurisdictions have the right to correct or amend their Personal Information if it is inaccurate or requires updating. You may also have the right to request deletion of your Personal Information; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by contacting us at privacy@elite365.com.  
  • Right to Erasure / Be Forgotten.  Data Subjects may have the right to request that we delete your Personal Information in certain circumstances, such as if holding the Personal Information is no longer necessary or if part of your Right to Object (below). Please note that if you request erasure of your account, we, in complying with your request, shall also delete any and all research data that has been submitted to us through our Services. It is your responsibility at all times to ensure that you are in compliance with all applicable rules, policies, and regulations at the institutional, administrative, and federal levels regarding retention of research data, including, but not limited to, United States regulations governing retention and disposal of research records. 
  • Right to Object.  Data Subjects may have the right to object to the use of Personal Information for direct marketing uses, scientific uses, or historical research.  If you do not wish to have your Personal Information shared with third parties, contact our Data Protection Officer as described at the end of this document.  If you do not wish to receive future commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. (But note that you may continue to receive certain communications from us, such as transactional or relationship messages, and/or messages about your account/profile). 
  • Right to Restrict Processing.  Citizens of some jurisdictions have the right to request that we stop processing their Personal Information. 
  • Right to Data Portability.  A Data Subject has the right to request that we provide your Personal Information for the purpose of sharing it with another service provider (through a secure process). 
  • Filing a Complaint.  A Data Subject who is not satisfied with how we manage your Personal Information has the right to make a complaint to a data protection regulator. 
  1. Geographic Information Transfers 

If you are located outside of the United States, please be aware that your Information will be transferred to, processed, and stored in the United States, where it will be treated in accordance with this Privacy Policy and applicable privacy laws in the United States.  These laws may be different from the privacy laws in your country.  

However, this does not change our commitments to safeguarding your privacy, and we will comply with all applicable laws relating to cross-border data disclosure of your Personal Information.  Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before disclosing any Personal Information. 

  1. Data Protection Officer 

Please see below for information regarding our appointed Data Protection Officer. 

If you have an inquiry regarding your Personal Information, pursuant to the rights listed in the preceding section (above), please send your message to the following: 

Marsha Abeln 

Attention:  Website Inquiry 

E-mail:  privacy@elite365.com 

  1. Data Controller for the Facebook Fan Page 

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook pages, https://www.facebook.com/elite365staffing and https://www.facebook.com/TherapyCareers/.  Note that we and Facebook are considered as Joint Controllers.  Personal Information may be shared from healthcare providers or potential corporate candidates should they choose to send it to us either in a direct message via Facebook Messenger or a post comment. Facebook is owned by Meta. 

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php. 

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States. 

  1. Facebook Insights 

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users. 

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period. 

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services. 

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation. 

  1. Changes in the Privacy Policy 

We reserve the right to modify and update this Privacy Policy at any time by posting an amended version of the statement on our Site. Please refer to this policy regularly.  If at any time we decide to use Personal Information in a manner different from that stated at the time it was collected, we will notify you either on the panel home page of our Site or via e-mail. 

  1. How to Contact Us 

If you have any questions or comments about our Privacy Policy, please contact us at:  
 

By e-mail:

privacy@elite365.com  

By mail:

Staffing Management LLC 

5000 Culbreath Key Way, Suite 9114 Tampa, FL 33611