Privacy Policy

Last modified: April 29, 2022

Introduction

Joshin, together with any and all present or future affiliate, successor, or related entities (referred to as “Joshin,” “Us,” or “We”) provides referral services (“Services”) through its proprietary website (the “Website”) and mobile application (the “Application”) that matches disabled and neurodivergent individuals and their families/guardians (each, a “Member”) with a national network of caregivers, specialists, practitioners and professionals that provide services that range from peer-to-peer support, encouragement, education, instructional and practical tips to help Members, as well as health care and other wellness services via in-person, phone and/or video chat sessions (such caregivers, specialists, practitioners and professionals, each a “Care Provider” and the services provided by such Care Providers, the “Care Provider Services”).

We are posting this Privacy Policy to let you know the ways in which we collect, use, share and protect the personal information you provide to us and that we collect through our Application, Website, and Services, including through any other online method such as through a website (collectively, the “App/Service”).

Privacy is important to us, and we collect, use and share personal information from you in compliance with this Privacy Policy, and as permitted or required by applicable law.  We also require compliance with this policy, or equivalent privacy protections, for those vendors who assist us in operating the App/Service.

Please read this policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, please do not use our App/Service.  Also, please be aware this policy permits you to make a number of choices regarding your personal information. By accessing or using this App/Service, and by indicating your agreement upon sign-up, you acknowledge this Privacy Policy and consent to the collection, use, sharing, and processing of personal information as described in this policy. This policy may change from time to time. Your continued use of this App/Service after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

This Privacy Policy does not apply to third-party apps, websites, or tools that may be linked to this App/Service.

This Privacy Policy is in addition to any statement regarding privacy included in any other agreement between you and Joshin (for example, Care Providers and Members each have separate agreements with Joshin with additional terms).

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our App/Service, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, and telephone number (“personal information“);
• That is about you but individually does not identify you; and/or
• About the equipment you use to access our App/Service, and usage details such as which pages you visit and how long you visit each page.

We collect this information:

• Directly from you when you provide it to us (for example, when you type in and provide us with your name, email address, and similar information as part of signing up for and installing the App/Service);
• Automatically as you navigate through the App/Service (information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies);
• From third parties (for example, from vendors and others, we do business with);
• From Care Providers Members choose to work with, who may provide us with information and updates from time to time about calls, emails or in person interactions they have had with the Members and others; and/or
• From Members who may provide us with information and updates from time to time about calls, emails or in person interactions they have had Care Providers and may also provide reviews after completed bookings with the Care Providers they have worked with

Information You Provide to Us

The personal information we collect on or through our App/Service may, now or in the future, include:

For members

• Onboarding Information and Other Responses. Information that you provide by filling in forms or answering questions on our App/Service, and/or as part of the onboarding process. For example, contact information, demographic information, profile information, diagnosis details (including medications, behaviors, routines, etc.), account log-in details, and more.
• Correspondence. Records and copies of your correspondence and User Comments, as defined below (including email addresses, phone numbers, and location), if you contact us through the App/Service or otherwise.
• Survey Responses. Your responses to surveys that we might ask you to complete.
• Member Ratings and Related Information. You may submit reviews of Care Providers who provide services to you on the Joshin Platform, and we may also collect information about calls, emails, or in-person interactions Members have with Care Providers.
• Transaction Details. Details of transactions you carry out through our App/Service.
• Search Information. Your search queries on the App/Service.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

For care providers

• Onboarding Information and Other Responses. Information that you provide by filling in forms or answering questions on our App/Service, and/or as part of the onboarding process. For example, contact information, business contact information, demographic information, profile information, details about your professional certifications and experience, and other information of the type that may be included in a resume, account log-in details, and more.
• Care Services and Care Plan Information. Care Providers may provide us with information regarding their calls, emails, or in-person interactions with Members.
• Correspondence.  Records and copies of your correspondence and User Comments, as defined below (including email addresses, phone numbers, and location), if you contact us through the App/Service or otherwise.
• Survey Responses. Your responses to surveys that we might ask you to complete.
• Transaction Details. Details of transactions you carry out through our App/Service.
• Search Information. Your search queries on the App/Service.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Now or in the future, this App/Service may permit you to write certain messages, reviews or postings that may be viewed by Members, Care Providers, or other users of the App/Service as well as by Joshin personnel (collectively, “User Comments“). Therefore, we are not responsible for any third-party action with respect to User Comments.  User Comments are not confidential as you are automatically posting User Comments to an area of the App/Service where it may be viewed by other users.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our App/Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Visit Details. Details of your visits to our App/Service, including traffic data, precise geolocation data, logs, and other communication data, and the resources that you access and use on the App/Service.
• Computer Information. Information about your mobile device, tablet, desktop, laptop, or another computing device (“Computer”), and an internet connection, including your IP address, operating system, and browser type.
• Web analytics. We use product analytics software to allow us to better understand the behaviors around our product and site. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and other user actions on the App/Service.

The information we collect automatically may include personal information, and we may maintain it or associate it with the personal information we collect in other ways. It helps us to improve our App/Service and to deliver a better and more personalized service.

The technologies we use for this automatic data collection may include

• Cookies (or browser cookies) and Cookie Opt-Out. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our App/Service. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our App/Service. For more information about cookies, visit http://www.allaboutcookies.org/.
• Flash Cookies. Certain features of our App/Service may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our App/Service. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of the App/Service and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Joshin, for example, to count users who have visited those pages or opened an email and for other related App/Service statistics (for example, analyzing the popularity of certain content and verifying system and server integrity).

Information We Collect From Third Parties

We may collect information directly from third parties or combine personal information we receive from you with personal information we obtain from other sources, such as

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Private sources, such as data providers, social media platforms, and data licensors.
• From Care Providers, such as information and updates about calls, emails or in-person interactions they have had with the Members.
• From Members, such as information or reviews about calls, emails or in-person interactions they have had with Care Providers.
• Marketing partners, such as joint marketing partners and event co-sponsors.
• Care Provider background checks are performed by third parties. As provided in the Terms and Conditions, we will run a background check on Care Providers. Any such background checks will be subject to the terms we establish for such checks on the Site pages where they are requested or authorized, the terms of this Privacy Policy, and our Terms and Conditions. Joshin may receive a copy of, or otherwise, have access to all background checks.
• By service providers, your use in connection with our App/Services. For example, if you pay to engage a Care Provider through Joshin.com, such as through a payment processor, that Care Provider or payment processor may provide us with information about you or your loved ones, such as information relating to your transactions with the Care Provider.

How We Use Your Personal Information

We use and process personal information that we collect about you or that you provide to us:

• To present our App/Service and its contents to you.
• To provide care to Members and to guide Care Providers in providing care to Members.
• To assist Members in connecting with and scheduling a booking with a Care Provider and to assist Care Providers in connecting with Members seeking care.
• To process payments from Members for Care Provider Services to provide payments to Care Providers.
• To process and provide any order from you for items offered through this App/Service.
• To provide you with information or other items that you request from us.
• To create anonymous, aggregated, or de-identified data.
• For research and development, including analyzing and improving the App/Service and our business.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights and protect our interests and those of third parties.
• To comply with applicable law including any applicable reporting requirements to the government or third-party insurance entities.
• To notify you about changes to our App/Service or any products or services we offer or provide through it.
• To allow you to participate in any interactive features on or related to our App/Service.
• In any other way, which we may describe when you provide the personal information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you.

Disclosure of Your Information

We may disclose aggregated information about our Members, Care Providers, and other users of the App/Service, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect, or you provide, as described in this Privacy Policy:

• To our subsidiaries and affiliates, if any.
• ​​To business and marketing partners.
• To professional advisors.
• To Care Providers.
• To personnel at Joshin.
• To Members to connect Care Providers and Members seeking care.
• To linked third-party services. If you log into the App/Service with or otherwise link your App/Service account to, social media or other third-party services, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
• To contractors, service providers, and other third parties we use to support our business. For example, we use a third-party hosting service to power this App, and we use third-party payment processors, such as Stripe, to collect and process payment information. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, court-ordered transfer or reorganization, or other sale or transfer of some or all of Joshin’s assets, whether as a going concern or as part of a legal proceeding in which personal information held by Joshin about our App/Service users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the personal information with your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including responding to any government, law enforcement, or regulatory request.
• To enforce or apply our Terms of Use.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Joshin, our Members, our Care Providers, other users of the App/Service, other Joshin personnel, or others.

Changing or Removing your Personal Information and Closing your Account

To access, correct, update or delete certain of your personal information, click on the edit button (pen symbol) in the app. Alternatively, you may send us an email at security@joshin.com. to request access to, correct, or delete certain such personal information that you have provided to us. If you close your Joshin account, we will remove your name and other contact and identifiable information from our publicly viewable database.

We generally retain personal information to fulfill the purposes for which we collected it, including (1) as may be necessary to prevent fraud or future abuse, (2) for legitimate business purposes, such as analysis of aggregated or de-identified information, account recovery, auditing our records, enforcing our rights and obligations under our agreements, (3) if required by law, or (4) for record-keeping purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

Communication Opt-Out Choices

As required by law, if we send you out-of-app communications, such as an email or text, we will provide an opt-out mechanism within the message, which you can utilize if you do not wish to receive similar communications. In addition, you may select additional communication preferences or opt-outs by clicking on the “unsubscribe” link at the bottom of the email.  In addition, you can control the push notifications you wish to receive or not receive by adjusting your account settings in the Application.

Do Not Track Disclosure

This App/Service does not monitor for or behave differently if your computer transmits a “do not track” or similar beacon or message.

Opt-Out Tools and Choices

Some tools permit the personalization of content viewed by you (for example, Google has tools that aim to deliver to you advertisements that reflect your interests or past browsing history).  We may, now or in the future, make use of some of these tools.  If you do not wish to participate in history/behavioral tracking to provide tailored content and advertising you may opt out by visiting the linked site below (current as of the last update of this Privacy Policy, but subject to change by the applicable third party).

Google’s Ads Settings https://www.google.com/settings/u/0/ads/authenticated or https://www.google.com/settings/ads/anonymous
DoubleClick https://www.google.com/settings/ads/plugin
NAI opt-out. http://optout.networkadvertising.org/#!/

Additional opt-out mechanisms and tools that may be of interest to you include

The Digital Advertising Alliance’s opt-out portal. http://optout.aboutads.info/
The Direct Marketing Association’s opt-out tool. https://dmachoice.thedma.org/

Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the App/Service through your social media account or other third-party platforms, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Children Under the Age of 13 / COPPA

Our App/Service is not intended for anyone under 18 years of age.  No one under age 18 may provide personal information to or on the App/Service. We do not request any information regarding our users’ age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us at security@joshin.com

Social Media

This App/Service may, now or in the future, include buttons or links that permit you to share and post information on social media platforms such as LinkedIn, Instagram, and Twitter.   Any postings on these third-party platforms are governed by the terms, conditions, and privacy policies of such third parties.

Servers Located in the United States

We are an entity located in the United States, and the servers and other technology supporting the operations of this App/Service are located in the United States.  The App/Service is intended exclusively for a U.S. audience and users.  If you submit any personal information to this App/Service (for example, if you provide your email in order to sign up for an email newsletter) you understand that you are voluntarily consenting to the transmission of such information to an organization in the United States and your information will be stored and processed in the United States.  We agree only to be subject to applicable U.S. laws and not to the laws of any other country or region.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We also make use of SSL, Secure Socket Layers, technology in an effort to protect your personal information.  Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our App/Service. Any transmission or provision of personal information is at your own risk. We are also not responsible for the improper use of the App/Service by third parties.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically reviewing this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at

Email: security@joshin.com

Postal:
Joshin, Inc.
855 Village Center Drive #304
North Oaks, MN 55127

California Privacy Rights Notice

This section describes how we collect, use, share, and process Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information.  For purposes of this section (“California Privacy Rights Notice”), the term “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA.  In some cases, we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.

Your California privacy rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with which we share Personal Information.
  • The categories of Personal Information that we sold or disclosed for a business purpose.
  • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Opt-out of sales. You can opt-out of any sale of your Personal Information.
• Opt-in. If we know that you are 13-18 years of age, we will ask for your affirmative authorization to sell your Personal Information before we do so.
• Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Exercising your right to information, access and deletion. You may submit requests to exercise your right to information, access or deletion by calling us toll free at 1-866-866-0345, or via email to security@joshin.com.

Personal information that we collect, use and disclose. The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140), and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.