Introduction

Netsmart Technologies, Inc. (“Netsmart”) respects your privacy and is committed to protecting it through our compliance with this privacy notice (“Privacy Notice”). The purpose of this Privacy Notice is to inform you about the types of information you may provide to us and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Applicability

This Privacy Notice applies only to the services (“Services”), such as our software, mobile applications, websites, electronic healthcare record systems, etc. for the Mobile Caregiver+ (MCG+) application. Your agency provider administrators and any affiliates and subsidiaries may have separate websites, subdomains, and applications through other web, mobile, or cloud platforms which are not subject to this Privacy Notice. We encourage you to read the privacy notices of all websites and applications that you visit and understand their privacy practices.

Personal Information We Collect

Personal information is any information accessed, collected, or used by Netsmart or your agency provider administrators that identifies an individual, or can reasonably be used to identify an individual, whether directly or indirectly (“Personal Information”). Upon your request or with your consent, your agency provider administrators may share Personal Information about you with Netsmart to provision and maintain Services. When you use the MCG+ application, we may collect additional Personal Information about you to provide Services to your agency provider administrators and improve your user experience with the application. Personal Information we may collect about you include, but are not limited to, the following categories:

Personal Information Category	Purpose Description
Personal Identifiers	The application collects personal identifiers from users for the purpose of user identification, authentication, authorization, auditing, and reporting. Personal identifiers can be used to identify, contact, or locate a single individual or can be used with other sources to identify a single individual. This information includes, but is not limited to, name, address, telephone and fax number, email address, account number.
Online Identifiers	The application collects online identifiers from application users for the purpose of user identification, authentication, auditing, and monitoring. Online identifiers can be used to identify a single individual by associating information traces an individual leaves when operating online. This may include userID, information relating to the device, applications, or protocols that an individual is using to access the application.
Geolocation Information	The application collects geolocation information when a visit starts and ends to verify that the services(s) is provided by the Caregiver at the scheduled location(s).
Individual Profile Information	The application collects profile information and user preferences to create a profile about a user, as required by the state agency based upon their electronic visit verification submission requirements.
Protected Characteristics	The application collects protected characteristics, such as gender and date of birth, from the system users to be submitted to the state agency based upon their electronic visit verification submission requirements.

How We Use Personal Information We Collect

We use Personal Information collected from application users in an effort to provide Services, improve your user experience with the MCG+ application, and communicate with you about information that you request from Netsmart. We may also use Personal Information to:

• Provision Services to enable the use of the MCG+ application
• Provide Services to agency provider administrators and users
• Respond to user service requests and administer user accounts
• Perform diagnostics and troubleshooting
• Conduct research and analysis

With regards to Personal Information shared by your caregiver and/or the state aggregator/payer, Netsmart will only use such information in accordance with any instructions or restrictions provided to Netsmart by the data controller or the covered entity, as defined in our services agreement.

How We Use Tracking Technologies

We use various technologies to collect Personal Information about users of the MCG+ application. These tracking technologies are used to activate user’s services, perform application diagnostics, troubleshoot application failures, improve the application functionality, perform data analysis and data audits. These technologies include, but are not limited to, the following:

Category	Description
Web Server Data	When you access or use our Services, we may track information to administer our Services and analyze its usage. We gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data.
Cookies	Cookies uniquely identify your device or user account associated with our Services. You can control the use of cookies by adjusting your browser preferences at any time. If you reject cookies, you may still use our Services, but your ability to use some features or areas of our MCG+ application may be limited.
Geolocation Services	When you enable a location-based service, we may collect information about your location for troubleshooting in the event of a service failure for the user with the MCG+ application.

How We Share Personal Information with Third Parties

We do not sell your Personal Information to third parties. We do not share your Personal Information with third parties for their promotional or marketing purposes. We may disclose Personal Information that we collect, as described in this Privacy Notice, with third parties who support our business (i.e., contractors, service providers, business partners, etc.) to:

• Comply with legal requirements and corporate transactions.
• Enforce applicable Terms of Service, including investigation of potential violations
• Detect, prevent, or otherwise address fraud, security, or technical issues
• Protect against harm to the rights, property or safety of our users, Netsmart, or the public as required or permitted by law
• Engage in merger, acquisition, reorganization, or sale of all or a portion of Netsmart’s assets.
• Comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• For any other purpose disclosed by us when you provide your Personal Information.

Protection of Your Personal Information

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We use physical, electronic and administrative safeguards to protect your Personal Information. The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to the MCG+ application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Retention of Your Personal Information

We will retain your Personal Information as needed to provide Services and as necessary to comply with our legal obligations, resolve disputes and enforce our contractual agreements.

Your Individual Privacy Rights

Please contact your Agency Provider Administrator(s) to exercise your individual privacy rights. Based on applicable laws and regulations, Netsmart is not permitted to fulfill your privacy rights as it relates to the Services described in this Privacy Notice.

Changes to our Privacy Policy

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on the MCG+ application website and update the policy’s “Last Modified” date. You are responsible for regularly reviewing the terms of the Privacy Notice to stay informed of changes or modifications of the Privacy Notice.

How to contact us

We understand you may have questions regarding this Privacy Notice and our use of your Personal Information. You may contact us at: Mail: Netsmart Technologies, Inc., Attn: Privacy Office, 11100 Nall Ave, Overland Park, KS, 66211 Email: privacy@ntst.com Phone: (800) 842-1973 and select the Privacy Office option for any privacy-related questions.