DRAFT FOR REVIEW. NOT LEGAL ADVICE.

This is a working draft for review by Andrew Scott. It is not legal advice and has not been reviewed by a lawyer. Please have a licensed attorney review it before you publish it or rely on it. Items marked [TBD] still need to be filled in.

CallBoard Privacy Policy

Effective date: [TBD effective date]

Last updated: [TBD date]

This policy explains what information CallBoard collects, why we collect it, and what we do with it. We've tried to write it in plain English.

"CallBoard," "we," "us," and "our" mean CALLBOARD LLC, an Illinois limited liability company, which runs the CallBoard service at callboard.work (the "Service").

1. Who this policy covers

CallBoard is a business tool. Organizations, such as hospital anesthesia departments, sign up so they can build and publish staff call schedules. In this policy:

• A Customer is the organization that has a CallBoard account.
• An Admin is a person the Customer authorizes to manage its account, schedules, and staff.
• A Staff Member is a person an Admin invites to view schedules, request time off, or swap covers.
• A Visitor is anyone who browses callboard.work without signing in.

If your organization invited you: your organization controls the schedule data in its account and decides how it is used. We process that data for your organization and follow its instructions. If you have a question about your schedule data, or want something changed or removed, start with your organization's Admin. You can also contact us, and we'll pass the request along or help where we can.

2. No patient health information

CallBoard is built for staff scheduling. It is not built to store patient information, and it is not set up to handle protected health information (PHI) under HIPAA.

Customers and users must not enter patient health information into CallBoard. That includes patient names, medical record numbers, diagnoses, procedures tied to a patient, and any other information that identifies a patient. This applies to every field, note, and message in the Service. [TBD: confirm with counsel whether a Business Associate Agreement will ever be offered; the current position is no.]

3. Information we collect

Information you or your organization gives us

• Account and profile information: names, work email addresses, role (Admin or Staff Member), and the team or department you belong to.
• Scheduling information: call schedules, shift and call assignments, drafts and published schedules, day sheets, cover swap requests and approvals, time-off requests and their status, and notes you add to them.
• Billing contact information: the name and email of the person who manages billing. Stripe, our payment processor, handles payments (see Section 5). We do not store full card numbers. We may receive limited details from Stripe, such as card brand, last four digits, expiration date, and billing status.
• Communications: messages you send us, for example to hello@callboard.work.

Information we collect automatically

• Authentication data: login records, session tokens, and the information we need to keep your account secure.
• Basic usage logs: what our servers record when you use the Service. This includes IP address, browser and device type, pages or features accessed, timestamps, and error logs.
• Bot protection: we use Cloudflare Turnstile to check that sign-up and login requests come from real people. Turnstile may look at browser and device signals to do this.
• Cookies and similar technologies: we use cookies and local storage that keep you signed in and make the Service work. [TBD: list any analytics or non-essential cookies, if any are used. If none are, say "We do not use advertising or cross-site tracking cookies."]

We don't buy personal information from data brokers.

4. How we use information

We use information to:

• Provide the Service. This means building and publishing schedules, showing day sheets, routing cover swaps to Admins for approval, handling time-off requests, and sending change alerts by email and in the app when a schedule that affects you changes.
• Run accounts and billing. This includes creating accounts, sending invites, processing subscriptions, sending trial and renewal reminders, and handling failed payments.
• Keep the Service secure. This includes verifying users, preventing fraud and abuse, and stopping bots.
• Support you. We use it to answer questions and fix problems.
• Improve the Service. We use basic usage data to understand how features are used and to fix bugs.
• Send service messages. These include account, security, billing, and policy notices. We don't send marketing email to Staff Members. [TBD: confirm whether you'll send product or marketing email to Admins, and how they can opt out.]
• Meet legal obligations and enforce our Terms of Service.

We do not sell personal information, and we do not use it for targeted advertising.

5. How we share information

We share information only in the following ways.

With service providers who help us run CallBoard. They may use the information only to provide their services to us:

Within your organization. Admins can see the schedule, time-off, and account information of the people in their organization's account. Staff Members can see the schedules their organization publishes to them. Depending on your organization's settings, that may include coworkers' names and assignments.

For legal reasons. We may share information to comply with the law, valid legal process, or a government request, or to protect the rights, safety, or property of CallBoard, our users, or others.

In a business transfer. If CallBoard is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that deal. This policy, or one that protects your information at least as well, will continue to apply to it.

With your permission. We'll share information in other ways if you or your organization tells us to.

6. How long we keep information

• Active accounts: we keep Customer data while the account is active.
• After cancellation: when a Customer cancels, we email an export of its data to the account owner first. We then keep the data for 90 days, in case the Customer changes its mind or needs anything else, and then delete it.
• Backups and logs: deleted data may stay in backups or system logs for a limited time until those copies are overwritten in the normal course. [TBD: backup/log retention period]
• Legal and billing records: we may keep some records, such as billing and tax records, for longer when the law requires it or when we need them to resolve disputes.

7. Security

We use reasonable technical and organizational safeguards to protect information. These include encryption in transit (HTTPS), access controls, and established infrastructure providers. [TBD: confirm and list specific measures, e.g. encryption at rest, role-based access, MFA for internal access.]

No system is perfectly secure, so we can't guarantee absolute security. If we learn of a security incident that affects your information, we'll notify affected Customers and others as the law requires.

8. Your choices and rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you
• Correct information that is inaccurate
• Delete your information
• Get a copy of your information in a portable format
• Object to or limit certain uses

How to make a request:

• If your organization invited you, contact your organization's Admin first, because they control the account. You can also contact us.
• Otherwise, email hello@callboard.work. We may need to verify your identity before we act on a request. We won't treat you differently for exercising your rights.

You can also update some profile details yourself in the app, and you can change some notification preferences. [TBD: confirm which alert settings users can change.]

9. Children

CallBoard is a workplace tool for adults. It is not directed to children, and we don't knowingly collect information from anyone under 18 [TBD: confirm age; 13 is the COPPA threshold, 18 is typical for B2B]. If you think a child has given us information, contact us and we'll delete it.

10. Where information is stored

CallBoard is based in the United States. Our primary database is hosted in Canada (Supabase, AWS ca-central-1), and information is also processed in the United States by our other providers. [TBD: confirm Vercel function region, or move the database to a U.S. region if you'd rather say U.S.-only.] If you use the Service from outside these countries, your information will be transferred to and processed in Canada and the U.S.

11. Changes to this policy

We may update this policy from time to time. When we do, we'll change the "Last updated" date above. If a change is significant, we'll notify Admins by email or in the app before it takes effect.

12. Contact us

CALLBOARD LLC

Email: hello@callboard.work

Mailing address: [TBD address]