Introduction

Afya MD, LLC (“Afya MD” or “Company” or “We” or “Us”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website afyamd.com (collectively, our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect:

• On the Services.
• In email, text, and other electronic messages between you and the Services.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party including our affiliates and subsidiaries; or
• Any third party including our affiliates and subsidiaries, including through any application or content (including advertising) that may link to or be accessible from or on the Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using the Services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

CCPA NOTICE: We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services and partner websites, including information:

• By which you may be personally identified, such as name, date of birth, postal address, e-mail address, telephone number, social security number, employment test data, or any other identifier by which you may be contacted online or offline (“Personal Information”);
• That is about you but individually does not identify you, such as job search criteria/preferences; and/or
• About your internet connection, the equipment you use to access our Services, and usage details.

Categories of Personal Data We Collect

The Personal Data we collect about you may include the following (as categorized by CCPA):

• Identifiers you provide directly such as first and last name, email address, postal address, and/or phone number.
• Personal information categories identified in the California customer records statute such as first and last name, email address, postal address, and/or phone number.
• Protected classification characteristics under California law such as race, gender, or age
• Identifiers collected through use of the services, such as unique online or device identifiers, IP address, device or session IDs and information regarding your system configuration (operating system and version), network, and connected hardware (e.g., computer or mobile device and carrier) and software applications (e.g., other applications installed on mobile device).
• Internet and other network activity, such as browsing and search history; and interactions with a website or application.
• Employment information

We do not collect commercial information; biometric information; geolocation data; sensory data, or inferences drawn from other Personal Data.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies.
• From third parties that we contract with to provide services.

Information You Provide to Us

The information we collect on or through our Services may include:

• Information that you provide by filling in forms on our Services. This includes information provided at the time of subscribing to our service, requesting further services, or working with our recruiters. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Services.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.

Information We Collect Through Automatic Data Collection Technologies

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

• Details of your visits to our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Services.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• HubSpot: The Services use a HubSpot tracking code which uses cookies or similar technologies to track visitors and gather demographic information about them. HubSpot keeps track of the Services and pages you visit within HubSpot. This data is used to deliver customized content and promotions to users whose behavior indicates that they are interested in a particular subject area. Further information about HubSpot’s privacy policy may be obtained from https://legal.hubspot.com/privacy-policy.
• Other tracking codes may also be utilized.

The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Service and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Services according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Services.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). 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 Services. 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 Services.
• Web Beacons.Pages of our Services 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 the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or that you provide to us.

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Services are served by third-parties, including content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. We may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Services and their contents to you.
• To provide you with information, products, or services that you request from us, including through text messages, where you have opted in to receive text messages from Afya MD.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To notify you about changes to our Services or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Services.
• To fulfill any purpose we may describe when you provide the information or as otherwise set forth in the CCPA.
• For any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, 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 potential work placement sites.
• To a representative of a healthcare employer, such as a staffing agency or healthcare facility (collectively, “Entity Users”), that creates an account on our Services for the purpose of collaborating with healthcare talent, hiring a healthcare worker, storing and transferring information, communicating with current/prospective employees, and/or any other purpose described on our Services.
• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Afya MD’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Afya MD about users of our Services is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Services, we will transmit the contents of that email and your email address to the recipients.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Afya MD, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Text Message and Email Communications

When you provide Afya MD with your phone number and/or email address and opt in to receive information about job postings that you may be interested in, Afya MD will send you recurring informational and marketing text messages and/or emails related to job postings and updates, including text messages that may be sent using an automated telephone dialing system. You may opt-out of marketing text messages at any time by replying “STOP” to a Afya MD text message. Message and data rates may apply. You may opt out of marketing emails at any time using the unsubscribe link in the email.

Afya MD will also send you informational text messages and/or emails, which you cannot unsubscribe from as they contain important information about employment requirements and changes.

Communications from Entity Users

Our Services may allow you to receive job-related information from Entity Users, including to job postings, onboarding documents, and other communications. Afya MD will provide your personal information to Entity Users as necessary to enable these communications.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our services, you can opt-out by checking the relevant box located on the form on which we collect your data or by sending us an email stating your request to info@afyamd.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of period of employment with Afya MD.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by emailing us at info@afyamd.com.

California residents may have additional personal information rights and choices. Please see Afya MD’s Privacy Notice for California Residents below for more information.

We may share your Personal Data by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Data confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Afya MD has disclosed Personal Data for a business purpose to service providers, affiliates, and partners. In the prior 12 months, we have not sold or shared for a commercial purpose your Personal Data to third parties.

Accessing and Correcting Your Information

You can review and change your personal information by sending us an email at info@afyamd.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California residents may have additional personal information rights and choices. Please see Afya MD’s Privacy Notice for California Residents below for more information.

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 depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 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 Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Children Under the Age of 13

Our Services are not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. 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 believe we might have any information from or about a child under 13, please contact us at info@afyamd.com.

Your State Privacy Rights

We do not meet the conditions as outlined in Section 1798.140 of the California Consumer Privacy Act of 2018 (the “CCPA”) and therefore are not subject to CCPA requirements. We also do not meet the eligibility conditions outlined in the Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, Oregon Consumer Privacy Act, Texas Data Privacy and Security Act, or Montana Consumer Data Privacy Act and are therefore are not subject to the requirements of these laws. For specific information related to your ability to access and correct your personal information, see Accessing and Correcting Your Information above.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Afya MD disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

Correction Request Rights

You have the right to request that we correct any inaccurate personal data we maintain about you.

Deletion Request Rights

You have the right to request that Afya MD delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Fulfill the contract of employment in which you have engaged, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

• To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at info@afyamd.com.

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.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address you have specified or through a notice on the Website home 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 visiting our Website and this privacy policy to check for any changes. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this privacy policy, the ways in which Afya MD collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: AfyaMD.com

Email: info@afyamd.com

Postal Address: 2700 Post Oak Blvd 21st Floor, Houston, TX 77056