Privacy Policy

1. Who We Are

Careocity Inc. ("Careocity," "we," "us," or "our") is a technology marketplace company incorporated in Wyoming and operating in California. We operate the Careocity platform (the "Platform"), a mobile and web-based application that connects Care Recipients and their Decision Makers with independent Care Ambassadors ("Care Ambassadors") for non-medical in-home care services.

Careocity is the data controller for personal information collected through the Platform. We are not a home care agency. Care Ambassadors are independent contractors who use the Platform; they are not employees, agents, or representatives of Careocity Inc.

Contact Information: Careocity Inc., 1309 Coffeen Avenue, Ste. 1200, Sheridan, WY 82801 | connect@careocity.co

2. Information We Collect

We collect personal information in three ways: information you provide directly, information collected automatically when you use the Platform, and information received from third parties.

A. Information You Provide

• Identity information: full name, date of birth, profile photo
• Contact information: email address, phone number, residential address
• Account credentials: username, password (stored in hashed form)
• Payment information: billing address, payment method details (processed and stored by our PCI-compliant payment processor; Careocity does not store full card numbers)
• Care Recipient information: care needs, health conditions relevant to care matching, mobility considerations, preferences
• Care Ambassador information: California HCA registration number and status (if applicable), background check consent and results, professional experience, service availability
• Communications: messages sent through in-platform messaging, support tickets, feedback and reviews
• Identity verification documents: government-issued ID submitted for identity verification

B. Information Collected Automatically

• Device and technical data: device type, operating system, browser type, IP address, device identifiers
• Usage data: pages and features accessed, session duration, clicks and interactions, booking history
• Location data: approximate location derived from IP address; precise location only if you grant permission in your device settings
• Log data: access times, error logs, platform events

C. Information from Third Parties

• Background check providers: results of criminal background checks conducted with your consent prior to Care Ambassador onboarding
• California Department of Social Services: HCA registration verification
• Payment processors: transaction confirmations, payment status
• Identity verification services: identity document verification results

D. Categories of Personal Information (CCPA)

The following table summarizes the categories of personal information we collect as defined under the CCPA:

3. How We Use Your Information

We use personal information for the following purposes:

Platform Operations

• Creating and managing user accounts
• Facilitating Care Ambassador matching based on Care Recipient needs, location, and Care Ambassador availability and credentials
• Processing bookings, payments, and refunds
• Enabling in-platform messaging between Care Recipients/Decision Makers and Care Ambassadors
• Verifying Care Ambassador HCA registration and identity prior to any match

Safety and Trust

• Conducting and reviewing background checks (Care Ambassadors)
• Investigating reports of misconduct, abuse, or safety concerns
• Complying with mandatory elder abuse reporting requirements under California law (Welfare & Institutions Code §15630 et seq.)
• Enforcing our Terms and Conditions and Community Guidelines

Communication

• Sending booking confirmations, reminders, and session updates
• Delivering platform notifications and policy updates
• Responding to support requests and feedback
• Sending marketing communications (only with your consent; you may opt out at any time)

Legal and Compliance

• Complying with applicable California and federal law
• Responding to lawful legal process, subpoenas, or government requests
• Establishing, exercising, or defending legal claims

Platform Improvement

• Analyzing usage patterns to improve platform features and matching quality
• Conducting internal research and analytics
• Developing new features and services

4. How We Share Your Information

Careocity does not sell your personal information. We share personal information only as described below:

A. With Other Platform Users (Necessary for Service)

Care Recipients and Decision Makers see Care Ambassador profiles, including name, photo, credentials summary, ratings, and availability. Care Ambassadors see the Care Recipient's first name, care needs summary, and location (neighborhood level) prior to booking confirmation, and full address only upon confirmed booking.

B. With Service Providers

We share personal information with third-party service providers who perform functions on our behalf, under data processing agreements that restrict their use of your data:

• Payment processors (payment handling)
• Background check providers (Care Ambassador screening)
• Identity verification providers (account verification)
• Cloud infrastructure providers (data storage and hosting)
• Analytics providers (platform usage analysis)
• Customer support tools (support ticket management)
• Email and notification providers (communications delivery)

C. For Legal Reasons

We may disclose personal information when required by law, including in response to subpoenas, court orders, or government investigations. In elder care contexts, California law requires mandatory reporting of suspected abuse, neglect, or exploitation of dependent adults and elders. Careocity will comply with these obligations, which may involve disclosing information without prior notice to you.

D. Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of Careocity's assets, personal information may be transferred to the successor entity. We will notify users via platform notification or email if such a transfer occurs and the Privacy Policy materially changes as a result.

E. With Your Consent

We share personal information with third parties when you have given us specific consent to do so, such as when you authorize a third-party integration with your account.

5. Sensitive Personal Information

Careocity collects certain categories of sensitive personal information as defined under the CPRA, including:

• Government-issued ID numbers (for identity verification)
• Precise geolocation (only with your express consent, for session matching)
• Health-related care information provided by Care Recipients or Decision Makers

We use sensitive personal information only for the purposes for which it was collected — specifically, to operate and improve the Platform, verify Care Ambassador credentials, facilitate appropriate matching, and comply with applicable law. We do not use sensitive personal information for advertising or profiling unrelated to care matching. California residents have the right to limit our use and disclosure of sensitive personal information. See Section 10.

6. Data Retention

We retain personal information for as long as necessary to provide the Platform services and fulfill the purposes described in this Privacy Policy, or as required by law. Our general retention framework:

When personal information is no longer required, we securely delete or anonymize it. Anonymized or aggregated data that cannot reasonably identify you may be retained indefinitely for analytics and platform improvement purposes.

7. Data Security

Careocity implements technical, administrative, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. These include:

• Encryption of personal information in transit (TLS) and at rest
• Access controls limiting personal information access to authorized personnel with a need to know
• Regular security assessments and penetration testing
• Incident response procedures for data security events
• Vendor security requirements in service provider contracts

No method of transmission or storage is 100% secure. If you believe your account has been compromised, contact us immediately at connect@careocity.co.

In the event of a data breach affecting California residents, we will comply with California's data breach notification requirements under Civil Code §1798.82, including notifying affected individuals and, where applicable, the California Attorney General.

8. Cookies and Tracking Technologies

Careocity uses cookies and similar tracking technologies to operate and improve the Platform. We use:

• Essential cookies: Required for Platform functionality including login sessions, booking flow, and payment processing. Cannot be disabled.
• Analytics cookies: Used to understand how users interact with the Platform (e.g., which features are used most). We use anonymized, aggregated data for this purpose.
• Preference cookies: Store your Platform settings and preferences.

We do not use third-party advertising cookies or allow advertisers to track you across the Platform. You can manage cookie preferences through your browser settings. Disabling essential cookies will impair Platform functionality.

California residents have the right to opt out of the sharing of personal information for cross-context behavioral advertising. Careocity does not engage in cross-context behavioral advertising.

9. Children's Privacy

The Careocity Platform is intended for users 18 years of age or older. We do not knowingly collect personal information from individuals under 18. If we become aware that a minor has provided personal information, we will delete it promptly. If you believe a minor has submitted information to us, please contact connect@careocity.co.

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights regarding your personal information:

A. Right to Know

You have the right to request that we disclose: the categories and specific pieces of personal information we have collected about you; the categories of sources from which we collected it; the business or commercial purposes for collecting it; and the categories of third parties with whom we share it.

B. Right to Delete

You have the right to request deletion of personal information we have collected from you, subject to certain exceptions (e.g., information we are required to retain by law or needed to complete a transaction).

C. Right to Correct

You have the right to request correction of inaccurate personal information we maintain about you.

D. Right to Opt Out of Sale or Sharing

Careocity does not sell personal information. We do not share personal information for cross-context behavioral advertising. If our practices change, we will update this Policy and provide you with a clear opt-out mechanism.

E. Right to Limit Use of Sensitive Personal Information

You have the right to direct us to use your sensitive personal information only for the purposes of providing the Platform services you have requested, complying with applicable law, and as otherwise permitted under the CPRA.

F. Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights. We will not deny services, charge different prices, or provide a lower quality of service because you exercised a right under the CCPA/CPRA.

G. How to Submit a Request

To exercise any of your California privacy rights, submit a verifiable consumer request by:

• Email: connect@careocity.co (include "Privacy Rights Request" in the subject line)
• Phone: 1-574-227-3247 (Monday–Friday, 9:00 AM–5:00 PM PT)

We will respond to verifiable requests within 45 days. If we require more time (up to an additional 45 days), we will notify you of the extension and the reason. We do not charge a fee for processing privacy rights requests unless they are manifestly unfounded, excessive, or repetitive.

We must be able to verify your identity before processing a deletion or disclosure request. We will use information already in our system to verify you and may request additional information for high-sensitivity requests.

H. Authorized Agents

You may designate an authorized agent to submit privacy requests on your behalf. We will require written proof of the agent's authorization and may verify your identity directly before processing the request.

11. Third-Party Links and Integrations

The Platform may contain links to third-party websites or services. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access through or in connection with the Platform.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email (to the address on file) and/or by a prominent notice on the Platform at least 30 days before the changes take effect. Your continued use of the Platform after the effective date of the updated Policy constitutes your acceptance of the changes.

The "Last Updated" date at the top of this Policy reflects the most recent revision. We maintain an archive of prior versions, available upon request.

13. Market Expansion

Careocity currently operates exclusively in California. This Privacy Policy is specifically designed to comply with California law. When Careocity expands to additional states, this Policy will be updated to reflect applicable state privacy laws in those jurisdictions. Market-specific supplements will be issued where required.

14. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact us:

• Careocity Inc. | 1309 Coffeen Avenue, Ste. 1200, Sheridan, WY 82801
• Email: connect@careocity.co
• Phone: 1-574-227-3247

If you are a California resident and believe we have not responded adequately to your privacy rights request, you have the right to file a complaint with the California Privacy Protection Agency (CPPA) at cppa.ca.gov.

Careocity Inc. | Privacy Policy | Effective June 1, 2026 | Confidential