PDS Connect Privacy Policy

Last Updated and Effective: 8/29/2025

Introduction

This PDS Connect Privacy Policy ("Policy") explains how PDS Health ("PDS Health," "we," "us," or "our") collects, uses, discloses, and protects information when Workforce Members use the PDS Connect mobile and web applications (together, "PDS Connect" or the "Services").

• Who this applies to: Current employees, contractors, and other workforce members who access PDS Connect ("Workforce Members" or "you"). PDS Connect is not offered to or intended for use by non-Workforce Members.
• What this covers: Information collected via PDS Connect only (including the PDS Connect mobile app(s) and web app).
• What this does not cover: Broader workforce/HR data collected outside PDS Connect (e.g., payroll, benefits, recruiting). For those topics, refer to the Workforce Member Privacy Policy made available to you in connection with your working relationship with PDS Health.

If there is a conflict between this Policy and the Workforce Member Privacy Policy, the Workforce Member Privacy Policy governs for workforce/HR data not collected via PDS Connect.

Information We Collect Via PDS Connect & How We Use It

Information Collected Automatically

Categories of Data	Description	Purpose
Contact Information	Your name, address, region, email, phone number, contact preference	To communicate with you, process your request, and provide PDS Connect
Communications or interactions	Information regarding your communications via PDS Connect, submissions, preference settings	To communicate with you and provide PDS Connect
Network activity information	Your device model, browser type, operating system, region, IP address, pixel tags, cookies	Optimize website and app performance and improving user experience and security
Website & App Analytics Information	Analytics regarding mobile and web app usage (through JavaScript, SDKs, pixel, web beacons, cookies, and similar technologies)	To ensure reliability, safety, and security of PDS Connect and to perform provide support
Diagnostic Data	Logs for identifying and troubleshooting unexpected software or connectivity issues, and other debugging log reports	To maintain and improve software issues, diagnostics and support, security and improvement of PDS Connect

Information Collected If You Grant Optional Device Permissions

Depending on your OS settings and features you choose to use, PDS Connect may collect:

• Precise Geolocation: If you enable location permissions via the mobile app, we may collect precise geolocation to power location-enabled features. You can disable this in your OS/app settings at any time.
• Camera/Photos/Media: To allow you to capture or upload images (e.g., incident photo, facility issue, profile image). Images are used only for the feature you initiate.
• Microphone: To capture audio only if you initiate a feature that requires it (e.g., voice note).
• Contacts/Calendar: If a feature allows inviting colleagues or scheduling, you may opt-in to share contacts or calendar entries; access is limited to enabling the requested feature.
• Push Notification Token: A device token used to deliver push notifications.

We do not enable third-party advertising via the app and do not collect advertising IDs for marketing.

How We Use Information Collected via PDS Connect

We use information collected through PDS Connect to:

• Provide & Operate PDS Connect (account provisioning, authentication, in-app features you select, push notifications you enable).
• Maintain & Improve app performance, usability, and accessibility (debugging, analytics, A/B testing of internal features).
• Security & Integrity (fraud/misuse detection, access control, auditing, incident response, and to protect the safety of Workforce Members and Company assets).
• Support & Communications (respond to in-app support requests; send service or security alerts; deliver push notifications consistent with your settings).
• Compliance with applicable laws, enforce our policies/terms, and exercise or defend legal claims.
• Location-Enabled Features you opt into. We do not use precise geolocation for cross-context behavioral advertising.

We may de-identify or aggregate information for analytics and to improve services. We will not attempt to re-identify de-identified data except to test our de-identification processes.

PDS Health uses administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the data and the threats posed. We have implemented a variety of safety and security features to consistently protect your information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure or compromised, please immediately notify us by using the contact information below.

Disclosures of Information Collected via PDS Connect

We disclose information collected through PDS Connect in these contexts:

• Third party service providers: Companies who provide services such as website/app hosting, data analysis and storage, information technology and related infrastructure, customer service, diagnostics, maintenance or related services, and other similar services.
• Affiliates: Within our corporate family for internal operations consistent with the course and scope of your role within the PDS Workforce.
• Legal, Safety & Compliance: To comply with law, legal process, or lawful requests (e.g., subpoenas), to protect the rights, property, or safety of Company, Workforce Members, or others, and to detect/prevent fraud or security incidents.
• Business Transfers: In a merger, acquisition, reorganization, or similar transaction, information may be transferred subject to this Policy.

We do not sell Workforce Member personal information and do not share it for cross-context behavioral advertising. We do not collect sensitive personal data via the PDS Connect App other than precise geolocation if enabled, and only for the purpose of providing the features requiring precise geolocation.

Retention

We retain information collected via PDS Connect only as long as needed for the purposes described above, to comply with legal, accounting, or reporting requirements, to resolve disputes, or to enforce our agreements. Specific retention periods vary by category of data.

Your Privacy Rights

Access and Use of PDS Connect is provided to our Workforce Members in the course and scope of their working relationship with PDS Health. Depending on where you live, you may have certain rights with respect to the personal data collected/processed in connection with PDS Connect, as follows:

California Residents

California residents have a right to knowledge, access, and deletion of their personal data under the California Consumer Privacy Act (CCPA), subject to certain exceptions. California residents also have a right to opt out of the sale of their personal data by a business and a right not to be discriminated against for exercising one of their California privacy rights. PDS Health does not sell personal data collected or processed in connection with PDS Connect, and does not discriminate in response to privacy rights requests. PDS Health does not process sensitive personal information for a non-permitted purposes under the CCPA.

To exercise the above privacy rights, please visit our Privacy Rights Request Form or email Privacy@pacden.com.

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in this section. We will process the agent's request consistent with applicable law. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity and/or confirm that you provided the agent permission to submit the request. If you use an authorized agent to submit a request to exercise your rights, please have the authorized agent take the following steps in addition to the steps described above:

• Mail a copy of your signed written declaration authorizing the authorized agent to act on your behalf to Privacy@pacden.com; and
• Provide any information we request in our response to your email to verify your identity. The information requested will depend on your prior interactions with us and the sensitivity of the personal information at issue.
• If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

Please note that not all requests will be granted. Certain legal exceptions may apply, such as if we are unable to verify your identity, or if there are legal or contractual reasons that prevent us from fulfilling a deletion request. Regardless of the outcome, you will receive a written response that either details the actions we took or explains why no action was possible. If you are dissatisfied with our initial response, you may seek further review. To initiate an appeal, please contact us within 30 days of receiving our initial response using the method provided in the response. You should include a copy of your original request, our response, and a detailed explanation of why you are seeking reconsideration. You may also attach any additional supporting information and documents that you believe are relevant. We will review your appeal and provide a final determination within 60 days.

Contact Information

If you have any questions or concerns about this Policy or our data practices, you can contact us through the following means: