1. Who We Are
The CloudNook services (the “Services”) are provided by Masterful Ventures LLC, a New Mexico limited liability company, doing business as “CloudNook” (the “Company,” “we,” “us,” or “our”). References in this Policy to “CloudNook” are references to Masterful Ventures LLC operating under that trade name. For the purposes of applicable data protection laws, the Company is the controller of Personal Information collected through the Services, except where this Policy states that we act as a service provider or processor on behalf of a Client.
2. Scope
This Policy applies to Personal Information we collect through the websites we operate at mycloudnook.com and its subdomains (the “Sites”), the CloudNook matching platform and directory, our webinars, training programs, marketing communications, and any related online or offline interactions with prospective or current Clients, applicants, medical virtual assistants, and website visitors (each, a “user”). This Policy does not apply to third-party sites, services, or platforms that are linked from or integrated with the Services and that have their own privacy notices.
3. Information We Collect
3.1 Information You Provide
- Account and contact information, including your name, email address, telephone number, business name, role, country, and, where applicable, your practice specialty.
- Applicant information, including your resume, professional credentials, licensure and certification numbers, headshot, work history, references, assessment responses, and video submissions provided during the application and vetting process.
- Client and engagement information, including the scope of work, preferences, hours, and materials you provide to enable us to match you with a medical virtual assistant.
- Billing information necessary to process payments, including billing name, address, and last four digits and expiration of the payment card. Full card data is collected and stored by our payment processors and is not retained by us.
- Communications, including messages you send us by email, form, webinar chat, or telephone, and records of those communications.
3.2 Information Collected Automatically
- Device and log data, including IP address, browser type, operating system, referring URL, pages viewed, and dates and times of access.
- Cookies and similar technologies used to operate and secure the Sites, remember preferences, and measure performance. You may disable cookies through your browser, but portions of the Services may not function properly.
- Analytics data from providers that help us understand how users interact with the Sites in aggregate.
3.3 Information From Third Parties
We may receive information about you from references, background-check providers, credentialing bodies, licensing authorities, and public sources when necessary to verify applicant qualifications or to prevent fraud.
4. Protected Health Information
CloudNook is not a healthcare provider and does not maintain patient records. In the ordinary course of the Services, we do not solicit and we do not want to receive Protected Health Information (“PHI”) as that term is defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Where a Client’s use of the Services or of a placed medical virtual assistant necessarily involves the disclosure of PHI, the Client is the covered entity or business associate, and the parties will execute a written Business Associate Agreement before any PHI is disclosed. Any incidental PHI submitted to the Company outside of an executed Business Associate Agreement will be handled with reasonable safeguards and returned or destroyed.
5. How We Use Information
We use Personal Information for the following purposes:
- To provide, operate, secure, and improve the Services, including matching, vetting, onboarding, and support.
- To verify credentials and qualifications of applicants and to conduct background and reference checks.
- To communicate with you about your account, transactions, service updates, and support requests.
- To send marketing communications you have not opted out of, subject to applicable law.
- To comply with legal obligations, respond to lawful requests, and enforce our agreements.
- To detect, prevent, and investigate fraud, abuse, and security incidents.
6. Legal Bases for Processing
Where the General Data Protection Regulation, the UK GDPR, or a similar law applies, we process Personal Information on the following legal bases: performance of a contract with you or steps taken at your request prior to entering into a contract; our legitimate interests in operating and improving the Services and protecting the Company; compliance with a legal obligation; and, where required, your consent, which you may withdraw at any time.
7. Sharing of Information
We do not sell Personal Information. We share Personal Information as follows:
- With Clients and applicants to the extent necessary to facilitate a match or engagement (for example, sharing an applicant’s profile with a prospective Client).
- With service providers that perform functions on our behalf under written contracts requiring confidentiality and use limitations, including hosting, analytics, payment processing, email delivery, and customer support.
- For legal reasons, when we reasonably believe disclosure is necessary to comply with law, valid legal process, or a governmental request, or to protect the rights, property, or safety of the Company, our users, or the public.
- In connection with a business transaction, such as a merger, financing, acquisition, or sale of assets, subject to customary confidentiality protections.
8. International Transfers
The Company is based in the United States, and our placed medical virtual assistants are located in the Republic of the Philippines. Personal Information may therefore be transferred to, and processed in, jurisdictions that provide different levels of data protection than your country of residence. Where required by law, we implement appropriate safeguards, including standard contractual clauses, for such transfers.
9. Data Retention
We retain Personal Information for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. When Personal Information is no longer required, we will delete or de-identify it in a commercially reasonable manner.
10. Security
We maintain administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, disclosure, alteration, or destruction. No method of transmission or storage is completely secure, and we do not guarantee absolute security.
11. Your Rights
Depending on where you reside, you may have the right to access, correct, delete, port, or restrict processing of your Personal Information, and to object to certain processing. Residents of California, Colorado, Connecticut, Utah, Virginia, and other jurisdictions with comprehensive privacy laws may also have the right to opt out of targeted advertising and certain profiling. To exercise a right, contact us using the details in Section 15. We will respond within the time required by applicable law. We do not discriminate against users for exercising their rights.
12. Children’s Privacy
The Services are not directed to children under 16, and we do not knowingly collect Personal Information from children under 16. If you believe a child has provided us with Personal Information, please contact us and we will take appropriate steps to delete it.
13. Third-Party Sites and Services
The Sites may contain links to third-party sites and integrations with third-party services. This Policy does not apply to those sites or services, and we are not responsible for their content or practices.
14. Changes to This Policy
We may update this Policy from time to time. If we make material changes, we will provide notice by posting the updated Policy on the Sites and updating the Effective Date above. Your continued use of the Services after the updated Policy takes effect constitutes acceptance of the updated Policy.
15. Contact
Questions or requests concerning this Policy may be directed to:
Masterful Ventures LLC (d/b/a CloudNook)
Attn: Privacy
Email: privacy@mycloudnook.com