Privacy Policy
Last updated
This draft is under legal review and may change.
This policy explains what personal information LocalCareProvider collects, why we collect it, who we share it with, and the choices and rights you have. It applies to this website and to the emails and verification calls or texts we send. It doesn’t apply to providers’ own websites or to other sites we link to.
It is part of our Terms of Use. Words like “we” and “us” mean [confirm: company legal name], the company that runs LocalCareProvider.
The short version
- We don’t sell your personal information, and we don’t share it for advertising.
- We don’t use advertising or analytics cookies. The only cookies we set are for signing in.
- Reviews are public, but they never show your name or email address.
- We collect only what we need to run the directory, publish reviews, and verify providers.
- You can ask us to show you, correct, or delete your information.
What we collect
You can browse the site without an account. Here is what we collect, and when:
- Account details: your email address, and a display name if you add one. Your display name may be shown to the other members of a provider team you belong to and in team invitations you send.
- Google sign-in: if you sign in with Google, we receive the name, email address, and profile picture on your Google account, and we store the sign-in tokens Google gives us, encrypted. [confirm: whether Google sign-in is offered at launch]
- Sign-in codes: the one-time code we email you. It is stored encrypted and expires after 5 minutes.
- Sign-in and security records: when you sign in, we record your session with your IP address and the type of browser and device you use. To limit abuse, we count recent requests from each IP address and sign-in attempts for each email address. Some of these counters are stored with the IP address itself; the others are stored under a keyed hash (a scrambled value that can’t be turned back into the address without our secret key). In our audit log of account, moderation, and provider actions, we store a keyed hash of your IP address, never the address itself.
- Reviews and replies: your rating, title, and text, and each edit you submit; your relationship to the resident or patient; when the care took place; and our moderation decisions. Providers’ replies, and reports that a review breaks a guideline, are kept the same way.
- Provider claims: the facility you claim, your job title and relationship to it, any note you add, the documents you upload to show you can act for it, and the result of phone verification. Verification codes go by call or text to the phone number CMS lists for the facility, not to your personal number.
- Provider profiles: the details a provider’s team adds to its listing, such as a description, a website, and an admissions phone number and email address, with a history of every change and who made it.
- Team invitations: when you invite a colleague to your provider team, the email address you enter and the role you offer. We email the invitation to that address.
- Photos and floor plans: the images providers upload, with the uploader’s rights and consent confirmations and when they were made. We remove location (GPS) and camera details from every copy we publish. The original file, which can still contain those details, is kept in private storage and is never shown or published.
- Usage logs: like most websites, our servers log requests (the page, the time, your IP address, your browser type, and any errors) to keep the site working and secure.
- Messages: anything you send us by email.
We don’t ask for medical records, Social Security numbers, insurance details, or payment information. Please don’t include them in reviews or messages.
How we use information, and why
We use personal information only for these purposes:
- To give you what you ask for: signing you in, publishing your reviews and replies, verifying claims, and showing providers’ profiles. (We need it to provide the service.)
- To keep the site safe and fair: stopping bots, spam, fake reviews, and fraud; moderating content; enforcing our terms; and keeping an audit trail of who changed what. (These are our legitimate interests, and they protect families and providers too.)
- To run and improve the site: fixing errors and understanding, in aggregate, how the site is used. (Legitimate interests.)
- To send you emails about your account and activity, such as sign-in codes, review decisions, claim updates, and team invitations. We don’t send marketing emails; we would ask you first.
- To meet legal obligations: responding to lawful requests, keeping required records, and protecting our rights. (Legal obligation.)
- Anything else only with your consent, which you can withdraw at any time.
Cookies and similar technology
We use cookies only for signing in:
- The session cookie keeps you signed in. It is named lcp.session_token, or __Secure-lcp.session_token on secure connections. We set it only when you sign in, scripts on the page can’t read it, and it expires after about a week without use, or when you sign out.
- If you sign in with Google, short-lived cookies are also used while that sign-in completes.
We don’t use advertising cookies, third-party analytics, tracking pixels, or cross-site tracking.
If you change settings in the Accessibility panel (in the footer), your choices are saved in your browser’s local storage on your device. They are never sent to us.
When you sign in or claim a listing, we use Cloudflare Turnstile to check that you are a person, not a bot. Turnstile looks at information about your browser and device, and our server sends Cloudflare your IP address along with the check. Cloudflare handles this information under its own privacy policy. [confirm: Cloudflare Turnstile cookies and data use]
Service providers we use
These companies help us run the site. They may use your information only to provide their service to us:
- Postmark: sends our emails, such as sign-in codes, notifications, and team invitations. It receives the recipient’s email address and the message.
- Twilio Verify: calls or texts a verification code to the facility phone number listed by CMS when a provider claims a listing.
- Cloudflare Turnstile: the bot check described above. It receives your IP address and information about your browser and device.
- Google: if you choose to sign in with Google, Google confirms your account and sends us the details described above. [confirm: whether Google sign-in is offered at launch]
- File storage and content delivery ([confirm: storage and CDN provider]): an S3-compatible service that stores uploaded photos, floor plans, and claim documents, and delivers approved photos to visitors. Claim documents and original photos are stored privately.
- Hosting ([confirm: hosting provider]): runs our servers and database.
- Call tracking ([confirm: call-tracking provider, and whether calls are recorded]): if the site shows a “Talk to a local advisor” phone number, calls to it go through this service.
Provider information such as ratings and inspection results comes from public data published by the Centers for Medicare & Medicaid Services (CMS). We download that data; we don’t send your information to CMS.
When we share information
We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We share it only:
- publicly, when you choose to post it: published reviews (without your name or email address), providers’ replies, approved photos, and provider profiles;
- with the service providers listed above, to run the site;
- when the law requires it, for example to respond to a valid subpoena or court order, or when we believe in good faith that it is needed to protect someone’s safety, prevent fraud, or protect our rights;
- with a company that acquires or merges with us, which would have to keep this policy’s promises for the information it receives (we would tell you first) [confirm: notice before an acquisition transfer];
- with your consent.
Providers see your review the same way everyone else does. We don’t give them your name or email address.
How long we keep information
We keep your account, and the reviews, replies, photos, and profile details you post, for as long as your account exists, so the site keeps working for you.
We also keep these records, to keep the site secure, to look into abuse, and to show what we decided and why:
- sign-in sessions, with the IP address and browser type recorded for each;
- the counters we use to limit repeated requests, some of which include an IP address;
- server logs;
- our audit log of account, moderation, and provider actions, which can include the text of a review, reply, or profile from before and after a change;
- claim documents, original photo files, and the text of reviews and replies that we declined or removed;
- backups of our database, which contain copies of all of the above.
We haven’t yet set a fixed period for each of these records, so for now we keep them. When we set the periods, we will list them here. [confirm: retention period for each kind of record]
There is no button to close your account yet. To close it, email [confirm: privacy contact email] from the address on your account. [confirm: what happens to a closed account’s reviews, claims, and roles]
Your choices and rights
Wherever you live in the United States, you can ask us to:
- tell you what personal information we have about you and give you a copy;
- correct information that is wrong;
- delete your information or close your account.
You can edit your reviews yourself from your account. For anything else, email [confirm: privacy contact email] from the address on your account, or tell us which address it is, so that we can check the request is really from you. You may also have an authorized agent ask for you. We will answer within 45 days [confirm: response times], and we will never treat you differently for using your rights. If we can’t do what you ask, we will tell you why, and you can ask us to look at it again.
California residents (CCPA and CPRA)
If you live in California, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, gives you these rights:
- Right to know: what personal information we collect, use, and disclose, and why.
- Right to access and to a copy of your personal information.
- Right to correct inaccurate personal information.
- Right to delete personal information we collected from you.
- Right to opt out of the sale or sharing of your personal information (“Do Not Sell or Share My Personal Information”). We do not sell or share personal information, including information about anyone under 16, so there is nothing to opt out of. We also treat a Global Privacy Control signal from your browser as an opt-out request. [confirm: Global Privacy Control handling]
- Right to limit the use of sensitive personal information. We use sensitive information, such as your account sign-in and anything health-related you write in a review, only to provide the service you asked for and to keep it secure.
- Right not to be discriminated against for using these rights.
In the past 12 months we collected these categories: identifiers (email address, display name, IP address); internet activity (sign-in records and usage logs); content you post (reviews, replies, photos, and provider profiles); professional information (a claimant’s job title and relationship to a facility, claim documents, provider profile contact details, and team invitations); and sensitive personal information (account sign-in, and health-related details if you include them in a review). We collect them from you, from your browser, and from the service providers listed above, for the purposes in “How we use information, and why”. We disclose them only as described in “When we share information”, and we keep them as described in “How long we keep information”.
To use your rights, email [confirm: privacy contact email]. We will confirm we received your request within 10 business days and answer within 45 days. [confirm: response times]
Washington consumer health data (My Health My Data Act)
Reviews can describe health care experiences, such as a stay in a skilled nursing facility or care from a hospice. Under Washington’s My Health My Data Act, information like that can be “consumer health data”. This section explains how we handle it, and it applies to everyone, not only Washington residents. [confirm: counsel: whether these rights apply to everyone]
- What we collect: only the health-related details you choose to write in a review or a message to us, and the fact that you reviewed a particular provider. We collect them only when you write them; we don’t ask for them anywhere else.
- Why: to publish your review and to moderate it. We don’t use it for any other purpose.
- Your consent: [confirm: counsel: how we ask for and record consent to collect and to publish consumer health data]
- What we don’t do: we don’t infer health conditions from your reviews or from the pages you visit, we don’t build health profiles, we don’t sell consumer health data or use it for advertising, and we don’t use geofencing around health care locations.
- Who receives it: the public, for published reviews (without your name or email address), and the service providers listed above, only to run the site.
You have the right to confirm whether we collect or share your consumer health data, to see it and get a list of everyone we have shared it with, to withdraw your consent, and to have it deleted. [confirm: counsel: how deletion requests reach backups] If you withdraw your consent, we take down your review. To use these rights, email [confirm: privacy contact email]. We will answer within 45 days. [confirm: response times] If we decline your request, you can appeal by replying to our answer, and you can also contact the Washington State Attorney General.
[confirm: whether a separate Consumer Health Data Privacy Policy page is needed, for counsel]
Children
LocalCareProvider is for adults choosing care and is not directed at children or minors. You must be 18 or older to create an account. We don’t knowingly collect personal information from children under 13. If you believe a child has given us personal information, contact us and we will delete it.
How we protect information
We use encrypted connections (HTTPS), one-time sign-in codes that expire quickly, rate limits and bot checks, and private storage for claim documents and original photos. Uploaded images are processed into new copies before anyone sees them. Our team’s access is limited to what they need, and their actions are recorded in an audit log.
No system is perfectly secure. If a breach affects your personal information, we will tell you as the law requires.
Where information is stored
LocalCareProvider is a directory of US providers, and we host the site and its database in the United States. [confirm: hosting and storage regions] Some of the service providers listed above, such as Cloudflare, Postmark, and Twilio, may process information in other countries. If you visit from outside the US, your information will be handled in the US and possibly elsewhere, where privacy laws may differ from those where you live.
Changes to this policy
We may update this policy as the site or the law changes. We will post the new version here with a new “Last updated” date. If a change is significant, we will also tell you on the site or by email before it takes effect. [confirm: advance notice of significant changes] We will ask for your consent before using consumer health data in a new way.
Contact us
Questions or requests about your privacy? Contact us:
- Email: [confirm: privacy contact email]
- Mail: [confirm: company legal name], [confirm: mailing address]