Inclusion Factor (If! Inc.) Privacy Policy

Effective Date: [Feb 2024]

Last Updated: [July 2025]

Introduction

Inclusion Factor, Inc. ("Inclusion Factor," "we," "our," or "us") is committed to protecting the privacy and security of personal and health information in accordance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the HIPAA Privacy, Security, and Breach Notification Rules, and other applicable privacy laws. This Privacy Policy outlines how we collect, use, disclose, and protect protected health information (PHI) and employee data as a HIPAA Covered Entity.

1. Scope

This Privacy Policy applies to personal and protected health information (PHI) we collect in our role as a Covered Entity providing healthcare services or functions, and to personal information collected from our employees for internal operations, including communication, workforce optimization, and process improvement.

2. Information We Collect

a. Protected Health Information (PHI):
We collect PHI directly from patients and other sources as needed to provide services. This includes: names, contact details, health records, insurance information, and other PHI.

b. Employee Information:
We collect employee information such as contact details, schedules, performance data, phone numbers (for SMS), and data used for workforce planning.

3. How We Use Information

For Healthcare Services:
- To provide care coordination, billing, analytics, and patient engagement
- To improve service quality using de-identified data in AI/ML tools

For Internal Business Operations:
- To manage shifts, communications, and training
- To send SMS alerts for shift changes
- To develop AI tools using de-identified employee data

We do not share personal or mobile information with third parties for marketing purposes, and such sharing is never permitted, even with consent.

We do not transfer consumer data to any external organizations under any circumstances.

4. Legal Basis for Processing

We process PHI in accordance with HIPAA as a Covered Entity. Permitted uses include treatment, payment, operations, and legal compliance. Employee data is processed for legitimate business purposes and legal obligations.

5. Disclosure of Information

We disclose information only as needed to care providers, insurers, employees, and legal authorities. We do not sell or rent personal or health data.

6. Communications

We may contact employees via SMS for shift updates and availability. By providing a number, you consent to receive these messages. Message/data rates may apply. You can opt out by replying STOP or contacting privacy@inclusionfactor.com. For help, reply HELP or contact privacy@inclusionfactor.com.

7. Use of Data for Artificial Intelligence and Machine Learning

We use de-identified/aggregated data to develop AI/ML tools for healthcare and workforce optimization. These models do not rely on identifiable information without legal authorization or consent.

8. Data Security

We use encryption, access controls, and trained staff to protect PHI and personal data in compliance with HIPAA Security Rule requirements. This includes regular audits and staff training to ensure ensure unauthorized sharing of user data is prevented.

9. Data Retention

Data is retained as long as necessary for operational, legal, and regulatory purposes.

10. Your Rights Under HIPAA

Patients have rights to access, amend, and restrict PHI, and request accounting of disclosures. Employees may have access and correction rights under labor laws. Contact privacy@inclusionfactor.com to exercise these rights.

11. Message Frequency

Message frequency will vary based on shift changes and operational needs, but you may receive several messages per week..

12. Your Rights Under HIPAA

13. Changes to This Policy

We may revise this policy periodically. Updates will be posted with the new date. Continued use implies acceptance.

14. Contact Us

Inclusion Factor, Inc. (If! inc)
Attn: Privacy Officer
6770 Stillwater Boulevard #200
privacy@inclusionfactor.com
Phone: 651-300-0182