CareNgen Privacy Policy

Last Updated: May 14, 2026

1. Introduction

CareNgen LLC (“CareNgen,” “we,” “us,” or “our”) is committed to protecting the privacy of every individual who uses our platform and website. This Privacy Policy explains what information we collect, how we use it, with whom we share it, and what choices you have regarding your information. It applies to all users of the CareNgen website and platform, including employees accessing the platform through an employer-sponsored account and visitors to our corporate website.

Please read this Policy carefully. By using the Services, you acknowledge that you have read and understood this Policy.

2. Information We Collect

2.1 Information You Provide Directly

When you create an account, complete an intake assessment, or otherwise interact with the platform, we may collect:

• Name, email address, and contact information
• Account credentials
• Information about your caregiving situation, including details about your care recipient’s health status, functional needs, geographic location, and family structure
• Documents you choose to upload or store within the platform, such as advance directives or powers of attorney
• Communications you send to CareNgen through support channels or contact forms

Sensitive Personal Information: Some of the information described above — including details about a care recipient’s health status, medical conditions, functional limitations, and related family circumstances — may constitute “sensitive personal information” under applicable privacy laws, including the California Privacy Rights Act. CareNgen collects this information solely to provide the Services and does not use it for inferring characteristics about you, advertising, or other purposes beyond those stated in this Policy. You may contact us at [email protected] to request that we limit our use of your sensitive personal information to the purpose of providing the Services.

2.2 Information Collected Automatically

When you access the Services, we may automatically collect:

• Device type, browser type, and operating system
• IP address and approximate geographic location
• Pages visited, features used, and time spent within the platform
• Referring URLs and navigation paths
• Session identifiers and usage timestamps

This information is collected through standard web technologies including cookies, pixel tags, and server logs. For more information about our use of cookies and your choices, see Section 7.

2.3 Information From Employers

If you access the platform through an employer-sponsored account, your employer may provide us with basic identifying information — such as your name and work email address — for the purpose of establishing your account and verifying your eligibility for the program.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To provide, operate, and improve the Services
• To personalize your experience and generate relevant care guidance through automated and manual means
• To surface appropriate local provider recommendations based on your stated needs and location
• To communicate with you about your account, program updates, and relevant resources
• To respond to your support requests and inquiries
• To generate anonymized, aggregated workforce-level analytics for employer reporting purposes
• To ensure the security and integrity of the platform
• To comply with applicable legal obligations
• To conduct internal research and product development aimed at improving caregiving guidance quality

4. How We Do Not Use Your Information

CareNgen does not:

• Sell, rent, or trade your personal information to any third party for commercial purposes
• Share individually identifiable employee caregiving data with your employer under any circumstances
• Use your caregiving information for advertising or marketing targeting purposes
• Use your information to make decisions that produce legal or similarly significant effects on you without human review
• Use sensitive personal information for inferring characteristics or for any purpose other than providing the Services

5. Employer Reporting — Data Separation Policy

This section is important for employees accessing CareNgen through an employer-sponsored account.

CareNgen maintains a strict technical and operational separation between individual employee usage data and any analytics or reporting provided to employers. Employers receive only aggregated, anonymized data describing program utilization and workforce-level trends. No data that could identify an individual employee’s caregiving situation, platform activity, or personal circumstances is included in employer reporting. This separation is not merely a policy commitment — it is enforced at the architecture level of the platform.

6. Information Sharing

We may share your information in the following limited circumstances:

6.1 Service Providers

We engage trusted third-party vendors to assist in operating the Services, including cloud hosting providers, analytics platforms, and customer support tools. These vendors are contractually prohibited from using your information for any purpose other than providing services to CareNgen and are required to maintain appropriate security standards. To the extent any such vendor processes your personal information on our behalf, it does so as a service provider or processor, not as a party authorized to use your data for its own purposes.

6.2 Provider Connections

If you choose to connect with a care provider surfaced through the platform, we will share the information necessary to facilitate that connection — such as your name, contact information, and relevant care needs — only with your explicit consent.

6.3 Legal Compliance

We may disclose your information if required to do so by law, regulation, or valid legal process, or if we believe in good faith that such disclosure is necessary to protect the rights, property, or safety of CareNgen, our users, or the public.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of CareNgen’s assets, your information may be transferred to the successor entity. We will provide reasonable advance notice before your information becomes subject to a materially different privacy policy, and the successor entity will be bound by the commitments in this Policy or will provide you with a new privacy notice.

7. Cookies and Tracking Technologies

CareNgen uses cookies and similar tracking technologies to operate and improve the Services. We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the platform to function and cannot be disabled. These include session authentication and security tokens.
• Functional Cookies: Enable enhanced features such as remembering your preferences and settings across sessions.
• Analytics Cookies: Help us understand how users interact with the platform so we can improve it. These cookies collect information in aggregated, anonymized form. Our analytics vendors are contractually prohibited from using this data for their own purposes.

We do not use advertising or targeting cookies, and we do not share cookie data with third-party advertisers.

Global Privacy Control (GPC): CareNgen honors the Global Privacy Control (GPC) browser signal as an opt-out of the sale and sharing of personal information, as required under the California Privacy Rights Act and applicable regulations. If your browser is configured to send a GPC signal, we will treat it as a valid opt-out request. Because CareNgen does not sell or share personal information for cross-context behavioral advertising, this signal has no practical effect on your current experience, but we honor it as a matter of compliance and principle.

Do Not Track: We do not currently respond to browser-level Do Not Track (DNT) signals, as no uniform standard for DNT has been established. We do, however, honor GPC signals as described above.

You may configure your browser to refuse or delete cookies. Please note that disabling strictly necessary cookies may affect the functionality of the Services. For more information about managing cookies, visit your browser’s help documentation.

8. Data Security

CareNgen employs administrative, technical, and physical safeguards designed to protect your information against unauthorized access, disclosure, alteration, and destruction. The platform is built to SOC 2 Type II standards and employs encryption in transit and at rest for sensitive data categories.

No method of electronic transmission or storage is completely secure. While we are committed to protecting your information, we cannot guarantee absolute security.

Breach Notification: In the event of a data breach affecting your rights or interests, CareNgen will notify affected users and applicable regulatory authorities in accordance with the timeframes required by applicable law, including the New York SHIELD Act (which requires notification in the most expedient time possible and without unreasonable delay), and any other applicable state breach notification laws. To report a potential security incident, please contact us at [email protected].

9. Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Services. The following retention periods apply to major categories of information:

If you close your account or request deletion of your data, we will delete or anonymize your personal information within the timeframes set forth above, except where retention is required by applicable law, legitimate business purposes such as fraud prevention, or active dispute resolution.

10. Automated Decision-Making and Profiling

CareNgen’s platform uses automated processes to generate personalized care guidance, surface relevant provider recommendations, and tailor your experience based on the information you provide. These automated outputs are informational in nature — they are not used to make binding decisions about your legal rights, employment status, financial situation, or access to benefits.

No automated processing performed by CareNgen produces decisions with legal or similarly significant effects without human review. All care guidance is intended to assist you in making your own informed decisions in consultation with qualified professionals.

Right to Opt Out of Profiling: Residents of California, Colorado, Connecticut, Virginia, and other states with applicable privacy laws may have the right to opt out of the processing of their personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects. To opt out, please contact us at [email protected] with the subject line “Opt Out of Profiling.” We will respond within the timeframe required by applicable law.

11. Your Rights and Choices

Depending on your location and applicable law, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information
• Object to or restrict certain processing of your information
• Receive a portable copy of your information in a commonly used format
• Opt out of the sale or sharing of your personal information (CareNgen does not sell or share personal information for advertising)
• Limit the use and disclosure of your sensitive personal information
• Opt out of profiling in connection with decisions that produce legal or significant effects

To exercise any of these rights, please contact us at [email protected]. We will respond to all verifiable requests within the timeframe required by applicable law. We will not discriminate against you for exercising your privacy rights.

Right to Appeal: If we decline to act on a privacy rights request, you have the right to appeal that decision. To submit an appeal, contact [email protected] with the subject line “Privacy Request Appeal” and include a description of your original request and the basis for your appeal. We will respond to your appeal within the timeframe required by applicable law and will provide a written explanation of our decision.

California Residents (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), enforced by the California Privacy Protection Agency (CPPA). In addition to the rights listed above, California residents specifically have:

• The right to know what personal information we have collected about you, including the categories, sources, business purposes, and third parties with whom it is shared
• The right to correct inaccurate personal information that CareNgen holds about you
• The right to delete personal information, subject to exceptions
• The right to opt out of the sale or sharing of personal information (CareNgen does not sell or share personal information)
• The right to limit the use and disclosure of sensitive personal information to the purpose of providing the Services
• The right to non-discrimination for exercising your CCPA/CPRA rights

CareNgen does not sell personal information and does not share personal information for cross-context behavioral advertising. As described in Section 7, we honor Global Privacy Control signals.

For CCPA/CPRA-specific inquiries, please contact us at [email protected]. You may also submit a complaint to the California Privacy Protection Agency at cppa.ca.gov.

Other U.S. State Residents

Residents of states with comprehensive consumer privacy laws — including Virginia, Colorado, Connecticut, Texas, Oregon, Montana, and others — may have rights similar to those described in this section under their applicable state law. These rights typically include access, correction, deletion, data portability, opt-out of certain processing, and the right to appeal a denial of a privacy request. To exercise any state privacy rights, please contact [email protected] and identify your state of residence.

We respond to all verifiable privacy rights requests within the timeframe required by applicable law, regardless of your state of residence.

12. State Health Data Privacy Laws

CareNgen collects information about care recipients’ health conditions, medical needs, and functional limitations. Several states have enacted health data privacy laws that apply to entities collecting consumer health data regardless of whether they are HIPAA-covered entities. To the extent these laws apply to CareNgen’s data practices, we comply with their requirements.

These laws include, among others:

• Washington My Health MY Data Act: Requires consent for the collection and sharing of consumer health data and provides Washington residents with rights to access, delete, and withdraw consent for health data processing.
• Nevada Consumer Health Data Privacy Law: Imposes consent requirements and restrictions on the use and disclosure of consumer health data for Nevada residents.
• Applicable health data provisions under the consumer privacy laws of Texas, Florida, Connecticut, and other states.

If you are a resident of Washington state or another state with applicable health data privacy protections, you may have additional rights regarding the health-related information we collect. To exercise those rights, please contact [email protected] and identify your state of residence and the specific rights you wish to exercise.

13. HIPAA Notice

CareNgen is not a covered entity under the Health Insurance Portability and Accountability Act (HIPAA). The information you provide about yourself and your care recipient through the platform is not “protected health information” (PHI) as that term is defined under HIPAA, because CareNgen is not a healthcare provider, health plan, or healthcare clearinghouse.

However, some employer clients that access CareNgen’s workforce benefit reporting tools may be HIPAA-covered entities or operate HIPAA-covered health plans. In those contexts, CareNgen and the relevant employer may execute a Business Associate Agreement (BAA) as appropriate to govern the handling of any PHI. If you have questions about your employer’s HIPAA compliance program and its relationship to CareNgen, please consult your employer’s human resources or benefits department.

Regardless of HIPAA applicability, CareNgen treats all health-related information with the highest level of sensitivity and applies the safeguards described in this Privacy Policy.

14. Children’s Privacy

The Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a person under 18 without parental consent, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a minor, please contact us at [email protected].

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. The date of the most recent revision will be reflected in the “Last Updated” notice at the top of this document. We will provide reasonable notice of material changes — which may include an in-platform notification or email — before those changes take effect. Your continued use of the Services following notice of a material change constitutes your acceptance of the updated Policy.

16. Contact

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

CareNgen LLC — Privacy Team
2556 Delaware Avenue
Buffalo, NY 14216
[email protected]

To submit a complaint with your state’s applicable privacy regulator, please consult the relevant agency’s website for your jurisdiction.