Effective Date: June 13, 2025

Last Updated: June 13, 2025

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREED TO THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

1. WHO WE ARE

FillerB, Inc. (“FillerB,” “we,” “us,” or “our”) is a staffing and workforce management platform that facilitates connections between schools, educational institutions, healthcare providers, and credentialed professionals who provide specialized services to children and school-aged populations, including therapists, educators, and healthcare professionals

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to information collected through our website, mobile application, platform, and related services (“Services”). This Policy does not apply to third-party sites or services linked to or integrated with our Services, nor to any information collected offline

3. TYPES OF INFORMATION WE COLLECT

a. Personal Information You Provide Directly

We collect and process:

• Full name, address, email, phone number
• Usernames and passwords
• Professional credentials, certifications, licenses, work history, resumes/CVs
• Educational background, references, and certifications
• Employment eligibility, tax documentation, payment information
• Background check information, criminal history, and employment verification results
• Health and immunization records, medical screenings, TB tests, and vaccination status (where legally permitted or required)
• Communication history (emails, platform messages, customer service communications)
• Any additional information voluntarily provided

b. Sensitive Information

Certain services may require collection of sensitive personal data, including:

• Protected Health Information (“PHI”) subject to HIPAA
• Health status or vaccination status related to employment requirements
• Data that may qualify as “sensitive personal information” under state or international law

c. Information Automatically Collected

We may automatically collect:

• Device identifiers (IP address, browser type, operating system, device information)
• Usage data (log files, clickstream data, activity on the platform)
• Geolocation information (subject to user consent)
• Cookies, web beacons, pixels, and similar technologies

d. Information from Third Parties

We may receive information from:

• Background check vendors
• Credentialing agencies
• Healthcare providers
• Educational institutions
• Public databases
• Licensing boards
• Government entities

4. PURPOSES FOR WHICH WE USE INFORMATION

We process collected information for the following purposes:

• To operate, manage, and maintain our Services
• To match professionals with suitable job placements and assignments
• To verify identity, credentials, employment eligibility, and background information
• To comply with legal obligations, including those related to health and safety, licensing, credentialing, and child protection laws
• To process payments and administer payroll (if applicable)
• To communicate with users regarding Services, assignments, policies, or legal matters
• To improve and optimize our platform functionality and user experience
• For security, fraud prevention, and risk management
• For legal defense, regulatory compliance, audit obligations, and dispute resolution

5. SMS COMMUNICATIONS OPT-IN AND CONSENT

• During signup, you will be given the option to provide your mobile phone number to FillerB.
• If you provide your mobile phone number to FillerB, you are opting in to receive SMS messages related to your use of the platform, such as account updates, job notifications, scheduling reminders, and other relevant communications. These messages may be sent through a third-party provider, such as Twilio.
• By opting in to receive SMS messages, you give us your express consent to contact you via text using the number you provided. Message and data rates may apply. Message frequency will vary based on your activity.
• You may opt out of SMS communications at any time by replying “STOP” to any message or by updating your communication preferences in your account settings. For additional support, reply “HELP” or contact us at hello@fillerb.com.
• We will not sell or share your mobile number with third parties for their own marketing purposes without your explicit consent.

5. LEGAL BASES FOR PROCESSING

We rely on various legal bases, including:

• Performance of a contract or steps necessary to enter into a contract
• Compliance with legal obligations
• Protection of vital interests
• Consent (where required by law)
• Legitimate business interests, provided such interests are not overridden by individual rights

6. DISCLOSURES OF INFORMATION

We may disclose your information to:

• Authorized Educational Institutions and Clients to facilitate placement opportunities and staffing services
• Third-Party Service Providers who provide operational support (including background screening, payroll, credentialing, cloud hosting, analytics, and IT support)
• Government Authorities and Regulators to comply with applicable legal obligations
• Healthcare Providers (when applicable to facilitate credentialing or work eligibility)
• Professional Advisors (legal counsel, accountants, auditors)
• Successors in Interest in the event of a merger, sale, or transfer of assets

We do not sell your personal information for monetary consideration.

7. PROTECTED HEALTH INFORMATION & HIPAA COMPLIANCE

To the extent we receive, store, or process Protected Health Information (“PHI”) on behalf of covered entities, we comply with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and execute Business Associate Agreements (“BAAs”) where applicable.

Important Clarification:

FillerB is not itself a Covered Entity under HIPAA; however, we act as a Business Associate when handling PHI on behalf of healthcare providers, school districts, or government agencies subject to HIPAA.

8. FERPA COMPLIANCE

To the extent we receive educational records from schools or school districts subject to the Family Educational Rights and Privacy Act (“FERPA”), we comply with applicable privacy obligations and process such records solely to fulfill contractual obligations with our educational institution clients.

9. DATA SECURITY

We implement reasonable and appropriate technical, administrative, and physical safeguards to secure personal data, including:

• Encryption of data at rest and in transit
• Role-based access control (RBAC)
• Multi-factor authentication for authorized users
• Secure cloud hosting environments
• Regular vulnerability assessments
• Incident response protocols

However, no method of transmission or storage is completely secure. We cannot guarantee absolute security of your information.

10. DATA RETENTION

We retain personal information as long as necessary to:

• Provide Services to you or your employer;
• Comply with applicable legal obligations;
• Resolve disputes; and
• Enforce our agreements.

Retention periods may vary based on record type, legal obligations, and applicable statutes of limitations.

11. INTERNATIONAL TRANSFERS

If you access the Services from outside the United States, you consent to the transfer of your personal information to the United States, which may not have the same legal protections for data as your jurisdiction.

12. CHILDREN’S PRIVACY

We do not knowingly collect personal information directly from children under the age of 13. All minor-related information is provided by authorized educational institutions, parents, or legal guardians solely for staffing or compliance purposes.

13. YOUR PRIVACY RIGHTS

Depending on your jurisdiction, you may have rights to:

• Access your personal information;
• Correct inaccurate data;
• Request deletion of your information (subject to legal exceptions);
• Restrict or object to certain processing activities;
• Request data portability.

To exercise any of these rights, please submit a written request to: [Insert Contact Info]. We may require identity verification before processing certain requests.

14. CALIFORNIA PRIVACY NOTICE

California residents have additional rights under the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”), including:

• Right to know what personal information we collect
• Right to request deletion
• Right to correct inaccurate information
• Right to limit use of sensitive personal information
• Right to opt out of certain data sharing
• Right against retaliation for exercising privacy rights

We do not sell personal information as defined by California law.

15. THIRD-PARTY SERVICES

We may include links to external websites or services not operated by FillerB. We are not responsible for the privacy practices of those third parties. Please review their privacy policies separately.

16. LIMITATION OF LIABILITY

To the maximum extent permitted by law, FillerB shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising out of or relating to this Privacy Policy or any breach thereof.

17. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. Material changes will be communicated by updating this Privacy Policy and revising the “Last Updated” date above. Continued use of our Services after such changes constitutes your consent to the updated Privacy Policy.

18. CONTACT INFORMATION

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal information, you may contact us at:

FillerB Co.

hello@fillerb.com