Welcome to the websites of Medical Staffing Solutions, Inc. (“MSSI”). This Privacy Policy (the

“Policy”) is intended to provide information to users regarding how MSSI collects, uses,

maintains, discloses, and otherwise processes personal information, and to identify certain rights

and choices users may have relating to MSSI’s processing of their personal information. This

Policy applies to information that MSSI collects offline; through its website (https://mssi.com/);

through its cellular and web applications, such as Staffbook (collectively the “Apps”); and other

information that MSSI may collect in the ordinary course of business. Different parts of this

Privacy Notice may apply depending on our relationship with you.

Individuals with disabilities may access this Policy in an alternative format by contacting us at

recruiter@mssi.com or 1-877-217-9825.

Please read this Policy before exploring any MSSI website or App or providing any personal

information to MSSI. If you do not agree with MSSI’s policies and practices, please do not use

the MSSI website, the Apps, or MSSI’s services. By accessing or using any MSSI website or App,

or providing MSSI personal information (as defined below), you agree to this Policy and MSSI’s

Terms and Conditions of Use (“Terms”). This Policy may change from time to time (see Changes

to the Privacy Policy, below). Your continued use of the MSSI website, Apps, or services after

MSSI makes such changes is deemed to constitute your acceptance of changes to this Policy and

the Terms, so please check this Policy and the Terms periodically for updates.

Personal Information Collected

When you download, register with, or use our services, Apps, or websites, you may be asked to

provide us with personal information. We collect, and in the last twelve months we may have

collected, personal information that falls into the categories below. Depending on your interactions

with us, we may not have collected each of these categories of personal information about you.

We may collect different categories of personal information from you depending on whether you

are a user of our website, Apps, or services, interact with us through an offline method, are an

applicant for employment with us, are our employee or an emergency contact or beneficiary of our

employee, or interact with us in a business-to-business context.

• Identifiers such as your name, postal address, telephone number, email address, birth

date;

• Categories of personal information described in California Civil Code § 1798.80,

such as name, social security number, ethnicity, nationality, gender, and other

demographic information, State ID or Driver’s License Number, banking information,

medical information, and;

• Demographic data, including protected classification characteristics, such as

ethnicity, nationality, gender, and other demographic information;

• Internet or other electronic network activity information such as details of your visits

to our websites and information about your computer or mobile device, including your IP

address, browser information, and unique device identifier, and other information

automatically collected through the Apps or website;

• Geolocation data, such as your physical location for timekeeping purposes while using

our Apps, with your express consent;

• Professional or employment information, such as your employment history and current

employer, licensure, tax or payroll information including information about

compensation, benefits and beneficiaries, and payroll and financial information like bank

account number, talent management information, compliance information, and other

information related to your position and/or the position for which you have applied;

• Education information, such as student records or other education information that is

not publicly available personally identifiable information as defined in the Family

Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99);

• Inferences and profiles based on other personal information, including inferences

drawn from the above information to create a profile about you; and

• Other information that you choose to provide, including other information which you

affirmatively consent to be collected, such as via a criminal background check, driver’s

record search, drug test results, credit check, or any other screening requirement for

which you consented.

MSSI does not sell or share “sensitive personal information” and does not use such information

for purposes other than those set out in Cal. Code Regs. tit. 11 § 7027(m).

How MSSI Collects Your Personal Information

We and our service providers collect personal information through various mechanisms in

connection with providing our services, and during the 12-month period prior to the effective date

of this Privacy Policy, we may have collected or received personal information, including:

• Information collected automatically or from other online sources, such as:

o Through our website(s), including through Google Analytics uses cookies to help

us analyze how visitors use the Website. For more information on Google

Analytics, including how Google Analytics collects, uses, and discloses

information, refer to the following page:

https://policies.google.com/technologies/partner-sites.

o Through the Apps;

o Through our social media platforms;

o Through email messages, such as tracking information on clicks-through to our

website, including IP addresses, and whether or not users are opening our emails

to track engagement;

o Through extranet sites made available to our customers and third parties; and

o Through our registration process for newsletters, seminars, webinars and events.

• Offline or directly from you, such as:

o When you provide information in conjunction with our products and services;

o When you provide information over the phone; or

o When you provide information through paper-based forms, applications, and

other documents.

• Other sources, such as:

o Publicly available databases;

o Joint marketing partners and event sponsors, when they share the information

with us;

o Entities to which we provide products and services, which may include your

employer;

o Referral sources and job applicant references;

o Our employees or contractors, such as when participating in employee reviews or

providing information relating to their dependents, family members or emergency

contacts;

o Social media platforms; and

o Our service providers and business partners involved in our employment and

retention processes, such as background check and licensing companies, subject

to your consent where required by applicable law.

If you disclose any personal information relating to other people to us or to our service providers

in connection with our products and services, you represent that you have the authority to do so

and have informed the relevant individuals of the contents of this Policy.

How MSSI May Use Your Personal Information

MSSI uses (and may have used in the 12-month period prior to the effective date of this Policy)

the personal information gathered for the following purposes (as permitted under law):

• presenting our website and Apps, and their features and contents to you;

• providing workforce solutions and connecting people to work;

• creating, managing, and securing online accounts;

• processing payments;

• managing business partner, client and vendor relationships;

• providing information or products that you request from us, including personalizing your

experience with us to enhance features and design relevant alerts, products or services;

• to send promotional materials, alerts regarding available positions and other

communications;

• for communicating with you about, and administering your participation in, special

events, promotions, programs, offers, surveys, contests and market research;

• responding to individuals’ inquiries and claims and providing support;

• operating, evaluating and improving our business (including developing, enhancing,

analyzing and improving our services; managing our communications; performing data

analytics; and performing accounting, auditing and other internal functions);

• troubleshooting, de-bugging, and otherwise addressing issues that may arise with website

or App functionality;

• protecting against, identifying and seeking to prevent fraud and other unlawful activity,

claims and other liabilities; and

• complying with and enforcing applicable court orders, laws, legal processes or legal

requirements, relevant industry standards, contractual obligations and our policies, or

responding to any government or regulatory request.

In addition to the activities listed above, if you interact with us as an employee or a job candidate

by applying for a position or creating an account to apply for a position, as permitted under local

law, MSSI uses the personal information described in this Policy for the following purposes:

• providing you with job opportunities and work;

• human resources management activities, such as providing HR services to you,

administrating benefit programs, payroll, performance management and disciplinary

investigations or actions, expense and travel management, operating our business,

managing disciplinary matters, grievances, and terminations;

• providing additional services to you, such as training, career counselling and career

transition services;

• assessing your suitability as a job candidate and your qualifications for positions,

including by performing background checks;

• ensuring business continuity including by protecting the health and safety of our staff and

others, protecting, monitoring, and maintaining our IT infrastructure, and facilitating

communication with you during an emergency;

• helping to ensure security and integrity, including of our IT, communications systems and

facilities, to the extent the use of your personal information is reasonably necessary and

proportionate for these purposes;

• troubleshooting, de-bugging, and otherwise addressing issues that may arise with our

devices or networks;

• undertaking internal research for technological development and demonstration; and

• performing data analytics, such as (i) analyzing our job candidate and associate base; (ii)

assessing individual performance and capabilities, including scoring on work-related

skills; (iii) identifying skill shortages; (iv) using information to match individuals and

potential opportunities, and (v) analyzing pipeline data (trends regarding hiring

practices).

MSSI also may use the information in other ways compatible with these purposes. If MSSI plans

to use your personal information in a manner that is not consistent with these purposes, MSSI will

provide an additional notice regarding those additional purposes and obtain your consent if legally

required.

How We Disclose Personal Information

We do not:

• Sell your personal information;

• Share or otherwise disclose your personal information for targeted or cross-context

behavioral advertising purposes; or

• Sell the personal information of any individuals under 16 years of age or share such

information for cross-context behavioral advertising purposes.

Please keep in mind that if you directly disclose personal information or other sensitive data

through public message boards, conversation pages, blogs, profile pages, or other similar online

services, the personal information or sensitive data you disclose may be publicly posted and

otherwise publicly available for use.

We may disclose your personal information, and in the past 12 months may have disclosed the

categories of personal information listed above in Personal Information Collected, to the below

categories of entities for business or commercial purposes as described in How MSSI May Use

Your Personal Information, above, and as further described in this section:

• To our affiliates for the purposes described in this Privacy Policy

o You can consult the list and location of our affiliates listed at the bottom of this

page. Subject to applicable law, this information may be used to provide products

and services offered by our other legal entities and for all the purposes outlined in

this Privacy Policy.

o MSSI is the party responsible for the management of the jointly-used personal

information.

• To our third party service providers and trusted business partners to facilitate

services they provide to us.

o These can include providers of services such as website hosting, products and

services-related consulting and monitoring, data analysis, information technology

and related infrastructure provision, customer service, email delivery, auditing,

matching you with roles for which you have applied, or to otherwise fulfill the

purpose for which you have provided your personal information.

o All such third parties are prohibited from using your personal information except

to provide these services to MSSI, and they are required to maintain the

confidentiality of your information.

• We also use and disclose your personal information to other third parties as

necessary or appropriate, especially when we have a legal obligation or legitimate

interest to do so. This may involve disclosing personal information:

o To public authorities in response to lawful requests to comply with national

security or law enforcement requirements.

o To comply with applicable law and regulations, including laws outside your

country of residence;

o To cooperate with public and government authorities, including authorities

outside your country of residence;

o To cooperate with law enforcement;

o For other legal reasons, such as to enforce our terms and conditions and other

agreements between us, in response to legal process (such as a subpoena), and/or

to protect our rights, privacy, safety or property, and/or that of our affiliates, you,

or others;

o To trade union representatives (if applicable);

o In connection with a sale, merger or business transaction;

o To other similar third parties where disclosure is required for an ordinary business

purpose in connection with our provision of services; and

o As otherwise permitted by applicable law.

How Long We Retain Personal Information

We retain personal information for as long as needed or permitted in light of the purpose(s) for

which it was obtained and consistent with applicable law. The criteria used to determine our

retention periods include, but are not limited to:

• The length of time we have an ongoing relationship with you and provide our services to

you (for example, for as long as we need to process your information);

• Whether there is a legal obligation to which we are subject (for example, certain laws

require us to keep records of your transactions or communications for a certain period of

time before we can delete them); and

• Whether retention is advisable in light of our legal rights (such as in regard to applicable

statutes of limitations, litigation or regulatory investigations).

We may destroy, de-identify, or anonymize the information when it is no longer needed in

identifiable form.

Protection of Your Personal Information

MSSI has implemented policies and procedures designed to secure your personal information

from accidental loss and from unauthorized access, use, alteration, and disclosure, which

includes restricting access to certain personal information as required by law. In addition, we

take measures to limit access to personal information to those employees, agents, contractors,

and other third parties that have a legitimate business need for such access.

The safety and security of your information also depends on you. Where we have given you (or

where you have chosen) a password for access to any MSSI website or service, you are

responsible for keeping your password confidential. It is vital that you not share your password

with anyone. We urge you to be careful about giving out information in public areas of any

MSSI website or service like message boards. The information you share in public areas may be

viewed by any user of these services.

Unfortunately, the transmission of information via the internet and mobile platforms is not

completely secure. Although we do our best to protect your personal information, we cannot

guarantee the security of your personal information transmitted to or through any MSSI website

or service. Any transmission of personal information is at your own risk.

Additional Information for California Residents

California residents have certain rights regarding their personal information. Please note that

these rights are various to subject exceptions. If we decide not to honor your request for

any reason, we will let you know as set forth below. These may include the following rights:

60737019.v1-OGLETREE

• Right to Access/Know. You may have the right to obtain confirmation from MSSI as to

whether or not personal information concerning you is being processed and how, what,

when, why and for how long your personal information is processed and to whom it is

disclosed.

• Right to Delete (Erasure). You may have the right to request that we delete any of your

personal information that we collect, subject to certain exceptions.

• Right to Correct. You have the right to request correction of inaccurate personal

information that we maintain about you or to update the information we have on file.

• Right to Data Portability. You may have the right to receive a digital copy (in a

commonly used format) of all personal information that has been collected from them by

any given organization.

• Right to Opt-Out of Sale or Sharing. You ordinarily have the right to opt out of the sale

of your personal information or disclosure of your personal information for targeted or

behavioral advertising. However, MSSI does not knowingly disclose information to third

parties for targeted or cross-context behavioral advertising or sell personal information. If

you believe this is occurring, please contact us as set forth in the Contacting MSSI section

below. 

• Right to Non-Discrimination. You have the right to be protected from discrimination for

exercising your rights. We will not discriminate against you for exercising your rights.

• Right not to be Subject to Automated Decision-Making, Including Profiling: You have

the right not to be subject to a decision based solely on automated processing, including

profiling, which produces legal effects concerning you or significantly affects you.

However, MSSI does not use automated decisionmaking technologies that produce a legal

effect, and as a result, this right is not available to you.

Please note that these rights are subject to various exceptions.

Exercising Your Rights

How to Submit a Request. To exercise your rights as set out above, California residents may

• calling 877-217-9825, or

• by submitting a request by email to recruiter@mssi.com.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify

your identity before granting access your personal information or complying with your request. In

addition, we may require you to sign a declaration under penalty of perjury that you are the

individual whose personal information is the subject of the request and provide appropriate proof

of identity.

For requests to know or delete information about a child under the age of 13, we accept requests

for information regarding minors under the age of 13 if we can determine that such requests were

submitted by a parent or guardian.

Authorized agents may initiate a request on your behalf using the same methods described above.

Authorized agents will be required to provide proof of your authorization, and we may also require

that you directly verify your identity and the authority of your authorized agent. You may also

provide us with a signed and dated power of attorney naming the authorized agent as your

representative.

Responding to Requests. For data subject requests for individuals located outside of California,

we will respond to your request in the time required by applicable law. Within 10 days of receiving

a request to delete, request to correct, or to know, we will confirm receipt of the request and provide

information about how we will process the request. Generally, we will respond to your request

within 45 days. If we need more time to respond, we will provide you with notice and an

explanation of the reason we need more time to respond. We may deny your request if we cannot

verify your identity or are legally permitted to deny the request, such as if doing so proves

impossible or would involve disproportionate effort.

If we deny your request, we will explain the basis for the denial, provide or delete any personal

information that is not subject to the denial, and refrain from using the personal information

retained for any purpose other than permitted by the denial. We will maintain a record of your

request and our response for 24 months. To the extent permitted by applicable law, we may charge

a reasonable fee to comply with your request if the request is manifestly unfounded, excessive, or

repetitive.

Universal Opt-out Mechanisms and Do Not Track

“Global Privacy Controls” or other universal opt out signals are signals you can send from your

browser to a website to convey your choice to exercise certain opt-out rights granted by individual

states. Because we do not knowingly disclose personal information for targeted or behavioral

advertising, we do not recognize or otherwise respond to such signals. Some internet browsers

incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to

have your online activity tracked. Given that there is not a uniform way that browsers communicate

the “Do Not Track” signal, our website does not currently interpret, respond to or alter its practices

when it receives “Do Not Track” signals.

Children’s Privacy

MSSI websites, Apps, and services are not intended for individuals under 21 years of age. No one

under age 21 may provide any information to or through our services. We do not knowingly collect

personal information from individuals under 21. If you are under 21, do not use or provide any

information to our websites or services or on or through any of their features, do not register to

become a member of our website or service, use any of the interactive features of our website or

services, or provide any information about yourself to us, including your name, address, telephone

number, email address, or any screen name or user name you may use. If we learn we have

collected or received personal information from a child (as defined in the applicable jurisdiction),

we will delete that information. If you believe we might have any information from or about a

child, please contact us at: recruiter@mssi.com.

Links

If the websites or Apps contain links to other sites and resources provided by third parties, these

links are provided for your convenience only. Those sites and services are not subject to this Policy.

The operators of the linked websites and services may have posted their own privacy policies that

you should review to learn more about their privacy policies. If you decide to access any of the

third-party websites linked to the websites or Apps, you do so entirely at your own risk and subject

to the terms and conditions of use for such third-party websites.

Changes to the Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in MSSI’s privacy practices

and legal updates. When we do so, we will update the Effective Date of the Policy below. You are

responsible for periodically reviewing this Privacy Policy to check for any changes. Please note

that continued use of the Website or MSSI services indicates your agreement to the changes.

Contacting MSSI

If there are any questions regarding this Privacy Policy or you want to direct a complaint to

MSSI, you may contact MSSI using the information below.

MSSI

PO Box 101

Rice Lake, Wisconsin 54868

Email: recruiter@mssi.com

Toll-free: 1-877-217-9825

Effective: April 18, 2024.