Effective Date: July, 2026

Daybreak Vantage Care (“Daybreak Vantage Care,” “us,” “we,” or “our”) is committed to respecting your privacy and protecting your personal data. Daybreak Vantage Care provides home care-related services in Connecticut and supports individuals who need care in their homes and the caregivers who assist them.

This Privacy Policy explains the types of personal data we may collect from visitors to and users of our website, online forms, mobile or web-based tools, and related online services, including employees, caregivers, contractors, applicants, prospective clients, and other Connecticut residents who interact with us. It also explains how we use personal data, when we disclose personal data, and the choices and rights that may be available to you.

We may collect or receive certain information that is governed by federal law, including the Health Insurance Portability and Accountability Act (“HIPAA”). Please review any applicable Notice of Privacy Practices for information about how protected health information is used, disclosed, and accessed. This Privacy Policy does not replace any HIPAA-required notice and does not apply to protected health information to the extent that HIPAA governs that information.

This Privacy Policy does not apply to third-party websites, applications, products, or services that we do not own or control, even if they are referenced by or connected to our online services. We recommend reviewing the privacy practices of those third parties before sharing personal data with them.

If you are a visually impaired individual, an individual with another disability, or an individual seeking support in another language, you may contact us using the information in the “Contact Us” section below for assistance accessing this Privacy Policy.

Summary of This Policy

• Collection of Personal Data: We may collect personal data when you interact with us through our online services or by other means.
• Use of Personal Data: We may use personal data to operate our services, communicate with you, manage employment and caregiver relationships, and comply with legal obligations.
• Disclosure of Personal Data: We may disclose personal data to service providers, affiliates, advertising and analytics partners, professional advisors, government entities, and other parties when permitted or required by law.
• Cookies and Tracking Technologies: We may use cookies and similar technologies to operate, analyze, improve, and market our services.
• Connecticut Privacy Rights: Connecticut residents may have rights to access, correct, delete, obtain a copy of, and opt out of certain processing of personal data.
• Contact Us: You may contact us using the information at the end of this policy.

1. Collection of Personal Data

For purposes of this Privacy Policy, “personal data” means information that relates to an identified or identifiable individual and does not include protected health information governed by HIPAA, publicly available information, de-identified information, or aggregate information. The types of personal data we collect may vary depending on how you interact with us.

Personal Data You Provide to Us

• Application information: first and last name, email address, phone number, education history, training or certification information, professional history, employment history, references, credentials, and other information submitted when applying for employment, caregiver, contractor, or related roles.
• Employment-related information: compensation and benefits information, performance evaluations, time worked, clock-in and clock-out information, signatures for timesheets or records, travel-related information, and records needed for workforce management.
• Registration and account information: name, address, email address, phone number, date of birth, work eligibility, emergency contact information, payroll-related details, and account profile information if you create or use an online account or similar tool.
• Financial information: bank account information, payment information, reimbursement information, payroll information, and other financial details needed to administer payments, payroll, reimbursements, or business expenses.
• Medical, leave, and accommodation information: insurance information, medical conditions, workplace accommodation records, leave records, workers’ compensation information, and related documentation when needed for employment, legal, safety, or benefits purposes.
• Biometric or identity-verification information: images, facial recognition information, or similar technology that may be used to identify caregivers, verify time entries, or support fraud prevention where permitted by law.
• Audio, electronic, visual, or similar information: call recordings, security video, photos, videos, audio files, or other content you submit or that we collect through business communications or access portals.
• Communications information: name, phone number, email address, and any personal data you choose to provide when contacting us by phone, email, online form, or other communication method.

Information We Automatically Collect

• Browser and device data: IP address, device identifier, device type, operating system, browser type, screen resolution, device manufacturer and model, language settings, plug-ins, add-ons, and similar technical information.
• Usage data: browsing history on our online services, pages viewed, links clicked, time spent, referring pages, language preferences, patterns of use, and other information about how you interact with our online services.
• Geolocation data: location-based information from a mobile device or other device when needed to provide location-based features, support timekeeping, or verify service-related activities, where permitted by law.

Information We Collect from Others

• Service providers: background check providers, credentialing providers, recruiters, communications providers, analytics providers, customer and technical support providers, internet service providers, operating systems and platforms, fraud prevention services, insurance brokers, and healthcare carriers.
• Social media and content platforms: information made available to us when you interact with our pages, posts, advertisements, or content on third-party platforms.
• Government entities: information needed to assist with benefits, compliance, licensing, or other services.
• Other individuals: information from employees, caregivers, contractors, clients, prospective clients, family members, or other users of our services.

We may create aggregated, anonymized, or de-identified information from personal data by removing or modifying information that identifies you. Our use of aggregated, anonymized, and de-identified information is not subject to this Privacy Policy unless applicable law provides otherwise.

2. Use of Personal Data

• Communicate with you and respond to your inquiries.
• Process applications, conduct screenings, schedule interviews, perform background checks, and evaluate caregiver, contractor, employment, or vendor relationships.
• Manage workforce planning, scheduling, performance reviews, evaluations, investigations, payroll, benefits, reimbursements, insurance, and related administrative functions.
• Provide customer service, technical support, and communications requested or required to deliver services.
• Provide information about services, opportunities, events, seminars, document requirements, or other communications that may interest you, where permitted by law.
• Operate, maintain, analyze, personalize, measure, secure, and improve our website, online tools, accounts, and services.
• Support targeted advertising, marketing, analytics, business development, research, and service improvement where permitted by law and subject to applicable opt-out rights.
• Protect the legal rights, safety, privacy, and property of Daybreak Vantage Care, our clients, caregivers, employees, contractors, applicants, and others.
• Prevent fraud, verify identity, and maintain a trusted, secure, and reliable environment.
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, sale, transfer, or similar business transaction involving some or all of our assets.
• Comply with legal obligations, respond to subpoenas, court orders, legal processes, regulatory requests, or law enforcement requests, and establish or defend legal claims.
• Use personal data in any other way we describe when you provide the information or with your consent.

3. Disclosure of Personal Data

• Affiliates: We may disclose personal data to affiliates that support our business, subject to this Privacy Policy.
• Service providers and processors: We may disclose personal data to vendors that provide services such as payment processing, payroll, benefits administration, analytics, advertising, hosting, marketing, communications, customer support, technical support, security, and administrative services.
• Advertising and analytics partners: We may disclose online identifiers, usage data, and similar information to advertising and analytics providers to help us understand website activity and deliver relevant content where permitted by law.
• Compliance and harm prevention: We may disclose personal data when we believe it is necessary to comply with law, enforce contractual rights, investigate possible wrongdoing, protect rights and safety, or respond to courts, regulators, law enforcement, or other public authorities.
• Business transfers: We may disclose or transfer personal data in connection with a merger, acquisition, asset sale, financing, restructuring, reorganization, dissolution, or similar transaction.

4. Cookies and Other Tracking Technologies

We may use cookies, web beacons, embedded scripts, tags, pixels, analytics tools, and similar technologies to collect and track information, improve and analyze our services, support security, remember preferences, measure performance, and deliver content or advertising that may be relevant to your interests.

• Strictly necessary cookies: Used to allow the website to function, prevent fraudulent activity, and improve security.
• Performance and analytics cookies: Used to assess website performance, understand how visitors use the website, and improve content and services.
• Functionality cookies: Used to remember preferences and support enhanced website features.
• Advertising cookies: Used to deliver content and advertisements that may be relevant to your interests, where permitted by law.
• Social media cookies: Used to support interaction with social networking and content platforms.

You can modify your browser settings to decline or accept cookies. If you decline cookies, some website features may not function as designed. We do not currently respond to browser “Do Not Track” signals.

5. Data Security

The security of your personal data is important to us. We maintain reasonable technical, administrative, and physical safeguards designed to help protect personal data against unauthorized access, destruction, loss, alteration, disclosure, or misuse. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

6. Data Retention

We retain personal data for as long as necessary for the purposes described in this Privacy Policy, including to provide services, maintain an ongoing relationship, comply with legal obligations, resolve disputes, enforce agreements, support internal analytics, improve services, and maintain security. Retention periods may depend on the nature of the information, our relationship with you, applicable legal requirements, statutes of limitations, litigation, regulatory investigations, and business needs.

7. Children’s Data

Our online services are intended for a general audience and are not intended for use by children under 18. We do not knowingly collect personal data from children under 18 through our website without appropriate consent. If you believe a child has provided personal data to us without appropriate consent, please contact us and we will take appropriate steps.

8. Transfers of Personal Data

Our services are operated in the United States and are intended for users located in the United States. We may transfer, store, and use personal data outside of Connecticut as necessary for business operations, service delivery, security, legal compliance, or vendor support. Data protection laws in other jurisdictions may differ from those in Connecticut.

9. Your Privacy Choices

• Promotional communications: If you provide your email address, postal address, or telephone number, we may use that information to communicate with you about pending requests, services, opportunities, and marketing communications where permitted by law. You may opt out of promotional emails by using the unsubscribe instructions in those emails or by contacting us.
• SMS messages: We may send SMS messages about visits, scheduling, clock-in and clock-out reminders, seminars, document requirements, service updates, or other notifications. You may cancel SMS messages by replying “STOP” to a text message you receive from us, where supported, or by contacting us.
• Account information: If you have an online account or application profile, you may be able to view or update certain account information through the account features or by contacting us.
• Account deletion requests: You may request deletion of an account or certain personal data by contacting us. We will respond as required by applicable law and may retain information where permitted or required for legal, compliance, security, fraud prevention, service, or business purposes.

10. Notice for Connecticut Residents

This section applies to Connecticut residents and is intended to provide notices in compliance with the Connecticut Data Privacy Act (“CTDPA”), subject to applicable exemptions and limitations. This section does not apply to protected health information governed by HIPAA or to personal data that is exempt from the CTDPA.

We limit disclosures of personal data to what is reasonably necessary and proportionate for the purposes described in this Privacy Policy. We may “sell” personal data or process personal data for targeted advertising as those terms are defined under applicable Connecticut law. You may opt out of such processing by contacting us using the information below.

Connecticut Privacy Rights

• Right to know and access: You may request confirmation of whether we process your personal data and access to that personal data, subject to legal limits.
• Right to delete: You may request deletion of personal data provided by or obtained about you, subject to legal exceptions.
• Right to correct: You may request correction of inaccuracies in your personal data.
• Right to data portability: You may request a copy of personal data you previously provided to us in a portable and, where technically feasible, readily usable format.
• Right to opt out: You may opt out of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.
• Rights concerning sensitive data: Where required, we will obtain consent before processing sensitive data and will handle sensitive data as required by Connecticut law.
• Right to non-discrimination: We will not discriminate against you for exercising privacy rights available under Connecticut law.

How to Exercise Your Connecticut Rights

To exercise your Connecticut privacy rights, contact us using the information in the “Contact Us” section below. Your request should include enough information for us to reasonably verify that you are the person about whom we collected personal data or that you are authorized to act on that person’s behalf. We may request your first and last name, email address, phone number, mailing address, or other information needed to authenticate the request.

We will respond to verified requests within the time required by applicable law. If reasonably necessary, we may extend the response period as permitted by law and will notify you of the extension. We generally do not charge a fee to process privacy requests unless a request is excessive, repetitive, manifestly unfounded, or otherwise permitted by law.

Appealing a Connecticut Privacy Request Decision

If you are a Connecticut resident and want to appeal our decision regarding a privacy rights request, contact us using the information below and state that you are submitting a privacy appeal. We will inform you in writing of any action taken or not taken in response to the appeal, including an explanation of our reasons, within the time required by Connecticut law. If your appeal is denied, you may contact the Connecticut Office of the Attorney General.

11. Links to Other Websites

Our online services may contain references to websites or services that we do not operate. We are not responsible for the content, security, or privacy policies of websites or services we do not own or control. We recommend reviewing the privacy policies of third-party websites and services before providing personal data.

12. Changes to This Privacy Policy

We may change this Privacy Policy from time to time to reflect new services, changes in our data practices, or changes in applicable law. When we update this Privacy Policy, we will update the effective date above. Changes are effective when posted or otherwise made available.

13. Contact Us

If you have questions about this Privacy Policy, our services, or your privacy rights, please contact Daybreak Vantage Care at:  info@daybreakvantagecare.com