Privacy Policy

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Effective Date: December 08, 2025

Last Updated: December 08, 2025

1. Introduction

This Privacy Policy explains how Staff Helm ("we", "us", "our") collects, uses, and protects information through the Lost Revenue Audit lead reactivation platform ("Service").

Our Commitment: We are committed to protecting your privacy and handling data responsibly in compliance with CCPA, TCPA, and CAN-SPAM.

2. Information We Collect

2.1 Client Account Information

When you register for the Service, we collect:

• Business name and contact person
• Email address
• Phone number (for qualification calls)
• Billing address
• Payment information (for $1 pilot fee and $75/nurse billing)

2.2 Lead Data (Dormant Nurses You Submit)

When you submit your dormant nurse list for processing, you provide:

• Phone numbers
• Email addresses
• Names (first, last)
• Any additional fields in your CSV (e.g., specialty, location, last shift date)

Important: This is YOUR data. We process it on your behalf as a service provider.

2.3 Communication Data

We automatically collect:

• SMS messages sent and received (if using SMS campaigns)
• Email messages sent and delivery status
• Response text from nurses
• Opt-out requests
• Bounce and complaint reports

2.4 System Data

We automatically log:

• API requests and responses
• Campaign execution timestamps
• AI classification results
• System errors and performance metrics
• IP addresses (for security and rate limiting)

2.5 Cookies and Tracking

We use minimal cookies:

• Authentication cookies (session management)
• Analytics cookies (usage analysis)

We do NOT use advertising or tracking cookies.

3. How We Use Information

3.1 Service Delivery

We use data to:

• Execute outreach campaigns (send emails to dormant nurses)
• Classify lead responses using AI (identify "hot leads")
• Identify and deliver hot leads to you
• Generate invoices ($75 per hot lead)
• Provide customer support

3.2 Compliance

We use data to:

• Honor opt-out requests (TCPA, CAN-SPAM)
• Prevent spam and abuse
• Comply with legal obligations
• Respond to legal requests (subpoenas, court orders)

3.3 Service Improvement and AI Training

We use nurse response data to train and improve our AI classification models:

• Improve AI classification accuracy (identify "hot leads" more effectively)
• Train models on email/SMS response patterns
• Optimize campaign messaging and timing
• Develop predictive models for nurse reactivation likelihood
• Analyze industry trends (e.g., nurse reactivation rates)

AI Training Data Usage:

• Response text and classification results retained indefinitely for continuous model improvement
• Used only for model training and service improvement
• You may opt out of AI training use at any time by emailing privacy@staffhelm.com

We do NOT:

• Sell or rent your lead data to third parties
• Use your nurses for our own recruiting
• Share identifiable data without your consent
• Use AI training data outside our service improvement purposes

4. Data Sharing and Disclosure

4.1 Service Providers (Subprocessors)

We share data with trusted third-party service providers in the following categories:

Email Delivery Services

• Purpose: Send reactivation emails to dormant nurses
• Data shared: Email addresses, message content
• Location: United States

SMS/Voice Delivery Services (if enabled)

• Purpose: Send and receive SMS, MMS, and voice communications
• Data shared: Phone numbers, message content
• Location: United States

Cloud Infrastructure Providers

• Purpose: Application hosting, databases, file storage, compute, AI/ML processing
• Data shared: All platform data
• Location: United States

All service providers are contractually required to protect your information and use it only for the purposes we specify.

4.2 Legal Requirements

We may disclose data if required by:

• Court orders or subpoenas
• Law enforcement requests
• Legal process or government regulations
• Protection of our rights or safety

4.3 Business Transfers

If we are acquired or merge with another company, your data may transfer to the new entity. You will be notified via email.

5. Data Retention

5.1 Active Campaign Data

• Retained while campaign is active (typically 2-7 days)
• Retained for 90 days post-completion for reporting

5.2 Historical Data

• Campaign summaries: 1 year
• Lead data (nurses): 3 years (to prevent duplicate outreach and track reactivation history)
• Invoices: 7 years (tax compliance)

Why 3 years for lead data?

• Prevents sending duplicate campaigns to nurses who already reactivated
• Tracks which nurses responded, when, and to which campaigns
• Protects nurses from repeated outreach (anti-spam measure)
• Maintains campaign effectiveness data across multiple runs
• After 3 years, data is anonymized or deleted unless required for compliance

5.3 AI Training and Model Improvement

To improve our AI classification system, we retain:

• Email and SMS response text: Indefinitely
• Nurse conversation patterns: Indefinitely
• Classification accuracy metrics: Indefinitely
• Campaign performance data: Indefinitely (aggregated)
• Analytics data: Indefinitely for service improvement and trend analysis
• Opt-out available: You may opt out of AI training use at any time by emailing privacy@staffhelm.com

5.4 Opt-Out Data

• Global opt-out list: Retained indefinitely (compliance requirement)
• Email unsubscribes: Retained indefinitely

5.5 Deletion Requests

You may request deletion of your data at any time:

• Email: privacy@staffhelm.com
• We will delete data within 30 days
• Opt-out data cannot be deleted (compliance)
• Invoices retained for tax purposes (7 years)
• AI training data can be excluded from future model training

6. Data Security

6.1 Technical Measures

We protect data using:

• Encryption in transit: TLS 1.2+ for all connections
• Encryption at rest: AES-256 encryption for stored data
• Access controls: API keys, authentication middleware
• Audit logging: All system actions logged
• Rate limiting: Prevents brute force attacks

6.2 Organizational Measures

• Limited employee access (need-to-know basis)
• Regular security training
• Incident response plan

6.3 Data Breach Notification

If a breach occurs, we will:

• Notify affected clients within 72 hours
• Report to relevant authorities (if required)
• Provide remediation steps
• Publish incident report (if material)

7. Your Privacy Rights

7.1 Access

You have the right to:

• Request a copy of your data
• Download lead data via export feature
• View campaign history and reports

7.2 Correction

You may:

• Update account information in your dashboard
• Request corrections via email

7.3 Deletion

You may request:

• Deletion of your account
• Deletion of specific campaign data
• Note: Opt-out data cannot be deleted (required for compliance)

7.4 Opt-Out

You may opt out of:

• AI training data use (email privacy@staffhelm.com)
• Analytics collection (email privacy@staffhelm.com)
• Marketing communications from us

7.5 File a Complaint

You may file complaints with:

• California: California Attorney General
• Federal: Federal Trade Commission (FTC)

8. TCPA Compliance

8.1 Outbound Communications

We send emails and (optionally) SMS only to nurses you submit. You represent:

• You have prior relationship with these nurses (they worked for you)
• You have obtained necessary consent to contact them
• Nurses have not revoked consent or opted out
• Data was collected lawfully

8.2 Opt-Out Mechanism

Every email includes unsubscribe option:

• One-click unsubscribe link in footer
• Nurses added to global opt-out list immediately
• No further messages sent to opted-out contacts

If SMS is used, every SMS includes:

• Reply "STOP" to opt out
• Immediate suppression from future campaigns

8.3 Rate Limiting

We enforce carrier-friendly sending limits:

• Email: Gradual sending to avoid spam filters (typically 1,000-2,000/hour)
• SMS (if used): 10DLC-compliant rate limits (4,800-14,400 msgs/day depending on brand trust score)
• Prevents carrier filtering and complaints while enabling timely campaign execution

10DLC SMS Rate Limits:

• Standard brand (verified): 4,800 messages/day (60 msgs/minute)
• High trust score: 14,400 messages/day (180 msgs/minute)
• Campaigns to 1,000 nurses complete within 1 business day
• Rate limits enforced automatically by carrier networks

9. CAN-SPAM Compliance

9.1 Email Requirements

All emails include:

• Accurate "From" name and email
• Clear subject line
• Your business address
• Unsubscribe link in every email

9.2 Unsubscribe Process

• One-click unsubscribe (no login required)
• Unsubscribe processed within 10 business days
• No charge for unsubscribing
• Nurses added to suppression list

10. CCPA Compliance (California Residents)

10.1 California Rights

If you are a California resident, you have:

• Right to know what personal information we collect
• Right to delete personal information
• Right to opt out of "sale" (we do NOT sell data)
• Right to non-discrimination for exercising rights

10.2 Categories of Data Collected

• Identifiers: Name, email, phone, IP address
• Commercial information: Invoices, payment records
• Internet activity: System logs, API calls
• Inferences: AI classifications, campaign performance

10.3 Exercising CCPA Rights

Email: privacy@staffhelm.com

• We will respond within 45 days
• We may request verification (to prevent fraud)
• You may designate an authorized agent

11. Children's Privacy

This Service is a business-to-business (B2B) platform. We do NOT knowingly collect data from individuals under 18 years old.

If we discover data from a minor, we will delete it immediately.

12. Third-Party Links

Our Service may link to third-party websites (e.g., support docs). We are not responsible for their privacy practices. Review their privacy policies.

13. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be:

• Posted on this page with updated "Last Updated" date
• Emailed to active clients (for material changes)
• Effective immediately upon posting

Continued use of the Service constitutes acceptance of changes.

14. Contact Us

For privacy questions, requests, or complaints:

Advanced Modern, LLC d/b/a Staff Helm
Email: privacy@staffhelm.com
Address: 6001 Menaul Blvd NE #1084, Albuquerque, NM 87110
Phone: (505) 494-1500

Response Time: Within 48 hours for urgent requests, 10 business days for standard requests.

15. Data Processing Summary

Data Type	Purpose	Retention
Account info	Service delivery	7 years
Lead data (nurses)	Campaign execution, prevent duplicates	3 years
Email/SMS logs	Compliance	3 years
AI training data	Model improvement	Indefinite (opt-out available)
Opt-outs	Compliance	Indefinite
Analytics	Service improvement	Indefinite (opt-out available)