Privacy Policy — TrustNet

1. Applicability and Scope

TrustNet is a home care agency management platform built for Michigan’s Home Help Program. This policy applies to all information collected through the TrustNet Services, including:

The TrustNet Admin Portal — a web-based dashboard used by agency super admins and admins for case management, payroll, compliance, and reporting.
The TrustNet Mobile App — used by caregivers for Electronic Visit Verification (EVV), timesheets, document uploads, and schedule management; and by patients for visit tracking and care plan visibility.
All electronic communications sent through or in connection with the Services, including SMS, email, and push notifications.

This policy does not apply to information collected by third-party services you may use in connection with TrustNet (such as state agency portals or financial institutions). We encourage you to review their privacy policies directly.

Permissible Age: The Services are not intended for users under the age of 18. We do not knowingly collect personal information from anyone under this age.

2. Information We Collect

TrustNet collects information necessary to operate home care case management, regulatory compliance, and caregiver payroll. This includes information you provide directly, information we receive from integrated third-party systems, and information collected automatically through your use of the platform.

2.1 Information You Provide to TrustNet

Personal identifiers: name, date of birth, phone number, email address, home address, Medicaid ID, and Social Security Number (where required for payroll or state reporting).
Account and authentication data: phone number used for OTP-based login on the mobile app, and email/password credentials for the admin portal.
Caregiver onboarding information: hourly pay rates, employment eligibility documentation, background check authorizations, certifications, and training records.
Patient case information: care plans, authorized service hours, assigned care tasks, and case-related notes entered by administrators.
Documents and e-signatures: identification documents, signed service agreements, and compliance forms uploaded to TrustNet or signed electronically through the platform.
Communications: messages exchanged within the platform, customer support requests, and any feedback you submit.
Financial information: banking details and tax forms provided for payroll processing, which are transmitted securely to our payroll service provider.

2.2 Information Collected Automatically

When you use the TrustNet web portal or mobile app, we may automatically collect:

Electronic Visit Verification (EVV) data: GPS coordinates captured at clock-in and clock-out, visit timestamps, and calculated visit duration — collected as required by Michigan Medicaid regulations for Home Help Program compliance.
Device information: device type, operating system, browser type, unique device identifiers, and push notification tokens registered for the mobile app.
Usage data: pages and features accessed within TrustNet, session duration, navigation patterns, and interaction events used for platform improvement.
Log data: IP addresses, access timestamps, error logs, and request metadata collected for security monitoring and technical diagnostics.
Cookies and local storage: used to maintain session state, authentication tokens, and user preferences within the admin portal.

2.3 Information from Third-Party Sources

TrustNet may receive information about you from integrated third-party systems, including:

CRM platforms used for lead intake and caregiver recruitment pipeline management.
Payroll processing services that provide payment reconciliation and check-level data for caregiver compensation records.
Marketing analytics platforms that provide aggregated campaign performance data (no individual personal data is received through this channel).

3. How We Use Your Information

TrustNet uses the information we collect to deliver, maintain, and improve the Services. Specifically, we use your information to:

Manage the full lifecycle of home care cases — from lead intake and caregiver application through onboarding, document compliance, active care, and case closure.
Process caregiver payroll, generate timesheets based on EVV records, calculate compensation including pay rates and deductions, and sync payment data with our payroll provider.
Operate Electronic Visit Verification as required by Michigan Medicaid — recording clock-in/clock-out times and GPS coordinates to verify that authorized care services are being delivered.
Facilitate caregiver onboarding by tracking required documents, certifications, and compliance milestones, and sending reminders for missing or expiring items.
Communicate with you about your account, case assignments, schedule changes, document requirements, and service updates via SMS, email, and in-app push notifications.
Authenticate your identity through OTP verification (mobile app) or email/password credentials (admin portal) to protect account access.
Comply with Michigan Department of Health and Human Services reporting requirements, Medicaid program rules, and applicable federal and state regulations.
Generate aggregated reports and analytics for agency operations, including lead conversion metrics, case volumes, payroll summaries, and EVV compliance rates.
Diagnose technical issues, monitor platform performance, and resolve errors to maintain a stable and functional service.
Detect, investigate, and prevent fraudulent activity, unauthorized access, or violations of our Terms of Use.

We may anonymize or de-identify information collected through the Services. De-identified data is not subject to this Privacy Policy and may be used for operational analysis and reporting without restriction.

4. How We Share Your Information

TrustNet does not sell your personal information. We may share your information only in the following circumstances:

4.1 Service Providers and Technology Partners

We work with third-party providers that support TrustNet’s operations. These include cloud hosting and database services, document storage and electronic signature platforms, email and SMS delivery services, and payroll processing systems. These providers are contractually required to keep your information confidential and to use it only for the purposes for which we share it.

4.2 State and Regulatory Agencies

TrustNet shares information with the Michigan Department of Health and Human Services (MDHHS) and other applicable agencies as required for Medicaid program compliance. This includes caregiver and patient identifying information, EVV visit verification records, care task documentation, and billing data necessary for the Home Help Program.

4.3 Payroll and Financial Partners

Caregiver compensation data — including hours worked, pay rates, tax information, and banking details — is shared with our payroll processing partner for the purpose of issuing accurate and timely payments. All financial data is transmitted using industry-standard encryption protocols.

4.4 Legal and Safety Disclosures

We may disclose your information when we believe in good faith that disclosure is reasonably necessary to comply with a legal obligation, court order, subpoena, or government request; to investigate or prevent suspected fraud, security threats, or violations of our Terms of Use; or to protect the rights, property, or safety of TrustNet, our users, or the public.

4.5 Business Transfers

In the event of a merger, acquisition, reorganization, asset sale, or similar corporate transaction, your personal information may be transferred as part of the business assets. We will provide notice of any such change in ownership or control of your information.

4.6 With Your Consent

We may share your information in other circumstances where we have obtained your explicit consent to do so.

5. Your Rights

You have the following rights regarding your information:

Access: You may request a summary of the personal information TrustNet holds about you.
Correction: You may request that we update inaccurate or incomplete information in your profile or case records.
Deletion: You may request deletion of your TrustNet account and associated personal data. Note that certain information may be retained where required by Medicaid record-keeping regulations, legal obligations, or fraud prevention needs. Backup copies may persist in our disaster recovery systems for a limited period.
Communication preferences: You may opt out of non-essential notifications by adjusting your preferences within the app or by following the unsubscribe instructions in our messages. You cannot opt out of administrative, legal, or service-critical communications.

To exercise any of these rights, contact your assigned case coordinator or email privacy@silverhomecare.com. We will respond within a reasonable timeframe as required by applicable law.

Your rights may be limited where fulfilling a request would infringe on the rights of another person, compromise an ongoing investigation, or conflict with legal retention requirements.

6. Data Security

TrustNet implements technical and organizational safeguards to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These include:

Encrypted data transmission via TLS/SSL for all communication between your device and TrustNet servers.
Role-based access controls — admin portal access is restricted by role (super admin, admin), and mobile app access is scoped to individual caregiver and patient accounts.
Row-level security policies on our database, ensuring that authenticated API requests can only access data the requesting user is authorized to see.
OTP-based authentication for mobile app users (caregivers and patients), eliminating password-based attack vectors.
Secure cookie-based session management with HTTP-only flags for the admin portal.
Automatic session expiration and token refresh mechanisms.
Infrastructure-level protections including web application firewall rules and HTTPS enforcement with HSTS headers.
Third-party payroll processors validated as PCI-compliant for handling financial data.

No method of electronic transmission or storage is completely secure. You play an important role in protecting your account by keeping your login credentials confidential, not sharing OTP codes with others, and notifying us immediately of any suspected unauthorized access. If we receive instructions authenticated with your credentials, we will treat them as authorized.

7. Data Retention

TrustNet retains your personal information for as long as necessary to provide the Services, fulfill our contractual obligations, comply with legal and regulatory requirements, resolve disputes, and enforce our agreements.

Specific retention periods vary by data type. EVV visit records, payroll data, and Medicaid billing documentation are retained for the periods required by Michigan state regulations and federal Medicaid rules, which may extend beyond the termination of your account. When information is no longer required for any of these purposes, we securely delete or de-identify it.

8. Third-Party Services

TrustNet integrates with and may contain links to third-party services that are not operated by us. These include, but are not limited to, state Medicaid portals, document storage providers, electronic signature services, payroll platforms, and communication delivery services.

We are not responsible for the privacy practices or content of these third-party services. We encourage you to review their privacy policies before providing them with personal information. TrustNet’s Privacy Policy governs only information collected and processed through our own Services.

9. Children’s Privacy

TrustNet’s Services are designed for adult caregivers, patients, and agency administrators. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected information from a minor, we will take prompt steps to delete it. If you believe a minor has provided personal information through TrustNet, please contact us at privacy@silverhomecare.com.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, the features of TrustNet, or applicable legal requirements. When we make changes, we will revise the “Last updated” date at the top of this page. The updated policy will be accessible through both the TrustNet web portal and mobile application.

Your continued use of the Services after any changes are posted constitutes your acceptance of the revised policy. For material changes, we may also notify you through the platform or via email.

11. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or how TrustNet processes your information, please contact us:

Silver Home Care LLC

Operating as TrustNet

Detroit, Michigan

Email: privacy@silverhomecare.com