TrustNetTrustNetTrustNet Signal

TrustNet Signal Privacy Policy

Effective Date: 08/01/26

TrustNet, LLC (“TrustNet,” “we,” “us,” or “our”) operates the TrustNet Signal platform (“Signal”). Signal is used by Silver Home Care (“SHC”) to support administration of Medicaid-funded, self-directed home care programs and related caregiver and care-recipient workflows. Signal may also be used by other authorized home care organizations in the future.

This Privacy Policy explains the information collected through Signal, how that information may be used and shared, and the choices available to users.

Signal and SHC may handle sensitive personal and health-related information as part of program enrollment, caregiver management, service administration and compliance. We protect that information in accordance with applicable federal and state law and applicable contractual requirements. Certain information may receive additional legal protections depending on the type of information, the program involved and the applicable law.

1. Information We Collect

Depending on how you use Signal and whether you are a care recipient, caregiver, family member, representative or other authorized user, we may collect or receive the following categories of information.

Contact and Account Information

This may include your name, mailing address, telephone number, email address, date of birth, login and account information, and relationship to a care recipient or caregiver.

Care, Program and Eligibility Information

Signal may contain information relating to participation in Medicaid-funded home care programs and related services. This may include caregiver and care-recipient information; enrollment and eligibility information; information about functional or care needs; medical-needs or other supporting documentation provided for program applications; state- or program-issued care plans, task authorizations or approved services; caregiver task and activity submissions; check-in responses and status updates; scheduling information; program approvals or status information; and notes or other information used to administer program participation.

Documents and Information You Submit

We may collect documents, photographs, forms, acknowledgments, signatures and other information that you upload or provide through Signal.

Communications

We may maintain records of communications made through or in connection with Signal, including in-app communications and notifications, text/SMS communications, email communications, telephone or customer-support interactions, check-in responses and communication preferences.

Payroll and Pay Information

For caregivers, Signal may receive limited payroll and compensation information from authorized payroll service providers, including Viventium, so caregivers can view information such as amounts already paid and related pay history. Signal does not currently originate or process caregiver payroll payments and is not the payroll system of record.

Device and Technical Information

When you use Signal, we may automatically receive limited technical information necessary to operate, protect and improve the platform, such as device type, operating system, app version, IP address, login information, date and time of access, technical logs, crash and diagnostic information and general usage information.

EVV and Location Information

Signal does not currently collect or manage Electronic Visit Verification (“EVV”) records or precise device-location information for EVV purposes. Where EVV is required, it is handled through a separate authorized platform, such as HHAeXchange. If Signal’s collection of EVV or precise location information changes in the future, this Privacy Policy will be updated and additional notice or consent will be provided where required.


2. How We Obtain Information

We may receive information directly from you; from a care recipient, caregiver, family member or authorized representative; from SHC or another participating organization; from government agencies, Medicaid programs, managed care organizations, access/case-management agencies or other program participants where permitted; from authorized payroll, communications or technology providers; through system integrations and APIs; and automatically when you use Signal.


3. How We Use Information

We may use information collected through Signal to create and administer user accounts; support applications, enrollment and eligibility workflows; administer home care program participation; coordinate caregiver and care-recipient activities; maintain care plans, task authorizations and service/activity records; communicate with users; send reminders, notifications and service-related messages; coordinate scheduling; support caregiver onboarding; display caregiver pay history; support payroll and billing administration; facilitate document collection and electronic forms; maintain compliance and operational records; provide customer service and technical support; monitor and improve Signal; protect Signal’s security and integrity; detect or prevent fraud, misuse or unauthorized access; comply with applicable laws, program requirements and lawful government requests; and perform other activities reasonably necessary to administer services and operate Signal.


4. How We May Share Information

We may disclose information when reasonably necessary for the purposes described in this Privacy Policy and as permitted by applicable law.

Silver Home Care and Authorized Personnel

Information may be shared with SHC personnel and authorized contractors who need the information to administer program participation, caregiver management, service coordination, billing, payroll, compliance, customer support or related operations.

Government Programs, Health Plans and Program Partners

Where appropriate and permitted, information may be shared with Medicaid agencies, state or local agencies, managed care organizations, access agencies, case-management organizations or other entities involved in determining eligibility, authorizing, administering or paying for services.

Authorized Service Providers

TrustNet and SHC may use service providers for cloud hosting and data storage, communications, payroll, billing, electronic signatures, customer support, security, analytics, software development and maintenance, and related functions. These providers may receive information only as appropriate to perform services on our behalf and subject to applicable contractual, privacy and security requirements.

Legal and Safety Purposes

Information may be disclosed when reasonably necessary to comply with applicable law; respond to a court order, subpoena or lawful government request; protect the rights, safety or property of users, SHC, TrustNet or others; investigate fraud, security incidents or misuse; or establish, exercise or defend legal claims.

Business Transactions

Information may be transferred as part of a merger, acquisition, financing, reorganization, sale of assets or similar business transaction, subject to applicable privacy and data-protection requirements.


5. We Do Not Sell Sensitive Health-Related Information

TrustNet and SHC do not sell sensitive health-related information for monetary consideration. We do not permit third-party advertising companies to use sensitive health-related information maintained through Signal for targeted advertising. If these practices materially change, we will provide any notice and obtain any consent or authorization required by applicable law before implementing the change.


6. Communications

By providing your contact information and agreeing to the Care & Communication Consent, you may receive communications related to your services, account, program participation or caregiver activities through Signal notifications, text/SMS, email, telephone calls and automated communications where permitted by law. Message and data rates may apply.

You may request changes to certain communication preferences by contacting SHC or TrustNet. Some administrative, security, service-related or legally required communications may still be necessary. Promotional or marketing communications, if offered in the future, will be handled separately where required by law.


7. Sensitive and Health-Related Information

Some information maintained through Signal may be considered sensitive personal information, health information or otherwise specially protected under federal or state law. TrustNet and SHC will handle such information in accordance with laws and contractual requirements that apply to the particular information and activity.

If applicable law provides you with additional rights regarding particular information, those rights are not limited by this Privacy Policy.


8. Security

We maintain administrative, technical and physical safeguards designed to protect information maintained through Signal from unauthorized access, disclosure, alteration, loss or misuse. No electronic system can guarantee absolute security. Users are responsible for protecting their account credentials and should notify us promptly if they believe their account has been accessed without authorization.


9. Data Retention

We retain information for as long as reasonably necessary to provide Signal and related services; administer home care program participation; satisfy applicable legal, regulatory, billing, payroll and recordkeeping requirements; resolve disputes; protect against fraud or misuse; and enforce applicable agreements. Certain program, employment, payroll or other records may be subject to required retention periods. When information is no longer required, it may be deleted, de-identified or securely retained as permitted by law.


10. Your Information and Choices

Depending on the information involved and applicable law, you may request access to certain personal information maintained about you; correction of information you believe is inaccurate or incomplete; updates to contact information; changes to certain communication preferences; or other rights provided by applicable law.

We may need to verify your identity or authority before fulfilling a request, and some requests may be limited by applicable law, program requirements, record-retention obligations or the rights of other individuals.


11. Authorized Representatives

A legally authorized representative may exercise rights or access information on behalf of another person when permitted by law. We may require documentation establishing the representative’s authority before providing access to protected or sensitive information.


12. Third-Party Services

Signal may connect with or display information received from third-party products or systems such as payroll, EVV, government, communications or other service platforms. Those third parties may have their own privacy policies and terms. TrustNet does not control the independent privacy practices or operation of third parties when users interact directly with their services.


13. Children

Signal is not designed for independent use by children under 13. Information about a minor may be maintained when necessary for legally permitted program participation or services and when provided or managed by an authorized parent, guardian or other legally authorized person.


14. State Privacy Rights

Residents of certain states may have additional rights regarding their personal information. Where applicable, TrustNet and SHC will honor rights required by state law. Some information or entities may be subject to specific health, Medicaid, employment or other privacy rules instead of or in addition to general consumer privacy laws.


15. Changes to This Privacy Policy

We may update this Privacy Policy when Signal, our information practices or applicable requirements change. When a material change is made, we will update the Effective Date and provide additional notice through Signal or another appropriate method when required.


16. Contact Us

Questions or requests concerning this Privacy Policy or information maintained through Signal may be directed to:

TrustNet, LLC

Email: contact@trustnetcare.com

Telephone: 203-293-7599

Questions concerning Silver Home Care program participation, caregiver administration or information maintained by SHC may be directed to:

Silver Home Care, LLC

Email: info@gosilverhomecare.com

Telephone: 866-708-5554

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