BlueSky Synergy, LLC PRIVACY POLICY

BlueSky Synergy, LLC (“BlueSky”) recognizes the importance of privacy and sensitivity of personal information. As a provider of employee or individual qualification services, we are committed to protecting any personal information we hold. This Privacy Policy outlines how we manage your personal information and safeguard the privacy of persons who give us personal information.

Privacy Rights

BlueSky is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this policy, and trained our employees and consultants about our policies and practices.

Why Does BlueSky Need Personal Information

BlueSky provides a secure Web-based “software as a service” set of tools that let users provide demographic information, healthcare event tracking, and professional credentials of individuals or employees. In order for employees, applicants, or test individuals to submit information via BlueSky’s web application, BlueSky needs to collect the required information from these individuals or from third party references, process it, store it, and disclose it per the terms and conditions of the License Agreement.

What personal information do we collect?

Personal information is any information that identifies employees, individuals or test individuals and third parties by which their identity could be deduced, as well as any judgment or opinion on such individual.

If we did not collect and use personal information and information about individuals provided by third parties, we could not provide our clients with competent service and could not therefore qualify employees’ credentials and test applicants’ results of event tracking.

How do we collect personal information?

We collect information only by lawful and fair means, and not in an unreasonably intrusive way. We collect personal information directly from individuals permitted to utilize the BlueSky system. We also collect personal information from third parties to obtain information in connection with the individuals qualifications for the event or project.

Consent

Except when we are required by law, we shall ask the individual and any third party to specifically consent, if we collect, use or disclose personal information. We ask for their consent in writing. Sometimes, their consent may be implied through their conduct with us.

Use of Information

We use personal information collected by us for the purposes indicated above and services to our clients.

Disclosure of Personal Information

In addition to the disclosures discussed above, under the circumstances provided by applicable privacy legislation, we may disclose personal information in our possession:

• when we are required or authorized by law to do so, for example if a court issues a subpoena;
• when the person from whom we have collected the information has consented to the disclosure;
• to a professional with whom we decide to work in the course of qualifying individuals for our clients, provided the professional is contractually bound by our privacy policy;
• if we engage a third party to provide administrative services to us (like computer back-up services or archival file storage), provided third party is contractually bound by our privacy policy;
• if the information is publicly available personal information, as it is defined under the applicable privacy legislation.

We will take all reasonable steps to ensure that all persons, including all prospective employers, to whom we may disclose personal information in our possession, will not use or disclose that information without the consent of the person from whom we have collected it, for purposes not relevant to the object of the disclosure.

Updating Information

As the personal information given by individuals and third parties is used to qualify individuals for events for which they may or may not be interested, it is important that the information be accurate and up-to-date.

If any of the personal information of individuals or third parties changes, we encourage them to inform us so that we can make any necessary changes.

Is Personal Information in Possession of BlueSky Secure?

BlueSky takes all reasonable precautions to ensure that personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

• premises security;
• restricted files access to personal information;
• deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;
• encryption of data held in BlueSky’s databases and encryption of the channels by which information is provided to BlueSky through the use of BlueSky’s Web-based “software as a service” set of tools;
• internal password and security policies.

Access to Personal Information

Individuals and third parties may ask for access to any objective personal information we hold about them. However, we are not authorized to disclose to individuals information (except the fact that they have provided information) collected from the third parties identified to us, without the express consent of those third parties.

Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees.

Correcting Errors

If BlueSky holds information about a individual or reference person and he or she can establish that it is not accurate, complete and up-to-date, BlueSky will take reasonable steps to correct it.

Denial of access to Personal Information?

Rights to access your personal information are not absolute. We may deny access in the situations provide by applicable privacy legislation.

If we deny a request for access to, or refuse a request to correct information, we shall explain why.

BlueSky does not use your Social Insurance Number as a way of identifying or organizing the information we hold upon individuals or third parties.

Communicating with Us

Persons communicating with us by e-mail should be aware that e-mail is not a 100% secure medium, and should be aware of this when contacting us to send personal or confidential information.

Changes to this Privacy Policy

Since BlueSky regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time.

Request for Access

If you have any questions, or wish to access your personal information, please write to our Privacy Contact at:

BlueSky Synergy, LLC
7135 Charlotte Pike
Suite 200
Nashvile TN 37209

Care of: The Chief Financial Officer

If you are not satisfied with our response, you have the right to communicate with the relevant privacy officer of your jurisdiction.

WebSite

Our website contains links to other sites, which are not governed by this privacy policy.

On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimise our web service. We may provide aggregate information to third parties, but these statistics do not include any identifiable personal information.