Privacy Policy

1. Introduction

This Privacy Policy explains how Center for Independent Living Jacksonville, a Florida nonprofit 501(c)(3) tax-exempt organization (EIN 59-1842440) (“CIL Jacksonville,” “we,” “us,” or “the operator”) collects, uses, shares, and protects information when you use PCAmatch.org (“PCAmatch,” “Platform,” “Service,” or “Site”). PCAmatch is a free platform that helps people with disabilities and their families (“Seekers”) connect with independent Personal Care Assistants (“Caregivers”). The Platform is developed and operated on our behalf by Innovative Applications, Inc., (“Technology Provider”) which processes information on our behalf as a service provider under our written instructions and subject to confidentiality and security obligations.

By accessing, browsing, registering for, or using PCAmatch, you acknowledge that you have read, understood, and agree to be bound by this Policy and our Terms of Service. If you do not agree, you must discontinue use of the Platform immediately. This Policy is incorporated into and operates alongside our Terms of Service. Capitalized terms not defined in this Policy have the meanings assigned in the Terms of Service.

2. Information we collect

We collect personal information that you provide directly, information generated through your use of the Platform, and limited technical information necessary to operate and secure the Service. Most information is provided voluntarily by you.

Account information:

• Your display name, email address, and the role you select (Seeker, Caregiver, or administrator);
• A password, which is handled by our third-party authentication provider (Firebase Authentication) and is not stored by us in plain text or reversible form.

Caregiver profile information:

• Your profile photo (optional), the personal care services you offer, your general availability, your hourly rate or fee range, a narrative description of your experience and qualifications, and your preferred methods of contact;
• A phone number (optional), which is collected only if you voluntarily choose to provide one and is shared with a Seeker only after you explicitly consent;
• If you choose to apply for a “Background Checked” badge, you may either (a) authorize us to look up your Level 2 background screening status in the State of Florida’s Agency for Health Care Administration (AHCA) Care Provider Background Screening Clearinghouse, in which case we collect your legal last name, date of birth, and Social Security number, together with an optional note to our staff (see the Background-Check Identifiers provisions in Section 4); or (b) submit background check reports, criminal history records, or similar documentation. Our staff reviews the lookup result or the documents you submit and assigns a badge status, which is displayed on your public profile. If a badge is granted, we also record the screening’s expiration date as reported by the Clearinghouse.

Seeker information:

• Information about the type of personal care assistance you need, your preferences for Caregiver characteristics or qualifications, and your availability.
• A phone number, if you choose to provide one.

Activity you generate on the platform:

• When a Seeker sends an inquiry to a Caregiver, we collect the inquiry itself and any short message included with it;
• Reviews you submit about Caregivers, including any narrative comments and ratings;
• Information you report about the outcome of a connection (e.g., whether you hired a Caregiver, or whether a match was successful);
• Any safety concerns, complaints, or incident reports you file through the Platform.

Technical information:

• A session cookie that keeps you signed in while you use the Platform;
• Information collected by Cloudflare Turnstile (our anti-bot protection service) when you access public forms, and limited request metadata used for rate-limiting and abuse prevention (such as request timestamps and anonymized indicators used to prevent spam)
• We deliberately avoid building a per-user activity profile or tracking individual browsing behavior across the Site.

3. How we handle your address and location

We collect and process location information in a privacy-protective manner. At sign-up, you may enter a street address. We send that address once to a third-party mapping service (Google Maps geocoding API) to convert it into approximate latitude and longitude coordinates (a geographic point). We do not store your street address. After the conversion, the address you entered is discarded. Only the approximate geographic coordinates are retained in our database to enable distance-based matching of Seekers and Caregivers. When you search for a Caregiver by location, the location you type into the search box is used to perform the search in real time and is not recorded or stored. This approach is a deliberate privacy design choice intended to minimize the collection and retention of precise location data.

4. Sensitive Information

Because PCAmatch facilitates personal care assistance, some information you choose to share, such as care needs, disability-related information, or health conditions, may be considered sensitive under applicable privacy laws.

Voluntary Disclosure. You decide what information to include in your profile, inquiries, and messages. We encourage you to share only what is necessary to find a suitable match and to avoid posting detailed medical, financial, or other highly sensitive information in free-text fields visible to other users.

HIPAA Status.CIL Jacksonville is not a “covered entity” or “business associate” under the Health Insurance Portability and Accountability Act (HIPAA), and HIPAA does not apply to the operation of PCAmatch. This Platform is a listing and connection service, not a healthcare provider or claims processor.

Background-Check Identifiers (Caregivers). If you are a Caregiver and you ask us to confirm your background screening through the state Clearinghouse, we collect the identifiers the state requires to locate your record: your legal last name, date of birth, and Social Security number, together with an optional note you may include for our staff. We collect these identifiers only with your explicit, recorded authorization, and we use them solely to perform the lookup you requested. We never require you to be screened; the Background Checked badge is optional.

Safeguards for Background-Check Identifiers. These identifiers are handled under stricter safeguards than any other information on the Platform: (i) they are encrypted at the application layer before they are stored — each record is encrypted under its own key, which is in turn protected by a managed key service (Google Cloud Key Management Service) — so they cannot be read from our database alone; (ii) they can be decrypted only by authorized CIL Jacksonville staff for the purpose of performing your lookup, and every decryption is individually logged; (iii) they are permanently erased as soon as your lookup result is recorded, and if no lookup is performed they are automatically erased after 14 days; (iv) after erasure we retain only the last four digits of the Social Security number, to reconcile our record of the request with the lookup that was performed; and (v) they are never displayed on any profile, never shared with other users, and never included in any email. The optional note you include is erased together with the identifiers. If a badge is granted, we retain the screening result and its expiration date as the basis for the badge.

5. How we use information

We use the information we collect for the following purposes, which are necessary to operate the Service, fulfill our contract with you, comply with legal obligations, and pursue our legitimate interests in providing a safe and effective platform.

We use information to:

• create and maintain your user account, authenticate your identity when you sign in, and manage your access to the Platform;
• Publish and display Caregiver listings to Seekers;
• Perform distance-based matching of Seekers and Caregivers using approximate geographic coordinates;
• Enable Seekers to send inquiries to Caregivers;
• Facilitate the consent-based sharing of contact details between Caregivers and Seekers;
• Perform a background-screening lookup in the state Clearinghouse when a Caregiver has authorized one, record the result and its expiration date, and display the resulting badge status;
• Send background-check status notifications, including renewal reminders to a Caregiver before their screening expires, and notices to that Caregiver and to connected Seekers when a Background Checked badge is removed;
• Screen user-submitted content (including profile descriptions, messages, and reviews) for prohibited content, spam, harassment, or policy violations;
• Review and respond to safety reports and complaints;
• Moderate reviews for compliance with our community guidelines;
• Investigate and enforce violations of our Terms of Service, this Policy, or applicable law;
• Suspend or terminate accounts that violate our policies or engage in fraudulent, abusive, or illegal conduct;
• Protect the Platform and its users against fraud, unauthorized access, spam, bots, distributed denial-of-service attacks, and other security threats;
• Implement rate-limiting, access controls, and anti-abuse measures;
• Monitor for and respond to security incidents;
• Comply with applicable federal, state, or local laws, regulations, or legal processes (such as subpoenas, court orders, or lawful requests from government authorities);
• Respond to claims that content violates the rights of third parties;
• Protect the rights, property, or safety of CIL Jacksonville, our users, the public, or others, including in emergencies involving imminent harm.

We use your email address and (if provided) phone number to send you (i) service-related notifications such as account confirmation, inquiry notifications, review alerts, connection updates, password reset instructions, and account security notices; (ii) updates to this Policy, changes to our Terms of Service, notices regarding violations or safety concerns, and other administrative communications necessary to operate the Platform; (iii) With your prior consent, we may send occasional announcements about new features, community updates, or nonprofit mission-related information. You may opt out of these non-essential communications at any time.

6. How we share information

We do not sell, rent, or lease your personal information to third parties for their marketing purposes. We share information only as described here, primarily to operate the Platform, ensure safety, and comply with legal obligations.

The Platform is designed to connect Seekers and Caregivers. Certain information is visible to other users as necessary for the Service to function. If you register as a Caregiver, your public listing is visible to all Seekers and includes: your display name, profile photo (if provided), services offered, hourly rate, general geographic area (city or region, derived from your approximate coordinates), a description of your experience, your “Background Checked” badge status (if any), and reviews submitted by Seekers. Your contact information (email address and phone number, if provided) is not displayed publicly. A Caregiver’s contact information is shared with a specific Seeker only after the Caregiver explicitly consents to share it—this is the “handshake” process that initiates a connection. When a Seeker sends an inquiry to a Caregiver, the Caregiver sees the Seeker’s display name and any message the Seeker included with the inquiry.

PCAmatch uses a consent-based mechanism to protect Caregiver privacy: (i) By default, no contact information is shared; (ii) When a Seeker expresses interest in a Caregiver, the Caregiver receives a notification; (iii) The Caregiver may review the inquiry and choose whether to share their contact details with that specific Seeker; (iv) Only after the Caregiver affirmatively consents is their contact information disclosed to the Seeker; (v) Seekers cannot access a Caregiver’s contact information without this explicit consent.

State of Florida (AHCA Clearinghouse).When a Caregiver authorizes a background-screening lookup, authorized CIL Jacksonville staff enter the Caregiver’s identifiers (legal last name, date of birth, and Social Security number) into the Florida Agency for Health Care Administration’s Care Provider Background Screening Clearinghouse to locate the Caregiver’s screening record. The state’s own systems, records, and privacy practices govern information held by the Clearinghouse; we do not control the state’s records.

Badge Status Notices to Connected Users.If a Caregiver’s Background Checked badge is removed because their screening reached its expiration date, we may notify the Seekers with whom that Caregiver completed the consent-based contact-sharing (“handshake”) process that the badge was removed. The notice states only that the screening lapsed and the badge was removed; it contains no background-check records or identifiers.

We share information with trusted third-party service providers that perform functions on our behalf under written agreements that limit their use of personal information and require them to protect it. These service providers include:

• Innovative Applications, Inc. Our Technology Provider, which builds, hosts, maintains, and operates the Platform on our behalf. Innovative Applications may access information as reasonably necessary to develop, secure, support, and troubleshoot the Service under our written instructions.
• Google Cloud Platform and Firebase. We use Google Cloud services for: (i) user authentication (Firebase Authentication); (ii) database hosting (Cloud SQL); (iii) file storage for profile photos and background check documents (Cloud Storage); (iv) address-to-coordinates conversion (Google Maps Geocoding API); and (v) automated content screening to detect prohibited or harmful content (Cloud Vision API and Cloud Natural Language API). We also use Google Cloud Key Management Service (Cloud KMS) to protect the encryption keys for background-check identifiers, as described in Section 4.
• Cloudflare.We use Cloudflare’s Turnstile service to provide anti-bot protection on public-facing forms.
• Resend. We use Resend to send transactional emails, such as inquiry notifications, account confirmations, and password resets.

Contractual Protections. Each service provider is prohibited from using your personal information for any purpose other than providing the specific service to us.

We may share aggregate, statistical, or de-identified information that does not identify you personally with partners, funders, researchers, or the public for purposes such as reporting on program impact, supporting grant applications, or improving services for people with disabilities. We may share information for purposes not described in this Policy with your explicit consent.

7. Cookies, Tracking Technologies, and Analytics

We use a small number of cookies and similar technologies strictly necessary to operate the Platform. A “cookie” is a small text file stored on your device by your web browser. We use a session cookie to keep you signed in while you navigate the Platform. This cookie is essential for authentication and account access and expires when you close your browser or log out. We use Cloudflare Turnstile, an anti-bot service, on public-facing forms (such as registration and contact forms). Turnstile may set a temporary cookie or use similar browser storage to verify that you are a human user and not an automated bot. We do not use cookies for advertising purposes. We do not use third-party cookies to track your activity across other websites. We do not integrate third-party advertising networks or social media tracking pixels. Because we do not engage in cross-site tracking, we do not respond to “Do Not Track” browser signals. Our default practice is privacy-protective by design. Most web browsers allow you to control cookies through browser settings. You may set your browser to refuse all cookies or to alert you when a cookie is being sent. However, if you disable or refuse the essential session cookie, you will not be able to sign in or use authenticated features of the Platform.

We measure usage of PCAmatch to understand whether the Service is effective and to identify opportunities for improvement. Our analytics practices are intentionally designed to avoid creating a detailed, per-person activity trail. Our usage analytics store outcomes and anonymous counts—such as the number of searches performed, the number of listings viewed, the number of inquiries sent, and whether searches returned results. These records contain no user identifiers, no IP addresses, no session identifiers, and no location information. We do not build individual user profiles or track what specific users do on the Platform. This is an intentional design decision to protect user privacy. We do not use Google Analytics, Facebook Pixel, or similar third-party analytics or tracking services that profile individual users.

8. Data Security

We implement reasonable technical, administrative, and organizational safeguards designed to protect the information we collect against unauthorized access, use, disclosure, alteration, and destruction. All data transmitted between your browser and our servers is encrypted using HTTPS (TLS encryption). Access to personal information is restricted to authorized personnel and service providers who need it to perform their functions, and is subject to authentication and role-based permissions. Profile photos and background check documents are stored in private cloud storage (Google Cloud Storage) and are served only through access-controlled routes that verify user permissions. We implement a content security policy and other security headers to protect against cross-site scripting, clickjacking, and other web vulnerabilities. We implement rate-limiting and anti-bot protections to prevent automated attacks, spam, and abuse. User passwords are managed by Firebase Authentication and are hashed and encrypted; we do not store passwords in plain text. No system is perfectly secure. Despite our safeguards, we cannot guarantee absolute security. Unauthorized access, hardware or software failure, human error, and other factors may compromise information security. To the fullest extent permitted by applicable law, neither CIL Jacksonville nor Innovative Applications, Inc., nor their respective officers, directors, employees, volunteers, or agents, is liable for any unauthorized access to, disclosure of, or loss of information that occurs despite our reasonable safeguards. The limitations of liability and releases set forth in our Terms of Service and any separate Liability Release and Waiver also apply to this Policy.

9. Data Retention

We retain your account information and profile data for as long as your account remains active and as necessary to provide the Service, enforce our agreements, resolve disputes, and comply with legal obligations. When you delete your account, your profile is removed from public listings and search results, your personal information is deleted or de-identified, and there is no address for us to delete because we never stored your street address.

We may retain certain information after account deletion as necessary to (i) comply with legal obligations (such as tax, audit, or regulatory recordkeeping requirements); (ii) resolve disputes or enforce our Terms of Service or this Policy; (iii) prevent fraud, abuse, or violations of our policies; (iv) maintain aggregate or de-identified data for analytical or reporting purposes.

Deleted information may persist in backup or archival systems for a limited period, but such information will not be used for operational purposes and will be securely deleted or overwritten in due course. Reviews you submit may remain visible after account deletion in a de-identified or anonymized form (e.g., attributed to “Former User”) to preserve the integrity of the review system.

Background-check identifiers follow the shorter retention schedule described in Section 4: they are erased when the lookup result is recorded, or automatically after 14 days if no lookup is performed, and only the last four digits of the Social Security number are retained for reconciliation. The screening result, the reviewing staff member, the review date, and the screening’s expiration date are retained as the provenance of the Background Checked badge.

10. Your Privacy Rights and Choices

You may access and update most of your account and profile information at any time by logging into your dashboard. You may delete your account at any time through your account settings or by contacting us. Deletion will remove your public listing and personal information. If you are a Caregiver, you control whether and when to share your contact information with a specific Seeker. You are not required to accept any inquiry or share your contact details. You may opt out of non-essential communications (such as community updates or announcements) by following the “unsubscribe” link in any such email or by contacting us. You cannot opt out of transactional or administrative messages necessary to operate the Service (such as account security notices).

Depending on where you reside, you may have additional rights under applicable privacy laws, including:

• The right to request correction of inaccurate personal information.
• The right to request deletion of your personal information, subject to certain exceptions (such as legal compliance, fraud prevention, or completion of a transaction).
• The right to obtain a copy of your personal information in a portable, machine-readable format where technically feasible.
• The right to opt out of the “sale” or “sharing” of personal information. (Note: We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.)
• The right to limit the use and disclosure of sensitive personal information to purposes necessary to perform the services you requested. (Note: We do not use sensitive information beyond what is necessary to provide the Platform.)
• The right to be free from discrimination for exercising any of these rights.

California Residents. If you are a California resident, you have the rights described in Section 10 above under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). For details on categories of information collected, purposes, and disclosures, see the provisions above. We do not sell personal information, and we do not share personal information for cross-context behavioral advertising. You may designate an authorized agent to make requests on your behalf by providing written authorization. To exercise your rights, contact us.

Virginia, Colorado, Connecticut, Utah, and Other State Residents.If you reside in Virginia, Colorado, Connecticut, Utah, or another state with a comprehensive privacy law, you may have rights similar to those described above, subject to the definitions and exceptions in your state’s law. Contact us to exercise your rights.

To exercise any of the rights described here, contact us. We will verify your identity before processing your request (for example, by confirming your email address or account information). We will respond to verified requests within the time periods required by applicable law (typically within 45 days, with the possibility of one extension). We do not charge a fee to process or respond to your privacy rights request unless the request is excessive, repetitive, or manifestly unfounded.

11. Children’s Privacy

PCAmatch is intended for use by adults age 18 and older. The Service is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. We comply with the Children’s Online Privacy Protection Act (COPPA). If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information promptly. If you are a parent or guardian and believe that your child under age 13 has provided us with personal information, please contact us immediately using the information in Section 17, and we will take steps to delete such information. We do not target or market the Service to individuals under 18. If you are between 13 and 18 years of age, you may use the Service only with the involvement, supervision, and approval of a parent or legal guardian.

12. Changes to This Policy

We may update or modify this Policy from time to time to reflect changes in our practices, legal requirements, or the features of the Platform. When we make changes, we will update the “Last Updated” date at the top of this Policy. Changes will take effect on the date specified in the notice or, if no date is specified, on the date the updated Policy is posted. Your continued use of PCAmatch after the effective date of an updated Policy constitutes your acceptance of the changes. If you do not agree to the updated Policy, you must discontinue use of the Platform and may delete your account.

13. California-Specific Disclosures

CCPA/CPRA Disclosures. This Section provides disclosures required by the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), for California residents.

Categories of Personal Information Collected. In the preceding 12 months, we have collected the following categories of personal information (as defined by the CCPA):

• Identifiers: Name, email address, display name, and optional phone number. For Caregivers who authorize a background-screening lookup: legal last name, date of birth, and Social Security number (retained only briefly, as described in Section 4).
• Demographic Information: User role (Seeker or Caregiver) and general location (approximate coordinates, no precise address).
• Commercial Information: Services offered, hourly rate (for Caregivers).
• Internet or Network Activity: Inquiry activity, review submissions, session cookies, and limited anti-abuse data (no comprehensive browsing history).
• Geolocation Data: Approximate geographic coordinates (not precise location).
• Professional or Employment Information: Caregiver experience descriptions and qualifications.
• Sensitive Personal Information: Care needs and disability-related information (voluntarily provided by Seekers), and background check documentation (voluntarily provided by Caregivers). Also: the Social Security number and date of birth a Caregiver provides for an authorized background-screening lookup (collected with authorization and erased after use, as described in Section 4).
• Inferences: None. We do not create profiles or inferences about users.

Sources of Personal Information. We collect personal information directly from you, from your device (technical information), and from our service providers (such as email delivery confirmation).

Purposes for Collection and Use. We collect and use personal information for the business and commercial purposes described above, including operating the Platform, facilitating connections, ensuring safety, and complying with law.

Categories of Third Parties with Whom We Share Information. We disclose personal information to the categories of third parties described above: other users (as necessary for the Service), service providers and technology partners, and legal authorities (when required).

No Sale or Sharing. We do not sell personal information. We do not share personal information for cross-context behavioral advertising.

Retention. We retain personal information as described above.

Your California Rights. California residents have the rights described above. You may also designate an authorized agent to submit requests on your behalf.

Shine the Light.Under California Civil Code § 1798.83, California residents may request information about disclosure of personal information to third parties for direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.

14. Nevada-Specific Disclosures

Under Nevada law (NRS 603A.340), Nevada residents may opt out of the “sale” of certain covered information. We do not sell covered information as defined by Nevada law. If you are a Nevada resident and have questions, you may contact us.

15. Accessibility

We are committed to ensuring that PCAmatch and this Privacy Policy are accessible to people with disabilities. If you experience difficulty accessing this Policy or any part of the Platform, please contact us and we will work with you to provide the information in an accessible format. Upon request, we will provide this Policy in alternative formats, including large print, electronic formats compatible with screen readers, or other formats as reasonably requested.

16. Supplemental Notices

While PCAmatch facilitates personal care connections, we are not a healthcare provider, health plan, or healthcare clearinghouse. We do not create, receive, maintain, or transmit protected health information (PHI) as defined by HIPAA in the course of providing the Platform. To the extent any information you provide could be considered health-related, you provide it voluntarily for the purpose of connecting with personal care assistance, and HIPAA does not govern our handling of such information.

17. Contact Us

Email: sdykes@ciljacksonville.org
Mail: Center for Independent Living Jacksonville
Attn: Privacy Officer / PCAmatch Privacy
2709 Art Museum Drive
Jacksonville, FL 32207