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Privacy Policy

Effective October 12, 2026

Last modified: October 12, 2026. This version supersedes the Privacy Policy dated July 20, 2026. A summary of what changed is at the end of this policy.

1. Overview and Scope

CareSwaps, LLC, a Colorado limited liability company that also does business as PatientSwaps (the "Company," "we," "us," or "our"), respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (this "Privacy Policy").

This Privacy Policy describes the types of information we may collect from you or that you may provide when you access and use www.careswaps.com ("CareSwaps") or www.patientswaps.com ("PatientSwaps") (collectively, the "Websites"), including any products or services offered on or through the Websites (collectively referred to as the "Services"), whether as a guest or a registered user, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

The Company operates two related web-based platforms:

  • CareSwaps (available at www.careswaps.com) — a family- and caregiver-facing platform that helps families explore senior-care transfer options through a subscription service.
  • PatientSwaps (available at www.patientswaps.com) — a facility-facing platform that provides algorithmic transfer matching technology to participating senior-care facilities.

The Company provides matching technology only. We do not provide care, and every admission and clinical decision is made by the participating facility's own licensed staff. The Services currently cover Colorado only.

This Privacy Policy applies to information we collect from CareSwaps and PatientSwaps users:

  • On the Websites and through the Services.
  • In email, text, and other electronic messages between you and the Company or the Websites.
  • Through mobile and desktop applications, if we make downloadable applications available from the Websites in the future, which provide dedicated non-browser-based interaction between you and the Websites.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by the Company or any third party.
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Websites.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites or the Services. By accessing or using the Websites and the Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to This Policy in Section 10 below). Your continued use of the Websites or the Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

2. Information We Collect and How We Collect It

We collect several types of information from and about users of our Websites and Services, including information:

  • By which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");
  • That is about you but individually does not identify you; and/or
  • About the Services you use, your internet connection, the equipment you use to access our Websites, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and similar technologies (see Section 6).
  • From third parties, for example, our business partners and the participating facilities.

2.1 Information You Provide to Us

The information we collect on or through our Websites and Services may include:

  • Information that you provide by filling in forms. This includes information provided at the time of registering to use our Websites, subscribing to our Services, joining a waitlist, or requesting further services. We may also ask you for information when you report a problem with our Websites or Services.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Websites, including the nature of any Services ordered and your billing address. You may be required to provide financial information before placing an order through our Websites.
  • Information that you provide to us or authorize us to request from third parties (including, but not limited to, healthcare providers) on your behalf in furtherance of your use of the Services offered on or through the Websites. This includes general personal and demographic information, medical history, and other personal or protected health information.
  • Information that you provide when responding to text message or email correspondence from us, if you have opted in to receiving such communications.

For CareSwaps users we may also collect:

  • Account and Contact Data: Name, email address, phone number, state of residence, relationship to the resident, and the access code you use to sign in to your dashboard.
  • Subscription and Billing Data: Billing name, billing address, and payment method. Credit card processing is handled by Stripe through Stripe Checkout (we do not see or store full card numbers). We receive your name, email address, and Stripe's customer and subscription identifiers.
  • Your acceptance of our agreements: When you accept our Client Subscription Agreement at checkout or when you first sign in to your dashboard, we record the date and time, your IP address, and the version of the agreement you accepted.
  • Intake Form Data: Information about your loved one or resident submitted through our intake form, which is hosted in Jotform's HIPAA environment. It may include the resident's name, date of birth, current living situation and current community, care needs and care level, power-of-attorney or other legal-authority status, preferred timeline and matching preferences (such as location and must-haves), payer information, your contact information as the family contact, and related details.
  • Payer eligibility: The Services are available only for residents whose care is paid by private pay, commercial insurance, or private long-term-care insurance. The intake form asks for the payer type and does not accept requests funded by Medicare, Medicaid (including pending Medicaid), Health First Colorado, PACE, TRICARE, the VA, or any other federal health-care program, and those requests are excluded from matching. We do not verify a resident's insurance coverage.
  • Your Information Sharing Authorization: Your typed electronic signature and date on our Information Sharing Authorization, a HIPAA authorization that lets us share the resident's identity with a specific facility only after you approve a specific match (see Section 4.1).
  • Colorado referral-service disclosure: Your electronic signature on our Colorado referral-service disclosure, signed through Jotform Sign (see Section 4.2).
  • Dashboard and Document Uploads: Documents or information you upload to your CareSwaps account dashboard, such as a medical durable power of attorney (MDPOA) or similar papers showing your authority to act. Uploads are made through a Jotform form in the same HIPAA environment, where the document stays, and Jotform notifies our Google Workspace records directly. We review each document you upload and note on your request whether it has been received and reviewed.
  • Your choices on the dashboard: Your authorization of a specific match, and any cancellation or withdrawal of your request, with the date and time.
  • Communications: Emails, support inquiries, form submissions, and phone conversations with our team.

For PatientSwaps users we may also collect:

  • Facility Account Data: Facility name, location, license numbers, regulatory identifiers, and designated account contacts.
  • Staff and User Credentials: Individual user names, work email addresses, job titles, and portal sign-in information. Portal users sign in with a one-time "magic link" sent to a registered work email, and we keep a record of active sessions.
  • Facility Operational Data: Bed inventory, bed types, availability status, care levels offered, admission criteria, payer acceptance profiles, occupancy metrics, and network participation information.
  • Matching Query Data: Parameters submitted to the matching algorithm, which may include patient-level information as directed by the facility. When a facility lists one of its own residents, we also collect the facility's attestations that the resident's payer type is eligible and that a signed authorization is on file, together with the attesting user's email address and the time of the attestation.
  • Communications: Messages, support inquiries, and correspondence between PatientSwaps users and the Company.

Facility business information is not health information, and some of it (such as a facility's name and the care levels it offers) may be shown to families as part of a match.

2.2 Automatically Collected Technical Data

As you navigate through and interact with our Websites and Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Websites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Websites.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Websites and to deliver a better service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Keep you signed in to your dashboard during a session.
  • Recognize you when you return to our Websites.

The technologies we use for this automatic data collection may include, without limitation:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Websites or Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites. For information about the cookies we use and how to manage them, see Section 6 (below).
  • Web Beacons. Pages of our Websites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Our hosting provider also processes standard technical information (such as IP address, browser type and the pages requested) to deliver the pages to you. We do not use this information to build advertising profiles.

Some content or applications on the Websites are served by third parties, including content providers and application providers (for example, the Jotform intake and document forms and the Stripe checkout page). These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Websites, under their own privacy policies. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible provider directly.

2.3 PHI and Health-Related Information

The Company is a healthcare technology platform. We are not a healthcare provider, and we are not a "Covered Entity" as defined by the Health Insurance Portability and Accountability Act ("HIPAA"). We act as a Business Associate of each participating facility, and we require a signed Business Associate Agreement ("BAA") with a facility before it can see any resident's identity. Our system shows a resident's identity to a facility only when that facility has a signed BAA with us on file and the family has authorized that specific match. When we process Protected Health Information ("PHI") on behalf of a facility, HIPAA individual rights (such as the right to access, amend, or receive an accounting of disclosures of PHI) should generally be exercised through the applicable healthcare facility (the "Covered Entity"), not directly through the Company. If you wish to exercise a HIPAA right relating to PHI that we have processed on behalf of a facility, please contact the applicable facility directly.

Information submitted directly by patients, families, and caregivers through CareSwaps (for example, through the intake form) is protected under this Privacy Policy and applicable federal and state privacy and security laws. Because resident information we receive from families is used with facilities, we treat all resident information we hold as PHI, whatever its source, and protect it under our written HIPAA Privacy, Security, and Breach Notification policies. When that information is shared with a facility under a BAA, it also becomes subject to the BAA terms.

The Company will cooperate with facility requests to fulfill individual rights obligations as required by the applicable BAA. If a breach involves PHI that the Company processes on behalf of a facility, we will notify the applicable Covered Entity as required by the BAA and HIPAA (45 CFR § 164.410), and we will notify affected individuals, or cause them to be notified, in coordination with that facility as HIPAA and the BAA require. The Company may also have independent state-law breach notification obligations for personal information it holds directly (see Section 8.3).

3. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Websites and their contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices. Our family subscription renews automatically each month. When you subscribe, we email you an acknowledgment that explains the renewal terms and how to cancel, and as a courtesy we send a notice before each monthly charge. If your subscription will continue past 12 continuous months, we also send the reminder that Colorado's automatic-renewal law (C.R.S. § 6-1-732) calls for, 25 to 40 days before that renewal, and again before each later 12-month mark.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Websites or any products or services we offer or provide through them.
  • To allow you to participate in interactive features on our Websites.
  • To provide you with the Services offered on or through the Websites including to: (a) provide you with access to algorithmic bed-matching and transfer matching software services; (b) identify and display potential transfer opportunities based on operational factors (geographic proximity, bed availability, payer acceptance, and timing) and other fixed eligibility criteria, without scoring or ranking facilities — options are shown with facts, ordered by distance and then date; (c) share de-identified operational signals and matching information with participating facilities as authorized and in accordance with the applicable Business Associate Agreement; and (d) maintain records regarding your use of the Platform, matching queries, and matching activity as required by applicable law.
  • To deliver the Colorado referral-service disclosure, track its signature, provide a copy to the admitting facility, and send cancellation notices to facilities (see Section 4.2).
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We do not: (a) sell personal data or PHI; (b) use PHI for advertising, marketing, or targeted content; or (c) use health information to make or influence clinical decisions.

We may de-identify information in accordance with HIPAA (45 CFR § 164.514(b)) such that there is no reasonable basis to believe the information can identify an individual. Properly de-identified information is not PHI and is not subject to HIPAA restrictions.

The Company may use de-identified and aggregated information for lawful business purposes, including:

  • Platform analytics, performance monitoring, and service improvement
  • Network-level benchmarking and utilization insights
  • Algorithm optimization and feature development
  • Research and quality improvement initiatives
  • Industry reporting and thought leadership (in aggregate form only)

We will not attempt to re-identify de-identified information and will not use de-identified data to contact or identify specific individuals.

3.1 Emails We Send

  • Welcome email after intake, with a copy of the Information Sharing Authorization you signed and a link to the Colorado referral-service disclosure.
  • Status notices about your request, proposals, authorizations, documents, and withdrawals. To protect privacy, these emails do not include resident health details; they tell you to sign in to see more. The welcome email is the exception: it includes the text of your own authorization and goes only to you.
  • Subscription emails: an acknowledgment when you subscribe (with how to cancel), a courtesy notice before each monthly charge, and a reminder 25 to 40 days before your subscription continues past each 12-month mark.
  • Reminders if your Colorado referral-service disclosure has not yet been signed.
  • Facility notices to portal users about new requests, proposals, authorizations, and withdrawals or cancellations. These do not contain resident health details.
  • Waitlist and launch emails, and for facilities, onboarding and outreach emails sent to business contacts. Outreach lists never include family or resident information.

Apart from the welcome email described above, which goes only to you through our Google Workspace email (covered by a BAA), if we need to send resident health information by email — for example, a copy of records you requested — we send it through Paubox, an encrypted email service that has signed a BAA with us.

Opting out. You can opt out of non-essential emails (waitlist, launch, onboarding, and outreach messages) by using the unsubscribe link or emailing privacy@careswaps.com. You cannot opt out of essential service, legal, or billing notices while you have an active request or subscription, because we need them to run the Services and meet the law.

4. How We Share Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

  • To contractors, service providers, and other third parties we use to support our business (see Section 5).
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred. Any such successor must take over the Services and be bound by this Privacy Policy, our Business Associate Agreements, and the same Colorado referral-service obligations. This is not a sale or transfer of your contact information to a third party for its own use, which we never do.
  • To payment processors (e.g., Stripe).
  • To a facility you have authorized for a specific match, as described in Section 4.1.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We have no subsidiaries or affiliates. If that changes, they will be bound by this Privacy Policy and will not receive resident information except as described in Section 4.1.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

For CareSwaps users, when a family user affirmatively opts into the matching process, we may share relevant information with participating facilities as needed to facilitate transfer matching, as described in Section 4.1. Resident identity is shared only with a facility that has a signed BAA with us on file, and only after the family authorizes that specific match. De-identified operational signals (such as geographic demand information) may be shared more broadly to notify facilities of interest, but never in a form that identifies a specific patient or family.

For PatientSwaps users, information about a resident is shared between facilities only as described in Section 4.1: de-identified facts before the family authorizes a specific match, and the resident's identity only after that authorization.

4.1 How Family Authorization Controls Sharing

Families decide when a resident's identity is shared:

  1. Before you authorize a match, a facility that might accept the resident sees only de-identified request facts — care level, payer category, timeline, and distance. It does not see the resident's name, date of birth, or care details.
  2. The resident's current facility is not told about the request at this stage.
  3. When a facility proposes a match, you see it on your dashboard. Only if you authorize that specific match, naming the facilities involved, do we share the resident's identity and the information needed for the transfer with those facilities. The admitting facility also receives a copy of the Colorado referral-service disclosure through our facility portal.
  4. If you cancel or withdraw the request, we re-lock the resident's identity so that facilities can no longer see it in the portal, mark any matches as withdrawn, and send a cancellation notice to the facilities that were shown the request (the proposed admitting facility always, and the resident's current facility if it had been told under your authorization).

Information already shared with a facility under your authorization becomes part of that facility's records, and the facility handles it under its own HIPAA obligations and its own Notice of Privacy Practices.

4.2 Colorado Referral-Service Disclosure

Colorado law (C.R.S. § 6-1-729) requires referral services to give families a written disclosure. Ours says, in summary:

  • We do not sell, rent, or transfer your contact information to anyone. This is our own promise to you.
  • We receive no fee from any facility for referrals or placements. Families pay a flat subscription. Participating communities currently pay CareSwaps nothing. If CareSwaps later charges a flat software subscription fee, it will never vary with referrals, transfers or outcomes. We have no financial relationship with any facility that depends on whether a resident moves there.
  • You may cancel at any time. When you cancel, we notify the facilities that were shown your request that it has been withdrawn.
  • We send you the full disclosure (linked in your welcome email) before any referral and ask you to sign and date it electronically; CareSwaps also signs and dates it. After you authorize a match, the admitting facility receives a copy of the disclosure through our facility portal.

5. Third-Party Service Providers and Data Architecture

We use third-party service providers to operate our platforms. The providers that hold resident health information and uploaded documents for us — Jotform (its HIPAA environment, including Jotform Sign), Google Workspace, and Paubox — operate under business associate agreements (BAAs) with us. Our hosting provider, Cloudflare, has not signed a BAA; it carries dashboard data between our records and your browser over encrypted connections, processing it in memory as it passes through, and does not store it. Our automation and billing tools (Make.com, Stripe, and Airtable) receive account, billing, and de-identified identifiers only; Airtable also holds facility business profiles and waitlist contacts. Our other providers receive only website-usage information or business contact information. We check what each provider receives whenever we add or change a provider or change how information flows to it.

FunctionProviderWhat it handlesBAA
Intake forms, document uploads, and e-signaturesJotform (HIPAA environment), including Jotform SignIntake answers, resident information, uploaded documents, signed authorizations and disclosuresYes
Records, email, and back-end logicGoogle Workspace (Sheets, Gmail, Drive, Apps Script)Our system of record for requests and matches, document-upload status, audit logs, and outbound emailYes (Google Workspace HIPAA Business Associate Addendum) for the services Google lists as covered
Encrypted emailPauboxAny resident health information we must send by emailYes
Website and dashboard hostingCloudflareHosts our sites and dashboards; keeps session identifiers only; dashboard data travels over encrypted connections and is processed in memory as it passes through, without being stored or logged thereNo (data in transit only)
PaymentsStripeSubscriber name, email, card details (held by Stripe), and subscription statusNot needed (no PHI)
Facility profiles and account recordsAirtableFacility business profiles, subscriber account status and Stripe identifiers, waitlist contacts, and a log of document-upload events that holds identifiers only — no resident health information and no document linksNot needed (no PHI)
AutomationMake.comConnects billing, subscription, renewal-notice, and waitlist events to our records and email, using account, billing, and de-identified identifiers onlyNot needed (no PHI)
Website analyticsGoogle AnalyticsPage-view statistics for our public marketing pages only (see Section 6)Not needed (no PHI)
Business email outreachAn email-outreach serviceFacility business contact lists onlyNot needed (no PHI)

Where resident health information lives. Intake answers, signed authorizations and disclosures, uploaded documents, and other resident health information stay in Jotform's HIPAA environment and our Google Workspace records. When you upload a document, the document stays in Jotform's HIPAA environment and Jotform notifies our Google Workspace records directly; neither the document nor a link to it passes through our automation tool (Make.com) or our account database (Airtable). Our automation and billing tools (Make.com, Stripe, and Airtable) and our analytics tool (Google Analytics) receive only account, billing, de-identified, or website-usage information, never resident health information.

We maintain a current list of service providers with PHI access. You may request this list at any time by contacting privacy@careswaps.com.

6. Cookies, Analytics, and Tracking

6.1 Types of Cookies

The Company uses a minimal set of cookies and similar technologies on the Websites to:

  • Maintain user login sessions and authentication on the dashboards
  • Track usage patterns on our public marketing pages and improve platform performance
  • Keep each dashboard session tied to the person who signed in

These cookies include:

  • Essential Cookies: Required for dashboard sign-in and basic functionality (session management). After you use a magic link (facilities) or an access code (families), a session cookie keeps you signed in. The dashboards do not work without them.
  • Analytics Cookies: Used on our public marketing pages only to measure page views and how visitors use those pages (Google Analytics). Google Analytics sets its own cookies and receives information such as the pages you view, your browser and device type, and your approximate location derived from your IP address, under Google's privacy policy. Google Analytics is not used on the family dashboard, the facility portal, the intake form, or the document-upload form, or on any page that handles PHI.

Pages hosted by Jotform and Stripe (for example, the intake form and the checkout page) may set their own cookies under those providers' policies.

6.2 What We Do Not Use

  • No cross-site advertising or retargeting cookies
  • No third-party marketing pixels
  • No social media tracking widgets
  • No fingerprinting or persistent tracking technologies beyond the cookies described above

6.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Refusing analytics cookies does not affect your use of the Services. Disabling essential cookies will prevent you from signing in to the dashboards. You can also use Google's browser add-on to opt out of Google Analytics.

7. Your Privacy Choices and Rights

7.1 General Rights (All Users)

Depending on your jurisdiction and our relationship with you, you may have the right to:

  • Access the personal data we hold about you or the resident you represent.
  • Correct inaccurate personal data.
  • Delete personal data we have collected, subject to legal retention obligations (see Section 8.2).
  • Obtain a portable copy of your personal data in a commonly used format.
  • Opt out of targeted advertising, sale of personal data, or profiling that produces legal or similarly significant effects.
  • Withdraw your authorization. You can revoke your Information Sharing Authorization at any time in writing (email is fine). Because the Services cannot match a resident without that authorization, withdrawing it withdraws the request: we re-lock the resident's identity and notify the facilities as described in Section 4.1. Revoking does not undo sharing that already happened while your authorization was in effect.
  • Cancel your request or subscription at any time, online from your dashboard or by emailing us. Your subscription ends at the end of the current billing period.
  • Stop marketing emails using the unsubscribe link or by emailing us.

To exercise any of these rights, contact privacy@careswaps.com. We will verify your identity (and, for a resident's information, your authority to act for the resident) before acting. We will respond within 45 days (or such shorter period as applicable law requires). We will not treat you differently for making a request.

7.2 Colorado Privacy Act (CPA) Rights

Colorado residents may have additional rights under the Colorado Privacy Act (C.R.S. § 6-1-1301 et seq.) if the Company meets the applicable processing thresholds, including:

  • Right to Know: What personal information is collected and how it is used
  • Right to Access: Obtain a copy of personal information
  • Right to Deletion: Request deletion, except where legally required to retain
  • Right to Correct: Request correction of inaccurate information
  • Right to Opt-Out: Opt out of "sale" or "sharing" of personal information

The Company does not sell personal data and does not engage in targeted advertising. If these practices change, we will update this Privacy Policy and provide opt-out mechanisms as required by the Colorado Privacy Act. Whether or not the Colorado Privacy Act applies to us, we honor the access, correction, deletion, and opt-out requests described in this policy.

7.3 Additional State Privacy Rights

Residents of other states with comprehensive consumer privacy laws (such as California, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia) may have similar rights under their respective statutes, including the rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Correct inaccuracies in their personal information, taking into account the information's nature and processing purpose.
  • Data portability.
  • Opt out of personal data processing for: (i) targeted advertising (excluding Iowa); sales; or profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
  • Either limit (opt out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights please send an email to: privacy@careswaps.com.

7.4 HIPAA Rights (PHI Under a BAA)

If your request relates to PHI that the Company processes on behalf of a healthcare facility under a BAA, HIPAA individual rights (including access, amendment, and accounting of disclosures) should be exercised through the applicable Covered Entity (the facility). Please contact the facility directly to exercise these rights. The Company will cooperate with the facility as required by the BAA. For information you gave us directly through CareSwaps, contact privacy@careswaps.com and we will respond as described in Section 7.1.

7.5 Right to Appeal

If we deny a privacy rights request, we will explain the basis for the denial and you may appeal by responding to our denial communication. If we deny your appeal, you may file a complaint with the Colorado Attorney General (coag.gov) or, for PHI matters, with the U.S. Department of Health and Human Services Office for Civil Rights (hhs.gov/ocr). We will not retaliate against you for filing a complaint.

7.6 Disputes

Our Terms of Service contain the full dispute-resolution terms, and the Terms control. In summary, disputes with families and other users are resolved by binding individual arbitration under the American Arbitration Association's Consumer Arbitration Rules, seated in Larimer County, Colorado, and governed by the Federal Arbitration Act. Claims may be brought only on an individual basis, not as a class, collective, or representative action. Either side may bring a qualifying claim in small-claims court instead. We pay the arbitration filing and administrative fees above your share under the AAA rules. You may opt out of arbitration by email within 30 days after you accept the Terms, as the Terms describe. If the class-action waiver is found unenforceable, the dispute goes to court in Larimer County, Colorado. Facility agreements contain their own dispute terms. Nothing in this section limits your right to file a complaint with the regulators listed in Sections 7.5 and 11.

8. Data Security and Retention

8.1 Security Safeguards

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The Company maintains administrative, physical, and technical safeguards designed to protect personal information and PHI, including:

  • Encryption in transit (HTTPS) on our sites, dashboards, and forms, and our providers' encryption of stored data
  • Encrypted email (Paubox) when we must email resident health information, other than your own authorization copy in the welcome email; our routine notice emails do not carry resident health details
  • Access controls: magic-link sign-in for facilities, access codes for families, and a separate key required for every action that returns or sends resident information, with each family session tied to that family's own request
  • A "minimum necessary" design, in which facilities see only de-identified facts until a family authorizes a specific match
  • Audit logging of notices, authorizations, and disclosure downloads

PatientSwaps users may request integration with their existing Electronic Health Records (EHR) or healthcare information systems. The Company may support such integrations in the future and, if offered, will execute appropriate data sharing agreements with the facility's vendor.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a magic link, access code, or password for access to certain parts of our Websites or Services, you are responsible for keeping it confidential. We ask you not to share or forward it.

Unfortunately, the transmission of information via the internet is not completely secure. Although we implement measures designed to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites, except to the extent such circumvention results from our failure to maintain reasonable safeguards.

8.2 Data Retention

We retain information only as reasonably necessary to provide our services and comply with legal obligations:

  • HIPAA documentation: Policies, procedures, and compliance records are retained for a minimum of six (6) years as required by 45 CFR § 164.530(j). This applies to compliance records — not to all PHI.
  • Authorizations and audit logs: Six (6) years.
  • Signed Colorado referral-service disclosures: Six (6) years (longer than the statute's minimum).
  • PHI processed under a BAA: Retained as specified in the applicable BAA and as required by law, then securely destroyed.
  • Family request records (intake, documents, and matches for withdrawn or completed requests): Six (6) years after the request closes, then securely deleted.
  • Account and subscription data: Retained for the duration of the account relationship and a reasonable period thereafter for billing, legal, and audit purposes.
  • Tax and financial records: Retained for seven (7) years.
  • Waitlist contacts: Until you unsubscribe or ask us to delete them.
  • De-identified data: May be retained indefinitely for analytics, benchmarking, and platform improvement.

When retention is no longer required, data is securely deleted or de-identified in accordance with applicable standards. You can ask us to delete your information sooner; we will delete what we can, but we may need to keep records that HIPAA, our Business Associate Agreements, Colorado law, tax rules, or a legal dispute require us to keep. Information already shared with a facility under your authorization is held by that facility, and we will tell you how to contact it.

8.3 Breach

In the event of a security breach that results in the unauthorized access, acquisition, or disclosure of personal information, we will investigate the incident and take appropriate steps to mitigate any harm. Where required by applicable state or federal law (including, without limitation, HIPAA, our Business Associate Agreements, the Colorado data-breach law, C.R.S. § 6-1-716, and the laws of any other state in which we operate), we will notify affected individuals (or cause them to be notified, in coordination with the affected facility) and, where required, the affected facility and the appropriate state or federal authorities, in the manner and within the timeframes prescribed by law. Such notification will include, to the extent known, a description of the incident, the types of personal information involved, and the steps individuals may take to protect themselves. We keep written information security practices and update them when our systems change and as new threats emerge.

9. Children's Privacy

The Services are designed for adult users (e.g., family members, caregivers, and healthcare facility staff arranging senior-care transfers); you must be 18 or older to use the family service (see our Terms of Service). Our Services are not directed to children under 13, and we do not knowingly collect personal data from children.

Family and caregiver users may provide information about a loved one or resident as part of the intake and matching process. By submitting such information, you represent that you have the authority to do so on behalf of that individual (for example, as a legal guardian, power of attorney, or authorized family member).

If we become aware that any user has provided information through the Websites about a child, we will delete that information promptly. If you believe a child under 13 has submitted information to us, please contact privacy@careswaps.com and we will promptly delete it.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal obligations. When we make material changes, we will:

  • Post the updated policy with a new effective date on both Websites.
  • Where required by law or contract, and whenever we make a material change to how we use or share resident information, provide advance notice to active subscribers and facility users by email.

Continued use of CareSwaps or PatientSwaps after the effective date of an updated policy constitutes acceptance of the updated terms. We encourage you to review this policy periodically.

11. Contact Information

For privacy questions, rights requests, or to report a concern, contact us:

  • Privacy Contact: Michael Ford, HIPAA Privacy Officer
  • Email: privacy@careswaps.com (general questions: hello@careswaps.com)
  • Phone: (970) 306-7131
  • Mail (including legal notices): CareSwaps, LLC (d/b/a PatientSwaps), 2519 S. Shields St., Suite 1K PMB 1159, Fort Collins, CO 80526

You may raise a privacy concern without giving your name by writing to the mailing address above.

For regulatory complaints contact:

  • HHS Office for Civil Rights — hhs.gov/ocr (PHI)
  • Colorado Attorney General — coag.gov (CPA and Colorado consumer matters)

Changes in this version

This version, effective October 12, 2026, updates and supersedes the Privacy Policy dated July 20, 2026; the section order is unchanged, and a short Disputes summary has been added as Section 7.6. It adds a description of how a family's authorization controls when a resident's identity is shared with a specific facility, and how withdrawal re-locks it (Section 4.1); a summary of our Colorado referral-service disclosure under C.R.S. § 6-1-729, including our no-sale promise, how the disclosure is signed and dated, the copy the admitting facility receives, and the cancellation notices we send to facilities (Sections 4.2 and 3.1); a plain statement that participating communities currently pay us nothing and that any future facility fee will be a flat software subscription that never varies with referrals, transfers or outcomes (Section 4.2); the payer types we accept, including private long-term-care insurance, and the federal programs we do not (Section 2.1); the subscription acknowledgment, the monthly courtesy notice, and the reminder sent 25 to 40 days before a subscription continues past each 12-month mark (Sections 3 and 3.1); the record we keep when you accept our Client Subscription Agreement (Section 2.1); Paubox encrypted email for resident health information we must email (Sections 3.1, 5 and 8.1); a summary of the arbitration terms in our Terms of Service (Section 7.6); a more specific cookie section that explains the dashboard session cookie and names Google Analytics, what it receives, and that it runs on public marketing pages only (Section 6); the privacy@careswaps.com contact throughout; and our mailing address (Section 11). It replaces the statement that every provider that processes PHI has a BAA with a description and table showing which providers hold resident health information under BAAs (Jotform, Google Workspace and Paubox), that our hosting provider carries data in transit without storing it, and that our automation, billing and account tools receive no resident health information or uploaded documents (Section 5). It describes portal sign-in as a magic link rather than multi-factor authentication, and it removes statements about features and safeguards we have not documented.

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Technology Platform Disclaimer: PatientSwaps is a healthcare technology platform providing algorithmic bed-matching and transfer matching software. PatientSwaps is not a healthcare provider, patient broker, placement service, medical advisor, or care coordinator. This Privacy Policy governs the handling of all information processed through the PatientSwaps Platform, including Protected Health Information (PHI) and non-PHI operational data. For healthcare facilities, our handling of PHI is further governed by the Business Associate Agreement (BAA) in compliance with HIPAA 45 C.F.R. Parts 160 and 164.

HIPAA Compliance: PatientSwaps is a HIPAA Business Associate and maintains valid Business Associate Agreements with all facility clients. All PHI is encrypted, access-controlled, and audit-logged in compliance with HIPAA Security Rule requirements.

State Privacy Rights: This policy includes provisions for Colorado Privacy Act and California Consumer Privacy Act rights. Individuals may request access, correction, deletion, or opt-out of certain uses by contacting privacy@careswaps.com.

© 2026 CareSwaps, LLC d/b/a PatientSwaps. All rights reserved. | Last Modified: July 20, 2026 | Terms of Service | Privacy Policy | About Our HIPAA Role

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