This Privacy Policy describes the personal and sensitive user data that the Thinkhealth website, web application and mobile applications for Android and iOS (together, the "App") access, collect, use and share, and how that data is stored, secured and deleted. It applies to all users of the App, including care professionals, subscribing organisations, clients and their authorised family representatives.

Think Health, Inc. | Privacy Policy | Last updated: 20 August 2026

1. Who We Are

The App is published and operated by Think Health, Inc. ("Thinkhealth", "we", "us", "our"), 4801 Glenwood Ave, Ste 200, Raleigh, NC 27612, United States. We are the data controller for account data and, where we process health information on behalf of a subscribing organisation, we act as that organisation's processor and business associate under a written agreement. For any privacy question or request, contact privacy@thinkhealthdata.com.

This Privacy Policy forms part of, and should be read together with, our Terms & Conditions and our Data Security statement.

2. Data We Collect

The App accesses, collects and uses the following categories of personal and sensitive user data:

1. Location. With your permission, the App accesses your device's approximate and precise location (GPS and network-based). See Section 3 for full details.
2. Travel and mileage data. For each trip you record: start, end and destination coordinates and addresses, the route travelled, distance, start and end times, odometer readings and odometer photographs, and the resulting reimbursement amount. See Section 3 for full details.
3. Personal information. Name, email address, password, telephone number, postal address, country, date of birth, gender, and your relationship to the client being evaluated.
4. Health information. Evaluation responses, existing conditions, health incidents, medications, care plans, recommendations and clinical notes relating to a client, entered by an authorised care professional or family member.
5. Signatures. Handwritten signatures captured on screen from the care professional and, where a visit requires confirmation, from the client or their authorised representative.
6. Photos, videos and files. Images, videos, documents and notes that you record or upload to a client record. The App accesses your camera and photo library only when you choose to capture or attach a file.
7. Audio and video calls. Where your organisation uses the in-app calling feature, the audio and video of calls between care professionals and nurse managers. The App accesses your microphone and camera only for the duration of a call you join.
8. Contacts and organisation data. Employees, team members, clients, emergency contacts, physicians, referral networks, office locations, schedules and calendar events that you enter into your account.
9. App activity and device identifiers. Device information, IP address, cookie data, crash and diagnostic logs, push notification tokens, and the time and date of recorded information.
10. We collect banking, tax and other financial account details related to payroll processing.

3. Location Data

We disclose the following about the App's use of location, in accordance with the Google Play User Data policy and the Apple App Store privacy requirements.

3.1 What We Collect

Approximate location and precise location (GPS coordinates) from the device of a care professional using the App.

The App collects location in two distinct ways, for two distinct purposes. They are described separately below because they behave differently: visit verification captures single points while you are using the App, whereas mileage tracking records your route periodically for the duration of a trip, including while the App is in the background.

3.2 Visit Verification ("GPS Clock-In")

Why. When a care professional starts or ends a visit, the App captures the device location at that moment so that the subscribing organisation can confirm that the visit took place at the client's address, produce accurate visit and timesheet records, and meet electronic visit verification, payroll and billing obligations. Location is also used to calculate the distance between the recorded check-in point and the client's registered address.

When. A single location is captured at the moment a care professional actively taps to check in or check out of a visit, and only while the App is open and in use in the foreground. For this purpose the App does not collect location continuously and does not collect location when the App is closed or not in use.

3.3 Mileage and Route Tracking

Why. Care professionals are reimbursed for travel between visits. When you start a trip in the App, we record the route you travel in order to calculate the reimbursable distance, to compare the distance actually travelled against the expected distance for that journey, and to allow your organisation to review journeys where the two differ significantly.

When. Route tracking runs only while a trip you have started is active. It begins when you tap to start a trip and stops when you end or cancel that trip, when you sign out, and when the App next starts if no trip is active.

How often. While a trip is active and the App is open, your position is recorded approximately every 30 seconds, or after about 50 metres of travel. If you have granted background location, recording continues while the App is in the background or the screen is locked — at a lower frequency, approximately once a minute or after about 100 metres — because agents cannot safely keep the App open while driving. We deliberately sample at this resolution rather than continuously: it is sufficient to calculate distance and to identify a significant detour, without producing a moment-by-moment record of your movements.

How you can tell it is running. Whenever the App is recording your route in the background, Android shows a persistent "Mileage Tracking" notification and iOS shows the system location indicator. The App does not track your device between trips, before a trip starts, after a trip ends, or when you are signed out.

What is recorded. The start and end coordinates and addresses, the destination address, the route travelled, the distance, the trip start and end times, and the odometer readings and photographs you enter.

3.4 Consent and Your Choices

The App requests the foreground location permission at the point of first use, alongside an in-app explanation of why it is needed. Location is never collected before permission is granted, and you may withdraw either permission at any time in your device settings.

Background location is requested separately and is optional. If you decline it, you can still record trips and still be reimbursed: distance is taken from the odometer readings you enter, and route tracking simply pauses whenever you leave the App. Declining background location does not prevent you from using the App or from recording a visit or a trip.

If you withdraw the foreground location permission, visits will be recorded without location verification. Your organisation may require verification as a condition of employment; that is a matter between you and your employer, not a technical restriction we impose.

3.5 Who Can See It

Location and route records are visible only to the care professional who created the record and to authorised administrators and supervisors within that person's own organisation account.

3.6 Automated Review of Journeys

We automatically compare the distance recorded for a trip against the expected distance for that journey and flag trips where the difference is significant, so that a supervisor can review them. This flag is an aid to human review. It does not by itself determine pay, disciplinary outcomes or any other decision about you, and a person in your organisation decides what, if anything, follows from it. If you are in the European Economic Area or the United Kingdom, you may ask for human intervention, express your point of view, and contest the outcome of any such review.

3.7 What We Do Not Do

We do not sell location or route data. We do not use it for advertising or marketing. We do not share it with data brokers or with any third party for that party's own purposes. We do not use location to track clients or family members; only the location of the care professional is recorded. We do not track your location outside an active visit check-in or an active trip.

3.8 How Long We Keep It

Visit location records are retained for as long as the associated visit record is retained under Section 7, and are deleted together with it. Trip and route records are retained for as long as the associated trip record is retained, which may be longer than the underlying visit where payroll, expense or tax rules require it. Buffered location points that are never attached to a completed trip are discarded from your device when the trip ends, when you sign out, or when the App next starts.

4. How We Use Your Data

We use the data described above to provide and maintain the services you have subscribed for, including evaluations, quality of life scoring, recommendations, caregiver burden analysis, visit verification, mileage calculation and reimbursement, benchmarking and insights; to authenticate users and secure accounts; to provide customer support; to comply with legal, regulatory and contractual obligations; and, in anonymised and aggregated form only, to improve our algorithms and services. We do not sell personal or sensitive user data, and we do not use it for advertising.

5. How We Share Your Data

We share personal and sensitive user data only:

1. with other users within your organisation's account to whom you have granted permission;
2. with service providers acting as our processors or subcontractors under written agreement and, where applicable, a HIPAA Business Associate Agreement. These are set out in the table below;
3. where required by law, regulation, legal process or an enforceable governmental request; and
4. in connection with a merger, acquisition or sale of assets, subject to the protections of this Privacy Policy.

The service providers we use, and what each receives, are:

We do not share personal or sensitive user data with third parties for their own independent purposes, and we do not sell it.

6. Security

All data is encrypted in transit using HTTPS and Transport Layer Security, and encrypted at rest on our cloud infrastructure. Access is controlled through user accounts, groups, roles and permissions that the customer administers.

Because care professionals work in places without reliable connectivity, the App stores a copy of the visits, client records and evaluations you are working on directly on your device, together with any changes that have not yet been sent to our servers. This local copy is protected by your device's own encryption and lock screen, which is why your organisation should require a passcode or biometric lock on any device used with the App. The local copy is cleared when you sign out. If a device is lost or stolen, report it to your organisation so that your account access can be revoked.

Our services are designed to meet HIPAA, DPA and EU GDPR requirements. We continuously monitor our services and underlying infrastructure against unauthorised access, malware and other threats. Further detail is set out in our Data Security statement.

7. Data Retention and Deletion

We retain personal and sensitive user data for as long as reasonably necessary for the ordinary operation of our business and the services, and in accordance with our agreements with subscribing organisations. This includes retaining records needed for electronic visit verification; patient care and healthcare operations; licensing, accreditation and quality assurance; billing, reimbursement and audits; payroll, wage and hour, tax and other employment obligations; fraud prevention, security and business continuity; resolving disputes and enforcing agreements; and compliance with applicable federal, state and local laws and regulations.

Retention periods vary according to the type of record, the state or other jurisdiction involved, the relationship between the parties and the purpose for which the record is maintained. Closing an account, ending a subscription or submitting a deletion request does not require us to delete records that we or a subscribing organisation must or may retain for healthcare, employment, electronic visit verification, contractual, legal, regulatory or ordinary business purposes.

We delete or de-identify personal and sensitive user data when required by applicable law, when directed by the subscribing organisation responsible for the records and legally permitted to do so, or when the applicable retention period and legitimate business need have ended. Data scheduled for deletion may remain in protected backups until those backups are overwritten in the ordinary course of business, unless earlier deletion is required by law.

8. Your Rights

Subject to applicable law, you may request access to, correction of, export of, deletion of or restriction of processing of your personal data, and you may withdraw any consent you have given, including the location permission. These rights are not absolute and may be limited where information must or may be retained for healthcare, employment, electronic visit verification, legal, regulatory, contractual or ordinary business purposes. Because subscribing organisations control patient, care and employment records, we may refer a request concerning those records to the responsible organisation. To exercise an applicable right, contact privacy@thinkhealthdata.com. If you are a resident of the European Economic Area or the United Kingdom, you also have the right to lodge a complaint with your local supervisory authority.

9. Changes and Contact

We will post any changes to this Privacy Policy on this page and update the effective date shown above. Material changes affecting how we handle personal or sensitive user data will be notified to account administrators before they take effect.

Think Health, Inc.
4801 Glenwood Ave, Ste 200
Raleigh, NC 27612
United States
privacy@thinkhealthdata.com