Privacy Policy

1. Overview & Scope

This Privacy Policy explains how Silver Lining, Inc. ("Silver Lining," "we," "us," or "our") collects, uses, shares, and protects information when you use our website, applications, and related services (the "Platform"). It applies to Families, Companions, and visitors.

Silver Lining is not a HIPAA-covered entity. We are a California Domestic Referral Agency connecting Families and Companions for non-medical companion care. We do not process protected health information as defined under HIPAA, and this Policy — not HIPAA — governs how we handle your data.

2. Information We Collect

• Account & profile data: name, contact details, address, photo, care preferences or caregiving experience.
• Identity verification data: government ID images and identity confirmation results processed via Stripe Identity.
• Background check data: criminal history and state registry results obtained through Checkr, for Companions.
• Location data: GPS coordinates captured at shift check-in and check-out for geofenced shift verification.
• Payment data: bank account and payout details processed via Stripe Connect; Silver Lining does not store full payment card or bank account numbers.
• Usage data: device information, log data, and interactions with the Platform.

Sensitive personal information

Under the California Privacy Rights Act (CPRA), some of the categories above are classified as sensitive personal information:

• Government identifiers — driver's license, state ID, passport, or Social Security number, collected through Stripe Identity and Checkr.
• Precise geolocation — GPS coordinates captured at shift check-in and check-out.
• Account credentials — your login credentials in combination with access to your account.
• Health-adjacent care details — care preferences and daily-living needs a Family chooses to share so a Companion can provide appropriate non-medical support. This is not protected health information under HIPAA, and we ask Families not to send clinical records through the Platform.

We use sensitive personal information only for the limited purposes permitted under CPRA §7027(m): verifying identity, performing services you requested, preventing fraud, ensuring physical safety, and complying with law. We do not use it to infer characteristics about you, and we do not disclose it for cross-context behavioral advertising.

3. How We Use Information

We use the information above to operate the Platform: verifying identity and eligibility, matching Families with Companions, facilitating scheduling and messaging, processing payments and payouts, monitoring shift check-in/check-out, preventing fraud, complying with legal obligations, and improving the Platform.

4. How We Share Information

We share information with the service providers necessary to operate the Platform, including Stripe (identity verification and payments) and Checkr (background checks). We share relevant profile information between a Family and a Companion once a shift is posted or claimed. We may disclose information to state registries as required for Companion certification, and to comply with legal process. We do not sell your personal information.

5. Data Retention

We retain each category of personal information only as long as needed for the purpose it was collected, or as required by law. Our current retention schedule:

6. Your Privacy Rights

If you are a California resident, the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA) gives you the following rights:

• Right to know — what personal information we collect, the sources, why we collect it, and who we disclose it to.
• Right to access — a copy of the specific pieces of personal information we hold about you.
• Right to delete — deletion of your personal information, subject to the legal retention obligations described in Section 5.
• Right to correct — correction of inaccurate personal information.
• Right to limit use of sensitive personal information — because we already use sensitive personal information only for the limited purposes listed in Section 2, no further limitation is available to request.
• Right to opt out of sale or sharing — see the notice immediately below.
• Right to non-discrimination — we will not deny service, charge different prices, or provide a different quality of service because you exercised any of these rights.

Do Not Sell or Share My Personal Information

Silver Lining does not sell personal information, and does not share personal information for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA. We have not sold or shared personal information in the preceding twelve months, including the personal information of consumers under 16 years of age. Because we do not sell or share, there is no opt-out for you to submit — but if this ever changes, we will update this Policy and provide a working opt-out mechanism before the change takes effect.

How to submit a request

Email privacy@silverlining.care or call (510) 555-0100. We will confirm receipt within 10 business days and respond within 45 calendar days, extendable once by another 45 days where reasonably necessary, in which case we will tell you why.

Verification. Before acting on a request to know, delete, or correct, we will verify your identity by matching information you provide against what we already hold. For requests covering sensitive personal information, we may ask for additional verification. We will not use information you provide for verification for any other purpose.

Authorized agents. You may designate an authorized agent to submit a request on your behalf. The agent must provide written permission signed by you, and we may still contact you directly to confirm the authorization and verify your identity, unless the agent provides a valid power of attorney.

If we deny your request. We will tell you why in writing. You may appeal by replying to our decision with the subject line "Privacy Request Appeal" within 30 days; a reviewer not involved in the original decision will respond within 45 days. If you disagree with the outcome, you may file a complaint with the California Privacy Protection Agency or the California Attorney General.

7. Cookies & Tracking

We use cookies and similar technologies to keep you signed in, remember preferences, and understand how the Platform is used. You can control cookies through your browser settings; disabling them may limit some Platform functionality.

8. Data Security

We use industry-standard safeguards, including encryption in transit and at rest, access controls, and reliance on PCI-compliant processors (Stripe) for payment data, to protect your information. No system is completely secure, and we cannot guarantee absolute security.

9. Children’s Privacy

The Platform is not directed to individuals under 18, and we do not knowingly collect personal information from children. Care recipients receiving care are not required to create accounts or provide personal information directly to Silver Lining.

10. International Users

The Platform is currently intended for use within the United States, beginning in the San Francisco Bay Area and expanding across California. We do not currently support accounts or data processing for users located outside the United States.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or an in-app notice before taking effect. Continued use of the Platform after changes take effect constitutes acceptance of the revised Policy.

12. Contact

Questions about this Privacy Policy or requests regarding your personal information can be sent to privacy@silverlining.care or made by phone at (510) 555-0100.