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SecondDesk AI, Inc.

Privacy Policy

Last Updated: August 4, 2026

1. INTRODUCTION AND SCOPE

SecondDesk AI, Inc. (“SecondDesk”, "Company," "we," "us," or "our") provides this Privacy Policy to describe how we collect, use, disclose, and otherwise process personal information in connection with our AI-powered licensed healthcare providers sourcing platform and our website at www.seconddesk.ai (collectively, the "Platform"). SecondDesk develops AI-driven tools that enable healthcare organizations, recruiters, and staffing agencies to identify and connect with physicians and other licensed healthcare professionals for recruiting purposes.

This Privacy Policy applies to two categories of individuals:

  1. "Candidates": physicians, doctors, and other licensed healthcare professionals whose professional information appears in our Platform database, whether sourced from publicly available information, licensure data compiled by private organizations from state medical boards, or third-party data providers. Candidates may not have a direct relationship with SecondDesk or have visited our website.
  2. "Website Visitors and Customers": individuals who visit our website, create accounts, or represent healthcare organizations, recruiting firms, or staffing agencies that subscribe to or use our Platform to discover and contact Candidates.

By accessing or using the Platform, Website Visitors and Customers agree to the practices described in this Privacy Policy. Because Candidate data is collected from third-party sources rather than directly from Candidates, this Privacy Policy also serves as the required notice to Candidates regarding our data practices and their rights, as described in Sections 5 and 6 below.

2. PERSONAL INFORMATION WE COLLECT

SecondDesk collects personal information about two categories of individuals: (1) Candidates, and (2) Website Visitors and Customers. The categories of information collected differ depending on the individual's relationship with SecondDesk.

2.1 Information About Candidates. SecondDesk collects information about physicians and healthcare professionals from the following sources: (a) publicly available information from public directories and similar online sources, which may include content from professional networking sites; (b) licensure and medical school education information obtained from the Federation of State Medical Boards (“FSMB”), a private nonprofit organization that compiles data from state medical boards; and (c) contact information, including email addresses and phone numbers, and other professional information purchased or licensed from commercial data providers.

SecondDesk's commercial data providers are contractually required to represent that their data collection practices comply with applicable laws. These providers maintain their own suppression and opt-out lists, and SecondDesk honors those suppression obligations when processing data received from such providers.

The information available through the Platform is compiled from third-party sources and is not verified by SecondDesk in real time. The Platform is not a substitute for formal credentialing, privileging, or background verification processes, and Customers should not rely on Platform data for those purposes.

Categories of Candidate information collected include: name; license number, license type, license status, and specialty; board certifications; education and work history; publications; professional affiliations; procedural expertise; languages; hobbies, personal interests, awards, and hometown ties; and contact information (email address, phone number, mailing address). The FSMB licensure data SecondDesk receives includes a gender field; however, this field is not displayed in the platform, not used in search, filtering, or ranking, and not processed by SecondDesk’s AI systems. SecondDesk does not otherwise intentionally collect sensitive personal information about Candidates, including race, ethnicity, disability status, or precise geolocation.

When Customers send emails to Candidates through the Platform, SecondDesk may collect additional information about Candidates, including email open and engagement data collected through tracking pixels embedded in outbound messages. Data collected through tracking pixels may also include IP address, timestamp, and approximate location; however, only aggregate open and engagement rates are displayed to Customers. SecondDesk may also collect the content of any responses Candidates send to Customer messages.

2.2 Information from Website Visitors and Customers. When Website Visitors and Customers interact with SecondDesk, the company may collect: account registration information (name, email address, organization); billing and payment information; communications submitted through the platform or customer support channels; and usage data related to platform activity.

2.3 Automatic Data Collection. SecondDesk uses a privacy-focused analytics tool to measure website traffic and performance. This tool does not use cookies, advertising pixels, or cross-site tracking technologies. The information collected is anonymized and aggregate only, and may include approximate IP-based location, browser type, operating system, and pages visited. This information is used solely for understanding site usage and improving performance.

3. HOW WE USE PERSONAL INFORMATION

We use the personal information we collect for the purposes described below, separated by the category of individual to whom the information relates.

3.1 Use of Candidate Information. SecondDesk uses personal information about Candidates for the following purposes:

  1. Operating and maintaining the AI-powered recruiting platform, including processing Candidate data through automated tools to organize, categorize, and present professional information to Customers;
  2. Enabling Customers to discover, evaluate, and contact Candidates through the platform's search and matching functionality;
  3. Improving the accuracy and relevance of the platform's search algorithms and matching capabilities, including through analysis of email engagement and response data;
  4. Generating inferences and likelihood assessments about Candidates' potential interest in new opportunities and responsiveness to outreach based on available professional data, including ordering Candidates by relevance to a specific role or search criteria;
  5. Maintaining the accuracy and currency of the Candidate database, including by cross-referencing data sources and updating records; and
  6. Complying with applicable legal obligations, responding to lawful requests, and establishing or defending legal claims.

3.2 Use of Website Visitor and Customer Information. SecondDesk uses personal information about Website Visitors and Customers for the following purposes:

  1. Providing, operating, and improving the platform and related services;
  2. Processing transactions and managing Customer accounts;
  3. Responding to inquiries and providing customer support;
  4. Sending marketing and promotional communications (subject to applicable opt-out rights);
  5. Conducting analytics to understand usage patterns and improve the platform;
  6. Detecting, preventing, and addressing fraud, security incidents, and technical issues; and
  7. Complying with applicable legal obligations and enforcing our terms of service.

3.3 Equal Employment Opportunity. SecondDesk is committed to supporting equal employment opportunity principles and designing its Platform to assist Customers in meeting their own EEO obligations. The Platform's candidate ranking and matching criteria are limited to job-related professional qualifications, including board certification, licensure status, specialty training, practice setting, and geographic fit. The Platform does not use race, ethnicity, gender, religion, disability status, or other protected characteristics in its search, filtering, ranking, or matching functions.

4. HOW WE DISCLOSE PERSONAL INFORMATION

SecondDesk may disclose personal information to the following categories of recipients for the purposes described in this Privacy Policy:

  1. Customers. Candidate personal information is made available to healthcare organizations, recruiters, and staffing agencies that use the platform to identify and contact potential candidates.
  2. Service Providers. SecondDesk shares personal information with third-party service providers that perform services on the company's behalf, including hosting, data processing, analytics, payment processing, and AI-powered data processing. SecondDesk’s AI service providers are configured with zero or minimal data retention settings where available, and Candidate data processed by these providers is not used to train their models.
  3. Data Partners. SecondDesk may share or receive personal information with data partners to maintain, update, or supplement its candidate database.
  4. Professional Advisors. Personal information may be disclosed to attorneys, accountants, auditors, and consultants as necessary for professional advice and compliance purposes.
  5. Law Enforcement and Government Authorities. SecondDesk may disclose personal information when required by law, subpoena, court order, or other legal process, or when disclosure is necessary to protect the rights, safety, or property of the company or others.
  6. Business Transaction Participants. In connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy, personal information may be transferred to the relevant parties, subject to standard confidentiality obligations.

5. YOUR PRIVACY RIGHTS AND CHOICES

SecondDesk provides different rights and choices depending on whether you are a Candidate or a Website Visitor/Customer.

5.1 Rights for Candidates. If you are a healthcare professional whose personal information appears in our platform, you may exercise the following rights:

  1. Removal: You may request that your personal information be removed from our database.
  2. Access: You may request confirmation of whether we hold personal information about you and, if so, obtain a copy of that information.
  3. Correction: You may request that we correct inaccurate personal information we maintain about you.
  4. Opt Out of Sale: You may opt out of the sale of your personal information to our customers. Upon receipt of a valid opt-out request, we will cease making your personal information available to customers through the platform.

To exercise any of these rights, please contact us using the information provided in Section 12 below.

We will respond to verified requests within the timeframes required by applicable law. We will not discriminate against any individual for exercising these rights.

5.2 Rights for Website Visitors and Customers. If you are a Website Visitor or Customer, you may:

  1. Account Information: Access, update, or delete your account information by logging into your account settings or contacting us directly.
  2. Marketing Opt-Out: Opt out of promotional email communications by using the unsubscribe link in any marketing email or by contacting us. Opting out of marketing emails will not affect transactional or service-related communications.

6. STATE-SPECIFIC PRIVACY DISCLOSURES

6.1 California Residents. If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA"), provides you with the following rights regarding your Personal Information:

  1. Right to Know: You may request the categories and specific pieces of Personal Information SecondDesk has collected about you.
  2. Right to Delete: You may request deletion of your Personal Information, subject to certain exceptions.
  3. Right to Correct: You may request correction of inaccurate Personal Information.
  4. Right to Opt Out of Sale or Sharing: You may opt out of the sale or sharing of your Personal Information by contacting us as described in Section 12.
  5. Right to Limit Use of Sensitive Personal Information: Where applicable, you may limit the use of Sensitive Personal Information to purposes authorized by the CCPA.
  6. Right to Non-Discrimination: SecondDesk will not discriminate against you for exercising any of these rights.

6.2 Other State Residents. Residents of Colorado, Connecticut, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, Virginia, and other states with comparable privacy laws may have similar rights, including the right to access, delete, and correct Personal Information, and to opt out of the sale of Personal Information or targeted advertising. To exercise any applicable rights, please contact us as described in Section 12.

7. DATA RETENTION

SecondDesk retains personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

In determining the appropriate retention period for personal information, we consider the following factors:

  1. The nature and volume of the personal information collected;
  2. The purposes for which the information is processed, including whether those purposes can be achieved through other means;
  3. Applicable legal, regulatory, and contractual obligations, including data broker agreement restrictions and state licensing record requirements;
  4. The sensitivity of the personal information;
  5. The potential risk of harm from unauthorized use or disclosure; and
  6. Applicable statutes of limitations and litigation preservation requirements.

For Candidate information, we generally retain data in our platform database for as long as it remains relevant to the recruiting purposes described in this Privacy Policy. We periodically review and update Candidate records to maintain accuracy and remove information that is no longer current or necessary.

For Website Visitor and Customer information, we retain account and transaction records for the duration of the customer relationship and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements.

When personal information is no longer required for the purposes set forth in this Privacy Policy, we will delete, de-identify, or aggregate such information in accordance with applicable law.

8. DATA SECURITY

8.1 SecondDesk implements administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, destruction, or loss. These measures include, but are not limited to:

  1. Encryption of Personal Information in transit and at rest;
  2. Access controls that restrict access to Personal Information to authorized personnel on a need-to-know basis;
  3. Regular security assessments and monitoring of systems for vulnerabilities;
  4. Employee training on data protection and information security practices; and
  5. Contractual requirements obligating service providers to maintain appropriate security measures for any Personal Information they process on behalf of SecondDesk.

8.2 Given the nature of the data maintained on the platform, including contact information and professional credentials of licensed healthcare professionals, SecondDesk applies security measures commensurate with the sensitivity and volume of the data processed.

8.3 No method of electronic transmission or data storage is completely secure. While SecondDesk strives to protect Personal Information using commercially reasonable measures, the company cannot guarantee absolute security. In the event of a data breach affecting Personal Information, SecondDesk will comply with all applicable breach notification laws and will notify affected individuals and regulatory authorities as required by law.

8.4 If you have reason to believe that your Personal Information has been compromised or that your interaction with SecondDesk is no longer secure, please contact us immediately using the information provided in Section 12 (How to Contact Us).

9. CHILDREN'S PRIVACY

The Platform and the services offered by SecondDesk are not directed to individuals under the age of 16. SecondDesk does not knowingly collect, process, or maintain Personal Information from anyone under the age of 16. Because the Platform is designed exclusively for the recruitment of licensed healthcare professionals, the data maintained in the Platform pertains to individuals who hold professional licenses and credentials, and who are therefore adults.

If SecondDesk becomes aware that it has collected Personal Information from an individual under the age of 16, the company will take prompt steps to delete such information from its systems. If you believe that SecondDesk has inadvertently collected Personal Information from a person under the age of 16, please contact us using the information provided in Section 12 (How to Contact Us) so that we may investigate and take appropriate action.

10. INTERNATIONAL DATA TRANSFERS

SecondDesk is based in the United States. All Personal Information collected through the Platform, whether pertaining to Candidates or Website Visitors and Customers, is processed and stored in the United States.

If you are accessing the Platform or if your Personal Information is collected from outside the United States, please be aware that your Personal Information will be transferred to, stored in, and processed in the United States, where privacy laws may differ from, and may not provide the same level of protection as, the laws of your jurisdiction. By using the Platform or by providing your Personal Information to us, you acknowledge and consent to such transfer, storage, and processing in the United States.

11. CHANGES TO THIS PRIVACY POLICY

SecondDesk may update or modify this Privacy Policy from time to time to reflect changes in our data practices, business operations, legal requirements, or regulatory guidance. When we make changes, we will revise the "Last Updated" date at the top of this Privacy Policy and post the updated version on our website.

If we make material changes to this Privacy Policy that affect how we collect, use, or disclose Personal Information, we will provide notice through one or more of the following methods prior to the changes taking effect:

  1. Posting a prominent notice on our website or within the platform;
  2. Sending an email notification to registered Customers at the email address associated with their account; or
  3. Providing an in-platform notification upon login.

For Candidates whose Personal Information appears in our database, notice of material changes will be provided by posting the revised Privacy Policy on our website, as we may not have a direct account relationship through which to deliver individual notice.

We encourage you to review this Privacy Policy periodically to stay informed about our data practices. Your continued use of the platform or our services following the posting of a revised Privacy Policy constitutes your acknowledgment of, and agreement to be bound by, the updated terms. If you do not agree with any changes to this Privacy Policy, you should discontinue use of the platform and, where applicable, exercise your rights as described in Section 5 (Your Privacy Rights and Choices) of this Privacy Policy.

The version of this Privacy Policy currently posted on our website is the operative version.

12. HOW TO CONTACT US

If you have questions or concerns about this Privacy Policy, our data practices, or your privacy rights, you may contact SecondDesk using the information below:

SecondDesk AI, Inc.
Email: contact@seconddesk.ai

To submit a request to exercise your privacy rights, including requests for data access, correction, deletion, or removal from the Candidate database, please contact us at the email address above.

We will respond to all verifiable privacy requests within the timeframes required by applicable law. If you are not satisfied with our response, you may have the right to lodge a complaint with your state attorney general or the applicable data protection authority.

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