Last updated May 12, 2022
We know that meaningful self-reflection requires a 100% private space, and we want you to have a very clear understanding of how our app collects, protects, and uses data. Here is a summary of our promise to you, as detailed in this Privacy Notice:
We encourage you to read the following Privacy Notice to understand in detail how we collect and use information through your use of Keener. It applies to your use of the Keener application and website, and your communications with us as a Keener user.
Keener is a standalone app focused on improving the wellbeing of nurses, created in collaboration with HealthStream, Inc. and NurseGrid. Keener is owned by HealthStream, Inc. (collectively, with its subsidiaries and affiliates, “HealthStream,” “us” or “we”). We keep your Keener user data separate from any data you may have with HealthStream. If you have an account with HealthStream, your Keener user account is not automatically connected to that HealthStream account. At some point in the future, we may offer features that allow you to elect to connect your Keener user account with other HealthStream products or services. At that time, we will explain the benefits and privacy implications of choosing to use those features.
When we say, “Personal Information,” we mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or household. Personal Information falls within these categories:
Not everything about you is your Personal Information. Specifically, Personal Information does not include (i) publicly available information (ii) aggregate information, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (iii) deidentified information that cannot be easily linked back to the individual.
Like most applications, Keener uses Personal Information to give you a great experience. This can include your name, email address, your location, your nursing specialty, and other details about your career. All this information is stored securely and controlled by you (via your secure username/password). We only collect, use, retain, and disclose your Personal Information as reasonable and necessary for you to use Keener and only with your consent or another lawful basis. The specific types of Personal Information we collect about you and the manner of collection depends on how you interact with us.
Categories. During the last 12 months, we have collected the following categories of Personal Information:
Sources. We collect Personal Information from the sources listed below. Click for details about how we use information collected from a source:
Directly from you as a Keener user, with your consent.
If you subscribe to Business Premium Service, from your Business Subscriber in our role as a service provider.
Directly from you when you complete our surveys, with your consent.
Directly from you when you communicate with us, with your consent.
Indirectly, from your use of Keener, with a legitimate interest.
From third parties, with a legitimate interest.
In addition to the specific uses above, there are additional circumstances in which we might use your Personal Information.
We only disclose your Personal Information in limited circumstances. None of your Personal Information is disclosed to other users of Keener, ever, without your consent. If any Keener feature allows for social connectivity or information disclosure, we will notify you of the privacy implications of using the feature before you proceed.
We may also disclose your Personal Information as necessary to provide you with Keener and to comply with our legal obligations. The categories and recipients of the Personal Information we disclose is detailed below.
Categories. During the last 12 months, we have shared the following categories of Personal Information for a business purpose:
Recipients. During the last 12 months, we have shared Personal Information with the categories of recipients listed below.
Law enforcement, and other governmental agencies as permitted or required by law.
Cookie information recipients subject to their respective privacy notices.
Other Third Parties, as permitted by applicable law. For example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
We only retain your Personal Information as long as we need it to provide you with Keener or for our internal business purposes. For example, we retain the Personal Information associated with your account profile until you delete it or instruct us to delete it. Personal Information on our marketing lists is retained until you opt-out or we determine that the information no longer serves our business purposes. Other types of data are retained and disposed of according to our company policies. We may retain Personal Information for longer if needed to meet our legal or regulatory obligations. We periodically review and delete or deidentify unnecessary data.
We do not share your personal Shift Reflection data with other Keener users or third parties without your consent. The Shift Reflection feature allows you to record personal details about your nursing shifts. The Shift Reflection collects your rating data (i.e., answers to standard choice questions) and your comments (i.e., answers to optional free text questions). The Shift Reflection is optional, and the information you input is 100% private. Any comments you make in your Shift Reflections remain 100% confidential.
The Keener editorial team creates all Keener content. We regularly work with nurses like you to create content, but this is always done with direct consent from the nurse. We promise never to publish any content created by you in or around Keener without your affirmative consent -- including any Shift Reflection, private feedback, or direct message to our team. We will either ask you for consent, or make sure you know that the feature you are using is intended to collect content and that providing it includes your consent for it to potentially be shared publicly.
We keep your Personal Information and content consumption 100% private, even when we report trends. Any trend reporting created by Keener only shows data across large samples, and never with any individual names or identifiers. All reporting is 100% deidentified, meaning that the data excludes all personal information about the creators, so it is impossible to link the information to a specific Keener user.
Keener advocates for the wellbeing of nurses. To accomplish this, we may create aggregate reporting based on Shift Reflection ratings. These reports could be made public or shared with third parties, but all reports of this nature are 100% anonymous and deidentified. We report trends across large data samples using only deidentified Shift Reflection data. Trend reports never include individual names or other identifiers. Comments made in Shift Reflects are never included in our trend reporting.
We create aggregate reporting about content consumption trends across large sample data. If we share these reports with anyone for any purpose, we ensure the report is 100% anonymous and deidentified.
As a premium service to Business Subscribers like hospital systems, employers, and associations, Keener provides aggregate reporting on Keener user trends in content consumption and Shift Reflection data. Rest assured that we will never allow Business Subscribers or anyone else to see your Personal Information. Reporting may be aggregated at a facility or department level, but will never include a sample size small enough for any Shift Reflection or content consumption data to be personally identifiable. Comments made by users in the Shift Reflection are never included in any premium service reporting.
We may also use the same fully anonymized, deidentified or aggregated reports to assist with our research, marketing, advertising, or other purposes. If Keener ever has a data collection mechanism specifically intended for a Business Subscriber's use, we will notify you that the data is being collected for that specific purpose and help you understand the privacy implications before you use it.
We provide you with methods to directly control how we collect and use your Personal Information. If you have questions or need help, you can submit a Consumer Privacy Request or send us an email at firstname.lastname@example.org.
Your Account Profile and Device Settings
You can access, correct, or update, or delete certain Personal Information by logging into your Keener account and making your chosen selections. You can also control the data we collect by adjusting your device settings.
Controlling Marketing Communications
When you create your Keener profile, you will be asked whether you wish to opt-in or opt-out of receiving marketing communications from us. If you opt-in, we may send you emails, push notifications or in-app messages related to your Keener activity, to inform you about Keener features, or for direct marketing purposes. We will only send you these communications in ways that are compatible with your privacy choices.
By providing us with your wireless phone number, you consent to us sending you text messages for informational or authentication purposes. The number of texts that we send to you will be based on your circumstances and requests. You can unsubscribe from text messages by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.
Do Not Track Requests
Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed below.
Consumer Privacy Requests
If you wish to exercise your rights beyond the methods provided, express concerns, lodge a complaint, or obtain additional information about the use of your Personal Information, please submit a verifiable Consumer Privacy Request:
Keener may only legally fulfill a Consumer Privacy Request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Information, and to properly understand, evaluate, and respond to the request. Note that if you subscribe to our Business Premium Service, then we process your Personal Information in our capacity as a service provider and we may be required to instruct you to submit your request directly to your Business Subscriber.
We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
This section provides the disclosures and notices required under the California Consumer Privacy Act of 2018 (“CCPA”) and offers informational notices to residents of Virginia, Colorado, Utah, Nevada, and other U.S. states with laws providing similar protections. The following paragraphs apply solely to residents of the State of California and other states to the extent the same legal protections apply (each a “Consumer”). Consumers may exercise the following rights over their Personal Information, subject to our receipt of a verifiable Consumer Privacy Request and any exceptions and limitations that may apply:
We endeavor to respond to a verifiable request from a California Consumer within 45 days of receipt. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. If we cannot comply with part or all of your request, we will explain the reasons in our response.
We take your data security very seriously. The following section outlines details about how your personal information is kept secure, and the rights you and Keener have regarding that privacy.
We implement reasonable and appropriate technical, organizational and physical measures in place to help protect your information from unauthorized or illegal access, destruction, use, modification, or disclosure. We maintain internal policies to govern the collection, processing, access, and handling of data. We use technical safeguards to protect information online and stored on our systems. Please note, however, that no transmission of data over the Internet or mobile platforms is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes.
When you create your Keener profile, you will have a login and password. We encourage you to take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your profile via unauthorized activity.
This Privacy Notice applies only to information collected by us when you use Keener. We may provide links to third-party platforms for your convenience, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third-party platforms, including Business Subscribers' platforms. Any access to and use of linked websites is not governed by this Privacy Notice, but instead is governed by the privacy notices of those platforms. HealthStream is not responsible for the privacy practices of any third party. We encourage you to review and understand the privacy notices of such websites before providing them with any information.
Keener is owned and operated by HealthStream in the United States. If you use Keener from outside of the United States, Personal Information we collect about you will be transferred to our servers in the United States and maintained there indefinitely. This may require the transfer of your Personal Information out of your country of origin with laws governing data collection and use that may differ from or be more restrictive than U.S. law, or may result in governments, courts, law enforcement or regulatory agencies having access to or obtaining disclosure of your Personal Information pursuant to the laws of the applicable foreign jurisdiction. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph.
Keener is designed for users age 18 and older. We do not knowingly collect Personal Information from children under 18. If we discover that a child under 18 has provided us with Personal Information, we will delete such information from our systems. If you believe we might have any information collected online from a child under 18, or if you become aware of any unauthorized submission of information to us, please contact us at email@example.com.
As Keener grows, we will learn new ways to support the wellbeing of nurses. With this it is possible that changes to this Privacy Promise may become necessary. Should the details of our Privacy Promise change, we will post those changes here and notify our users. We will always provide a way for Keener users to opt out. Your continued use of Keener after we make changes is an acceptance of those changes.