Health & Virtuals
Effective Date: 1st April, 2026
This Privacy Policy (“Policy”) governs the collection, processing, storage, use, disclosure, and protection of personal data by LaCharme LLC, a Florida limited liability company doing business as Health & Virtuals (“H&V,” “Company,” “we,” “us,” or “our”), in connection with:
- https://healthandvirtuals.com
- https://talent.healthandvirtuals.com
- all associated subdomains, portals, applications, systems, integrations, and services (collectively, the “Platform”).
By accessing, using, registering with, or submitting information through the Platform, you acknowledge that you have read, understood, and agree to the terms of this Policy.
1. CONTROLLER STATUS AND PROCESSING ROLES
1.1 The Company acts as a Data Controller with respect to personal data collected directly through the Platform.
1.2 In the course of providing workforce solutions, the Company may also act as:
- (a) a Data Processor on behalf of Client organizations; and/or
- (b) an intermediary facilitating controlled data exchange between Talent and Clients.
1.3 The Platform forms part of an integrated workforce system in which personal data processing is necessary for screening, evaluation, classification, training, placement, and operational delivery functions.
2. CATEGORIES OF PERSONAL DATA
The Company collects and processes personal data in a structured and purpose-bound manner, including:
2.1 Identity and Contact Information
Information capable of identifying a data subject, including name, email address, telephone number, and location.
2.2 Professional and Application Information
Information submitted in connection with applications, including resumes, employment history, qualifications, availability, and recorded or video submissions.
2.3 Assessment, Evaluation, and Derived Data
Data generated through structured evaluation systems, including performance scores, cognitive outputs, behavioral indicators, psychometric responses, and classification results.
Such data may include behavioral indicators and psychometric responses; however, all such assessments are strictly non-clinical, non-diagnostic, and are used exclusively for occupational, operational, and workforce-related purposes. No inference or conclusion shall be interpreted as a medical, psychological, or clinical determination.
2.4 Technical and Usage Data
Information automatically collected through Platform interaction, including IP address, device identifiers, session data, and usage patterns.
2.5 Special Category and Sensitive Data
The Platform is not designed to collect special category data; however, where such data is voluntarily submitted or incidentally processed, it shall be subject to heightened safeguards and strictly limited use.
Where personal and non-personal data are inextricably linked, the entire dataset shall be treated as personal data for compliance purposes.
3. PURPOSES OF PROCESSING
Personal data is processed exclusively for legitimate, specified, and operationally necessary purposes, including:
- (a) evaluation, scoring, and classification of Talent;
- (b) facilitation of workforce placement and client matching;
- (c) administration of training and certification programs;
- (d) operation, monitoring, and optimization of Platform systems;
- (e) prevention of fraud, misuse, or system abuse;
- (f) compliance with legal, regulatory, and contractual obligations.
Personal data shall not be processed in a manner incompatible with these purposes.
3.1A Multi-Stage Data Collection Framework
Personal data may be collected, generated, and processed at multiple stages of the Platform lifecycle, including but not limited to:
- (a) initial application and onboarding;
- (b) screening and assessment processes;
- (c) training and certification programs; and
- (d) placement, engagement, and operational delivery.
Data collected at each stage may be combined, analyzed, and utilized as part of a unified evaluation and workforce management system.
4. LEGAL BASIS FOR PROCESSING
Where applicable under the GDPR, the Company relies on one or more of the following legal bases:
- (a) Consent, including explicit consent for assessments, recordings, and optional submissions;
- (b) Legitimate Interests, including workforce operations, system security, and service optimization;
- (c) Contractual Necessity, including pre-contractual evaluation and service execution;
- (d) Legal Obligation, including compliance with applicable laws.
5. AUTOMATED PROCESSING AND PROFILING
5.1 The Platform utilizes structured systems involving automated processing and profiling, including but not limited to scoring, ranking, classification, eligibility filtering, and progression-based decision mechanisms.
5.2 Such processing may materially influence a User’s progression through the Platform, including advancement through screening stages, eligibility for training programs, and potential visibility to Clients.
5.3 The logic underlying such systems is based on predefined operational, competency, and performance criteria developed by the Company and may include weighted scoring models, threshold-based filtering, and comparative evaluation frameworks.
5.4 Such processing:
- (a) is strictly occupational and operational in nature;
- (b) does not constitute clinical, psychological, or diagnostic evaluation;
- (c) is subject to internal validation, oversight, and discretionary review; and
- (d) does not constitute solely automated decision-making producing legal or similarly significant effects without human involvement.
5.5 By using the Platform, you expressly acknowledge and consent to such processing.
6. DATA SHARING AND DISCLOSURE
Personal data may be disclosed, strictly on a need-to-know basis, to:
- (a) affiliated entities and operational divisions;
- (b) Client organizations for evaluation and placement purposes;
- (c) authorized service providers and infrastructure partners;
- (d) legal, regulatory, or governmental authorities where required;
- (e) professional advisors, including legal and compliance consultants.
The Company does not sell personal data.
6.1 Nature and Scope of Data Shared with Clients
Where Talent is considered for placement or engagement, the Company may share relevant information with Clients, including:
- (a) professional background and qualifications;
- (b) assessment results and performance indicators;
- (c) classification, ranking, or eligibility status; and
- (d) other information reasonably necessary for evaluation or engagement decisions.
Such sharing shall occur only where operationally necessary and subject to appropriate confidentiality and contractual safeguards.
7. INTERNATIONAL DATA TRANSFERS
Personal data may be transferred and processed outside the jurisdiction of the data subject, including outside the European Economic Area.
Such transfers shall be subject to appropriate safeguards, including Standard Contractual Clauses or equivalent lawful mechanisms.
8. DATA RETENTION
Personal data shall be retained only for as long as necessary to fulfill the purposes for which it was collected, including ongoing operational, legal, and compliance requirements.
The Company may retain anonymized or aggregated data indefinitely for analytical and operational purposes.
8.1A Talent Data Lifecycle and Reuse
Personal data submitted by Talent Applicants, including application materials, assessment results, training performance, and derived evaluation data, may be retained for the purpose of ongoing operational use, including:
- (a) consideration for future opportunities or roles;
- (b) re-evaluation or reactivation within the Platform;
- (c) benchmarking, analytics, and system improvement; and
- (d) internal classification and talent pool management.
Such data may continue to be processed even where a User is not immediately placed or engaged, subject to applicable legal requirements and user rights.
9. DATA SECURITY AND BREACH RESPONSE
9.1 The Company implements appropriate administrative, technical, and organizational safeguards designed to protect personal data.
9.2 In the event of a data breach affecting personal data:
- (a) the Company shall take reasonable steps to contain and assess the breach;
- (b) where required by applicable law, affected individuals and relevant authorities shall be notified;
- (c) remedial measures shall be implemented to mitigate impact.
10. HIPAA AND HEALTH INFORMATION POSITIONING
10.1 The Platform, including all publicly accessible websites, application portals, and intake systems, is not intended to collect, receive, store, or process Protected Health Information (“PHI”) as defined under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).
10.2 Users are expressly instructed not to submit PHI or any sensitive patient-identifiable information through the Platform unless explicitly requested and authorized under a separate, secured, and contractually governed process.
10.3 The Company may, in the course of providing services to Clients under separate written agreements, including Business Associate Agreements (“BAAs”), act as a Business Associate and process PHI strictly in accordance with:
- (a) the applicable BAA;
- (b) HIPAA and its implementing regulations; and
- (c) applicable data protection and confidentiality obligations.
10.4 Any processing of PHI shall occur exclusively outside the scope of this Platform and shall be governed solely by the terms of the applicable contractual agreement.
10.5 The Company disclaims any responsibility or liability for PHI submitted through the Platform in violation of this Policy.
11. DATA SUBJECT RIGHTS
Where applicable, data subjects have the right to:
- access personal data;
- request correction of inaccurate data;
- request erasure;
- restrict or object to processing;
- request data portability;
- withdraw consent at any time.
Requests may be submitted to:
The Company reserves the right to verify identity prior to fulfilling any request.
Data subjects also have the right to lodge a complaint with a competent supervisory authority.
12. DATA ACCURACY AND USER RESPONSIBILITY
Users are responsible for ensuring that all submitted data is accurate, complete, and current.
The Company shall not be liable for decisions made based on inaccurate or incomplete information.
13. COOKIES AND TRACKING
The Platform uses cookies and tracking technologies in accordance with the Company’s Cookie Policy.
14. THIRD-PARTY SERVICES
The Platform may integrate or rely upon third-party systems and services. The Company is not responsible for the privacy practices of such third parties.
The Platform may utilize third-party systems for the delivery of assessments, training modules, evaluation tools, and learning management systems. Such systems may process personal data, including assessment responses, performance data, and interaction metrics, on behalf of the Company.
The Company undertakes reasonable measures to ensure that such providers operate under appropriate contractual and data protection safeguards; however, Users acknowledge that such third parties may independently process data in accordance with their own policies.
15. CHILDREN’S DATA
The Platform is not intended for individuals under the age of eighteen (18), and the Company does not knowingly collect personal data from minors.
16. LIMITATION OF LIABILITY
To the fullest extent permitted by law, the Company shall not be liable for any loss, damage, or claim arising from:
- (a) unauthorized access to personal data;
- (b) data loss or system compromise;
- (c) reliance on Platform-generated outputs or assessments.
17. POLICY MODIFICATIONS
The Company reserves the right to amend this Policy at any time. Continued use of the Platform following such modifications constitutes acceptance.
18. GOVERNING LAW
This Policy shall be governed by the laws of the State of Florida, United States.
19. CONTACT INFORMATION
Health & Virtuals
3919 Tampa Road, Oldsmar, FL 34677, USA
📧 legal@healthandvirtuals.com
📞 +1 (813) 566 5627