SHADOWSOURCE LLC PRIVACY POLICY

Effective Date: September 7, 2026
Last Updated: September 7, 2026

ShadowSource LLC (“ShadowSource,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you provide when using the ShadowSource platform, website, applications, and related services (collectively, the “Platform”).

This Privacy Policy explains what information we collect, how we use and disclose it, how we protect it, and the choices available to you.

By creating an account or using the Platform, you acknowledge that you have reviewed this Privacy Policy.

1. INFORMATION WE COLLECT

We collect information you provide directly to us, information generated through your use of the Platform, and information we receive from certain third parties.

A. Account and Profile Information

Depending on whether you are a student or provider, we may collect:

Full name
Email address
Telephone number
Date of birth or age confirmation
Profile photograph
ZIP code and general location information
Biographical information
Educational institution, program, and educational history
Resume or curriculum vitae
Professional specialty and experience
Practice, clinic, or organization information
Professional license information
National Provider Identifier (NPI)
CME-related information
Other information you voluntarily include in your profile

Providers may be required to provide a valid NPI. ShadowSource may verify NPI information against publicly available or third-party sources.

B. Scheduling and Platform Activity

We may collect information relating to your use of ShadowSource, including:

Shadowing sessions you create, request, accept, cancel, or attend
Appointment dates and times
Provider availability
Student preferences and filters
Scheduling history
Reviews and ratings
Recommendation-letter information
Job-board activity
Referral-network activity
CME activity
Notifications and communications
Reports, complaints, and other interactions with ShadowSource

C. Communications

If you use ShadowSource messaging or otherwise communicate through the Platform, we may collect and retain those communications.

This may include messages between students and providers, communications with ShadowSource support, and information associated with those communications.

We may review, monitor, preserve, or disclose communications when reasonably necessary to operate the Platform, investigate complaints, address safety concerns, enforce our policies, comply with legal obligations, or protect ShadowSource or others.

D. Payment Information

Payments and subscriptions are processed through third-party payment processors, including Stripe.

We may receive information such as:

Payment status
Subscription type
Transaction amount
Transaction date
Billing information
Limited payment-method information

ShadowSource does not intend to store complete payment-card numbers on its own systems. Payment information is processed by the applicable payment processor under that provider’s privacy policy and terms.

E. Technical and Usage Information

When you access the Platform, we may automatically collect information such as:

IP address
Browser type and version
Device type
Operating system
Pages and features accessed
Date and time of activity
Referring website or application
General geographic information
Cookies and similar technologies
Platform usage and interaction information

We may use this information to operate, secure, analyze, and improve the Platform.

2. HOW WE USE PERSONAL INFORMATION

We may use personal information for the following purposes:

Providing and Operating ShadowSource

Creating and managing accounts
Creating student and provider profiles
Matching students with available shadowing opportunities
Facilitating scheduling and appointments
Processing subscriptions and payments
Providing messaging and notifications
Facilitating reviews
Providing recommendation-letter tools
Providing CME-related tools and documentation
Operating the job board and referral network
Providing customer support

Safety, Security, and Integrity

We may use information to:

Verify account and professional information
Verify provider NPI information
Investigate complaints and reports
Detect fraud, abuse, or suspicious activity
Investigate violations of our Terms of Use or Community & Safety Policy
Protect students, providers, patients, ShadowSource, and others
Enforce our policies
Prevent unauthorized access or misuse of the Platform

Communications

We may use your contact information to send:

Account-related communications
Appointment confirmations and reminders
Scheduling notifications
Messages and message notifications
Subscription and billing communications
Recommendation-letter reminders
CME-related notifications
License or credential reminders
Security notices
Customer-service communications

We may also send promotional or marketing communications where permitted by law. You may opt out of marketing communications through the available unsubscribe mechanism or by contacting us.

Analytics and Improvement

We may analyze Platform usage and other information to:

Improve functionality
Develop new features
Understand user behavior
Measure Platform performance
Troubleshoot technical problems
Conduct research and analytics
Improve user experience

We may create aggregated or deidentified information from personal information and may use such information for lawful business purposes.

Advertising and Marketing

We may use personal information for advertising and marketing purposes, including targeted advertising.

This may involve using cookies, pixels, advertising identifiers, usage information, demographic information, or other information to help us or our advertising partners deliver more relevant advertising.

Where required by applicable law, you may opt out of targeted advertising.

Business Purposes

We may also use personal information for legitimate business purposes, including:

Maintaining business records
Accounting and financial administration
Auditing
Legal compliance
Exercising or defending legal claims
Corporate transactions
Protecting our rights and property

3. ARTIFICIAL INTELLIGENCE

ShadowSource uses artificial-intelligence technology to assist with certain Platform features, including recommendation-letter drafting.

For example, information provided by a provider regarding a student’s performance, professionalism, communication, clinical observations, or other relevant characteristics may be processed by an AI service to generate a draft recommendation letter.

AI-generated content may contain errors, omissions, or inaccurate statements. AI-generated recommendation letters are drafts only and must be reviewed and modified by the provider before being used or submitted.

Information submitted to an AI feature may be transmitted to and processed by third-party AI service providers acting on ShadowSource’s behalf.

ShadowSource may use reasonable contractual, technical, and administrative measures to govern such processing. However, no internet-based system can be guaranteed to be completely secure.

Users should not submit patient-identifying information, protected health information, or other information that they are not authorized to disclose into ShadowSource’s AI tools.

4. INFORMATION SHARING AND DISCLOSURE

We may disclose personal information to the following categories of recipients.

A. Other ShadowSource Users

Certain information is shared with other users as necessary to operate the Platform.

For example, information contained in a student or provider profile may be visible to other authorized Platform users.

Information made available through the Platform should not be assumed to be confidential unless specifically identified as confidential.

B. Service Providers

We may share personal information with vendors and service providers that perform services on our behalf, including providers of:

Hosting and cloud infrastructure
Payment processing
Email and communications
SMS and push notifications
Analytics
Advertising
Customer support
Security
Identity or account verification
AI processing
Database and software services

These providers may access personal information only as reasonably necessary to provide services to ShadowSource, subject to applicable agreements and law.

C. Advertising and Marketing Partners

We may share information with advertising, analytics, and marketing partners to support targeted advertising, measurement, attribution, and related activities.

D. Business Transfers

If ShadowSource is involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction, personal information may be transferred as part of that transaction.

E. Legal and Safety Purposes

We may disclose information when we reasonably believe disclosure is necessary to:

Comply with applicable law, regulation, legal process, subpoena, or court order
Respond to government or law-enforcement requests
Protect the rights, property, or safety of ShadowSource
Protect users, patients, or other individuals
Investigate fraud, abuse, or misconduct
Enforce our Terms of Use or other agreements
Investigate or respond to complaints or disputes

F. With Your Direction or Consent

We may disclose information when you direct us to do so or otherwise provide consent.

5. SALE OF PERSONAL INFORMATION

ShadowSource may, now or in the future, sell, rent, license, disclose, or otherwise transfer personal information to third parties for monetary or other valuable consideration, to the extent permitted by applicable law.

Examples may include information used in connection with advertising, marketing, business-development, recruiting, analytics, or other commercial purposes.

We will provide any disclosures and opt-out rights required by applicable law.

You may opt out of the sale or sharing of your personal information, and of processing for targeted advertising, using any of the following methods:

By email to info@shadow-source.com, identifying your request and the ShadowSource account involved;
Through any “Do Not Sell or Share My Personal Information” or opt-out control ShadowSource makes available on the Platform; or
By enabling a recognized universal opt-out preference signal, such as Global Privacy Control (GPC), which ShadowSource honors where required by applicable law.

ShadowSource will act on your opt-out request without undue delay and, in any event, within the time required by applicable law (for example, within 45 days under Texas law, subject to any permitted extension, and within shorter periods where other state laws apply). An opt-out stops future sales or sharing; it does not require deletion of information already lawfully shared. ShadowSource will not discriminate against you for exercising your privacy rights.

ShadowSource does not knowingly sell the personal information of children under 13.

Sensitive Personal Information

ShadowSource will not sell or share sensitive personal information without first obtaining any opt-in consent required by applicable law. Even where ShadowSource may otherwise qualify for an exemption, it will not sell sensitive personal data without consent where consent is required by law.

6. YOUR PRIVACY RIGHTS

Depending on where you live and applicable law, you may have certain rights regarding your personal information.

These may include the right to:

Confirm whether we process your personal information
Access personal information we maintain about you
Obtain a copy of certain personal information
Correct inaccurate personal information
Request deletion of personal information
Opt out of targeted advertising
Opt out of the sale of personal information
Opt out of certain forms of profiling
Appeal a decision concerning a privacy request
Exercise applicable privacy rights without unlawful discrimination or retaliation

Not every right is available to every person or in every circumstance.

Certain information may be excluded from deletion or other requests where retention is permitted or required by law.

Submitting a Privacy Request

To submit a privacy request, contact:

info@shadow-source.com

Please clearly identify the nature of your request and provide sufficient information for us to reasonably verify that you are the person whose information is involved.

We may request additional information reasonably necessary to verify your identity and protect against fraudulent requests.

We will respond to qualifying privacy requests within the time required by applicable law.

If we deny a request where applicable law provides a right to appeal, you may appeal our decision by contacting:

info@shadow-source.com

Please identify the original request and explain why you believe our decision should be reconsidered.

7. COOKIES AND SIMILAR TECHNOLOGIES

ShadowSource may use cookies, web beacons, pixels, software development kits, local storage, and similar technologies.

These technologies may be used to:

Keep you signed in
Remember preferences
Maintain Platform functionality
Analyze usage
Improve performance
Detect fraud and security threats
Measure advertising effectiveness
Deliver targeted advertising

Some third-party services used by ShadowSource may also place cookies or similar technologies on your device.

You may be able to control cookies through your browser or device settings. Disabling certain cookies may affect Platform functionality.

Where required by applicable law, ShadowSource will provide additional controls for opting out of targeted advertising or other forms of tracking.

ShadowSource honors recognized universal opt-out preference signals, such as Global Privacy Control (GPC), where required by applicable law.

8. DATA RETENTION

ShadowSource retains personal information for as long as reasonably necessary to provide the Platform, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce agreements, maintain business records, protect users and the Platform, and otherwise operate our business.

When you delete your account, we may delete or deidentify information that is no longer reasonably necessary for these purposes.

However, certain information may be retained after account deletion, including:

Transaction and billing records
Communications
Reviews
Complaints and reports
Information relating to safety investigations
Records concerning violations of our policies
Information necessary to comply with legal obligations
Information necessary to establish, exercise, or defend legal claims
Aggregated or deidentified information

We may also retain limited information where necessary to prevent a user who has been removed from the Platform from creating a new account or otherwise circumventing enforcement measures.

9. DATA SECURITY

ShadowSource uses reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction.

However, no method of transmitting or storing information over the internet is completely secure.

Accordingly, ShadowSource cannot guarantee the absolute security of your information.

Users are responsible for maintaining the confidentiality of their account credentials and should immediately notify ShadowSource if they believe their account has been compromised.

In the event of a data-security incident affecting personal information, ShadowSource will investigate and will provide notice to affected individuals and, where applicable, to regulators, in accordance with applicable law.

10. HEALTH INFORMATION AND HIPAA

ShadowSource is designed to facilitate educational shadowing experiences and is not intended to function as an electronic health record, clinical communication system, or repository for protected health information (“PHI”).

ShadowSource does not intend to act as a “business associate” (as defined by HIPAA) for any provider or healthcare organization, and the Platform is not offered for that purpose. A provider or organization that believes a business-associate arrangement is required should contact ShadowSource before transmitting any PHI.

Users must not upload, enter, transmit, or otherwise submit patient-identifying information or PHI to ShadowSource unless expressly authorized and permitted by ShadowSource.

This prohibition applies to, among other things:

Patient names
Medical record numbers
Dates of birth
Addresses
Telephone numbers
Insurance information
Clinical photographs
Medical records
Patient-specific diagnoses
Patient-specific treatment information
Other information that identifies or could reasonably identify a patient

Do not use ShadowSource messaging, reviews, profiles, recommendation-letter tools, job-board features, or other Platform features to communicate patient-specific information.

Providers remain responsible for complying with applicable privacy, confidentiality, patient-consent, and professional obligations in connection with shadowing experiences.

ShadowSource may remove content or restrict accounts when users submit prohibited information.

11. STUDENTS AND MINORS

ShadowSource’s Platform is intended for individuals 18 years of age or older.

ShadowSource does not knowingly permit individuals under 18 to create accounts or participate in shadowing experiences.

If we learn that an individual under 18 has created an account, we may terminate the account and delete associated information as appropriate.

If you believe a minor has provided information to ShadowSource, please contact us at info@shadow-source.com.

12. THIRD-PARTY WEBSITES AND SERVICES

The Platform may contain links to or integrations with third-party websites, applications, services, or platforms.

Examples may include payment processors, professional organizations, educational resources, healthcare organizations, job sites, and other third-party services.

ShadowSource does not control the privacy practices of third parties.

Your use of a third-party service is governed by that service’s own terms and privacy policy.

We encourage you to review the privacy practices of third parties before providing them with personal information.

13. USER-GENERATED CONTENT

Users may submit photographs, biographies, resumes, reviews, messages, recommendation-letter information, professional information, educational information, and other content to ShadowSource.

By submitting content to the Platform, you represent that you have the right to provide that content and that doing so does not violate any law, agreement, confidentiality obligation, professional duty, or third-party right.

ShadowSource may process and display user-generated content as reasonably necessary to provide Platform functionality.

ShadowSource may also remove, restrict, or retain content as necessary to enforce its policies, investigate complaints, protect users, or comply with legal obligations.

Users must not submit patient information or other confidential information they are not authorized to disclose.

14. PROFESSIONAL AND EDUCATIONAL INFORMATION

ShadowSource may collect professional information from providers and educational information from students for purposes of operating the Platform.

Examples include:

School and program information
Professional specialty
NPI information
License information
CME information
Resume/CV information
Shadowing history
Reviews and recommendation-related information

This information may be used to facilitate connections, scheduling, credential management, recruiting, referrals, recommendations, and other Platform functions.

ShadowSource does not guarantee the accuracy, completeness, licensure status, educational status, qualifications, or professional conduct of any user.

15. NO SALE OR SHARING OF PAYMENT CARD NUMBERS

ShadowSource does not intend to sell or publicly disclose complete payment-card numbers or other highly sensitive payment credentials.

Payment information is processed through third-party payment providers, including Stripe.

16. INTERNATIONAL USERS

ShadowSource is currently designed primarily for use in the United States.

Users are responsible for complying with the laws applicable to them in their location.

The Platform is not intended to offer services outside the United States, and ShadowSource makes no representation that the Platform is appropriate or available in every jurisdiction.

17. CHANGES TO THIS PRIVACY POLICY

ShadowSource may update this Privacy Policy from time to time.

When we make changes, we will update the “Last Updated” date above.

If we make material changes, we may provide additional notice through the Platform, email, or another reasonable method.

Your continued use of the Platform after an updated Privacy Policy becomes effective constitutes acceptance of the updated policy to the extent permitted by applicable law.

18. CONTACT US

Questions, concerns, privacy requests, or other inquiries regarding this Privacy Policy may be directed to:

ShadowSource LLC
Email: info@shadow-source.com

IMPORTANT NOTICE: This Privacy Policy is intended to describe ShadowSource’s current and anticipated information practices. ShadowSource may update this Privacy Policy as its Platform, technology, business model, and applicable legal requirements evolve.