Privacy Policy - Shearwater Health

Privacy Policy

Shearwater Health respects your right to privacy and aims to comply with the requirements of all relevant privacy and data protection laws that may apply to our collection, processing and handling of the personal data that you share with us.

Please do not submit any personal data to us if you do not consent to our collection, processing and on how we handle your personal data as detailed in this Privacy Notice.

This Privacy Notice will apply to all personal data we collect online through or in connection with this website, including its subdomains as well as through other Shearwater Health-managed websites or pages where this Privacy Notice is posted or linked (collectively, “Website”).


Who is collecting the data?

Shearwater Health, Inc. and its subsidiaries, Shearwater Health Advisors, Inc. and Shearwater Health Evolution, Inc., and affiliates (collectively, “Shearwater Health”) collect your personal data which will be processed fairly and lawfully, and will be used solely in accordance with the purposes as set out in this Privacy Notice.


What data is being collected?

Whenever you browse our Website, we automatically record the information described in the Log Data section below. In most instances, the Log Data, by itself, is not sufficient to determine your identity.

We also collect the personal information which generally consists of your name, contact details and other information you submit online in your response to our online questions you will find on the Nurse Recruitment page and Careers page on our Website and those contained in your CV/Resume and other documents you will upload, email or communicate or send to us.

The term “personal data” for purposes of this Privacy Notice will include all the personal information you share with us and the Log Data about your visit to our Website.


How we use your personal data

Your Log Data is used primarily to help keep our Website safe and secure. In addition, it may also be used for bug tracking, investigations relating to a security or data breach and usage statistics.

The other personal data collected will be used to:

  • Evaluate data about you against vacancies which we or our clients may have that we determine may be suitable for you as part of our nurse recruitment or internal job hiring requirement. Consistent with the nature of recruitment services or internal hiring, we will keep your data on our database with your consent.
  • Submit your personal data to our clients to qualify you as a candidate for vacancies or to assess your eligibility for any available vacancies.
  • Communicate with you about relevant job opportunities and provide career guidance and support.
  • Comply with any legal requirement to disclose to third parties in relation to the detection of crime, the collection of taxes or duties, compliance with regulatory requirement for your nurse recruitment or job hiring, or in order to comply with any applicable law and court orders.
  • Perform any required background checks and other types of screenings or verifications for employment or work assignment purposes either to be performed by Shearwater Health, any of its clients or third parties engaged by Shearwater Health or client as against databases or records of any applicable government offices, licensing agencies, professional organizations or accrediting organizations or institutions.
  • Qualify and deploy me for future employment with Shearwater Health and/or potential or future work assignments to clients of Shearwater Health.
  • Process either through automated or manual means, record, organize, store, update, modify, retrieve, consult, use, consolidate, profile, encode, as well as to share, disclose, transfer or release, block, delete/erase or destruct, and/or retain any of your personal data.

This list is not exhaustive and we may seek to collect, process, use or disclose your personal data for any other purpose which has not been listed above but always with your explicit consent.


Will the data be shared with any third parties?

Your personal data may be made available to our employees, our subsidiaries and affiliate companies, our clients, service providers, vendors and the third parties as set out above.

Your personal data will not be stored in any part of the European Economic Area (“EU”) as Shearwater Health has no presence or operation in the EU. EU residents or citizens may submit their personal data online through our Website which is managed by Shearwater Health in the U.S.A. For EU residents or citizens, the personal data you submit online will be sent outside the EU as we are operating outside of the EU. You consent to this Privacy Notice includes consent to the transfer and sharing of your personal data outside of the EU and we will take appropriate steps to guarantee that your privacy rights continue to be protected as detailed in this Privacy Notice. Please also refer to the following Additional Disclosures for EU Data Subjects:

Additional Disclosures for EU Data Subjects:

If you are an individual in the EU, we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The following are the legal bases for the collection, processing, use and sharing of your personal data:

  • We need it to provide or operate the Website and process your nurse recruitment application or internal job application;
  • It satisfies another legitimate interest that is not overridden by your data protection interests, including our interest in:
    • collecting analytics and performance data relating to our Website and our nurse recruitment or job hiring services, in order to maintain, analyze, develop, update, and improve our services;
    • maintaining records of bugs, customer support requests and similar requests you file, and our response to these requests;
    • using information to personalize content and features on our Website and our services;
    • detecting, investigating and preventing activities that may violate our policies or applicable laws (such as fraud detection and prevention); and
    • protecting against activities that may threaten the security, integrity, or availability of our or another party’s systems and services.
  • We are processing your information to protect our legal rights;
  • You give us consent to process your personal data;
  • We need to process your data to comply with a legal obligation, such as a lawful subpoena or law-enforcement request or to fulfill the lawful instructions of our clients (when they are acting as the controller); and/or
  • We have another lawful basis for processing in accordance with applicable EU laws.

If an individual in the EU has consented to our use of their personal data, and our processing is based on that consent, that individual has the right to withdraw their consent in accordance with the General Data Protection Regulation (“GDPR”), but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. client) have a legitimate interest to do so, individuals in the EU have the right to object to that use as specified the GDPR, though, in some cases, this may mean no longer using the Website or availing of Shearwater Health’s nurse recruitment services or proceeding with your job application. Shearwater Health acknowledges that EU data subjects have certain other rights under the GDPR, including the right to lodge a complaint with a supervisory authority and to request from the controller access to, and rectification or erasure of, personal data, restriction of processing concerning the data subject, and data portability (in each case, as specified under the GDPR). Where Shearwater Health is acting as a controller, you can initiate a request by contacting us as specified in the “Contacting Us” section below. Please note that if you object to or restrict processing, you may not be able to use the Website and Shearwater Health’s services or certain features any longer.

For Philippine residents or citizens who submit their personal data online through our Website which is managed by Shearwater Health in the U.S.A., the personal data you submit online may be shared with Shearwater Health’s subsidiaries in the Philippine and will also be sent outside the Philippines as Shearwater Health operates in the U.S. Your consent to this Privacy Notice includes consent to the transfer and sharing of your personal data within and outside of the Philippines and we will take the appropriate steps to guarantee that your privacy rights continue to be protected as detailed in this Privacy Notice.

Additional Disclosures for Philippine Data Subjects:

Philippine data subjects have rights under Republic Act No. 10173 of the Philippines, otherwise known as the Data Privacy Act of 2012 and its Implementing Rules and Regulations, which include the right to be informed, right to object to collection and processing, right to access and to rectification, right to erasure or blocking, right to damages, right to data portability, and to be apprised of the transmissibility of their rights as data subjects. For the exercise of any of these rights, please contact the Data Protection Officer as specified in the “Contacting Us” section below.


How long will the data be stored?

We will retain your personal data for as long as reasonably necessary to achieve the declared purpose for our collection. In no case is it retained longer than reasonably necessary, unless a different retention period is required or permitted by law. We will also retain and use your information as long as necessary to resolve disputes and/or enforce our rights and agreements.


Log Data

We want to inform you that whenever you visit our Website, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser version, pages of our Website that you visit, the time and date of your visit, the time spent on those pages, and other statistics.



Cookies are files with small amount of data that is commonly used as an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive.

Our Website uses these “cookies” to collect information and to improve our service. You have the option to either accept or refuse these cookies, and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our Website.


Service Providers

We may employ third-party companies and individuals due to the following reasons: To facilitate, manage or perform any kind of services to our Website or to assist us in analyzing how our Website is used.

Please know that these third-parties may have access to your personal data while providing services to us. However, they are obligated not to disclose or use the information for any other purpose.



We value your trust in providing us your personal data. With this in mind, we strive to use commercially acceptable means of protecting your personal data. We would like to point out, however, that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security. There is always that possibility that your personal data could be unlawfully observed by a third party while in transit over the Internet. Shearwater Health accepts no liability should this occur.


Links to Other Sites

Our Website may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.


Changes to This Privacy Notice

We may update this Privacy Notice from time to time. Please review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Notice on this page. These changes are effective immediately, after they are posted on this page.


Contacting Us

You have rights under the law regarding your personal data. Should you wish to exercise these, or if you have some questions relating to this Privacy Notice or Shearwater Health’s data protection efforts, please contact our Data Protection Officer (DPO) at: or send mail to:


If you are in the U.S. or any country other than the Philippines:

Data Protection Officer
Shearwater Health, Inc.
20 Burton Hills Blvd.
Suite 400
Nashville, TN 37215

If you are in the Philippines:

35/F, Netpark Building
5th Avenue, Bonifacio Global City
Taguig City, Metro Manila
Philippines 1634