Incoming Docs™
Draft for counsel review. Not yet in effect. Bracketed items are to be completed.

Incoming Docs Privacy Policy

Effective date: November 9, 2026 · Last updated: November 7, 2026

Incoming Docs is a service of Monadnock Cyber, LLC, Amherst, New Hampshire ("Monadnock Cyber," "we," "us"). This policy explains what personal information we collect, where it comes from, how we use and disclose it, and the rights you have. It is written to meet the California Consumer Privacy Act as amended by the California Privacy Rights Act (together, the "CCPA"), the California Online Privacy Protection Act ("CalOPPA"), California's "Shine the Light" law, and the California Delete Act. We extend the same rights to everyone, wherever they live.

Incoming Docs is a business-to-business service. It is sold only to real estate professionals and firms for use in their business. It is not offered to consumers or directed to children.

In short.

This policy covers two groups of people:


Part A: Physicians and clinicians in the service

A1. What the service does

Incoming Docs identifies physicians and other clinicians who appear, from public federal records, to be taking a new job in a new area. It tells subscribing real estate professionals about them. For example, a practice address moved to a new state, or a new Medicare enrollment appeared in that state.

A2. What we collect, and where it comes from

We collect professional information only, from public U.S. government records:

Category (CCPA) What we hold Source
Identifiers Name, credential (e.g., MD, DO), National Provider Identifier (NPI) CMS National Plan and Provider Enumeration System (NPPES), the federal NPI registry
Professional or employment information Specialty; practice address and practice telephone; state license numbers and states as listed in the NPI registry; Medicare enrollment state; the medical group a clinician bills through; hospital affiliations; medical school and graduation year NPPES; CMS Medicare provider enrollment and reassignment files; CMS Doctors and Clinicians file; CMS facility affiliation data
Inferences Our assessment that a clinician has likely taken a job in a new area, with a likelihood term, a confidence level and an estimated move or training-completion window Derived by Monadnock Cyber, by fixed rules, from the records above
Geolocation (coarse) The ZIP codes of the practice locations above, used to measure how far a practice moved Public U.S. Census Bureau ZIP-area data

What we do not collect or sell:

A3. Why we use it (business purposes)

A4. Who receives it

Recipient What they receive
Subscribing real estate professionals and firms The information in A2, for their business prospecting, under contract terms that prohibit resale, screening uses and contact at a physician's home
Service providers (hosting, email delivery) Only what they need to run the service for us, under contracts that limit their use
Authorities When required by law

Sale of personal information. Providing this information to subscribers for a fee is a "sale" under the CCPA. We have sold the A2 categories (identifiers, professional information, inferences and coarse geolocation) to real estate professionals and firms in the past 12 months. We do not "share" personal information for cross-context behavioral advertising. We do not knowingly sell or share the personal information of anyone under 16.

The CCPA's definition of personal information excludes information lawfully made available from government records. Much of what we hold is that kind of information. We still honor the rights below for all of it, including our own inferences.

A5. How long we keep it

A6. Your rights

You have the right to:

We have no sensitive personal information about you to limit.

Removal, regardless of where you live. Any physician or clinician can ask to be removed from Incoming Docs. We remove you from the service and keep you out of it, whether or not a law requires us to.

Global Privacy Control. We treat a browser Global Privacy Control signal as a valid request to opt out of sale for that browser and any account it is linked to.

Data broker registration. We register as a data broker in each state where the law requires it.

California Delete Request and Opt-out Platform. Where California law requires, we process deletion requests received through the California Privacy Protection Agency's Delete Request and Opt-out Platform (DROP).

A7. How to make a request

Verifying your identity.

Authorized agents. An authorized agent may submit a request with your written permission. We may ask you to confirm your identity directly.

Response times.


Part B: Customers and site visitors

B1. What we collect

Category Examples Source
Identifiers and contact information Name, business email, business phone, brokerage or firm, account login You, when you subscribe or contact us
Commercial information Subscription plan, territory, billing history You and our payment processor
Internet activity Pages viewed, searches and filters used in the service, which leads you download and when, log data, IP address, browser type Automatically, when you use the Site
Professional information Your real estate licenses (state and number), which set the territory you may see You; we check them against public license records

Payment card details go directly to our payment processor. We do not store them.

B2. How we use it

B3. Who receives it

We do not sell customer or visitor personal information. We do not share it for cross-context behavioral advertising.

B4. Cookies and tracking

Do Not Track (CalOPPA). We honor Global Privacy Control as described above. Because we use no cross-site tracking, browser "Do Not Track" signals do not change how the Site works.

B5. Retention

B6. Your rights

California residents, and everyone else, have the rights to know, access, delete and correct their information, and the right to non-discrimination. Make requests as described in A7.

Shine the Light. We do not disclose customer personal information to third parties for their direct-marketing purposes.


General

Security. We protect information with reasonable administrative, technical and physical safeguards suited to its sensitivity. This includes encryption at rest and access limited to people who need it.

Where it is processed. In the United States.

Children. The service is for businesses and is not directed to anyone under 18. We do not knowingly collect children's information.

Changes to this policy. We will post any update here with a new "Last updated" date. If the change is material, we will notify customers by email, and post a notice on the Site, before it takes effect.

Contact. Monadnock Cyber, LLC · Amherst, New Hampshire · [email protected] · [mailing address]