Privacy Policy

Overview

EFFECTIVE MAY, 2024

This privacy policy (the “Privacy Policy”) explains the collection, use, and disclosure practices of the websites and other online and offline products and services, including our senior living referral services (collectively, the “Services”) owned and operated by Senior Places. For clarity, this Privacy Policy describes how we collect and use information when you access and use our websites, including but not limited to seniorplaces.org. Please be advised that the practices described in this Privacy Policy also apply to information that you submit to us offline and to Personal Information (as described below) that we may collect from third parties.

CONSENT

Privacy Policy. By using our Sites or submitting information to us, you acknowledge and understand the terms of our Privacy Policy.

Automatic Telephone Dialing System: By providing us with your telephone number, including on our Sites or over the telephone, you agree to be contacted by Senior Places and contracted senior care network providers to explore options relating to our Services. You agree to be contacted by telephone call or text message at the telephone number you provided using automatic telephone dialing systems, even if you previously registered on a Do Not Call registry, and consent is not a condition of any purchase.

GATHERING & UTILIZATION OF YOUR PERSONAL DATA

In this Privacy Policy, “Personal Data” refers to any data that identifies, is connected to, describes, is capable of being linked with, or can be indirectly or directly associated with an individual or household, or as defined under relevant law.

We acquire Personal Data from four main sources: directly from our clients or users, through the usage of our Services, from both affiliated and non-affiliated external parties, and by generating new Personal Data from the data we gather. The kinds of Personal Data we gather about you are based on your interactions with us and are further detailed below.

Data Collected Directly from You. We gather data from you in several ways. Any data you provide us is given freely, but it's important to note that certain data might be essential for us to deliver our Services. You might also supply Personal Data about another individual, such as a senior housing and/or care Services seeker (“Resident”).

The types of Personal Data we collect directly from you include:

• Identifying details like your first and last name, telephone number, email address, and postal address;
• Types of personal data as outlined in subdivision (e) of Section 1798.80 of the California Civil Code, including name, physical characteristics or description, address, telephone number, and medical or health insurance details;
• Characteristics of protected classifications under federal or state law, such as age, gender, marital status, medical conditions, and disability data;
• Data you input on our Sites to request Services for yourself or someone else, like your username, password, location, postal/zip code, mailing address, fax number, and email address;
• Financial data, including the Resident’s budget for senior housing options and their Medicare or Medicaid status;
• Commercial data, including records of your move-in status with referred senior care network providers;
• Your feedback about our Services, including responses to surveys or via our customer service centers; and
• For Residents, information such as gender; household income; budget; senior care requirements; and veteran status, along with other voluntarily provided details like marital status, religion, or ethnicity.

Data Automatically Collected Through Your Use of the Sites. We may automatically gather data about you through your use of our Services, including using website analytics tools and technologies like cookies and web beacons (further explained below).

The categories and types of data we automatically collect include:

• Identifiers like your IP address and unique device identifiers;
• Internet or other electronic network activity data, such as your browser type, app version, access times and dates, pages viewed, and the preceding page you visited before our Sites;
• Geolocation data, like the country you access our Sites from;
• Additional data that can be associated with you, such as details about the computer or mobile device you use to access our Services, including hardware model, operating system and version, and mobile network information.

Cookies. Cookies are small text files stored on your computer when you visit certain online pages, recording your preferences. We use cookies to track usage of our Sites and Services. We may also use cookies to monitor traffic, enhance the Sites, make them more user-friendly and relevant for you, and boost the effectiveness of our advertising on other platforms. You have the option to refuse cookies by modifying your browser settings to not accept cookies or to alert you when a cookie is sent. However, some features of our Sites or Services might not function properly if you disable or delete cookies.

Web Beacons. Some of our Sites' pages and our emails may contain tiny electronic files known as web beacons (also called clear gifs, pixel tags, and single-pixel gifs) that allow us, for instance, to count users who have visited those pages or opened an email, and for other related website statistics (like tracking the popularity of certain website content and verifying system and server integrity).

INFORMATION WE COLLECT FROM OTHER SOURCES

We may collect information about you from other sources. For example, we may collect information about you from:

• Residents (if you are not the Resident) or a person who contacts us seeking Services for a Resident;
• From senior care network providers;
• Third-party social media services, such as Facebook, Twitter, and Instagram, that you use to interact with our Services (e.g., to provide feedback on our Services) or that allow you to share information (e.g., via plugins, widgets or other tools); and
• Unaffiliated parties, such as our service providers, analytics companies, advertising networks, affiliates, and other third parties that provide us with information, so we can better understand you and provide you with information that may be of interest to you.

INFORMATION WE INFER

We may derive information or draw inferences about you based on the other information we collect about you. For example, we may infer your location from our collection of your IP address.

APPLICATION OF YOUR DATA

For each type of Personal Data we gather about you (both directly and indirectly), we utilize each category for the business and commercial objectives outlined below:

• To deliver the Services to you, fulfill the transactions and/or referrals you seek, execute our contractual responsibilities, and as expected within the framework of our continuous business interactions;
• Establish and maintain your online accounts;
• Communicate with you, including via phone, text, email, and chat, about your utilization of the Services;
• Address your inquiries and other communications from you, including offering customer support;
• Dispatch promotional or marketing messages about products, services, offers, promotions, rewards, and events from us, our partners, and other entities, as well as provide news and information we think will interest you;
• Organize and manage surveys, contests, prize draws, sweepstakes, and other promotional activities;
• Undertake internal research and development;
• Assess your interactions with Senior Places and senior care network providers, as well as your use of our Services, to better comprehend your interests and behaviors and tailor your experience;
• Identify security incidents and guard against malicious, deceptive, or unlawful activities, including fraudulent transactions, errors, negligence, and contract breaches, and to safeguard against harm to the rights, property, or safety of Senior Places and our users, clients, staff, or the public;
• Troubleshoot, pinpoint, and rectify issues that impair the functionality of our Services;
• Facilitate solely internal uses that align with your expectations based on your relationship with our business;
• Adhere to our legal responsibilities, including those related to taxation, fraud prevention, anti-money laundering, and enabling you to exercise rights recognized by law or any regulatory requirements or provisions; and
• Collaborate with our legal, financial, insurance, and other advisors in relation to the types of transactions mentioned above or in managing all or part of Senior Places' business or operations.

SHARING OF PERSONAL DATA

We will share your Personal Data in the following ways:

With Senior Care Network Providers. As your referral agent, we may disclose Personal Data to senior care network providers to facilitate the Services you have requested. These providers may reach out to you directly, including via email, phone, traditional mail, or in-person meetings.

With Partners and Other External Entities. We might transfer Personal Data to partners and other external entities.

With Individuals Representing You. We may divulge Personal Data to the individual who recommended you as a Resident or to someone else representing you.

With Our Service Providers. We may share Personal Data with third-party service providers we have engaged to render services to us or to deliver the Services you have sought from us.

With Affiliated Entities. Your Personal Data may be shared with our parent company, subsidiaries, joint ventures, or other entities under a shared control framework.

For Internal Analysis and Operations. Personal Data may be shared with third-party vendors for our own internal statistical, design, or operational needs, such as calculating our audience size, tracking aggregate traffic patterns, and understanding demographic trends among our users. These third parties are restricted to using and disclosing your Personal Data solely for these tasks and are bound by confidentiality obligations.

For Legal and Compliance Purposes. We may share Personal Data when deemed necessary for legal reasons, including to: (a) adhere to legal requirements; (b) enforce or apply this Privacy Policy or our other policies or agreements; (c) protect our rights, property, or safety, or that of our users; (d) guard our users against fraudulent, abusive, or unlawful use of our Site; or (e) if we believe in good faith that an emergency posing immediate danger of death or serious physical harm to any individual necessitates the sharing of communications or justifies the immediate sharing of records.

During Business Transactions. Personal Data may be shared as part of any merger, acquisition, debt financing, sale of company assets, or other similar business dealings.

As Aggregated or Anonymized Data. We may share aggregated, anonymized, or de-identified data with our advertisers, business partners, and other third parties, which cannot reasonably be used by those parties to identify you.

Upon Your Request. We may also share Personal Data in other ways if you consent to it or direct us to do so.

LINKS TO THIRD PARTIES

We may provide links to third party websites from our Sites as a service to our users, but we have no ability to control nor are we responsible for the privacy and data collection, use, and disclosure practices of third party websites. When you click on links that take you to external websites, you will be subject to their privacy policies and practices and not ours. We encourage you to review and understand the privacy policies of such websites before providing them with any information.

SECURITY

We use reasonable security measures to store and protect your Personal Information while it is under our control. Please note, however, that no transmission of data over the Internet is 100% secure.

THIRD PARTY ANALYTICS

To learn more about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit https://www.aboutads.info/choices. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

RECORDED TELEPHONE COMMUNICATIONS

Telephone communications between You and Senior Places may be recorded or monitored for quality control purposes. By providing information to us, you expressly consent to the recording of these telephone communications.

CHILDREN

Our Services are designed for adults, not children under the age of 16. As such, we do not intend to collect Personal Information from children under the age of 16, and our Services are not designed for such information.

ADDITIONAL INFORMATION FOR CALIFORNIA CONSUMERS

The California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.) requires us to disclose to California consumers the categories of Personal Information (as defined in the CCPA) we have collected in the preceding 12 months, our business and commercial purposes for collecting, using, or selling such Personal Information, the categories of sources from which we collect Personal Information, whether we have disclosed or sold any Personal Information for business or commercial purposes in the preceding 12 months, the categories of Personal Information we have disclosed or sold for a business or commercial purpose in the preceding 12 months, and the categories of third parties with whom we share Personal Information. We have provided these disclosures in the prior sections of this policy. Additionally, in the preceding 12 months, we have disclosed the following categories of Personal Information for business purposes to the following categories of recipients:

Category of Personal Information: Identifiers, such as your first name, last name, phone number, email address, and mailing address

Categories of Recipients: Cloud storage service providers, marketing service providers, data analytics providers, internet service providers, email service providers, customer communication service providers

Category of Personal Information: Categories of personal information described in subdivision (e) of Section 1798.80 of the California Civil Code, such as name, physical characteristics or description, address, telephone number and medical or health insurance information

Categories of Recipients: Cloud storage service providers, marketing service providers, data analytics providers, internet service providers, email service providers, customer communication service providers

Category of Personal Information: Internet or other electronic network activity information, such as the type of browser you use, app version, access dates and times, pages viewed, and the page you visited before navigating to our Sites

Categories of Recipients: Cloud storage service providers, marketing service providers, data analytics providers, internet service providers, email service providers, customer communication service providers

Category of Personal Information: Geolocation data, such as the country from which you access our Sites

Categories of Recipients: Cloud storage service providers, marketing service providers, data analytics providers, internet service providers, email service providers, customer communication service providers

Categories of Personal Information: Gender; household income; budget; senior care needs; and veteran status, as well as other information you may choose to voluntarily provide, such as marital status, religion, or ethnicity

Categories of Recipients: Cloud storage service providers, marketing service providers, data analytics providers, internet service providers, email service providers, customer communication service providers

The CCPA also requires us to communicate information about rights California consumers have to request access to their Personal Information, to request deletion of their Personal Information, to request additional details about our information practices, to request to opt out of the “sale” of their Personal Information, if applicable, and to not be discriminated against for exercising such rights.

Your options in regard to the Personal Information we collect about you are described below. You may designate an authorized agent to exercise these options on your behalf by providing your authorized agent with written permission to act on your behalf and by verifying your own identity with Senior Places. Alternatively, you may provide a power of attorney pursuant to Probate Code sections 4000 to 4465. We will verify your request by asking you to provide information related to your interactions with us, such as by confirming your email address and/or your state of residence. In some cases, we may need to collect additional information to verify your identity, such as a government issued ID.

Access: As a California resident, you may request access to your Personal Information we collect, use, disclose, or sell and the specific pieces of Personal Information we have collected about you, subject to specified exceptions. You may also request additional details about our information practices, including the categories of the Personal Information we collected, the sources of collection, categories of Personal Information we share for a business or commercial purpose, and the categories of third parties we share your information with. You may request access by visiting the Personal Information Request Page. You must provide your First and Last Name, email address, and phone number used with Senior Places services in order for us to match you within our systems, as well as certify that you are a California resident.

Deletion: As a California resident, you may request that we delete the Personal Information we have collected from or about you. Please note that we may retain certain information as required or permitted by applicable law. You may request that we delete personal information about you by visiting the Personal Information Request Page. You must provide your First and Last Name, email address, and phone number used with Senior Places services in order for us to match you within our systems, as well as certify that you are a California resident. If you request to delete your Personal Information, certain of our products and services may no longer be available to you.

Personal Information We Disclose or Sell (as defined by the CCPA): California law requires that we provide transparency about Personal Information we “sell,” which, for purposes of the CCPA, broadly means instances in which APFM has shared Personal Information with certain senior care network providers and with partners and other third parties in exchange for valuable consideration. If in the preceding 12 months, Senior Places may have disclosed Personal Information to senior care network providers to facilitate providing services to you and with partners and other third parties, this disclosure may be considered a sale under California law. In the preceding 12 months, we have “sold” the following categories of personal information to the following categories of third parties:

Category of Personal Information: Identifiers, such as your first name, last name, phone number, email address, and mailing address

Categories of Third Parties: senior care network providers, partners, and other third parties

Category of Personal Information: Information about the Services you are seeking for yourself or a Resident

Category of Third Parties: Categories of Third Parties: Senior care network providers, partners, and other third parties

For information about opting out of these “sales,” please see the “Do Not Sell My Info” section below. We do not knowingly disclose or sell personal information of minors under 16 years old without affirmative authorization.

Do Not Sell My Info: As described above, we may provide Personal Information for the purpose of connecting you with senior care network providers to discuss services that you may be interested in for yourself or for a Resident and to our partners and other third parties. We give you the option to opt out of such sharing at any time by following the Do Not Sell My Personal Information Page. The link is also available on our Sites and mobile apps.

California’s Shine the Light law also permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. Under the law, a business must either provide this information or permit California residents to opt in to, or opt out of, this type of sharing. Senior Places qualifies for this alternative option. To opt out of having information about you shared with third parties for direct marketing purposes, please email support@seniorplaces.org.