CHANGES TO THIS POLICY:
We may amend this Policy at any time by posting a revised version on our sites and via the Service. The revised version will be effective at the time we post it. Visits to our sites, use of our Service, or use of our Service subsequent to Policy changes is deemed to be your acceptance of the new changes. We ask that you please refer back to this Policy on a regular basis.
- The information we collect and why we collect it;
- How we use that information;
- How we share information; and
- The choices we offer.
Personally Identifiable Information That We Collect:
We may ask you for, or you may voluntarily submit, personally identifiable information when you are using the Service. The personally identifiable information which you may provide to us could include, but is not limited to:
- Your name;
- Your contact information (including, without limitation, name, company name, title, mailing address, telephone, electronic mail address, facsimile address, etc.);
- Your IP address;
- Other personal information;
- Communications to and from you; and
- Various data and information pertaining to the operations and attributes of your business, as well as data and information pertaining to the transactions, communications, and other data driven items concerning your business, its customers, and other businesses and vendors (collectively, “Business Identifiable Information”).
Non-Personal Or Aggregate Information That We Collect:
When you access our Service, we may automatically collect non-personally identifiable information from you, such as IP host address, web pages viewed, browser type, operating system, referring service, search information, device type, page views, usage and browsing habits on the Service and similar data. We may also aggregate demographic information collected from our users (such as the number of users in a particular geographical location) in a manner which does not identify any one individual. We may also aggregate information collected offline in connection with the Service, obtain non-personally identifiable information from third party sources and develop aggregate information by anonymizing previously collected personally identifiable information. Additionally, we may combine aggregate information from the pixel tags, event tracking (e.g., clicks, scrolling behavior, “contact us” behavior, “chat” behavior, etc.), web beacons, and cookies with similar data we collect from other visitors to help us improve our Service. When doing so, we use commercially reasonable efforts to ensure that the any aggregated information cannot be linked back to you.
It is possible at times when collecting non-personally identifiable information through automatic means that we may unintentionally collect or receive personally identifiable information that is mixed in with the non-personally identifiable information. While we will make reasonable efforts to prevent such incidental data collection, the possibility still exists. If you believe that we have inadvertently collected your personal information, please notify us at [email protected].
We may share or disclose aggregated personal data or non-personal information with service providers or with other persons we conduct business with, including but not limited potential third-parties for the purpose of showcasing the performance of the Service. These service providers and other persons may also share with us aggregated non-personal information that they have independently developed or acquired.
We will only use your personally identifiable information as described below, unless you have specifically consented to another type of use, either at the time the personally identifiable information is collected from you or through some other form of consent from you or notification to you:
- We may share your personally identifiable information collected in connection with providing the Service.
- We may use your personally identifiable information to respond to your inquires or requests.
- We may share your personally identifiable information with third parties (collectively, the “Third
Party Vendors”) to further the purpose for which you provided such information to us. For example, we may share your information with Elastic Email, for the purpose of sending emails. We urge you to read the privacy practices of all of our Third Party Vendors before submitting any personally identifiable information through the Service.
- We may disclose personally identifiable information as required by law or legal process.
- We may disclose personally identifiable information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the terms or policies for our services or our sponsors.
Non-personally identifiable or aggregate information may be used by us for any purposes permitted by law and may be shared with any number of parties, provided that such information shall not specifically identify you.
Cookies and Similar Technologies:
If you delete your cookies, change browsers or use a different cookie, our cookie (or an opt-out cookie) may no longer work and you will have to reinput (or opt-out) again.
Analytics and Conversion Tracking:
We may collect information about your computer, including your IP address, operating system and browser type, for system administration and in order to create reports. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
Like many services, the Analytics Service uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our site. We then use the information to compile reports and to help us improve our site.
Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page.
The Analytics Service collects information anonymously. They report website trends without identifying individual visitors. You can opt out of the Analytics Service without affecting how you visit our site. For more information on opting out of being tracked by Google Analytics across all websites you use, visit https://tools.google.com/dlpage/gaoptout.
We may also use Google conversion tracking and/or similar services to help us understand your and other users’ use of the Service.
Automatically Collected Information:
When you access the Service or open one of our HTML emails, we may automatically record certain information from your system by using cookies and other types of tracking technologies. This “automatically collected” information may include Internet Protocol address (“IP Address”), a unique user ID, device type, device identifiers, browser types and language, referring and exit pages, platform type, version of software installed, system type, the content and pages that you access on the Service, the number of clicks, the amount of time spent on pages, the dates and times that you visit the Service, and other similar information. Depending on the law of your country of residence, your IP address may legally be considered personally identifiable information.
The security of your personally identifiable information is very important to us. When we collect your personally identifiable information online, we use reasonable efforts to protect it from unauthorized access. However, due to the inherent open nature of the Internet, we cannot guarantee that your personally identifiable information will be completely free from unauthorized access by third parties such as hackers and your use of our Service demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your personally identifiable information. For more information on protecting your privacy, please visit www.ftc.gov/privacy.
Your Disclosures In Blogs And Other Social Media:
You should be aware that personally identifiable information which you voluntarily include and transmit online on the Service or in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum such as an in-person panel or survey, may be viewed and used by others without any restrictions. We are unable to control such uses of your personally identifiable information, and by using the Service or any other online services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties for any number of purposes.
Children’s Personal Information:
We are committed to protecting the privacy of children. The Service is not intended for children and we do not intentionally collect information about children under 13 years old. The Service does not collect personal information from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the Service, please contact us at [email protected] and we will take required steps to delete such information and (or) delete her account.
Other Services, Third Party Websites and Links, and Social Media:
Marketing and Sharing of Data:
We do not sell your personal data to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize the Service, content and advertising. If you do not wish to receive marketing communications from us or participate in our ad programs, you can send an email to [email protected].
Data Sharing Program:
We strive to create opportunities for our users to better leverage and more efficiently engage with senior housing communities and vice versa. In order to do so, we may ask you from time to time to opt-in to our data sharing program, whereby we compile, aggregate, and share certain limited personally identifiable data from our opt-in users to communicate with senior housing communities so as to achieve greater pricing efficiencies between our users of such senior housing communities (the “Data Sharing Program”).
We believe that by doing so, we can create cost and other efficiencies that result in better care and better outcomes for our users and their customers. While we do not intend to sell any such data for any monetary compensation, by sharing such data to housing communities, that may enhance the Service and its value proposition to our users. Accordingly, we will not do so with regard to any user, unless and until such user expressly opts-in the Data capturing Program.
The following describes what data we collect from users generally, and how we share such data with third-party housing communities that will identify those users who opt-in to the Data Sharing Program to such housing communities:
Aggregated Data We Collect and Analyze from ALL Users (whether or not such users have opted into the Data Sharing Program)
o The identity of Senior housing communities that have at least one or more contract with any of our users;
o How many total referrals all of our users have provided to specific housing communities against various timeframes;
o How many total placements all of our users have had at various housing communities against various timeframes; and
o How many times a given housing community’s info has been shared with clients across all Senior Place customers against various timeframes.
Use of Aggregate Data that Identify Users that Opt-In to the Data Sharing Program
Using the above datasets, we intend to make outreach efforts to various identified housing communities to connect them with users who opt-in to the Data Sharing Program. Such outreach efforts may identify such users based on certain parameters including but not limited to the following:
o Opt-in users that have contracts or relationships with an identified housing community;
o Opt-in users that have made referrals (and how many) within various timeframes to an identified housing community.
o Accordingly, any such housing communities will know the specific identity of opt-in users (i.e., placement agencies), as well as other Business Identifiable Information related to the use by such users of the Service in relation to the applicable housing community.
o HOWEVER, WE WILL NOT SHARE ANY NAMES OR OTHER PERSONALLY IDENTIFIABLE INFORMATION OF ANY PERSONS REFERRED TO OR PLACED IN ANY HOUSING COMMUNITY BY ANY OF OUR USERS.
We cannot guarantee that the Data Sharing Program will be effective, timely, nor efficient. In addition, without limiting the generality of the foregoing, we cannot guarantee that we will be able to secure permissions or access to enough data on third-party housing communities in order to make the program successful.
Any user that has previously opted into the Data Sharing Program can request to opt out, for any reason, or no reason (however, we cannot guarantee that any data of such user that has been shared with any third-party housing community can be retrieved or deleted from any such third-party housing community).
All unsubscribe or opt-out requests may be made by clicking the “unsubscribe” link at the bottom of the relevant email or by replying to such an email with an email body containing only “unsubscribe”. You may also opt-out by sending an email with a statement of what data collection practices you wish to opt out of by sending an email to our designated address: [email protected]. You also have certain opt out rights if you are a resident of the states further described below and/or potentially if our state has a law pertaining to consumer data privacy rights.
Consent to Receive Electronic Notifications:
Communications with SeniorPlace.io:
By using the Service, you expressly consent to receive in-product communications from us (including, without limitation, push notifications on the App).
Any phone calls and/or text messages delivered to your phone or device may cause you to incur extra data, text messaging, or other charges from your wireless carrier. MESSAGE AND DATA RATES MAY APPLY. You are solely responsible for any carrier charges incurred as a result of phone and/or text communications from SeniorPlace.io.
No Rights of Third Parties:
US Based Servers:
International Users and Visitors:
Due to requirements of the General Data Protection Regulation or other applicable international privacy laws or regulations, please be aware that we are hosted in the United States. If you are a user accessing the Service from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Service, which is governed by US law, you are transferring your Personal Information to the United States and you consent to that transfer. EU and Swiss residents: Please bear in mind that we may transfer your Personal Information to the United States where data protection is not deemed adequate under applicable data protection law.
If you delete your information from any of the Service including but not limited to any mobile applications or request that your information be deleted, we still may retain some information that you have provided to us to maintain the Service or to comply with relevant laws.
NOTICE TO CALIFORNIA RESIDENTS:
Shine the Light
Pursuant to Section 1798.83 of the California Civil Code (a separate law from the CCPA), residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact us via [email protected].
You may request access to the personal information that we have collected and maintained about you (along with information regarding its use and disclosure) over the past twelve (12) months upon appropriate verification. You may only make such requests twice (2) per every twelve (12) months.
To protect your privacy, we will need to take steps to verify your identity.
You have the right to request that we delete personal information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your personal information accordingly. Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.
Exercising Your Rights
To exercise the access and deletion rights described above, please submit a request to us by either:
• Emailing us at [email protected].
• Calling us at 425-272-5443.
Please note that consumers have a right to not receive discriminatory treatment for the exercise of their rights under the CCPA.
Verifying Your Request
Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request.
Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf (e.g., previous transactions of person to whom request relates).
We will only use the personal information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.
Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.
NOTICE TO UTAH RESIDENTS:
If you are resident of Utah, you may have rights similar to those under the CCPA by and through the Utah Consumer Privacy Act (the “UCPA”). In addition you may have the right to be informed about and/or opt out of the sale and transfer of your personal information. We do not sell any personal information for monetary compensation to any third party. If you reside in Utah, you have the right to submit a request under the UCPA to our designated request address [email protected] regarding the foregoing.
NOTICE TO NEVADA RESIDENTS:
If you are resident of Nevada, you may have rights similar to those under the CCPA by and through Nevada officially approved Senate Bill 220 (SB-220) and Nevada’s existing online privacy law from 2017 (NRS 603A.300-603A.360) (collectively, the “NPA”). In addition you may have the right to be informed about and/or opt out of the sale and transfer of your personal information. We do not sell any personal information for monetary compensation to any third party. If you reside in Nevada, you have the right to submit a request under the NPA to our designated request address [email protected] regarding the foregoing.
NOTICE TO VIRGINIA RESIDENTS:
If you are resident of Virginia, you may have rights similar to those under the CCPA by and through the Virginia Consumer Data Protection Act (the “VCDPA”). In addition you may have the right to be informed about and/or opt out of the sale and transfer of your personal information. We do not sell any personal information for monetary compensation to any third party. If you reside in Virginia, you have the right to submit a request under the VCDPA to our designated request address [email protected] regarding the foregoing.
NOTICE TO COLORADO RESIDENTS:
If you are resident of Colorado, you may have rights similar to those under the CCPA by and through the
Colorado Privacy Act (the “CPA”). In addition you may have the right to be informed about and/or opt out of the sale and transfer of your personal information. We do not sell any personal information for monetary compensation to any third party. If you reside in Colorado, you have the right to submit a request under the CPA to our designated request address [email protected] regarding the foregoing.
For questions or concerns relating to privacy, we can be contacted at [email protected]