SENIOR LIVING SPECIALISTS OF CALIFORNIA LLC
PRIVACY POLICY
Last updated: June 3, 2024
SLS OF CALIFORNIA LLC, (“SLSOFCA”, “we”, “us”, or “our”) is committed to respecting your privacy. This Privacy Policy explains our practices regarding the collection, use, and disclosure of information that you (“you” or “user”) may provide to us through your use of our website located at www.slsofca.com and any other websites that we link to this Privacy Policy (collectively, the “Website”), and all services, materials, tools, and functionality provided by us in connection with our Website, including our social media pages, and your use of our senior/assisted living referral services (collectively with our Website, our “Services”).
This Privacy Policy is incorporated into, and is part of, our Terms of Use available at [add website address for TOU], which governs your access to and your use of our Services. If you have entered into a separate agreement with us and/or agreed to additional notices or additional terms and conditions relating to our Services, that separate agreement, notice, or terms shall control, and only those terms within this Privacy Policy that do not conflict with such separate agreement, notice, or terms shall apply. This Privacy Policy does not cover information we receive from third parties. If you have any questions regarding this Privacy Policy, please contact us at info@slsofca.com.
By accessing our Services, you agree to be bound by this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Services.
INFORMATION WE COLLECT
We collect two types of information from users of our Services: “Personal Information,” which is information that can be used to identify you or another individual (such as your name or your email address), and “Aggregate Information,” which is information that cannot be used to identify you or any other individual (such as frequency of visits to our Website or browser type).
INFORMATION YOU PROVIDE TO US
We collect Personal Information that you voluntarily provide to us when you use our Services – this Personal Information may relate to you or to some other person for which you have the authority to provide us their Personal Information. If you do not have authority to provide us that Personal Information on behalf of others, or you are under a guardianship or other arrangement and cannot provide your own Personal Information, you should not so submit any Personal Information. We assume and rely on the fact that those seeking our referral Services (which by its nature requires us to collect and transmit such Personal Information to Potential Communities) have the authority to provide us the Personal Information and also (and do) authorize us to transmit such Personal Information in order to provide our referral services. For example, you may provide us with your or another person's contact information such as email address, first and last name, the content of your communication, or other Personal Information when you choose to submit such information to us through email, an online form, or other method (such as contacting us through the “Contact” or any other intake feature on our Website or sending us an email or text). If you interact with us on social media, we may collect your social media profile information, your communications with us, and your communications and posts on our social media pages.
SLSOFCA SERVICES
SLSOFCA is a senior housing and assisted living referral agency that provides resources and personalized assistance to senior potential residents and their relatives/loved ones to find senior housing and care. We help potential residents and their family members and other loved ones find options based on the potential resident’s needs and preferences and provide information for them to find suitable living communities that meet their needs, and provide the family members with information about relevant communities that may meet the required needs (“Potential Communities”). In order to provide these Services, we collect information and Personal Information about potential residents and their family members. We obtain this information directly from potential residents and/or from their family members. This information includes:
- Potential Residents:
o Contact information such as name, phone number, email address, and physical address;
o Demographic information such as date of birth, gender, marital status, religion, ethnicity, and veteran status;
o Care and needs information and preferences, including dietary restrictions;
o Medical information and physical and mental condition;
o Heath insurance, Medicare, and Medicaid information;
o Lifestyle and activity information;
o Information we gather through our communications and interactions with potential resident or family members;
o Emergency contact information;
o Preferred budget, financial information, and income information;
o Other information relevant to the selection of Potential Communities; and
o Any other information you deem necessary or pertinent to share with us.
- Family Members:
o Contact information such as name, phone number, email address and physical address;
o Relationship to potential resident;
o Information we gather through our communications and interactions with family members or the potential resident; and
o Other information relevant to the selection of Potential Communities.
You control what information you share with us, however, some information is required in order to provide our Services. We may ask you for such information but you are never required to share that information. Additionally, Potential Communities may require us to collect certain information in order to consider a potential resident’s eligibility for the Potential Community, and Potential Communities may independently collect additional information from the potential resident and family members. We cannot control and cannot be held responsible for what Potential Communities may request or do with your Personal Information or contact details.
If you provide us information, including Personal Information, relating to you or another individual, you must have all required permission or consent from such individual to provide such information to us. We can only provide our Services and refer you or another person by collecting Personal Information and relaying that information to Potential Communities which we deem, in our discretion, to be good matches for you or such other person. Accordingly you represent and warrant that you have full and complete authority to provide us your or such other person's Personal Information, and that our use of any information that you provide to us (including, without limitation, Personal Information) for the purposes set forth in this Privacy Policy will not violate the privacy or other rights of yourself or of the individual for whom you are reaching out to us or any third party, and will not violate any applicable privacy or data protection laws. Prior to providing any information to us that relates to another individual, you agree to provide such individual with a copy of this Privacy Policy.
With your permission and consent, we may record and/or monitor telephone and video communications that we have with you, potential residents and/or family members. We will provide you or anyone else on a call or communication notice before making any such recording or engaging in monitoring activities during communications.
INFORMATION WE AUTOMATICALLY COLLECT
When you use our Website, we automatically receive and collect information from your device. This information may include the following:
• Information about your device, such as the operating system, hardware, system version, Internet Protocol (IP) address, device ID, and device language.
• The specific actions that you take when you use our Website, including but not limited to the pages and screens that you view or visit, search terms that you enter, and how you interact with our Website.
• The time, frequency, connection type, and duration of your use of our Website.
• Information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message.
• Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (as further described below).
• Pages you visited before or after navigating to our Website.
AGGREGATE INFORMATION COLLECTED
Aggregate Information may be collected when you use our Services, independent of any information you voluntarily enter. Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains. We may collect, use, store, and transfer Aggregate Information without restriction.
COOKIES AND ANALYTICS
Like most websites, our Website may use “cookies.” Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to help us identify you when you come to our Website.
Our Website collects cookies and may use cookies for reasons including, but not limited to:
• Analyze our web traffic using an analytics package.
• Identify if you are signed in to the Website.
• Test content on the Website.
• Store information about your preferences.
• Recognize when you return to the Website.
Overall, cookies help us provide you with a better Website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This setting may prevent you from taking full advantage of the Website.
We may use third parties, such as Google Analytics or other analytics providers, to analyze traffic to our website. Google Analytics does not create individual profiles for visitors and only collects aggregate data. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google at http://www.google.com/intl/en/analytics/privacyoverview.html. You may find additional information about Google Analytics at http://www.google.com/policies/privacy/partners/. You have the option to opt out of Google’s use of cookies by changing your settings through Google Ad Settings via the Google advertising opt-out page at http://www.google.com/policies... may also use cookies, pixels, beacons, or other web tracking technologies to track the amount of time spent on our website or social media and whether or not certain content, such as a video was viewed. We may work with a third party to collect and process this information for us, based on our instructions and in compliance with this Policy.
At the present time we are not able to respond to “Do Not Track” signals from your browser.
Interest-Based Advertising
We may also participate in interest-based advertising using similar technology. This means that you may see advertising on our website tailored to how you browse, or you may see advertising for SLSOFCA on other websites based on your browsing behavior across websites. Some websites where we may advertise belong to ad networks that use your web browsing history to choose which ads to display on their network websites; these ads include advertising for SLSOFCA and our Services. Other websites where you see our ads, such as Facebook, may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you. Some internet browsers, websites such as Facebook and mobile devices offer opt-outs for interest-based advertising. Please refer to the website that you are visiting, your browser and/or your device settings for additional information.
You can opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website (http://www.networkadvertising.org/choices/) and DAA website (http://www.aboutads.info/choices/).
HOW WE USE YOUR INFORMATION
In general, we collect information and Personal Information so that we can provide our Services, operate our business, and provide information that you request from us. This includes but is not limited to the following:
· Provide, operate, improve, maintain, and protect our Services.
· Identify, evaluate fitness for, and refer potential residents to Potential Communities.
· Communication, including by telephone, video chat, text message, email, and other means.
· Provide technical and other support.
· Send updates, marketing communications, promotional materials, and other information about SLSOFCA, our Services, Potential Communities, and other third-party products and services that we believe you may be interested in.
· Send notices and alerts.
· Conduct research, analytics, and monitor and analyze trends and usage.
· Contact you and respond to your inquiries.
· Enhance or improve user experience, our business, and our Services, including the safety and security thereof.
· Personalize our Services to you.
· Conduct surveys.
· As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request.
· Enforce contracts and our Terms of Use, including investigation of potential violations thereof.
· Have the ability to (without assuming the obligation to) detect, prevent, or otherwise address fraud, security or technical issues.
· Have the ability to (without assuming the obligation to) protect against harm to the rights, property or safety of SLSOFCA, our users, potential residents and their family members, Potential Communities, or the public as required or permitted by law.
HOW WE SHARE YOUR INFORMATION
We do not rent or sell your Personal Information. By submitting your or another person's information (including, without limitation, Personal Information) to us in connection with our referral Services, you are intentionally directing us to use and disclose such information and Personal Information in order to provide our referral Services, including disclosure of such information and Personal Information to Potential Communities for these purposes. Our referrals to Potential Communities may or may not yield any compensation for us from the Potential Communities. Other than to Potential Communities or as otherwise stated in this Privacy Policy[BC1] , we will not provide any information (including, without limitation, Personal Information) to anyone else without your consent.
Like most companies, we share information, including Personal Information, in certain circumstances with third parties through operation of our Services and our business. Below we explain when that happens.
POTENTIAL COMMUNITIES; FAMILY MEMBERS
When you provide us with your or another person's information (including, without limitation, Personal Information) you consent to our transmittal of such information to Potential Communities which we, in our discretion, believe are good fits for your or such other person's needs. When we identity a Potential Community that may be a good fit for you or such other person, we provide the Potential Community with the information, including Personal Information, we have collected about you or such other person to determine eligibility and further evaluate whether the Potential Community may meet your needs. We also may share the contact and other information of family members that are assisting you or such other person you may be helping with your search. Once we share your or such other person's information, the Potential Community may contact you or such other person directly using the contact information that we provide. This includes telephone, email, mail, and other means. We do not control Potential Communities and are not responsible for their use of any information that we or you provide to them. Potential Communities’ use of information that we or you provide to them is governed by their privacy policies, and not by this Privacy Policy.
If you or a potential resident is having the assistance of a family member to work with us, we may, with the potential resident’s and/or the family members’ permission, share information that we obtain about the potential resident with the family member. The potential resident may ask us at any time to no longer share the potential resident’s information with the family member.
Additionally, in some cases, we may work with and share information with other third-party referral services to assist potential residents with finding Potential Communities that are outside of our scope of Services. We will obtain your permission before sharing your information with such third-party referral services. Once we share your or another person's information, the third-party referral service may contact you directly using the contact information that we provide. This includes telephone, email, mail, and other means. We do not control the third-party referral service and are not responsible for their use of any information that we or you provide to them. The third-party referral service’s use of information that we or you provide to them is governed by their privacy policies, and not by this Privacy Policy.
SERVICE PROVIDERS
We may transfer Personal Information to third parties for the purpose of providing our Services or operating our business. For example, we may transfer your Personal Information third-party service p[BC2] roviders to assist with providing our Services, and to communicate with you about current or future offerings.
ADVISORS AND AFFILIATES
We may share your Personal Information with our legal, financial, tax, and other professional advisors. We may also share your Personal Information with our corporate affiliate companies.
REQUIRED TRANSFERS
We may also transfer your Personal Information to third parties under the following circumstances: (i) to comply with a legal requirement, law, subpoena, judicial proceeding, court order, governmental request, or legal process; (ii) to investigate a possible crime, such as fraud or identity theft; (iii) in connection with the sale, purchase, merger, asset sale, financing, reorganization, liquidation or dissolution of SLSOFCA, including the evaluation thereof; (iv) when we believe it is necessary to protect the rights, property, or safety of SLSOFCA or other persons, or (v) as otherwise required or permitted by law, including any contractual obligations of SLSOFCA.
AS DIRECTED BY YOU AND WITH YOUR CONSENT
Except as otherwise provided in this Privacy Policy, we share Personal Information with companies, organizations or individuals outside of SLSOFCA only at your direction or when we have your consent to do so.
PHONE CALLS AND TEXT MESSAGES
By providing your email and telephone number to us, you are agreeing to be contacted by or on behalf of SLSOFCA at the email and telephone number you have provided, including via calls and text messages, to receive informational and Service-related information. We will seek your consent to receive non-Services related marketing communications relating to other services and related to Potential Communities. Once we refer you to Potential Communities, you may be contacted by such Potential Communities, however, they will have separate terms of use, communications and/or privacy policies that will be different than ours. We don't make any representations or warranties related to such other separate terms of use, communications and/or privacy policies of the Potential Communities, or for Potential Communities’ use of your information. Authorized emails, calls and text messages may be made by automated or automatic means. Message and data rates may apply. For help, text the word “HELP.” To stop receiving text messages text the word “STOP.” We may confirm your opt out by text message. If you subscribe to multiple types of text messages from us, we may unsubscribe you from the service that most recently sent you a message and/or respond to your stop message by texting you a request to identify services you wish to stop. Keep in mind that if you stop receiving text messages from us you may not receive important and helpful information. To the extent that you provide us with contact information (address, phone, email and the like) for relatives for which you may be contacting us, you represent that you have the authority to provide us such contact information, that we may contact them accordingly, and that we may use such information consistent with our terms, policies and practices without violating their privacy rights or any applicable law.
CALIFORNIA RESIDENTS
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
CHILDREN'S PRIVACY
Our Services are not intended for use by children under the age of 18 and we do not knowingly collect Personal Information from children under the age of 18 in connection with our Services.
OPTING OUT
If we ever start sending you marketing offers, we will add an opt out feature to our communications. That way, if you no longer wish to receive our marketing and promotional communications, you may opt-out by following the instructions included in each communication.
HOW WE PROTECT YOUR INFORMATION
We take the security of your Personal Information very seriously. We use reasonable administrative, physical, and technical safeguards to secure the Personal Information you share with us. Despite these safeguards and our additional efforts to secure your information, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and the security provided by our third-party service providers, and improperly collect, access, steal, or modify your Personal Information.
THIRD-PARTY WEBSITES
Our Services may contain hyperlinks to websites operated by third parties, which may include social media features, such as social media buttons or links. We provide such hyperlinks for your reference and convenience only. We do not control such websites and are not responsible for their content or the privacy or other practices of such websites. It is up to you to read and fully understand their privacy policies. Our inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators. If you are submitting information to any such third-party through our Services, you should review and understand that party’s applicable policies, including their privacy policies, before providing your information to the third-party.
CHANGES TO OUR PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time. Each time you use our Services, the current version of this Privacy Policy will apply. When you use our Services, you should check the date of this Privacy Policy (which appears at the top of the Privacy Policy) and review any changes since the last version. If we make any material changes to this Privacy Policy, we will notify where required by law.
QUESTIONS
If you have any questions about this Privacy Policy or our privacy practices, please contact us at:
info@slsofca.com
502891235v.1
[BC1]Note: As discussed via email, a "sale" of personal information under CCPA does not occur when a consumer uses or directs the business to intentionally (i) disclose personal information; or (ii) interact with on or more third parties.
We do not have clear guidance from regulators as to whether consumers may provide genearal consent to share personal information, or whether consent must be specific. In other words, it is not clear whether a consumer may generally consent to you disclosing his/her personal informaiton to Potential Communities generally, or whether the consumer must consent specifically in each instance to you discosing his/her personal information to each specific Potential Community.
Since you are small and do otherwise not meet the CCPA applicability thresholds, you may be comfortable taking a more risk-based approach and considering general consent to be valid. Note that may need to revisit this analysis once you become subject to the CCPA.
[BC2]Note: This is meant to refer to your own third-party service providers, such as your website hosting providers, marketing vendors working on your behalf, etc.
