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Luxury residences for those
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Senior Resource Group Privacy Policy
Last Updated March 2023
Overview
This Privacy Policy (“Policy”) describes the information practices of Senior Resource Group LLC (“SRG”) when you visit our website (“Site”), become a resident at one of our communities, and otherwise engage with us online or offline. In this Policy, the terms “company,” “us,” “we,” and “our” refer to SRG and its affiliates and subsidiaries.
Quick Reference Guide
1. Personal Information We Collect and How We Use It
1.1 When you Contact Us or Submit a Question Online
1.2 To Operate Our Communities
1.3 Marketing and Advertising
1.4 Communications and General Inquiries
1.5 Our Collection and Use of Sensitive Personal Information
2. Sources of Personal Information
3. How We May Disclose Information
4. Cookie Policy
4.1 What Are Cookies
4.2 How We Use Cookies
4.3 How to Manage Cookies
5. Information Regarding Children
6. California Privacy Rights
7. Legal Disclaimer
8. External Links
9. Update to the Privacy Policy
10. Questions and Contact Us
1. Personal Information We Collect and How We Use It
We collect information from you that identifies, describes, or is reasonably capable of being associated with you (“Personal Information”). Personal Information does not include publicly available information from government records, deidentified information, or aggregated information. We collect and use certain types of Personal Information for various reasons depending on how you interact with us. The following details the purposes for which we collect Personal Information and the types of Personal Information we collect.
1.1 When You Contact Us or Submit a Question Online
If you use our online forms to contact us, we collect the following categories of Personal Information from you.
- Personal Identifiers. We may collect your first and last name, email address, mailing address, and phone number.
- Contact Information. We may collect the contact information of your personal representative.
- Commercial Information. We may collect information about services you used and any other notes you may provide when you submit your inquiry.
- Inferences and Preferences. We may also collect your communications and other preferences information if you provide this information when you contact us.
We use this information to provide customer service, engage in follow-up communication, and improve our Site and services.
1.2 To Operate Our Communities
To operate our communities, including verifying your eligibility for applications, entering into contracts with you, collecting payment from you, surveys, and providing care and other services in our communities, we may collect the following categories of Personal Information from you.
- Personal Identifiers. We may collect your first and last name, address, phone number, email address, social security number, driver’s license number or state identification card number, and who you are contacting us for (yourself, spouse, my parent, my friend).
- Financial Information. We may collect your bank account number, or credit or debit card number.
- Commercial Information. We collect information about products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
- Employment Information. We collect current employer information and employment history.
- Protected Classifications. We may collect your age, marital status, physical or mental disability, or sex.
- Inferences Drawn from Other Personal Information. We collect profiles reflecting preferences, characteristics, predispositions, behavior, and attitudes, such as feedback from your tour with us.
- Medical Information. We collect information such as past and present medical conditions, use of assistive devices, and care level.
- Internet or Other Network Activity. We collect your browsing history, search history, information on interaction with our Site or advertisements.
- Geolocation Data. When you visit our Site, we may collect geolocation information from your IP address, which links to the region you live in, or if your location settings on your device are set to share your location with us.
- Sensitive Personal Information. To operate our facilities and provide our residents with appropriate care, we collect information such as health information, social security number, driver’s license number, or state identification card number.
1.3 Marketing and Advertising
To market and advertise our communities, we may collect the following information either directly from you or from our partners and vendors.
- Personal Identifiers. We may collect your first and last name, address, phone number, email address, and who you are contacting us for (yourself, spouse, my parent, my friend).
- Commercial Information. We collect information about products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
- Protected Classifications. We may collect your age, marital status, physical or mental disability, or sex.
- Inferences Drawn from Other Personal Information. We collect profiles reflecting preferences, characteristics, predispositions, behavior, and attitudes.
- Medical Information. We collect information such as past and present medical conditions, use of assistive devices, and care level.
- Geolocation Data. When you visit our Site, we may collect geolocation information from your IP address, which links to the region you live in, or if your location settings on your device are set to share your location with us.
- Inferences and Preferences. We collect information regarding how you heard about us (web, mailer, print ad, email, referral).
- Sensitive Personal Information. We may collect information such as your age, health information, and other demographic information.
1.4 Communications and General Inquiries
To communicate with you about our communities and services, as well as to answer questions or inquiries you may have about SRG, we may collect the following information from you.
- Personal Identifiers. We may collect your first and last name, address, phone number, email address, and who you are contacting us for (yourself, spouse, my parent, my friend).
- Internet or Other Network Activity. We collect your browsing history, search history, information on interaction with our Site or advertisement.
- Geolocation Data. When you visit our Site, we may collect geolocation information from your IP address, which links to the region you live in, or if your location settings on your device are set to share your location with us.
2. Sources of Personal Information
In general, we may collect Personal Information from the following categories of sources:
- Directly from you
- Automatically through our Site
- Services providers or business partners
- Industry and patient groups and associations
- Advertising networks
- Mailing list providers
- Data analytics providers
- Social networks
- Operating systems and platforms
- Government entities
3. How We May Disclose Personal Information
We may disclose the categories of Personal Information identified in Section 2 above to the following recipients.
- Business Partners and Affiliates. We may disclose Personal Information to our employees, affiliated companies, and subsidiaries.
- Our Service Providers. We may disclose Personal Information to our service providers who perform services on our behalf. Our service providers are generally obligated to take appropriate security measures to protect your Personal Information in line with our policies and are not permitted to use Personal Information for their own purposes.
- Data Analytics Providers. To monitor and secure our Site, we may disclose the following categories of Personal Information to data analytics providers: identifiers and internet and network activity information.
- Third-Party Advertising and Marketing Vendors. As further described in the section below on Cookies, we may disclose the following categories of Personal Information to our advertising partners and marketing support providers: identifiers, demographic information, and internet and network activity information.
- Government Entities and Regulatory Bodies. To comply with our legal obligations and where otherwise required by law, we may disclose categories of Personal Information to applicable regulatory and government entities.
We may disclose Personal Information for the following purposes:
- To Operate Our Business. We may disclose Personal Information to our business partners, affiliates, service providers, and other vendors in order to operate our business and provide our Services.
- Marketing and Advertising. We may disclose Personal Information to marketing and advertising vendors to support our marketing efforts.
- In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the Personal Information we have collected from you with or to the other company. We may also disclose certain Personal Information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
- Compliance and Legal Obligations. To comply with our legal and compliance obligations and to respond to the legal process. For example, we may disclose Personal Information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
- Security and Protection of Rights. Where we believe doing so is necessary to protect our rights and property, or the rights, property, and safety of others. For example, we may disclose Personal Information to prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse, and in situations involving potential threats to the health, safety, or legal rights of any person or third party. We may also disclose Personal Information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
- Other Disclosures. We may disclose Personal Information in other ways not described above that we notify you of or that we obtain your consent for.
4. Cookie Policy
When you visit our Site or use our services, we may automatically collect certain Personal Information through our use of cookies.
4.1 What Are Cookies
Cookies are small text files of data that are stored on your computer or device when you visit our Site. Cookies contain Personal Information, such as your preferences, and other data which we use to provide you a more personalized experience and make it easier for you to navigate our Site and services each time you visit. There are two types of cookies we use to enhance your experience when visiting our website: session and persistent cookies.
- Session Cookies. Session cookies are temporary cookies that are only active while you are browsing our Site. They are deleted when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you while visiting our website or while you are logged into your account. This allows us to process your online transactions, requests, verify your identity after you have logged in, as well as provide you with a better experience while you navigate our website and explore our services.
- Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
We may also use Clear GIFs, Pixels, Tags, and other technologies. A Clear GIF is a small, transparent graphic image that is embedded in a web page or email and is used to track online activity similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly in emails, web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags), in connection with our website to, among other things, track the activities of Site visitors, help us manage content, and compile data about Site usage and preferences.
4.2 How We Use Cookies
We use Cookies for the following purposes:
- Website Operation. Cookies help us run our Site securely and enable basic functions like page navigation.
- Performance and Analytics. Cookies help us analyze how you interact with our Site. These cookies enable us to monitor and improve our Site performance, services, and your experience.
- Advertisements. Cookies allow us to deliver advertisements that are meaningful to you. Our third-party advertising partners may use the Cookies to build a profile of your interests, deliver relevant advertising on other sites, and measure the efficiency of the advertisements.
- Third-Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site, and to the extent permitted, our Apps. We also may use other analytic means to evaluate our website. We use these tools to help us improve our Site’s and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons, to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
- Cross-Device Use. We may use the Personal Information that we collect about you to help us, and our third-party service providers, identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third-party service providers also may use the cross-device use and other information we learn about you to serve targeted advertising on your devices and to send you emails. To opt out of cross-device advertising, you may follow the instructions set forth in the “How to Manage Cookies” section below. Please note: if you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt out on each browser or device that you use.
4.3 How to Manage Cookies
To prevent cookies or third-party advertisers from tracking your activity on our Site or visits across multiple websites, there are tools you can use to disable cookies and opt out of interest-based advertising. Using the resources below does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads) and as described above. Your opt-out may not be effective if your browser is configured to reject cookies.
- Browser Solutions for Disabling Cookies. You can set your browser to block certain cookies or notify you when a cookie is set. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.
- Industry Solutions for Opting Out of Interest-based Advertising. Notwithstanding the above, you may follow the steps provided by initiatives that educate users on how to set tracking preferences for most online advertising tools. These resources include the Network Advertising Initiative (https://thenai.org/about-online-advertising/) and the Digital Advertising Alliance (https://digitaladvertisingalliance.org/).
- Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests.
- Google Analytics. You can download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
5. Information Regarding Children
We do not knowingly collect information from children under 13 years old. If we become aware that we have collected information from a child under 13 years old, we will delete such information from our records. If you are a parent or legal guardian and believe your child has given us information and you did not provide consent, please call us at 888-615-7550 or email us at privacy@srg-llc.com for assistance.
6. California Privacy Rights
If you are a California resident, you may have additional privacy rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”). If we collected Personal Information about you in your role as an applicant, employee, or independent contractor of SRG, please refer to the Employee or Applicant Privacy Notice, this Privacy Policy does not apply to you.
The Right to Know/Access
You may have the right to request more information about how we treated your Personal Information (up to twice per year and subject to certain exemptions), including:
- The categories of Personal Information we collected;
- The categories of sources from which we collected that information;
- Our business or commercial purpose for collecting that information;
- The categories of third parties with whom we shared that information; and
- The specific pieces of Personal Information we collected about you.
The Right to Delete
Under certain conditions, you have the right to request that we delete your Personal Information. Not all requests to delete can be fulfilled. If we are unable to comply with your request, we will provide a response explaining why your data cannot be deleted.
The Right to Correct
You have the right to request that we correct inaccuracies in your Personal Information.
The Right to Opt-Out of Sales/Sharing
California residents may have the right to opt-out of “sales” or “sharing” of their Personal Information under the CCPA. CCPA defines a "sale" as disclosing or making Personal Information available to a third-party in exchange for monetary or other valuable consideration. CCPA also defines “sharing” as disclosing or making available Personal Information to a third party for purposes of cross-context behavioral advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA) identifiers and internet and electronic network activity information to third-party ad networks. We do so in order to improve and evaluate our advertising campaigns and better reach customers and prospective customers with more relevant ads and content.
To opt out from the sharing or sale of information described above, please click on the “Do Not Sell or Share My Personal Information” Link on the bottom of the website homepage. Please note that submitting an opt out request will only opt you out of disclosures that are considered “sales” or “sharing” under the CCPA, but it will not opt out of other disclosures, such as to our service providers.
You may also opt-out of “sales” and “sharing” of your Personal Information through the use of an opt-out preference signal. If our website detects that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control” or “GPC” signal, we will opt that browser or device out of cookies on our website that result in a “sale” or “sharing” of your Personal Information. Please note, if you come to our website from a different device or a different browser on the same device, you will need to opt out, or use an opt-out preference signal, for that browser and/or device as well.
We do not sell or share sensitive personal information, nor do we sell or share any Personal Information about individuals who we know are under sixteen (16) years old.
Right to Limit the Use and Disclosure of Sensitive Personal Information
As further described above, we use certain personal information, such as care level and similar information, to operate our facilities, provide the appropriate level of care to our residents, and provide you with information about other relevant services and facilities. You may have the right to limit our use and disclosure of Sensitive Personal Information. You can make a request to limit use/disclosure by clicking on the “Your California Privacy Choices” link in the footer of our webpage.
The Right to Non-Discrimination
We will not unlawfully discriminate against you for exercising any of these rights.
How to Exercise These Rights
To submit a request to exercise these rights you may use one of these methods:
- Online Request: Please submit here.
- Phone: (888) 914-9661. When prompted for a PIN, please enter 234209.
- Email: privacy@srg-llc.com
For all requests submitted via email, please clearly state that the request is related to “Your California Privacy Rights” and provide your name, mailing address, and phone number where you may be reached.
Verification
Before responding to your request, we will verify your identity using your first and last name, email address, zip code, state, and the community you lived in or visited. If we cannot verify your request, we will contact you for more information. If we cannot verify your identity after a good faith attempt, we may deny the request, and if so, will explain the basis for the denial.
Retention
We retain your Personal Information for as long as needed, or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions that require data retention (e.g., issued any legal holds or otherwise need to preserve data). From time to time, we may also deidentify your Personal Information, retain it and use it for a business purpose in compliance with CCPA.
Designating an Authorized Agent
You may designate someone to submit requests and act on your behalf (an “Authorized Agent”). To do so, you must provide us with written permission to allow your Authorized Agent to act on your behalf.
7. Legal Disclaimer
Nothing in this Privacy Policy restricts SRG’s ability to:
- Comply with federal, state, or local laws;
- Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
- Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local law;
- Exercise or defend legal claims;
- Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
- Transfer Personal Information as part of a merger, acquisition, dissolution of SRG, bankruptcy, or any other transaction in which a third party assumes control of all or part of SRG.
8. External Links
When you use this Site, you may find links to other websites we don’t own or control. We are not responsible for the content or any other aspect of these third-party sites, including their collection of your Personal Information. You should review their terms and conditions and privacy policies before proceeding to that site.
9. Updates to this Privacy Policy
This Privacy Policy is reviewed and updated regularly. If we change this Policy, we will post the updated Privacy Policy here, and those changes will go into effect on the “last updated” date shown above.
10. Questions and Contact Us
If you have questions or concerns regarding this Privacy Policy or our privacy practices, you may contact us at 888-615-7550, send us an e-mail message to privacy@srg-llc.com, or via mail at:
SRG
Attn: Webmaster
500 Stevens Avenue, Suite 100
Solana Beach, CA 9207
