Privacy
Policy

Senior Resource Group Privacy Policy

Last Updated January 2022

Overview

This Privacy Policy helps you understand how Senior Resource Group LLC (“SRG”) collects, stores, uses, shares, and secures your Personal Information when you visit our website (“Site”), become a resident at one of our communities, and otherwise engage with us. In this Policy, the terms “company,” “us,” “we,” and “our” refer to SRG and its affiliates and subsidiaries.

Quick Reference Guide

1. What 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 Inquries

2. How We May Disclose Information

3. Cookie Policy

4. Information Regarding Children

5. California Privacy Rights

6. Legal Disclaimer

7. External Links

8. Update to the Privacy Policy

9. Questions and Contact Us

1. What 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 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.

We use this information to provide customer service, engage in follow-up communication, and improve our Site, products, 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, and providing services in our communities, we may collect the following types 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 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.
• Medical Information. We collect past and present medical conditions.
• 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.

1.3 Marketing and Advertising

To market and advertise our communities, we may collect the following information from you or our business partners and vendors.

• 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).
• 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.
• 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).

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, 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).
• 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. How We May Disclose Information

We may disclose Personal Information to our employees, affiliated companies, subsidiaries, agents, and third-party vendors to perform our obligations and provide services to our customers. We may also disclose personal information to legal or other regulatory bodies as required by law to fulfill legal, reporting, and regulatory requirements. We do not and will not sell your Personal Information without first providing you notice and an opportunity to opt-out.

3. Cookie Policy

Our Site uses cookies, tags, and similar tracking technologies (“Cookies”) to provide, customize, evaluate, improve, and secure our Site and services. A Cookie is a small piece of text that is placed on your website browser when you visit a website. These include our own first-party Cookies as well as third-party Cookies of our service providers and marketing partners. Some Cookies are only stored temporarily and are destroyed each time you close your web browser. Our Site also uses persistent Cookies, which do not delete when you close your browser and may collect and store data for a set period of time after you’ve left our Site. You can discover more about Cookies in general and how they work at Cookiepedia.

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.

How to Manage Cookies. If you wish to prevent Cookies from tracking your activity on our Site or visits across multiple websites, you can set your browser to block certain Cookies or notify you when a Cookie is set. If you block Cookies, certain features on our Site may not work. For more information on how you can customize your browser’s Cookie setting please visit the link to your web browser below:

• Chrome
• Google
• Safari
• Internet Explorer
• Mozilla

You may opt out of interest-based advertising in general by visiting the Digital Advertising Alliance’s or Network Advertising Initiative’s websites. We are not responsible for the completeness, effectiveness, or accuracy of any third-party opt-out options or programs.

4. 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.

5. California Privacy Rights

If you are a California resident, you may have additional privacy rights under the California Consumer Privacy Act (“CCPA”). If we collected Personal Information about you in your role as an applicant, employee, or independent contractor of SRG or a business partner, this Privacy Policy does not apply to you.

The Right to Request More Information

You may have the right to request more information about how we treated your Personal Information in the past 12 months, 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 Request Access

You may also have the right to receive a copy of the Personal Information we collected about you in the past 12 months, no more than twice in a 12-month period.

The Right to Request Deletion

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.

Third-Party Marketing and Selling

We do not currently sell or intend to sell your Personal Information to third parties without first providing you notice and an opportunity to opt-out. We also do not provide your information to third parties for their direct marketing purposes.

We do not have actual knowledge that we sell Personal Information of consumers under 16.

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 must first 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.

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.

Do Not Track Requests

As explained in the section above on Cookies, we use Cookies to collect information about your internet activity to help us provide you with relevant advertisements. Some web browsers or smartphones have the ability to set “Do Not Track” requests to block user activity from being tracked across web pages or devices. Our Site does not recognize “Do Not Track” signals.

No Discrimination

We will not unlawfully discriminate against you for exercising any of these rights.

6. 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.

7. 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.

8. 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. We will not use or share your Personal Information for materially different purposes without first taking reasonable steps to provide you notice.

9. 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 92075