Greenfield Senior Living, INC.

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CCPA/CPRA Privacy Policy

State Law: Applicable To California Residents

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125 N Washington St, Falls Church, Virginia 22046

 

Phone:(703) 237‐5606

 

 

Part I – Overview of California Consumer Privacy Laws

 

This California Privacy Policy applies only to California consumers (“you” or collectively as “consumers”) and supplements the Privacy Policy of Greenfield Senior Communities LLC and any of its subsidiaries (collectively, “we,” “us,” or “our”). The California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), collectively referred to as “California Consumer Privacy Laws”, provide California consumers with specific rights regarding their personal information. This California Privacy Policy describes your privacy rights under the California Consumer Privacy Laws, explains how you may exercise your privacy rights, and provides an overview on the types of personal information we collect.

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Your Rights Under California Consumer Privacy Laws and this Privacy Policy

 

California Consumer Privacy Laws provide you with the following rights:

 

• Right to know. You have the right to know what categories and specific pieces of personal information we collect about you; the categories of sources from which we collect personal information; our business or commercial purpose for the collection, use, and sharing of your personal information; and any categories of third parties with whom we share your information.

• Right to delete. You have the right to request that we delete the personal information that we collect about you.

• Right to opt out. You have the right to opt out of the sale or sharing of personal information. If we sell any of your personal information, you have the right, at any time, to tell us not to sell your personal information. At the time this Privacy Policy was last updated, we do not sell any personal information. You also have the right to request that we do not share your personal information.

• Right to correct. You have the right to request the correction of any personal information we maintain about you.

• Right to limit use or disclosure of sensitive personal information (“SPI”). You have the right to limit the use and disclosure of your SPI, if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services.

• Right to nondiscrimination. If you exercise any of your privacy rights, we will not discriminate against you.

 

California Consumer Privacy Laws allow you to exercise your privacy rights and request your information from us, at no cost. We will provide our response in a readily usable format, which is usually electronic.

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How to Contact Us About Your Privacy Rights

 

Ways to Contact Us. If you would like to exercise any of your privacy rights, please contact us through any of the following:

 

(1)  by writing to: Greenfield Privacy, 125 N. Washington Street, Falls Church, Virginia, 22046

(2) by email: privacy@greenfieldseniorliving.com

(3) www.GreenfieldSeniorLiving.com

 

Verification of Your Identity. To protect your privacy, we will ask you to verify your identity. We will ask you to confirm your name, email address, phone number and other information so that we can reasonably confirm your identity. We will not share any information until we can reasonably confirm your identity.

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Our Response Time to Your Privacy Request

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• Response Time. We will respond to your privacy request within forty‐five (45) days from when you contacted us.

• Response Time for Complex Requests. If you have a complex privacy request, state privacy laws allow us up to ninety (90) days to respond. We will still contact you within forty‐five (45) days from when you contacted us to let you know we need more time to respond.

 

We provide more detailed information below about  your specific privacy rights under the  California Consumer Privacy Laws.

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Part II – Detailed Explanation of Privacy Rights Under the California Consumer Privacy Laws

 

Right to Know About Personal Information Collected, Disclosed, Shared or Sold

 

• Your Right to Know. You have the right to know what personal information we collect, use, disclose, share, and/or sell.

• How Long We Retain Your Information. We will retain your information as long as it is reasonably necessary for each disclosed purpose, as outlined in the tables below. If you have any questions or would like to exercise any privacy rights, please contact us.

• Response Contents. Our response is based on your request. The contents of our response may include the following information:

• Categories of personal information we collected about you.

• The specific pieces of personal information we collected.

• The categories of the sources of the personal information.

• Our business or commercial purpose for collecting your personal information.

• Any third parties we shared your personal information with.

• Confirmation that we have not sold any of your personal information.

 

Right to Request Deletion of Personal Information

 

• Your Right to Deletion. You have the right to ask us to delete your personal information that we have collected and shared.

• Information We May Keep. California Consumer Privacy Laws allow us to keep your personal information that we need to provide you with goods and services, ensure the security and integrity of your personal information, fix any errors, exercise free speech, use your information lawfully for our internal purposes, and to comply with the law.

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Right to Opt‐Out of the Sale or Sharing of Personal Information

 

• Your Right to Opt‐Out. If we sell or share any of your personal information, you have the right, at any time, to tell us to stop. At the time this Privacy Policy was last updated, we do not sell any personal information.

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Right to Correct Personal Information

 

• Your Right to Correction. You have the right to request the correction of any inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.   We will use commercially reasonable efforts to correct the inaccurate personal information as you may direct.

 

Right to Limit Use or Disclosure of Sensitive Personal Information (“SPI”)

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• SPI We Collect. Typically, we collect SPI only to determine whether we are able to provide care or as a part of our ongoing care services. We use your SPI in a reasonable and proportionate manner in order to provide you with the appropriate level of care.

• Your Rights Regarding SPI. You have the right to limit the use and disclosure of your SPI, if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services. Please see the Tables “Categories of Personal Information” and “How We Use Your Personal Information” for more details about our practices around SPI and your rights related to SPI.

Right to Non‐Discrimination for Exercising Your Privacy Rights

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• Our Non‐Discrimination Policy. If you choose to exercise any of your privacy rights under the California Consumer Privacy Laws, we will not discriminate against you.

Financial Incentives for Your Personal Information

 

• Notice of Financial Incentives. California Consumer Privacy Laws allow us to provide financial incentives for collecting, selling, or retaining your personal information. At the time this Privacy Policy was last updated, we do not provide any financial incentives.

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Asking Others to Exercise Your Privacy Rights

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• Authorized Agent. California Consumer Privacy Laws allow you to ask someone else to exercise your privacy rights for you. This person is your “Authorized Agent.” Before we will share anything with your Authorized Agent, you will need to provide your written permission or other proof, such as a valid Power of Attorney. Please contact us if you would like us to know who your Authorized Agent is.

• Verifying the Identity of Your Authorized Agent. Once we have your written permission, we will also ask your Authorized Agent to verify their identity with us directly.

• Protecting Your Privacy. We will not share any of your information with your Authorized Agent unless we have both your written permission and have verified the identity of your Authorized Agent.

 

Part III - Our Information Collection Practices

 

Information Collection and Use

 

• Sources of Information. During our interactions, we may request that you provide us with personal information, such as your name, email, and/or phone number. In addition to any personal information that you voluntarily provide to us, our website and other websites may collect your personal information through the use of cookies and other third‐party tools. Please refer to the sections below on “Cookies,” “Third Party Analytics Tools,” and “Third Party Advertising Tools.”

• Information Use. We may use your personal information to provide you with services or information you have requested; verify that you are a customer or a prospective customer; send you information you have signed up to receive, such as notices about our services; and to improve the content of our website and our services.

• Cookies. We use both session ID cookies and persistent cookies.

• A session ID cookie expires when you close your browser. We use session ID cookies, so it is easier for you to navigate our website and to improve our website.

• A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies allow us to track, store, and target the interest or our users to enhance and improve our website. You can remove persistent cookies by following the directions of your Internet browser. If you reject cookies, you may still use our website. However, in some areas, your use may be limited.

• Third Party Analytics Tools. In addition to the information, you voluntarily provide to us, we utilize analytics tools, such as Google Analytics, to collect information for our analysis and advertising efforts. The analytics tools collect certain types of personal information, such as geolocation, website usage and behavior, and device type.

• Third Party Advertising Tools. We also use third party advertising tools, such as Google Analytics, Google Ads, Facebook, or other similar types of tools, in order to display advertisements to consumers who have previously visited our website or may be interested in our services.

• This type of advertising is referred to as remarketing or retargeting. Our remarketing and retargeting activities may use sessions ID and persistent cookies to assist our advertising efforts.

• Aggregated consumer data may be used to create “lists” or groups of consumers with similar online behaviors or demographics.

• You can learn more about Facebook’s use of cookies by Facebook Data Policy and Facebook Advertising Policy.

• You can learn more about Google’s use of cookies by visiting Google’s Privacy and Terms website at http://www.google.com/policies

• You may opt out of being tracked by Google Analytics by:

• Turning off cookies in your browser’s settings;

• Downloading the Google Analytics opt‐out add‐on available
  at https://tools.google.com/dlpage/gaoptout

• Opting out of user interest and demographic categories in the Google Ads settings
  at https://adssettings.google.com ; and/or

• Managing cookies used for online advertising companies at the US‐based Network Advertising Initiative at https://optout.networkadvertising.org/?c=1

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Personal Information We Collect

 

California Consumer Privacy Laws define personal information as information that identifies, relates to, describes, is reasonably  capable of being associated  with, or could reasonably be  linked, directly or indirectly, with a particular consumer or household. Personal information does not include:

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• information that is lawfully made available from federal, state, or local government records;

• de‐identified or aggregated information; and

• information excluded from the California Consumer Privacy Laws such as health or medical information covered under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and financial information covered under the Fair Credit Reporting Act (“FCRA”) or Gramm‐Leach Bliley Act (“GLBA”).

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To help consumers make informed privacy decisions, the California Consumer Privacy Laws create and define categories of personal information. Some types of personal information may apply to multiple categories. We collect the categories of personal information described in Table 1 below. Depending on your level of interaction with us, we may not have collected your personal information from all of the categories.

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