INFORMATION WE COLLECT ABOUT YOU

For purposes of this Privacy Policy, “Personal Information” means information about you, which may be of a confidential nature and may include personally identifying information, medical and health history information, and/or financial information. We collect several types of information about you, such as the information described below.

Information You Provide

When you use our Services, you may voluntarily provide us with the following types of Personal Information:

• Caregivers. When you register to become a caregiver you will provide us with your Name, Email Address and Password

• Clients/Caregiverseekers. When you register to become a Caregiverseeker/Clients, you will provide us with your Name, Email Address and Password

• Email Us: If you send us an email or otherwise contact us, you may provide personal information such as your email address, name and any personal information that appears in your message.

Information as Your Navigate the Services

We automatically collect certain Personal Information through your use of the Services, such as the following:

• Usage Information. We collect information such as which of the pages on the Services you access, the frequency of access, and what you click on while on the Services.

HOW WE USE INFORMATION

We may make use of your Personal Information for various lawful business purposes. Among others, these purposes may include using your Personal Information to:

• Process your registration. For example, if you register to be a caregiver, we will conduct a criminal background check and check your driver’s license records.

• Engage in customer support. For example, we might confirm and complete transactions requested by you, verify information you provide to us and provide you with administrative notices.

• Contact you and provide you with information. For example, we might provide or contact you through telephone, email, postal or other communications with Service updates, promotional materials, surveys, offers, quotes, personalized information and other information from us or our business partners.

• Analyze, improve and manage our Services and operations. For example, we might obtain feedback regarding our Services, understand and anticipate your needs and preferences, better understand your use of our Services, customize and tailor Service content and advertising, improve our marketing and promotional efforts, engage in statistical analysis and provide feedback to our vendors, advertising and research partners, and business affiliates.

• Resolve problems and disputes, and engage in other legal and security matters. For example, we may use your information to comply with, monitor compliance with and enforce this Privacy Policy, our Terms of Use and any other applicable agreements and policies, meet other legal and regulatory requirements, and to protect the security and integrity of our Services and your information.

HOW WE DISCLOSE INFORMATION

We may disclose your Personal Information

• As a referral agent, and in states where applicable (including California and Oregon), we are a mandated reporter of suspected and known elder abuse. As such, we may release your name, phone number, address, and other information you’ve shared with us to the state authorities in cases of suspected or known elder abuse;

• To any person who, in our reasonable judgment, is authorized to receive your Personal Information as your agent, including as a result of your business dealings with that person (for example, your attorney);

• To our third-party vendors so that they may provide support for our internal and business operations, including for the handling of data processing, data verification, data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials, and our Services’ maintenance and security. These companies are authorized to use your information only as necessary to provide these services to us and are contractually obligated to keep your information confidential;

• To third parties when you use our Services to obtain a quote, services, or information from one or more of those third parties (e.g., a senior living community in connection with your completion of an information request form) (“Service Providers”), such as by clicking “Find Cost Information” or other similar buttons at the end of a form, and we may be compensated in connection with such disclosure;

• To third parties when you engage in certain activities through our Services that are sponsored by them, such as purchasing products or services offered by a third party, electing to receive information or communications from a third party, or electing to participate in contests, sweepstakes, games or other programs sponsored, in whole or in part, by a third party. When we disclose your information to these third parties, we may be compensated, and your information will become subject to the information use and sharing practices of the third party, and the third party will not be restricted by this Privacy Policy with respect to its use and further sharing of your information;

• To third parties that are interested in contacting you or providing offers to you that may be related to our Services or about products or services you may find of interest, and we may be compensated for such disclosure;

• As required by law or ordered by a court, regulatory, or administrative agency;

• As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another’s rights or property, including, without limitation, our rights or property;

• If requested by authorities in the event of any act of terrorism or instance of local, regional or national emergency;

• To enforce our Terms of Use, this Privacy Policy, and any other applicable agreements and policies;

• To enforce or protect our rights;

• To any other person or entity as part of any business or asset sale; and

• To our affiliated companies (i.e., companies under common control or management with us).

If you do not want your Personal Information shared as described above, then you should not provide us with Your Information.

Requests for Quotes, Information and Services from Service Providers and Consent to Automatic Telephone Dialing System

As noted above, we may share your Personal Information with Service Providers when you use our Services to obtain or request a quote, services or information from one or more third parties (an “Inquiry”). The Service Providers we may share your Personal Information with may be determined subsequent to your Inquiry (e.g., after you talk to a family advisor or by an automated matching algorithm). IF YOU SUBMIT AN INQUIRY, SERVICE PROVIDERS MAY CONTACT YOU DIRECTLY VIA MAIL, TELEPHONE, TEXT MESSAGE, FAX, EMAIL AND OTHER MEANS OF COMMUNICATION. IN ORDER TO ASSIST YOU IN FINDING SENIOR CARE, YOU MAY RECEIVE CALLS FROM OUR FAMILY ADVISORS OR SERVICE PROVIDERS AS A CONSEQUENCE OF SUBMITTING AN INQUIRY THROUGH OUR SERVICES. BY SUBMITTING AN INQUIRY, YOU CONSENT AND AGREE THAT WE AND OUR PARTNERS AND SERVICE PROVIDERS MAY CONTACT YOU, VIA TELEPHONE CALL, TEXT, OR FAX WITH AN AUTOMATIC TELEPHONE DIALING SYSTEM OR PRERECORDED OR ARTIFICIAL VOICE FOR TELEMARKETING PURPOSES AT THE TELEPHONE NUMBER YOU PROVIDED, EVEN IF YOUR TELEPHONE NUMBER IS ON A “DO NOT CALL” LIST. THIS CONSENT IS NOT REQUIRED TO OBTAIN OUR OR OUR PARTNERS’ SERVICES OR PRODUCTS AND YOU MAY OPT OUT AT ANY TIME. CALL OR TEXT FREQUENCY VARIES. MESSAGE AND DATA RATES MAY APPLY. TELEPHONE COMMUNICATIONS BETWEEN YOU AND US MAY BE RECORDED OR MONITORED FOR QUALITY CONTROL PURPOSES. BY PROVIDING INFORMATION TO US, YOU EXPRESSLY CONSENT TO THE RECORDING OF THESE TELEPHONE COMMUNICATIONS.

If you are matched with Service Providers, you expressly consent to the Service Providers conducting any research necessary to provide you with information related to your Inquiry. Service Providers may need to share your Personal Information to conduct such research. If you do not want Service Providers to conduct necessary research to provide you with information for your Inquiry, then you should not submit an Inquiry.

Please note that if you submit an Inquiry through our Services and we share your Personal Information as described above in connection with your Inquiry, you will not have the opportunity to opt out of the disclosure of your Personal Information in connection with that Request.

COOKIES AND OTHER TRACKING TECHNOLOGIES

How We Use Cookies

Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

• Estimate audience size and usage patterns;

• Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;

• Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and

• Recognize when you return to the Site and Services.

We set some Cookies ourselves and others are set by other entities. We use Cookies set by other entities to provide us with useful information to help us improve our Site and Services, to conduct advertising, and to analyze the effectiveness of advertising.

How You Can Opt-Out of Cookies

Browser Settings

Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site and Services.

You can find out more about Cookies and how to manage them by visiting

www.AboutCookies.orgorwww.allaboutcookies.org

Platform Controls

You can opt out of Cookies set by specific entities by following the instructions found at these links:

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google.

“Do Not Track” Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Services do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.

SECURITY

We maintain commercially reasonable security measures to protect the Personal Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee absolute security.

CHILDREN’S PRIVACY

The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.

Choices About Your Personally Identifiable Information

Review and Request Changes to Your Personally Identifiable Information

You may use your account to access, correct, or view certain Personal Information we have collected and which is associated with your account. To review or request changes to any of your Personal Information, please contact us at contactus@SeniorCareOnline.com

Third Party Links

The Site and Services may contain links that will let you leave the Site and Services and access another website. Linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to Personal Information that is acquired by us on this Site and Services. We accept no responsibility or liability for these other websites

Notice to California Residents

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

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

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:

• Specific pieces of Personal Information that we have collected about you;

• Categories of Personal Information that we have collected about you;

• Categories of sources from which the Personal Information was collected;

• Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;

• Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and

• The business or commercial purpose for collecting or, if applicable, selling Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

Collection of Personal Information

We currently collect and, in the 12 months prior to the Effective Date of this Privacy Policy, have collected the following categories of Personal Information:

• Identifiers (name, alias, postal address, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number)

• Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)

• Telephone number

• Credit and debit card number

• Insurance policy number

• Medical information

• Insurance policy number or subscriber identification number

• Any unique identifier used by health insurer to identify consumer

• Any information in the consumer’s application and claims history, including appeals records, if information is linked or reasonably linkable to consumer or household, including via device, by business or service provider

• Geolocation data

• Education information

• Professional or employment-related information (including employment history)

• Characteristics of protected classifications under California or federal law (race, color, sex/gender (including pregnancy, childbirth, breastfeeding and/or related medical conditions), sexual orientation, gender identity/expression, age (40 and older), religion (including religious dress and grooming practices), national origin, ancestry, disability (mental and physical including HIV/AIDS, cancer, and genetic characteristics), citizenship status, genetic information, marital status, medical condition (genetic characteristics, cancer or a record or history of cancer), military or veteran status, political affiliations or activities, status as a victim of domestic violence, assault or stalking, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and retaliation for reporting patient abuse in tax-supported institutions)

• Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

In addition to the purposes stated above in the section “HOW WE USE INFORMATION” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

• Debugging to identify and repair errors that impair existing intended functionality

• Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction

• Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider

• Undertaking internal research for technological development and demonstration.

• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business

• Advancing a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

Disclosure of Personal Information

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy and, for each category, the category of third parties to whom the Personal Information was disclosed. We did not sell Personal Information to third parties in the 12 months preceding the Effective Date of this Privacy Policy.

We do not knowingly collect or sell the Personal Information of minors under 16 years of age.

We do not knowingly collect or sell the Personal Information of minors under 16 years of age.

Right to Request Deletion of Personal Information

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

You may submit a request to know or delete by calling us at [client must provide 1-800 number] or emailing us at

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.

For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Right to Opt-Out of Sale of Personal Information

If you are a California resident, you have the right to direct businesses to stop selling your Personal Information. We do not sell Personal Information as it is defined in the CCPA.

Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.”

Authorized Agents

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Shine the Light Law

We do not disclose personal information obtained through our Site or Services to third-parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please contactus@SeniorCareOnline.com