This privacy policy (the “Privacy Policy”) explains the collection, use, and disclosure practices of the websites, mobile applications, and other online and offline products and services, including, without limitation, our senior living referral services (collectively, the “Services”) owned and operated by BEST ASSISTED LIVING PLACE, Inc., and/or any of their affiliates (“APFM,” “we,” “us,” or “our”). For clarity, this Privacy Policy describes how we collect and use information when you access and use our websites, including but not limited to www.assistedliving.com; www.alzheimers.net; www.nursinghomes.com; www.agingcare.com; www.veteranaid.org; www.senioradvisor.com; www.OurParents.com and www.caregivers.com (individually and collectively, the “Site” or “Sites”). For the purposes of this Privacy Notice, “you” and “your” mean you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy. Please be advised that the practices described in this Privacy Policy also apply to how we handle information that you submit to us offline.
Privacy Policy. By using our Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Notice, please do not use or access the Services.
Phone Calls. By providing us with your telephone number through your use of our Services, you agree to be contacted by APFM and contracted senior care network providers to explore options relating to our Services. You agree to be contacted by telephone call or text message at the telephone number you provided, even if you previously registered on a Do Not Call registry.
We collect information from four primary sources: directly from you, automatically from your use of our Services, from third parties, and by using information we collect to derive new information. The types of information we collect about you depend on your interactions with us and are described in more detail below.
Information We Collect Directly from You. We collect information directly from you in a variety of ways. Any information you provide to us is voluntary, but some information may be necessary for us to provide you with our Services. The categories of information we collect directly from you may include:
You may also provide information to us about another person for whom you may be seeking the Services (“Resident”).
Information Automatically Collected from Your Use of the Sites. We automatically collect information about you from your use of our Services, including by using website analytics tools or other technologies, like cookies and web beacons (which are described in more detail below).
The categories and types of information we collect automatically from your use of the Services include:
Cookies. Cookies are small text files that are stored on your computer when you visit certain online pages that record your preferences. We use cookies to track use of our Sites and other Services. We may also use cookies to monitor traffic, improve the Sites, make the Sites easier and/or relevant for your use, and improve the performance of our advertising on other websites. You can opt out of accepting cookies by adjusting your browser settings to not accept cookies or to notify you when you are sent a cookie. However, certain features of our Sites or other Services may not work if you delete or disable cookies.
Web Beacons. Some pages of our Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email, and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of your information when you visit various websites. To learn more about “do not track” signals, you can visit http://www.allaboutdnt.com/. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/.
To learn more about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit https://www.aboutads.info/choices. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.
We may collect information about you from other sources. For example, we may collect information about you from:
Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Links to Third Parties.
We may derive information or draw inferences about you based on the other information we collect about you. For example, we may infer your location from our collection of your IP address.
In addition to the specific uses described above, we may use any of the above information to provide you with the Services and to maintain our business relationship, including by enhancing the safety and security of our Services (e.g., troubleshooting, data analysis, testing, system maintenance, and reporting), providing customer support, sending service and other non-marketing communications, monitoring and analyzing trends, conducting internal research and development, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting the Services, our rights, and the rights of our employees, users or other individuals.
Finally, we may de-identify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be reasonably linked to you (“de-identified information”). We may also collect information about you that has already been de-identified/anonymized. We may use such de-identified information for any purpose, including but not limited to, sharing or selling to third parties for their own use. To the extent we possess or process any de-identified information, we will maintain and use such information in de-identified/anonymized form and not attempt to re-identify the information, except solely for the purpose of determining whether our de-identification/anonymization process satisfies legal requirements.
For each category of information we collect about you or Resident (whether directly or automatically), we use such category of information for the purposes set forth below:
We will disclose your information to third parties for legitimate purposes, subject to this Privacy Policy, including the following categories of third parties:
To Senior Care Network Providers. As your referral agent, we may disclose information about you as a Resident or as a person seeking Services on behalf of a Resident to senior care network providers to provide you with the Services. The senior care network providers may contact you directly via email, telephone, text, regular mail, or in-person visits.
To Partners. We may disclose your information to partners so that they can provide services to you; however, we do not disclose this information without first confirming that you wish to receive their services. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes unless you request that we do so. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties for marketing/promotional purposes.
To People Acting On Your Behalf. We may disclose information to the person who referred you as a Resident or to another person acting on your behalf.
To Our Service Providers and Vendors. We may disclose information to our service providers and vendors who help us provide the Services, including system administration, cloud storage, security, customer relationship management, marketing communications, and web analytics.
To Marketing Providers. We may disclose your information for marketing purposes.
To Affiliated Companies or Others Within Our Corporate Group. We may disclose your information to our parent company, subsidiaries, joint ventures, or other companies under common control with us.
For Legal and Other Compliance. We may disclose information when we believe it is appropriate for legal purposes, including to: (a) comply with the law; (b) enforce or apply this Privacy Policy or our other policies or agreements; (c) protect our or our users’ rights, property, or safety; (d) protect our users from fraudulent, abusive, or unlawful use of our Site; or (e) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.
As Part of Business Transfers. We may disclose information as part of any merger, acquisition, debt financing, sale, or transfer of company assets, or other business transaction. In the event of a merger, acquisition, restructuring, reorganization, or other sale or transfer of some or all of company assets, your information may be part of the assets that will be transferred.
As Aggregated, Anonymized Information. We may disclose aggregated, anonymous, or de-identified information to our advertisers, business partners, and other third parties. This information cannot reasonably be used to identify you and may be shared or sold to third parties for their own use.
At your request. We may otherwise disclose information with your consent or at your direction, such as through your use of social media widgets or login integration.
Depending on where you live, you may have some or all of the privacy rights listed below relating to information we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law, including if, in the event you reside in a state that does not currently grant you these rights.
You may have the right to (1) request that we confirm whether we process information about you and give you access to that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment, (2) request deletion of your information, and (3) request correction of inaccurate information.
You have a right to request the following information about our collection, use, and disclosure of your information:
We process information to understand and improve your experience with our Services and to serve you advertisements on non-APFM web properties. These activities may result in our engaging in targeted advertising. Please email privacy@bestassistedlivingplace.com to submit a request to opt out of targeted advertising.
You have the right to direct us not to sell or share your personal information. To exercise this right, please use the following form: Do Not Sell My Personal Information.
We will not discriminate against you for exercising your privacy rights, however, we cannot provide you with some of our Services if you do not share certain information.
You may exercise any of these rights by contacting us via email at privacy@bestassistedlivingplace.com or by visiting our privacy portal.
We may verify your request by asking you to provide information related to your recent interactions with us, such as by confirming your email address and/or your state of residence, before providing a substantive response to your request. In some cases, we may need to collect additional information to verify your identity, such as a government-issued ID. If we deny your request, you may appeal our decision by contacting us at privacy@bestassistedlivingplace.com. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfill your request or process your appeal. We will not require you to pay a fee for the verification of your request or appeal.
You may designate an authorized agent to exercise these rights on your behalf by providing your authorized agent with written permission to act on your behalf and by verifying your own identity with APFM. Alternatively, you may provide a power of attorney pursuant to Probate Code sections 4000 to 4465. We may verify your request by asking you to provide information related to your interactions with us, such as by confirming your email address and/or your state of residence. In some cases, we may need to collect additional information to verify your identity, such as a government-issued ID. If you are an authorized agent seeking to make a request, please contact us via email at privacy@bestassistedlivingplace.com or by visiting our privacy portal. We will not require your authorized agent to pay a fee for the verification of your request or appeal.
Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to access our pages on third-party platforms, and from there, “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, the information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. For more information, see the section below, Links to Third Parties.
We may provide links to third-party websites from our Sites, but we cannot control nor are we responsible for the privacy and data collection, use, and disclosure practices of third-party websites. When you click on links that take you to external websites, you will be subject to their privacy policies and practices and not ours. We encourage you to review and understand the privacy policies of such websites before providing them with any information.
We use reasonable security measures to store and protect your information while it is under our control. Please note, however, that no transmission of data over the internet is entirely secure. Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you use secure channels to send us sensitive or confidential information.
Telephone communications between you and APFM may be recorded or monitored for quality control purposes or as required by state law. By participating in telephone communications with us, you expressly consent to the recording of these communications.
Our Services are designed for adults, not persons under the age of 18. As such, we do not intend to collect personal information from persons under the age of 18, and our Services are not designed for such information. If we become aware that we have unknowingly collected information about a person under 18 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a person under the age of 18 who has provided us with their personal information, you may contact us using the information below to request that it be deleted.
This section supplements this Privacy Policy for California residents and describes our data practices today and in the preceding 12 months. This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “Personal Information” shall include “Sensitive Personal Information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).
We collect the categories of Personal Information that are indicated in the table below. We collect this Personal Information from the following categories of sources: directly from you, automatically using certain technologies, and from third parties. For more information about the specific data points we collect and the sources from which we collect them, please see the Collection of Your Personal Information section above.
In the preceding 12 months, we have collected and disclosed your Personal Information and Sensitive Personal Information (denoted by *) as follows (described in more detail in the Use and Disclosure of Information sections above):
| Category of Personal Information Collected | Purpose for Processing | Categories of Recipients |
|---|---|---|
| Identifiers: such as name, email, telephone number, physical address, and IP address |
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| Personal Information Categories Listed in the California Customer Records Statute: such as name, physical characteristics, address, and telephone number |
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| Characteristics of Protected Classifications Under California or Federal Law: such as ethnicity*, religion*, sex (including gender and gender identity*), age, physical or mental disability*, and veteran status |
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| Commercial Information: such as records of services provided to you by senior care network providers and your move-in status |
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| Internet Or Other Electronic Activity Information: such as information regarding your interactions with the Sites |
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| Geolocation Information: such as IP address |
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| Audio: such as voice recordings of telephone communications |
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| Financial Information: such as income and budget |
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| Inferences Drawn from Personal Information |
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| Account Access Credentials*: such as account username and password |
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| Ethnic origin and religious beliefs* |
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| The contents of a resident’s mail, email, and text messages* |
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| Personal Information concerning a resident’s health* such as medical conditions and medical history |
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Privacy Rights: Please see the Privacy Rights section above to learn more about your right to request access to your Personal Information, to request deletion or correction of your Personal Information, to request additional details about our information practices, to request to opt out of targeted advertising, “sales,” or “sharing” of your Personal Information, how to exercise those rights, and the right to not be discriminated against for exercising such rights.
Personal Information We “Sell” or “Share” (as defined by the CCPA): The CCPA requires that we provide transparency about Personal Information we “sell,” which, for purposes of the CCPA, broadly means instances in which APFM has disclosed Personal Information with partners and other third parties in exchange for valuable consideration, and “share,” which means to disclose for the targeted advertising purposes described above. We do not have actual knowledge that we “sell” or “share” (as those terms are defined under the CCPA and used throughout this section) personal information of residents under 16 years of age. However, we do sell and share certain categories of Personal Information and in the preceding 12 months, we have sold and shared the following categories of Personal Information to the following categories of third parties:
| Category of Personal Information | Sold and/or Shared | Categories of Recipients |
|---|---|---|
| Identifiers | Shared |
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| Commercial information about the Services you request | Shared |
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| Internet or other electronic activity information | Shared |
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For information about opting out of these “sales” or this “sharing,” please see the Privacy Rights section above.
Sensitive Personal Information: to the extent we collect Sensitive Personal Information, we use and disclose such information only as reasonably necessary to provide the Services.
Data Retention: We store Personal Information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy. To determine that period, we take into account a number of factors, including our legal and regulatory obligations, and whether we may need to retain Personal Information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes, and/or enforce our agreements.
You have the right to submit a complaint or to object to the collection and use of your Personal Information by APFM at any time. Upon written request, you may access or request the deletion of your Personal Information that is in our possession and request a correction or update of any such information.
Acknowledgement and authorization: In making a request, you confirm that you are:
You can exercise these rights by contacting APFM at:
Email: privacy@bestassistedlivingplace.com
Toll Free: 555-666-7777
Canadian Mailing Address:
BEST ASSISTED LIVING PLACE, Inc.
455 N End Ave, New York, NY 10282
New York, USA
At any time, you may visit https://my.bestassistedlivingplace.com/preference-center to adjust your communication preferences.
Promotional Communications: When you receive a newsletter or other promotional communications from us by email or phone, you may indicate a preference to stop receiving further newsletters and other promotional communications by visiting https://my.bestassistedlivingplace.com/preference-center.
Mobile Push Notifications/Alerts: With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
If you wish to opt out of communications with senior care network providers, you must contact them directly, as we do not control communications from senior care network providers.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.
If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@bestassistedlivingplace.com
