Privacy Policy - Senior Guidance

Privacy Policy

Last Updated: November 6, 2018

This Privacy Policy describes how we collect, use and share information when you use our Services. The terms "we," "us," or "our" mean SeniorGuidance.org, its operating company, parent company and each of their legal subsidiaries and affiliates. The term "Services," means, collectively, various websites, applications, widgets, email notifications and other mediums, or portions of such mediums, through which you have accessed this Privacy Policy. By accessing or using our Services, you consent to the collection, transfer, manipulation, storage, disclosure and other uses of Your Information (collectively, "Use of Your Information") as described in this Privacy Policy.

For purposes of this Privacy Policy, "Your 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.

This Privacy Policy applies to our Use of Your Information as a result of you using our Services, and does not apply to the following:

• Information collected through mediums other than our Services;
• Information collected through our Services where a separate privacy policy applies, such as a sweepstakes entry (you should refer to the official rules and privacy policy for each individual sweepstakes for our specific policies regarding information sharing and disclosure pursuant to sweepstakes entry); or
• Information collected by any person or entity other than us, even if related to our Services (such as a third-party website, application, widget or lead form).

In addition to this Privacy Policy, our Services are also governed by our Terms of Use and any other documents referred to in this Privacy Policy and our Terms of Use. These documents describe information that we collect from you or that you provide on or to the Services and how Your Information may be used and disclosed by us. They also describe the choices available to you regarding our Use of Your Information and how you can access and update Your Information. Please read this Privacy Policy and the Terms of Use carefully.

Information We Collect and Receive About You

We might receive or collect several types of information about you, such as the information described below.

Information You Provide

The following are situations in which you may provide Your Information to us:

• When you fill out forms or fields through our Services;
• When you sign up for any newsletters or other materials, or other products and services through our Services;
• When you provide information to us through a third-party application, service or website;
• When you communicate with us or request information about us or our Services, whether via email or other means;
• When you participate in online surveys;
• When you participate in any of our marketing initiatives, including, contests, events, or promotions; and
• When you participate in forums or provide user generated content or submissions.

Information Third Parties Provide We may collect information about you from sources other than you, such as from social media websites (i.e., Facebook, LinkedIn, Twitter or others), blogs, other users and our business partners.

General Use and Preference Information We may collect, receive and store information regarding your general use of our Services (such as details of how and when you used our Services, interactions with our Services, log in information, resources that you access, your Internet protocol address, your browser type, and your device type), as well as your preferences.

Device Information When you use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.

Location Information If you enable the collection of location information on your device, then we may collect information about your actual location, such as your mobile device's GPS coordinates. We may also use other technologies to determine your location (such as through the location of nearby Wi-Fi access points or cell towers), or obtain your location information from third parties.

Phone Numbers We may collect your phone number in several ways. For example, we may collect your phone number: (i) if you submit your phone number to us through our Services; (ii) by capturing your phone number if you call us; or (iii) if a third party provides your phone number to us.

Non-Personally Identifiable Information We may collect demographic information about you such as gender, zip code, and birth date, and information regarding your preferences and usage. This type of information is not, by itself, personally identifiable information. However, if we link such information with personally identifiable information in a manner that identifies a particular individual, then we will treat all such information as personally identifiable information for purposes of this Privacy Policy.

Log Files, Cookies and Anonymous Identifiers As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality, and to document your consent to receiving products, services or communications from us or our partners. If we link such information with personally identifiable information in a manner that identifies a particular individual, then we will treat all such information as personally identifiable information for purposes of this Privacy Policy.

Technologies such as cookies, beacons, tags and scripts are used by us and our partners, affiliates, advertisers, analytics teams, or service providers. These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies to help us know that you are logged on, provide you with features based on your preferences, understand when you are interacting with our Services, and compile other information regarding use of our Services. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use cookies to collect and store information. You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

We use Local Storage Objects (LSOs) such as HTML5 Storage to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML5 Storage to collect and store information.

Network Advertising From time to time, we may participate in, partner with, or use advertising networks, such as third-party advertising servers, advertising agencies, technology vendors and research firms. For example, we use Google AdSense to publish ads on our Services. When you view or click on an ad, a cookie will be set to help better provide advertisements that may be of interest to you on this and other Web sites. In addition, we may use third-party advertising networks to serve advertisements to you on our Web site, or to manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. This practice is often referred to as "online behavioral advertising." Please see the "Online Behavioral Advertising" subsection of Choices About How We Use and Collect Your Information below to read about how you can prevent certain third-party advertising networks from collecting information about you.

How We Secure Your Information

Our web servers support the TLS and Secure Sockets Layer (SSL) transport and encryption protocols. The purpose of these protocols is to keep the information passed back and forth between a web server and its users confidential. In addition, we use cipher suites that offer at minimum 112 bit encryption. We work to protect personally identifiable information stored on the site’s servers from unauthorized access using industry standard computer security products, such as firewalls, as well as carefully developed security procedures and practices. In addition, a username, member ID name and password are required for you to use, view or change application or interview information. We use both internal and external resources to review the adequacy of our security measures on a regular basis.

How We Use Information

We may make Use of Your Information for various lawful business purposes. Among others, these purposes may include using Your Information to:

• 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, advert
• 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](/about/terms) 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

General Disclosure of Your Information We will share your personally identifiable information with third parties only in the ways that are described in this privacy policy.

We may disclose Your Information:

• To any person who, in our reasonable judgment, is authorized to receive Your 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;
• In connection with a Business Transfer, as defined below (see Business Transfers below); and
• To our affiliated companies (i.e., companies under common control or management with us).

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

Requests for Quotes, Information and Services from Service Providers.

As noted above, we may share Your 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 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, EVEN IF YOU ARE ON THE NATIONAL DO NOT CALL REGISTRY OR ANY OTHER DO NOT CALL REGISTRY. THE FCC MAY VIEW THESE CALLS AS TELEMARKETING CALLS.

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 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 Information as described above in connection with your Inquiry, you will not have the opportunity to opt out of the disclosure of Your Information in connection with that Request.

Aggregation and De-Personalization We may take Your Information and de-identify it either by combining it with information about other individuals (aggregating Your Information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-identifying Your Information). We reserve the right to share, loan, rent, sell, or otherwise disclose such information to third parties at any time, for any lawful purpose, without notice or compensation to you.

Sharing with Friends If the Services contains any functionality allowing you to send content to a friend, then please be aware that: (a) we may display your email address to your friend; and (b) we may use information you provide about your friend to facilitate the communication and as otherwise set forth in this Privacy Policy. We do not store your friends email address in our database. Your friend will receive a one-time message notifying them of the shared content.

Sweepstakes If you are submitting information to us pursuant to a sweepstakes entry, we reserve the right to share, loan, rent, sell or otherwise disclose the information that you submit with third parties at any time, for any lawful purpose without notice or compensation to you. Participation in these sweepstakes is completely voluntary and you therefore have a choice whether or not to disclose Your Information. Please refer to the official rules and privacy policy for each individual sweepstakes for our specific policies regarding information sharing and disclosure pursuant to that sweepstakes entry.

Circumvention of Security Measures No method of transmission or method of electronic storage, is 100% secure, and we cannot guarantee absolute security. Additionally, by way of example (without limiting the foregoing), we may be forced to disclose Your Information to the government or third parties under certain circumstances, or third parties may unlawfully intercept or access transmissions or private communications. Therefore, notwithstanding anything to the contrary within this Privacy Policy, our Terms of Use or any other applicable agreement or policy, you use our Services at your own risk and we do not promise or guarantee, and you should not expect, that Your Information will always remain private. In the event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third party's ability to view, use or disseminate Your information.

Business Transfers We specifically and expressly reserve the right to disclose, lease, sell, assign or transfer Your Information collected through our Services, and any of our databases, together with any personally identifiable information contained in such databases, to third parties in connection with a Business Transfer. A "Business Transfer" means a share or asset sale, acquisition, merger, consolidation, reorganization, spin-off, bankruptcy or other corporate change involving us and/or our affiliates, even if the Business Transfer is only being contemplated and regardless of whether the Business Transfer relates to a part or a whole of our business. Nothing in this Privacy Policy is intended to interfere with our ability to transfer all or part of our business, equity, and/or assets (including our Services) to an affiliate or independent third party at any time, for any lawful purpose, without compensation to you.

Children's Information

You must be at least 13 years of age to register with or use certain portions of the Services. The Services are not intended for children under 13 years of age. No one under 13 years of age may provide any personally identifiable information to or on the Services. We do not knowingly collect personally identifiable information from children under 13. If you believe that we may have any information from or about a child, please contact us at privacy (at) seniorguidance.org.

User Generated Content

We offer publicly accessible blogs and other interactive media through our Services. To request removal of Your Information from our blog or community forum, contact us at info (at) seniorguidance.org. In some cases, we may not be able to remove Your Information, in which case we will let you know if we are unable to do so and why.

You are responsible for any content, including personally identifiable information, that you contribute to be published or displayed ("posted") on our Services, or that you transmit to other users of our Services (collectively, "User Generated Content"). Your User Generated Content is posted on and transmitted to other users of our Services at your own risk. We cannot control the actions of other users of our Services with whom you may choose to share your User Generated Content. We are not responsible for circumvention of any privacy settings or security measures of our Services. As a result, we cannot and do not guarantee that your User Generated Content will not be viewed by unauthorized persons. You understand and acknowledge that, even after removal, copies of your User Generated Content may remain viewable in cached and archived pages, or might have been copied or stored by other Service users. Proper access and use of information provided through our Services, including User Generated Content, is governed by our Terms of Use.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personally identifiable information you provide to us. Below are some mechanisms that provide you with control over certain information:

• Cookies. If you do not wish us to collect cookies, you may set your browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of our Services may then be inaccessible or may not function properly.
• Email Offers from Us. If you do not wish to receive email offers or newsletters from us, you can opt out of receiving email information from us (other than emails related to the completion of your registration, correction of user data, change of password and other similar communications essential to your transactions through our Services) by using the unsubscribe process at the bottom of the email.
• Accessing and Correcting Personally Identifiable Information. If a portion of our Services allows you to create an account with us, then you can review and update Your Information by logging into that portion of our Services, visiting your account profile page and making changes. We will retain Your Information for as long as your account is active or as needed to provide you services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
• Log Files. Various browsers may offer their own management tools for removing HTML5 Storage LSOs.
• Online Behavioral Advertising. If you wish to not have third party advertisers collect your information for the purpose of serving you interest-based ads, you may opt-out by clicking here. In addition, certain third-party advertising networks that deliver behavioral advertising are members of the Network Advertising Initiative ("NAI"). You can prevent NAI member companies from collecting preference data about you by clicking here and following the NAI's directions. You may also opt-out of Google Adsense's use of its cookie by visiting Google's Advertising and Privacy page. Please note that these opt-outs do not opt you out of being served ads. You will continue to receive generic ads.

Information You Disclose to Third Parties

You may be presented with an opportunity to receive information and/or marketing offers from third parties in connection with our Services. All information you disclose to such third parties will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to disclosing information to them. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

Links to Third-Party Websites

Our Services, as well as the email messages sent with respect to our Services, may contain links or access to websites operated by third parties that are beyond our control. For example, if you click to apply for a product such as a credit card through our Services, you may be linked to a third-party website to complete an application. Links or access to third parties from our Services are not an endorsement by us of such third parties, or their websites, applications, products, services, or practices. We are not responsible for the privacy policy, terms and conditions, practices or the content of such third parties. These third-parties may send their own cookies to you and independently collect data. If you visit or access a third-party website, application or other property that is linked or accessed from our Services, we encourage you to read any privacy policies and terms and conditions of that third party before providing any personally identifiable information. If you have a question about the terms and conditions, privacy policy, practices or contents of a third party, please contact the third party directly.

Third Party Widgets and Plug-ins

Our Services include social media features, such as the Facebook Like button, links to our various social media pages and widgets, such as the Share this button or interactive mini-programs that run on our Services. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly through our Services. Your interactions with these features are governed by the privacy policy of the company providing it.

Operation of our Services in the United States

Our Services are operated in the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Services or providing us with Your Information, you consent to this transfer.

Changes to this Privacy Policy

We reserve the right to update, amend and/or change this Privacy Policy at any time in our sole discretion. Amendments will take effect immediately upon us posting the updated Privacy Policy on our Services. If we make any material changes we will notify you by means of a notice on this Site prior to the change becoming effective. You are encouraged to revisit this Privacy Policy from time to time in order to review any changes that have been made. The date on which this Privacy Policy was last updated will be noted immediately above this Privacy Policy. Your continued access and use of our Services following the posting of any such changes shall automatically be deemed your acceptance of all changes.

Contacting Us

If you have questions or concerns about our privacy practices or wish to make a request regarding your information, please contact us at privacy (at) seniorguidance.org.

Special Notification for California Residents -- Your California Privacy Rights

Individuals who are residents of California and have provided their personally identifiable information to us may request information regarding our disclosures, if any, of their personally identifiable information to third parties for direct marketing purposes. Such requests must be submitted to us at privacy (at) seniorguidance.org.

California privacy rights requests must include the reference "Request for California Privacy Information" on the subject line and in the body of the message and must include the email address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than to the address specified above.