Privacy Notice
Integral Senior Living California Privacy Notice
Effective Date: Jan. 1, 2020
This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to other privacy policies or notices issued by Integral Senior Living. (“ISL,” “us,” “we,” “our”). In the event of a conflict between any other ISL policy, statement, or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA.
In accordance with the CCPA’s requirements, this Notice describes our collection, use, disclosure, and “Sale” of California Consumers’ “Personal Information” or “PI” as defined by the CCPA, as well as the rights California Consumers have under the CCPA. Terms defined in the CCPA that are used in this Notice have the same meanings as in the CCPA.
Consistent with the CCPA, job applicants, current and former employees and contractors, and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered Consumers for purposes of this Notice or the rights described herein.
Collection and Use of Personal Information
We collect PI about California Consumers as described in the table below.
| Category | Examples of PI Collected | Sources of PI | Purposes for PI Collection |
|---|---|---|---|
| Protected Characteristics | This may include but is not limited to: sex, race, ethnicity, military/veteran status, marital status, sexual orientation, religion, and disability. | Directly from Consumer and/or referral agency(ies). | (1) Processing interactions and transactions, and personalizing services. Including without limitation: Processing payments/financing, personalizing services, processing medical and government paperwork. |
| Commercial Information / Purchase Details | This may include but is not limited to: records of purchase history or purchase tendencies. | Directly from Consumer. | Fulfilling Consumer requests, consumer safety, processing payments/financing, advertising and incentivizing purchases. |
| Geolocation Data | This may include but is not limited to: precise physical location, movements, or travel patterns | Directly from Consumer and Data Resellers. | (1) Managing interactions and transactions; (2) performing services; (3) corporate research and development; (4) personalizing services; (5) safety and security; (5) debugging. Including without limitation: Selling services, customer service, auditing anonymous users, detecting security incidents or abnormalities, internal research. |
| Inferences from PI Collected | This may include but is not limited to: creating consumer profiles reflecting preferences and predispositions. | Directly from Consumer, Service Providers (e.g., marketing firm, referral agency(ies)), Data Resellers. | (1) Performing services; and (2) corporate research and development. Including without limitation: Advertising and incentivizing purchases. |
| Sensory Data | This may include but is not limited to: closed circuit TV, video recording in communications. | Directly from Consumer and Service Providers (e.g. video recording agencies). | (1) Corporate research and development; (2) quality assurance; and (3) safety and security. |
| Internet Usage Information | This may include but is not limited to: browsing history, search history, and information regarding Consumer’s interaction with an Internet Web site, application or advertisement. | Directly from Consumer, Service Providers (e.g. website provider, marketing firm), and Data Resellers. | (1) Managing interactions and transactions; (2) corporate research and development; (3) security; and (4) debugging. |
| Customer / Individual Records | This may include but is not limited to: bank account number, debit card number, credit report information, health information, criminal record information, background check information. | Directly from Consumer and Service Providers (e.g., customer service providers), healthcare providers, referral agency(ies), and Government Entities. | (1) Managing interactions and transactions; (2) corporate research and development; (3) performing services; (4) processing interactions; and (5) security. Including without limitation: Fulfilling Consumer requests, consumer safety, processing payments/financing, advertising and incentivizing purchases. |
| Identifiers | This may include but is not limited to: a real name, alias, postal address, email address, online identifier or username, telephone number, social security number, driver’s license number, passport number, insurance policy number, or other similar identifiers. | Directly from Consumer and Service Providers (e.g. customer service providers), healthcare providers, referral agency(ies), Government Entities. | (1) Managing interactions and transactions; (2) corporate research and development; (3) performing services, (4) processing interactions; and (5) security. Including without limitation: Fulfilling Consumer requests, consumer safety, processing payments/financing, advertising and incentivizing purchases. |
In addition, we may collect, use, and disclose your PI as required or permitted by applicable law. We do not treat “Deidentified” data or “Aggregate Consumer Information” as PI, and we reserve the right to convert, or permit others to convert, your PI into Deidentified data or Aggregate Consumer Information.
Subject to the CCPA’s restrictions and obligations, our affiliates, service providers, and vendors also may use your PI for some or all of the above-listed business purposes.
We may share your PI with certain business partners, service providers, vendors (including those that facilitate interest-based advertising and other advertising and marketing), and other parties as described in the table above.
ISL has not “Sold” (as the term “Sell” is defined by the CCPA) Consumer PI in the past year.
California Privacy Rights
Under the CCPA, California Consumers have certain rights which they may exercise independently or through an authorized agent. CCPA rights requests are subject to an identification and verification process. We will not fulfill a CCPA request unless we have been provided sufficient information for us to reasonably verify the identity of the requestor and the validity of the request.
Some PI we maintain about Consumers (e.g., clickstream data) is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI. Accordingly, we will not include such information in response to Consumer requests. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create an account with us to make a verifiable request, but you may use your account to do so. We will use PI provided in your request to verify your identity or authority to make the request and to track and document request responses, unless you also provided the PI to us for another purpose.
Your California Consumer privacy rights are described below. To make a request, email us at CAPrivacyrequest@islllc.com or call us at (925) 492-7677. You may be required to provide certain PI to allow us to verify that you are the Consumer about whom the request is being made. If you request that we provide you with specific pieces of information about you, we will apply heightened verification standards. An authorized agent may submit a request on behalf of a Consumer if the Consumer has provided the authorized agent with power of attorney in accordance with California law; alternatively, the agent must (1) present verifiable written authorization from the Consumer that the agent has the Consumer’s permission to submit the request; and (2) independently verify the agent’s own identity with ISL.
We may collect, use, and disclose your PI as required or permitted by applicable law. Please note we are not obligated to comply with Consumer requests to the extent that doing so would infringe on our, or any other person’s or party’s, rights, or conflict with applicable law.
Disclosure Rights
You have the right to request that we disclose the following information about your PI that we have collected and are maintaining for the 12-month period prior to your request date. Consumer requests of this nature may be made no more than two times in a 12-month period.
- The categories of PI we have collected about you.
- The categories of sources from which we collected your PI.
- The business or commercial purposes for collecting or Selling your PI.
- The categories of third parties to whom we have shared your PI.
- The specific pieces of PI we have collected about you.
- A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred.
You have the right to make or obtain a portable copy of your PI that we (1) collected in the 12 months prior to the request date, and (2) currently are maintaining. Please note that we retain PI for various time periods in accordance with applicable law and our internal recordkeeping policies and procedures.
“Do Not Sell” Rights
We do not Sell California Consumer PI as defined under the CCPA, and until such time as we change our practices by updating this Notice, will treat PI collected under this Notice as subject to a “do not sell” request.
Some browsers include features that may be characterized as “Do Not Track” signals. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. Further, we do not interpret “Do Not Track” signals to represent a “do not sell” request for CCPA purposes. We understand that various parties are developing “do not sell” signals and we may recognize certain such signals if we conclude such a program is appropriate. We do not interpret the use of third-party cookies as representing a sale of California Consumer PI.
Deletion Rights
Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with applicable laws and regulations, to exercise or defend legal claims, and to cooperate with law enforcement.
Non-Discrimination Rights
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.
Other California Notices
California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of PI to third parties for their own direct marketing purposes.
We do not share personal information with third parties for their direct marketing purposes. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us by sending a letter to Integral Senior Living, Attention: Privacy Inquiry, 2333 State Street, Suite 300, Carlsbad, CA 92008. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per Consumer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
Contact Us
For more information regarding your California privacy rights, email us at CAPrivacyrequest@islllc.com, call us at (925) 492-7677, or write to us at: Integral Senior Living, Attention: Privacy Inquiry, 2333 State Street, Suite 300, Carlsbad, CA 92008.
Arbor Village Privacy Policy
This Privacy Policy was last updated: January 13, 2024
Thank you for visiting Seasons Management, LLC’s (“Arbor Village” or “we”) Internet web site (“Site”) located at the URL https://eugenehotelretirement.com. This Privacy Policy details certain policies implemented throughout Arbor Village governing Arbor Village’s collection and use of personally identifiable information about users of the Site and our services.
Privacy Policy Updates
Arbor Village may need to update this Privacy Policy from time to time. If so, Arbor Village will post its updated Privacy Policy on the Site along with a change notice on the Site. Arbor Village may also send registered users of our services a notice that this Privacy Policy has been changed. Arbor Village encourages you to review this Privacy Policy regularly for any changes. Your continued use of this Site and/or services and/or your continued provision of personally identifiable information to us after the posting of such notice will be subject to the terms of the then-current Privacy Policy.
Information Collection
In certain sections of this Site, we may require you to submit your personally identifiable information to us, and we may invite you to submit questions, comments and request information. In addition to any personal information that you may voluntarily provide, the Site collects information using cookies and other third-party tools. Please refer to the sections below on “Cookies” and “Third Party Analytics Tools” and “Third Party Advertising Tools” for more information about the information these tools collect and use.
Due to the nature of some of our services, you may provide us with personally identifiable information such as your name, email address, username, password, address, phone number, and other contact information that you voluntarily transmit with your communication to us.
Information Use
We may use your personally identifiable information to deliver our services or information you have requested, verify your authority to enter certain password protected areas of the Site, verify that you are a customer or prospective customer, send you information that you have signed up to receive, notices about our products and/or services that you have used or that may be of interest to you and notices about events, and improve the content and general administration of the Site and our services.
If you are a user of our services, we may use your personally identifiable information to provide the services to you.
Children’s Privacy
Arbor Village recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Neither the Site nor our services are intended for children under the age of 16. Arbor Village does not target its services or this Site to children under 16. Arbor Village does not knowingly collect personally identifiable information from children under the age of 16.
Cookies
We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.
On the Site, we use session cookies to make it easier for you to navigate the Site by remembering your locale preferences and to improve and track the overall Site experience. For the Site, we set a persistent cookie to authenticate your login and authorization to use the services. Persistent cookies enable us to track, store and target the interests of our users to enhance the experience on the Site. If you reject cookies, you may still use the Site, but your ability to use some areas of the Site may be limited.
Third Party Analytics Tools
Beyond the personally identifiable information you voluntarily provide to us directly, Arbor Village utilizes analytics tools including third party technologies, such as Google Analytics, to collect information utilizing cookies. Certain types of information, including geolocation, device type, onsite website usage and behavior, demographic data, and purchase history, is collected and aggregated across Arbor Village Site users for our analysis and advertising efforts.
Third Party Advertising Tools
Arbor Village uses Google Analytics and Google Ads and similar types of technologies to display relevant advertisements to users who have previously visited the Site. Referred to as remarketing or retargeting, Arbor Village may utilize previous session information to serve display advertisements to you on the Site and based on such session information Google may set a cookie and serve ads to you on third party websites on the Google Display Network. Third party vendors such as Google may display Arbor Village ads on websites across the Internet. Aggregated user data may be utilized to create remarketing/retargeting “lists,” or groups of users with similar onsite behaviors or demographics. Arbor Village also uses Google tools to display advertisements to users based on their inferred interests and demographics.
Users may learn more about Google’s use of cookies by visiting the Google Privacy and Terms page at http://www.google.com/policies/. You may opt out of being tracked by Google Analytics by i) Turning off cookies in the preferences settings in your browser ii) Downloading the Google Analytics opt-out browser add on available at: https://tools.google.com/dlpage/gaoptout/ iii) Opting out of user interest and demographic categories in the Settings for Google Ads feature to manage or opt out of Google interest based ads at: or iv) Managing cookies used for online advertising across multiple companies at the US-based Network Advertising Initiative at http://www.networkadvertising.org/choices/.
Usage Information
We automatically collect information about your interactions with the Site, including information about the device you use to interact with and/or access the Site, such as: IP address, access dates and times, information about your approximate location (as determined through your IP address), hardware and software information, mobile, computer or hardware device information (e.g., operating system version, Hardware model, IMEI number and other unique device identifiers, MAC address, and device settings), device event information, and crash data. This information allows Arbor Village to understand how you’ve used the Site (which may include administrative and support communications with us or whether you have clicked on links to External Web Sites), and other actions you have taken in connection with your use of the Site. We automatically collect log data when you access and use the Site, even if you have not created an account or logged in.
Aggregate Information
We may collect and track the total number of visitors to the Site, the number of visitors to each page of the Site, External Web Sites (defined below) linked to and other aggregated data collected through our services and we may analyze this data for trends and statistics in the aggregate but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such information for purposes such as analyzing trends, administering the Site, and to understand how users interact with the Site.
Disclosure of Personally Identifiable Information
We may provide your personally identifiable information and the data generated by cookies and third party analytics tools and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our services to you. For example, we engage with G5 Search Marketing, Inc. to assist us in creating and hosting this Site.
We will disclose your personally identifiable information if we reasonably believe we are required to do so by law, regulation or other government authority or to assist in any investigation, to protect our or our users’ rights or to enforce our terms of use. We will not sell your personally identifiable information to any company or organization except we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which Arbor Village participates or to a purchaser of all or substantially all of Arbor Village’s assets to which this Site relates.
Links to Third Party Sites
The Site may provide links to other Web sites or resources over which Arbor Village does not have control (“External Web Sites”). Such links do not constitute an endorsement by Arbor Village of those External Web Sites. You acknowledge that Arbor Village is providing these links to you only as a convenience, and further agree that Arbor Village is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites.
Security
We may employ industry standard procedural and technological measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Arbor Village may use, without limitation, firewalls, password protection, secure socket layer, and other security measures to help prevent unauthorized access to your personally identifiable information.
Privacy Notice for California Residents
Personal Information We Collect
For purposes of this section “personal information” means 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:
- information that is lawfully made available from federal, state, or local government records;
- de-identified or aggregated information; and
- information excluded from the scope of the California Consumer Privacy Act of 2018 (“CCPA”) 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”).
In the last twelve (12) months, we have collected the categories of personal information described in the table below.
[table “1” not found /]Personal Information We Disclose
- Sale of Personal Information
We do not sell personal information.
- Disclosure of Personal Information for Business Purposes
We disclose the following categories of personal information for business purposes: identifiers, biometric information, internet or other similar network activity information, geolocation data, and inferences.
We do not sell personal information on minors under the age of sixteen (16) years of age without affirmative authorization.
Your Rights
If you are a resident of the state(s) identified above, you have specific rights regarding your personal information. This section describes your rights and how to exercise them.
- Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to request that Arbor Village disclose to you what personal information we collect, use, disclose, and sell. You may exercise this right following the methods described under the subsection titled “Exercising Your Rights” below.
- Right to Delete Personal Information
You have the right to request that Arbor Village delete personal information we may hold about you. You may exercise this right following the methods described under the subsection titled “Exercising Your Rights” below. Please be aware that we may not always be able to delete your personal information. For example, there may be business or operational reasons why we need to retain personal information. If we deny your request to delete personal information, we will inform you of the basis for our denial in our response to you.
- Right to Opt-Out of Sale of Personal Information
You have the right to opt out of the sale of your personal information.
Because we do not sell personal information, this right does not apply to Arbor Village
- Right to Non-Discrimination
You have the right to not receive discriminatory treatment from Arbor Village for exercising any of your rights described under this “Your Rights” section. This means we will not treat you differently for exercising any of the rights described above.
Exercising Your Rights
You may exercise each right once every twelve (12) months. To exercise your rights, you must submit a verifiable request to us. To submit a verifiable request, please follow the methods described below:
To verify your request, we will require certain pieces of information. You may designate an authorized agent to submit a request on your behalf. To designate an authorized agent, you may include submitted signed authorization letter. We will respond to your rights request within forty-five (45) days from the date we receive it. In some cases, we may require additional time to complete your request and will inform you if additional time is needed. Where additional time is needed, we may take up to a maximum of ninety (90) additional days to complete your request.
Financial Incentives
Arbor Village does offer financial incentives or price or service differences in exchange for the retention or sale of personal information. Notice of Financial Incentives.
Notice to Users Located Outside the United States
This site and the services on this site are targeted for users in the United States of America only. Any information you enter on this site may be transferred outside your home country to the United States of America, which may not offer an equivalent level of protection to that required by your home country’s data protection laws.
PRIVACY POLICY NOTICE ADDENDUM
I. INTRODUCTION
This Facility is obligated by law to safeguard your PHI and provide you with information regarding our legal duties and privacy practices concerning PHI. The affiliated covered entity, comprising this Facility, its employees, and members of the Seasons Living affiliated covered entity, is collectively committed to adhering to the terms outlined in this notice.
II. PROTECTED HEALTH INFORMATION (PHI)
PHI is information that may identify you and is related to your physical or mental health, provision of health care products and services, or payment for such services. This Notice explains how we may use and disclose PHI and outlines your rights regarding your PHI.
III. NOTICE OF PRIVACY PRACTICES
Use and Disclosure Without Authorization
For Treatment: PHI may be used to provide and coordinate your treatment and services. This includes disclosure to relevant staff and external entities involved in your care.
For Payment: PHI may be used for obtaining payment for services. This involves sharing information with insurance companies and other healthcare entities.
For Health Care Operations: PHI may be used for the facility’s health care operations, including quality assessment and improvement activities.
Other Uses and Disclosures Without Authorization
Business Associates: PHI may be shared with third-party service providers (Business Associates) to perform services on our behalf while ensuring the protection of PHI.
Health Benefits: We may contact you for appointment reminders, treatment information, or other health benefits.
Fundraising: Subject to applicable law, we may contact you for fundraising efforts, providing the option to opt-out.
Directory: Information may be included in the Community Directory unless you request otherwise.
Disclosures to Family, Friends, or Designated Individuals: PHI may be disclosed to individuals involved in your care or payment for your care.
Other Disclosures as Permitted or Required by Law: Various circumstances, such as disaster relief, public health activities, correctional institutions, victims of abuse, and more, may require disclosure without authorization.
IV. AUTHORIZATION REQUIREMENTS
Certain uses or disclosures, such as psychotherapy notes, marketing, and the sale of PHI, require your prior written authorization. Other uses and disclosures not covered in this Notice will also require authorization.
V. YOUR HEALTH INFORMATION RIGHTS
Right to Inspect and Copy: You have the right to inspect and copy your PHI. Requests must be submitted in writing to the Office.
Right to request an Amendment: You may request amendments to your PHI, and if denied, you will receive a written explanation.
Right to Accounting of Disclosures: You can request a list of certain disclosures made of your PHI in the past six years, with the first accounting within a 12-month period provided free of charge.
Right to Request Restrictions: You have the right to request restrictions on the use or disclosure of your PHI.
Right to Request Alternate Communications: You may request communication about your health matters in a specific way or at a certain location.
Right to a Paper Copy of This Notice: You have the right to obtain a paper copy of this Notice, even if you agreed to receive it electronically.
Notification of a Breach: In the event of a breach of your unsecured PHI, you will be notified as required by applicable law.
VI. NOTICE UPDATES
This Facility reserves the right to update this Privacy Policy Notice. Any changes will be posted on our website and made available at our facilities.
For questions about this Notice, please contact the Office.
If you have any questions regarding this Privacy Policy, please contact us by phone at 657-400-3880.