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
Categories of third parties with which the PI is shared, if shared
IdentifiersThis 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.
Service Providers (e.g., customer service agencies, marketing firms, data analytics firms, referral agency(ies)), healthcare providers, banking partners, External Auditors, Government Entities.
Customer / Individual RecordsThis 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.
Service Providers (e.g., customer service agencies, marketing firms, data analytics firms), healthcare providers, referral agency(ies), banking partners, External Auditors, Government Entities.
Protected CharacteristicsThis 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.
Service Providers, External Auditors and Government Entities.
Commercial Information / Purchase DetailsThis 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.Business Partners (e.g., banking partners offering financing), External Auditors and Government Entities.
Internet Usage InformationThis 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.
Service Providers (e.g., website hosts).
Geolocation DataThis 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.
Service Providers (e.g., website hosts, marketing agencies).
Sensory DataThis 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.
Service Providers (e.g., customer service / video or call recording agency).
Inferences from PI CollectedThis 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.
Service Providers (marketing firms, referral agency(ies)).

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 877-837-3717. 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 877-837-3717, or write to us at: Integral Senior Living, Attention: Privacy Inquiry, 2333 State Street, Suite 300, Carlsbad, CA 92008.