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Privacy Policy

This Privacy Policy was last updated: December 2022

Thank you for visiting Claiborne Senior Living’s (“CSL” or “we”) Internet web site (“Site”)  located at the URL www.theclaiborne.com. This Privacy Policy details certain policies  implemented throughout CSL governing CSL’s collection and use of personally identifiable  information about users of the Site and our services.

1. Privacy Policy Updates

CSL may need to update this Privacy Policy from time to time. If so, CSL will post its updated  Privacy Policy on the Site along with a change notice on the Site. CSL may also send registered  users of our services a notice that this Privacy Policy has been changed. CSL 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.

2. 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, age (our services are designed for senior care and  our facilities may have certain minimum age restrictions (i.e. 55+)), username, password,  address, phone number, and other contact information that you voluntarily transmit with your  communication to us.

3. 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 by email or other means 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.

4. Children’s Privacy

CSL 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. CSL does not target its services or this Site to  children under 16. CSL does not knowingly collect personally identifiable information from  children under the age of 16.

5. 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.

6. Third Party Analytics Tools

Beyond the personally identifiable information you voluntarily provide to us directly, CSL may  utilize 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, may be collected  and aggregated across CSL Site users for our analysis and advertising efforts. 

This site is being monitored by one or more third-party monitoring software(s) and may capture  information about your visit that will help us to improve the quality of our service. You may  control the data being collected from your visit by visiting http://www.onlinewetrak.com/ through a universal consumer options page located at  

https://tracking.onlinewebtrak.com/Unsub/unsub.html

7. Third Party Advertising Tools

CSL may use 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, CSL 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 CSL 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. CSL 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/.

8. 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 CSL 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.

9. 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.

10. 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 may use the information  collected to notify you of changes made to our Site, to send you promotional materials, and to  determine what information and services users want the most. If you contact us for assistance or  support, we may use your information to provide service and support to you. We may also  provide the information to third parties who assist us in contacting customers about special  offers and other services, programs or events that would likely be of interest to you. When you  submit your information, you agree to be contacted by a Claiborne Senior Living  representative at the telephone number you’ve provided, in response to your inquiry, between  the hours of 7AM and 11PM ET. You agree that we may use automatic telephone dialing  systems and technology to contact you by phone or text message at the telephone number  provided, and send you email notifications regarding promotions and related material  on senior living. 

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 CSL participates or to a purchaser of all or substantially  all of CSL’s assets to which this Site relates.

11. Links to Third Party Sites

The Site may provide links to other Web sites or resources over which CSL does not have  control (“External Web Sites”). We are not responsible for the nature, quality or accuracy of the  content or opinions expressed in such External Web Sites, and such External Web Sites are not  investigated, monitored or checked for quality, accuracy or completeness by us. Inclusion of any linked External Web Sites does not imply or express an approval or endorsement of the External  Web Sites by us, or of any of the content, opinions, products or services provided on these  External Web Sites. Even if an affiliation exists between the Site and a third-party web site, we 

exercise no control over linked External Web Sites. You acknowledge that CSL is providing  these links to you only as a convenience, and further agree that CSL 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.

12. 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. CSL may use, without limitation, firewalls, password  protection, secure socket layer, and other security measures to help prevent unauthorized access  to your personally identifiable information. Please note that your email or other electronic  correspondence with us through the Site, like most, if not all, non-encrypted Internet  communications, may be accessed and viewed by other Internet users, without your knowledge  and permission, while in transit to us. For that reason, to protect your privacy, please do not use  email or the contact forms provided through the Site to communicate information to us that you  consider confidential. While we strive to protect your personal information, we cannot ensure or  warrant the security of any information you transmit to us or through the Site, and you do so at  your own risk. Once we receive your transmission, we will use reasonable efforts to ensure its  security on our internal systems. Depending on the nature of the inquiry, your communication  may be discarded or archived. If you wish, you may contact us instead via telephone at the  numbers provided throughout the Site.

13. Consent and Jurisdiction

This Site is controlled, operated and administered entirely within the United States. By using the  Site, you signify your agreement to the terms of this Policy. If you do not agree with this Policy,  please do not disclose any personal information through the Site. This Policy and the use of the  Site are governed by Tennessee law. Any claim related to the Site or this Policy shall be brought  in a federal or state court in Nashville, Tennessee, within one year after the claim arises. Users  of the Site consent to the jurisdiction and venue of such courts as the most convenient and  appropriate for the resolution of disputes concerning this Policy. This Policy and the notices  outlined herein are not intended to and do not create any contractual or other legal rights in or on  behalf of any third party.

13. Privacy Notice for California Residents

This section supplements the information provided in the Privacy Policy above and applies only to visitors and users who are residents of the state of California.

If you have questions or concerns about any of the information provided in this Privacy Notice for California Residents, please contact us using the information provided in the “Contact Us” section of this Privacy Policy below.

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 identified in the third column entitled “Collected” in the table below:

CategoryExamplesCollected
1. Identifiers

Real name (such as first name and last name); alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Yes
2. Customer Records Information

Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Yes
3. Characteristics of protected classifications under California or federal law

Age (other than age of 55+ commiserate with the company’s business), race, color, ancestry, national origin, citizenship, religion or creed, marital or familial status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), medical conditions, political affiliations or activities, status as a victim of domestic violence, assault, or stalking.

No
4. Commercial Information

Records of products or services purchased, personal property, or other purchasing or consuming histories or tendencies.

No
5. Biometric Information

Fingerprints, facial or hand imagery, voice recordings from which an identifier template can be extracted, keystroke patterns, gait patterns, sleep, health, or exercise data.

Yes
6. Internet or other similar network activity information

Browsing history, search history, information regarding consumer’s interaction with a website, application, or advertisement.

Yes
7. Geolocation data

GPS coordinates or other location tracking information.

Yes
8. Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

Yes
9. Professional or employment-related information

Employer, employment history, resumes and CVs, background checks, and other employment-related information.

No
10. Education information

Records maintained by an educational agency or institution that pertain to a student, such as grades and transcripts.

No
11. Inferences

Inferences drawn from any of the categories described above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes

The table below describes the sources for each category of personal information we collect, the business and/or commercial purposes for which we use each category of personal information, and the third parties with whom we share each category of personal information we collect.

  • 1. Identifiers

    Sources:

    • Directly from consumers
    • Website cookies
    • Website analytics providers

    Business or Commercial Purposes:

    • To fulfill specific consumer requests
    • To enhance the website experience
    • For marketing purposes

    Third Parties Shared with:

    • Website providers
    • Analytics providers
    • Advertising providers
    • Telephone service providers
  • 2. Customer Records Information

    Sources:

    • Directly from consumers
    • Website cookies
    • Website analytics providers

    Business or Commercial Purposes:

    • To analyze website traffic
    • For marketing purposes

    Third Parties Shared with:

    • Website providers
    • Analytics providers
    • Advertising providers
  • 3. Biometric Information

    Sources:

    • Website cookies
    • Website analytics providers

    Business or Commercial Purposes:

    • To enhance the website experience
    • For marketing purposes

    Third Parties Shared with:

    • Website providers
    • Advertising providers
  • 4. Internet or other similar network activity information

    Sources:

    • Website cookies
    • Website analytics providers

    Business or Commercial Purposes:

    • To enhance the website experience
    • For marketing purposes

    Third Parties Shared with:

    • Website providers
    • Advertising providers
  • 5. Geolocation Data

    Sources:

    • Directly from consumers
    • Website cookies
    • Website analytics providers
    • Advertising providers

    Business or Commercial Purposes:

    • To enhance the website experience
    • For marketing purposes

    Third Parties Shared with:

    • Website providers
    • Analytics providers
    • Advertising providers
  • 6. Sensory Data and Inferences

    Sources:

    • Advertising providers
    • Website analytics providers

    Business or Commercial Purposes:

    • For marketing purposes

    Third Parties Shared with:

    • Analytics providers
    • Advertising providers

Personal Information We Disclose

  1. Sale of Personal Information

We do not sell personal information.

  1. 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 of 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.

    1. Right to Know About Personal Information Collected and Disclosed

    You have the right to request that CSL disclose to you what personal information we collect, use and disclose. You may exercise this right following the methods described under the subsection titled “Exercising Your Rights” below.

    1. Right to Delete Personal Information

    You have the right to request that CSL 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.

    1. 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 CSL.

    1. Right to Non-Discrimination

    You have the right to not receive discriminatory treatment from CSL 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: Send an email request indicating which right you have chosen to exercise to Quality Connection@TheClaiborne.com.

    To verify your request we may send an email response back to you to confirm your request or ask for clarification if necessary.

    You may designate an authorized agent to submit a request on your behalf. To designate an authorized agent you must email a signed authorization letter to QualityConnection@TheClaiborne.com.

    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

    CSL does not offer financial incentives or price or service differences in exchange for the retention or sale of personal information.

    14. Notice to Users Located Outside of 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 of your home country to the United States of America, which may not offer an equivalent level of protection to that required of your home country’s data protection laws.

    Contact Us

    If you have any questions regarding this Privacy Policy please contact us via email at QualityConnection@theclaiborne.com or by phone at 1-844-971-0025.