Erickson Senior Living Privacy Policy—California Residents

Last modified: April 20, 2023

About This Policy

Erickson Senior Living Management, LLC, as agent for each Community (as defined below) ("Erickson Senior Living," "Erickson," "we," "us," or "our"), provides this privacy policy (“Policy”) to describe how we collect, use, and share the information of individuals who visit our website www.ericksonseniorliving.com, the MyErickson app, and any other websites or apps that link to this Privacy Notice ("Site"). This Policy also applies to information we collect about you through offline channels such as visits to our communities, telephone calls, emails, or through our authorized services providers. As used herein, "Community" means each Erickson managed-branded continuing care retirement community.

Please read this Policy carefully before using the Site or otherwise submitting personal information to us. By accessing or visiting the Site, or providing your personal information, you indicate your understanding that the collection, use, disclosure, and retention of your personal information is subject to the terms of this Policy and our Terms of Use. Except as otherwise noted, any capitalized terms not defined in the Policy have the meaning set forth in the Terms of Use.

If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this Policy, please do not provide us with such information.

Personal Information We Collect

You may voluntarily submit information including your name, address, email address, phone number, and any other information you choose to provide when using our Site, subscribing to our mailing list, requesting a good or service, contacting us, or interacting with us for any other purpose.

If you apply for a job through the Site, we will collect any information you provide in your application, including but not limited to, educational background, employment history, and references.

If you visit one of our communities or are a resident, we may collect information related to your visit or residence.  

If you choose to make a purchase with us, we (or our third-party processor) will collect your payment card or other purchasing information.

We collect information through cookies and similar technology relating to your interactions with us and our Site, including your IP address, browser type, domain names, access times and referring website addresses.

From time to time, Erickson Senior Living may send surveys requesting your interest in health care services or educational programs about health care services. If you choose to respond, this information may include disclosure of health information. This information is collected only on behalf of your local Erickson Senior Living managed community and maintained by that community. Please visit our HIPAA page to see the notice of privacy practices concerning your protected health information for each community.

We may also collect anonymous demographic information, such as age, gender, preferences, interests, and favorites.

As described below, we may collect or have collected the following categories of personal information (“PI” or “personal information”) in the preceding 12 months. We may add to the categories of PI we collect and the purpose(s) we collect and use it. In those cases, we will inform and update this section of the Policy.

Identifiers

– such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, or other similar identifiers.

Other elements

– such as name, signature, characteristics or description, address, telephone number, education, bank account number, credit card number.

Characteristics of protected classifications under California or federal law

– such as race, religion, and age.

Commercial information

– such as products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Education information

– such as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).

Internet or other electronic network activity

– such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.

Geolocation data

– such as location information while using one of our apps.

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

– such as identifiable information obtained about you from voicemail messages, while speaking with our service representatives, including on the telephone, and captured by video cameras.

Professional or employment-related information

– such as information on job applications, information needed during onboarding for payroll and benefits, and information needed for evaluating performance.

Consumer profile

– such as inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.

Sensitive information

– information that includes

• a Social Security, driver’s license, state identification card, or passport number;
• account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
• precise geolocation;
• racial or ethnic origin;
• religious or philosophical beliefs;
• union membership;
• contents of mail, email, and text messages unless we are the intended recipient of the communication;
• genetic data;
• biometric information;
• health information; and
• information regarding sex life or sexual orientation.

Personal information does not include publicly available information from government records and deidentified or aggregated consumer information.

How Long We Retain Your Information

We retain your personal information for as long as necessary to provide you products and services, while you have an open account with us, etc. and in accordance with the Company’s data retention schedule, unless we have or deidentified or deleted your personal information in response to a request to delete. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, collect fees, etc. or as permitted or required by applicable law.

We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; applicable legal requirements. 

Business or Commercial Purposes for Which We Collect or Disclose Your Information

In general, we will use the personal information we collect about you only for the purpose it was collected or compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, with your consent or as otherwise provided in this Policy. For example, we may use your personal information in the following ways:

To Operate Our Site, Facilities or Services. We may use your personal information to monitor, administer, improve, safeguard, and enable use of the Site, services, facilities, and communities.

For Internal Use. We may use your personal information to operate our business. This may include contract management, IT and website administration and security, fulfillment, analytics, fraud prevention, corporate governance, reporting, and legal compliance; to enforce our rights including those arising from any contracts entered into with you including for billing, payment, and collections; for testing, research, analytics, and product and service development; for employee training; and to process applications for employment, as well as to evaluate and improve our recruiting efforts.

To Communicate With You. We may use your personal information to communicate with you, including responding to your inquiries, sending messages about the availability of our Site, security, or other product, service-related or community issues. (You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.) We may also send you administrative or account-related information to keep you updated about your account and the Site. Such communications may include information about Policy updates, confirmations of your account actions or transactions, security updates or tips, or other relevant transaction-related information. Site-related communications are not promotional in nature.

To Provide Support Services. We may use your personal information to provide support to Site visitors or client/customer/residents, or to engage in quality control activities concerning our products, services and communities.

To Enforce Compliance With Our Terms and Agreements or Policies. When you access or use our Site, you are bound to our Terms of Use and this Policy. To ensure compliance, we may process your personal information in connection with monitoring, investigating, preventing, and mitigating prohibited, illicit or illegal activities on our Site. We may also process your personal information to investigate, prevent or mitigate violations of our internal terms, agreements, or policies; enforce our agreements with third parties and business partners; and for other purposes related to the services we provide to you, operation of our business, or your application for or employment with us.

To Ensure the Security of the Site and Our Communities. We may process your personal information as necessary or appropriate to protect the rights, property, security, and safety of our employees, applicants, visitors, customers/clients, residents, the Site, our information systems, and the public.

To Maintain Legal and Regulatory Compliance. Our business is subject to certain laws and regulations which may require us to process your personal information. We may use your personal information to respond to law enforcement requests, as required by applicable law, court order, or governmental regulations, and for other lawful processes or public safety purposes.

To Engage in Marketing Activities. We may use your information to send surveys, promotions, and marketing materials that may be of interest to you, keep you updated about the Site, and our business and communities; provide you with information about events or other materials; and deliver targeted marketing to you.

Other Purposes. We may use your personal information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Sources of Information

We may collect your personal information from the following sources:

You

When you interact with us, including through our Site, by email or phone, and at our locations, events or, programs. When you visit our Site, we also collect information through online tracking tools, such as browser cookies, flash cookies, and web beacons. We collect information you provide as an applicant for employment or during your employment with us.

Related entities and affiliates

We may collect information about you from our affiliates and other related parties including joint ventures.

Service providers and contractors

We may collect your personal information from service providers or contractors who collect information about you to provide products or services on our behalf or in connection with your application for or employment with us.

News outlets, social media, surveys, and certain third parties

In the course of providing products and services or marketing activities, or in connection with your application for or employment with us, we or third parties on our behalf may conduct research and other activities resulting in the collection of information about you. We may also collect information from relatives or other individuals involved in your care or residence in one of our communities.

Information collected automatically

As you navigate through and interact with our Site, we may compile statistical information concerning your usage of the Site through analytics services, such as those provided by Google Analytics. To do so, we may collect certain information about your equipment, browsing actions, and patterns.

Cookies, Tracking, and Certain Communications

We use cookies and other web technologies to collect and store certain types of information when you visit the Site. A cookie is a small file consisting of letters and numbers that automatically collects certain information from you. This file uniquely identifies and recognizes your browser or device and transmits information back to the server. Depending on the cookie type, it may perform functions such as remembering your user preferences, improving the quality of your visit, recording the website pages you view, remembering the name or address you entered during a visit, or delivering ads that are targeted to your interests and browsing activity.

Types of Cookies

First and Third Party Cookies. First party cookies are generally placed on your computer or device by the website you are visiting. For example, we may use a first party cookie to improve website security. Third party cookies are placed on your computer or device by a source other than the website you are visiting in order to enable third-party features such as advertising, analytics, videos, or interactive content.

Essential or Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually set in response to actions taken by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. These cookies do not store any personally identifiable information.

Performance and Functionality Cookies. Although these are non-essential cookies, they help the website perform and function as designed. For example, performance and functionality cookies may help the website display videos, enable chat sessions, or recognize whether you visited the website before.

Analytics Cookies. These cookies track your usage of the website. The information these cookies collect can be used for various purposes such as understanding how visitors use the website, site and content customization, or advertising and marketing.

Advertising Cookies. Advertising and marketing cookies perform functions such as helping customize your website experience, personalizing ads based on your online activities and interests, measuring the effectiveness of ads, preventing an ad from reappearing, and serving you targeted advertisements. Information from these cookies may be disclosed to third parties or third parties may place these cookies on your computer or device. Advertising and marketing cookies may track your online activities.

The Site uses essential, functional, and performance cookies to function and perform as designed; analytics cookies to understand how you use the Site, improve its functionality, and related purposes; and advertising cookies to help us with our advertising and marketing activities. We and our third-party partners and service providers may collect and track information about your online activities over time and across different websites, applications, and devices.

Web beacons. Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to perform functions such as count users who have visited those pages or opened an email and for other related Site statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Digital advertising analytics. We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Site and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

We may also work with third parties that collect data about your use of the Site and other sites or apps over time for non-advertising purposes. These analytical tools will place cookies or other tracking technology on your computer or device to collect information that may include

• Details of your visits to our Site, such as traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, and the website that referred you to our Site.
• Information about your preferences to make your use of the Site more productive, via the use of Cookies.

While all this information can be associated with the IP address your computer had while you visited the Site, it will not be associated with you as an individual or with any other information you may submit through the Site or that we may store about you for any other purposes. We may use this information to generate aggregate statistics about visitors to our Site.

Erickson uses Google Analytics and other third-party services to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit https://www.google.com/policies/privacy/partners/, and to opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/

Embedded content. The Site contains embedded content (e.g., videos) which may place third party cookies on your device that track your online activity to enhance your experience or assess the success of their application. We have no direct control over the information these third party cookies collect, and you should refer to their website privacy policy for additional information.

Third-Party Links, Tools, and Social Media

The Site may provide links to third-party websites or apps, including our social media pages. We do not control the privacy practices of those websites or apps, and they are not covered by this privacy notice. You should review the privacy notices of other websites or apps that you use to learn about their data practices.

The Site may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Site, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third-party companies and your use of their features are governed by the privacy notices of the companies that provide those features. We encourage you to carefully read the privacy notices of any accounts you create and use.

Controlling Cookies

You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. Most browsers will allow you to block or refuse cookies. However, you may need to manually adjust your preferences each time you visit a site. For more information, see the Help section of your browser. Please note that if you block certain cookies, some of the services and functionalities of our Site may not work.

Do Not Track

“Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Site is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests. We track individual consumer’s online activities over time and across different Internet websites or online services when the consumer uses our Site.

Disclosures of Personal Information

In general, we will not disclose your personal information except with your consent and as described in this Policy. We may disclose your personal information for the same reasons that we may use it, as described in this Policy, which includes disclosing it to our affiliates and non-affiliates as we deem necessary to carry out those purposes. We endeavor to choose affiliates and non-affiliates whose standards for the protection of data match ours.  

The following chart describes the categories of personal information we have collected or may collect about you and the categories of third parties to whom we may disclose or have disclosed the information in the preceding twelve months. We may share information that has been anonymized or aggregated without limitation.

We do not share your personal data with any third-party advertisers for their advertising.

Categories of Personal Information	Categories of Third Parties to Whom Disclosed & Purposes for Disclosure
identifiers and contact information – such as name, postal address, email address, phone number, account name, date of birth, Social Security number, driver’s license number, photograph, passport number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers	Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose your personal information to one of our business partners for collaborating on providing services to you. Services providers. For example, we may disclose information to certain service providers or agents that perform activities for us, such as those used to help us perform statistical analysis, provide payment services, send you email or postal mail, provide customer support, arrange for deliveries, marketing and advertising companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. Third parties as necessary to comply with federal, state, or local laws; comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; detect, investigate and prevent fraud or other unlawful activities; protect and defend ourselves, our property, our employees, our customers, and our users; and exercise or defend legal claims. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Internet or other electronic network activity – such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement NOTE: The information in this category may include the following elements of Sensitive Personal Information: the contents of mail, email, or text messages, to which the business was not the intended recipient.	Third parties as directed by you. We may disclose your personal information to third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. Services providers. For example, we may disclose information to certain service providers or agents that perform activities for us, such as those used to help us perform statistical analysis, provide payment services, send you email or postal mail, provide customer support, arrange for deliveries, marketing and advertising companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. Third parties as necessary to comply with federal, state, or local laws; comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; detect, investigate and prevent fraud or other unlawful activities; protect and defend ourselves, our property, our employees, our customers, and our users; and exercise or defend legal claims. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Audio, electronic, visual, thermal, olfactory, or similar information.	Third parties as directed by you. We may disclose personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. Services providers. For example, we may disclose information to certain service providers or agents that perform activities for us, such as those used to help us perform statistical analysis, provide payment services, send you email or postal mail, provide customer support, arrange for deliveries, marketing and advertising companies, professional service providers, debt collectors, information technology providers, payroll and benefits managers, and data storage companies. Third parties as necessary to comply with federal, state, or local laws; comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; detect, investigate and prevent fraud or other unlawful activities; protect and defend ourselves, our property, our employees, our customers, and our users; and exercise or defend legal claims. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Professional and employment-related information. This category includes, without limitation, information regarding job applications, information related to onboarding for payroll and benefits, and information needed for evaluating performance.	Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. Services providers. For example, we may disclose information to certain service providers or agents that perform activities for us. We might also authorize our service providers to collect personal information on our behalf. Third parties as necessary to comply with federal, state, or local laws; comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; detect, investigate and prevent fraud or other unlawful activities; protect and defend ourselves, our property, our employees, our customers, and our users; and exercise or defend legal claims. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Inferences drawn from personal information – such as individual profiles, preferences, characteristics, behaviors or other similar identifiers NOTE: The information in this category may include the following elements of Sensitive Personal Information: racial or ethnic origin, religious or philosophical beliefs, union membership, health information, genetic information, and/or information regarding an individual’s sex life or sexual orientation.	Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct. Our business partners. For example, we might disclose personal information to one of our business partners for purposes of collaborating on providing products or services to you, or to invite you to an event we are organizing. Services providers. For example, we may disclose information to certain service providers or agents that perform activities for us. We might also authorize our service providers to collect personal information on our behalf. Third parties as necessary to comply with federal, state, or local laws; comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; detect, investigate and prevent fraud or other unlawful activities; protect and defend ourselves, our property, our employees, our customers, and our users; and exercise or defend legal claims. Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

Your Choices

You have the right to limit the information you provide us.  If you choose not to provide us certain information, we may be unable to provide you access to certain parts of our Site, services, or communities.

To opt-out of our email marketing, you can use the link provided at the bottom of each marketing message. You may also opt-out or unsubscribe from future emails by sending a request to [email protected] using the subject line "Unsubscribe from email communications." To ensure your opt-out request is properly processed, be sure to send your message using the same email account to which we sent our correspondence.

Accessing Your Account Information

In the event you set up an account with Erickson, you can access, review, correct and/or delete the personal information saved in your account. You may also ask us to assist by emailing us at [email protected].

Third Party Website Links

Some portions of our Site may contain links to other websites on the Internet that are neither under our control nor maintained by us. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that we are providing these links to you only as a convenience, and you agree that we are not responsible for the content of such websites. Your use of these other linked websites is subject to the terms of use and privacy policies located on the linked websites.

Email and SMS Communications

We may collect your email address via cookies and pixels on the Site through the use of trusted third-party partners. These partners may combine your email information with other information they have access to such as mailing address so that we may send relevant marketing offers to you via direct mail.

You may elect to receive text messages from us. When you sign up to receive text messages, we will send you information about promotional offers and more. These messages may use information automatically collected based on your actions while on our Sites and may prompt messaging such as cart abandon messages. To the extent you voluntarily opt to have SMS notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number or when you read a text message. You may opt out of receiving text messages at any time by texting “STOP” to our text messages.

Our Sites and Children

Our Site is not intended for children under the age of 16. We do not knowingly collect personal information on individuals under the age of 16. If you believe personal information was provided to us by someone under 16, please contact us immediately at [email protected].

Security

We take precautions to protect data and information under our control from misuse, loss or alteration. Our security measures include industry-standard physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal information. However, no system for safeguarding personal or other information is 100% secure and, although we have taken steps to protect your personal information from being intercepted, accessed, used, or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal information.

Please note that protecting your personal information is also your responsibility. We ask you to be responsible for safeguarding the password, security questions and answers, and other authentication information you use to access our Site.

Applicable law

This Policy is governed by the laws of the State of Maryland, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the state and federal courts within Maryland. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.

Notice to Site Users Located Outside the U.S.

The Company operates in accordance with the laws of the U.S. When you access our Site from outside the U.S., we may transfer the information we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this Site, you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the U.S.

Changes to This Policy

We reserve the right, at our sole discretion, to change, modify, add, or remove portions of this Policy at any time. If this Policy changes in the future, we will let you know by posting the updated policy on our Site with the most recent modification date. Please check the Site periodically for changes. Your continued use of our Site means you acknowledge and understand our current and updated Policy.

Accessibility

Persons with disabilities may obtain this notice in alternative format upon request using the contact information below. 

Contact Us

If you have questions, you can contact us by

• Emailing [email protected]
• Submitting our Contact Us form
• Calling us at 1-877-640-8155
• Mailing us at Erickson Senior Living, 701 Maiden Choice Lane, Catonsville, MD 21228

California Residents

This section supplements and amends the information contained in the Policy with respect to California residents. The other provisions of the Policy continue to apply, except as modified in this California section.

Shine the Light

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of the Company to third parties for the third parties’ direct marketing purposes. Requests may be made one time per calendar year. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we disclosed customer information for the immediately prior calendar year (e.g., requests made in 2022 will receive information regarding 2021 sharing activities). You may submit your request using the contact information in this Policy.

California Consumer Privacy Act (“CCPA”)

This CCPA section describes our policies and practices regarding the collection, use, and disclosure of personal information we obtain about California residents through online (i.e., the Site) and offline channels (e.g., phone and email conversations, when you visit our locations or attend our events, or through our authorized services providers).

Any terms defined in the CCPA have the same meaning when utilized in this section. All other provisions of the Policy continue to apply except as modified herein. Please read this section carefully before using the Site or otherwise submitting information to us. By accessing or visiting the Site, or submitting personal information to us, you indicate your understanding that the collection, use, and sharing of your information is subject to the Policy, terms of this section and our Terms of Use.

Business or Commercial Purpose for Selling or Sharing Personal Information. We may sell or share your personal information, and/or have sold or shared your personal information in the preceding 12 months, to the following categories of third parties for the purposes listed below. Under the CCPA, “selling” means an exchange of personal information for monetary or other valuable consideration. “Sharing” means making available a consumer’s personal information to a third party for cross-context behavior advertising, whether or not for monetary or other valuable consideration.

We do not have actual knowledge that we have sold or shared the personal information of minors under the age of 16.

Consumer Rights

California residents have the following rights with respect to the personal information we collect about them. Exceptions may apply.

Right to Know About Personal Information Collected or Disclosed. The Policy discloses our current practices as they relate to how we collect, use and disclose personal information. As a California resident, you have the right to request that we disclose additional information as it relates to our data collection activities during the preceding 12 months. To the extent applicable, you have the right to know:

• the categories of personal information we have collected about you
• the categories of sources from which we collected the personal information
• the business or commercial purpose for collecting, selling, or sharing personal information, if applicable
• the categories of personal information we sold or disclosed for a business purpose
• the categories of third parties to whom we sold or disclosed personal information
• the specific pieces of personal information we have collected about you

Upon receipt of a verifiable consumer request and as required by the CCPA, we will provide a response to your requests. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to personal information collected on and after January 1, 2022, and to the extent expressly required by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not require a disproportionate effort by us.

Right to Delete. You have the right to request that we delete personal information we collected or maintain about you, subject to certain exceptions. Upon receipt of a verifiable request, we will delete and direct any service providers, contractors and third parties to whom we disclosed your personal information, to delete your personal information.

We are not required to comply with deletion requests if we, or our service providers, contractors, or third parties need the subject information in order to:

• Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between the Company and you.
• Help to ensure security and integrity to the extent the use of the consumer's PI is reasonably necessary and proportionate for those purposes.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when the Company's deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
• Comply with a legal obligation.
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Request Correction. You have the right, subject to certain limitations, to request that we correct any inaccurate personal information we maintain about you. Upon receipt of a verifiable consumer request, and as required by the CCPA, we will take appropriate steps to respond to your request.

Right to Opt Out of Having Your Information Sold or Shared. You have the right, subject to certain limitations, to opt-out of having your personal information sold or shared. You may exercise this right by sending an email to [email protected].

Right to Limit the Use of Sensitive Personal Information. In certain circumstances, you have the right to limit our use of the sensitive personal information we collect about you. You may exercise this right by sending an email to [email protected].

Right to Non-Discrimination for the Exercise of Privacy Rights. We will not discriminate against you for exercising any of your rights under the CCPA. This includes but is not limited to: (A) denying you goods or services; (B) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (C) providing you with a different level or quality of goods or services; or (D) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Employees, applicants, and independent contractors have the right not to be retaliated against for exercising any of their rights under the CCPA.

Submitting Consumer Rights Requests

How to submit. To submit a California consumer rights request, please contact us at:

[email protected]

Verifiable Requests. We reserve the right to only respond to verifiable consumer requests to Know, Delete, or Correct. A verifiable consumer request is one made by any individual who is:

• the consumer who is the subject of the request,
• a consumer on behalf of the consumer’s minor child, or
• the authorized agent of the consumer.

To verify your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information which we will only use to verify your identity, and for security or fraud-prevention purposes. Making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. 

Authorized agents.You may authorize a natural person or a business (the Agent) to submit a request on your behalf. The Agent must provide signed permission to submit the request, and you must either (i) verify your own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. These steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

Our response. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Fees. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.

Contact Us

If you have questions, you can contact us by

• Emailing [email protected]
• Submitting our Contact Us form
• Calling us at 1-877-640-8155
• Mailing us at Erickson Senior Living, 701 Maiden Choice Lane, Catonsville, MD 21228