Clearwater Living Privacy Policy

Thank you for visiting Clearwater Living’s Internet web site located at the URL https://www.clearwaterliving.com/. This Privacy Policy details certain policies implemented throughout CLIENT’s website governing CLIENT's collection and use of personally identifiable information about users of our Site and our services.

 

PART I – OVERVIEW OF CALIFORNIA CONSUMER PRIVACY LAWS

This California Privacy Policy applies only to California residents (“you” or collectively “consumers”) and supplements the Privacy Policy of Clearwater Senior Living, LLC and any of its subsidiaries (collectively, “Clearwater,” “we,” “us,” or “our”). The California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), collectively referred to as “California Consumer Privacy Laws,” provide California consumers with specific rights regarding their personal information. This Privacy Policy describes your rights as a California consumer under the California Consumer Privacy Laws, explains how you may exercise your rights, and provides an overview on the types of personal information we collect.

Your Rights Under California Consumer Privacy Laws and this Privacy Policy

California Consumer Privacy Laws provide you with the following rights:

  • Right to know. You have the right to know what categories and what specific pieces of personal information we collect about you, the sources from which we collect it, and our business or commercial purpose for doing so.  You also have the right to know how we use and share your personal information, and to know any categories of third parties with whom we share your information.
  • Right to delete. You have the right to request that we delete the personal information that we collect about you.
  • Right to opt out. You have the right to opt out of the sale or sharing of personal information.  If we were to sell any of your personal information, you would have the right, at any time, to tell us not to do so.  At the time this Privacy Policy was last updated, we do not sell any personal information.  You also have the right to request that we do not share your personal information.  You can make this request by clicking a separate link on our website titled “Do Not Share My Personal Information/Limit the Use of My Sensitive Personal Information.”
  • Right to correct.  You have the right to request the correction of any personal information that we maintain about you.
  • Right to limit use or disclosure of sensitive personal information (SPI).  You have the right to limit the use or disclosure of your SPI, if we are using your SPI beyond what is reasonable and proportionate to provide requested goods or services.  You can make a request for us to limit the use or disclosure of your SPI by clicking a separate link on our website titled “Do Not Share My Personal Information/Limit the Use of My Sensitive Personal Information.”
  • Right to nondiscrimination.  We will not discriminate against you if you exercise any of your privacy rights.

California Consumer Privacy Laws allow you to request your information from us up to twice during a twelve (12) month period.  We will provide our response in a readily usable format, which is usually electronic.  If you have any questions, please contact us as set forth below.

How to Contact Us About Your Privacy Rights

Ways to Contact Us. If you would like to exercise your privacy, please contact us through any of the following:

Verification of Your Identity. To protect your privacy, we will ask you to verify your identity in the event that you contact us .  This will involve confirming your name, email address, telephone number and other information.  We will not comply with any privacy requests until we can reasonably confirm your identity.

Our Response Time to Your Request

  • Response Time. We will respond to your request within forty five (45) calendar days from when you contacted us.
  • Response Time for Complex Requests. If you have a complex request, the California Consumer Privacy Laws allow us up to ninety (90) calendar days to respond. We will still contact you within forty five (45) calendar days from when you contacted us to let you know we need more time to respond.

We provide more detailed information below about your specific rights under the California Consumer Privacy Laws.

PART II – DETAILED EXPLANATION OF CONSUMER RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY LAWS

Right to Know About Personal Information Collected, Used, or Disclosed

  • Your Right to Know. You have the right to know what personal information we collect, use, or disclose.
  • How Long We Retain Your Information.  We will retain your information as long as it is reasonably necessary for each disclosed purpose, as outlined in the tables below.  If you have any questions or would like to exercise any privacy rights, please contact us.
  • Response Contents. Our response is based on your request.  Depending on your request, our response may include the following information:
    • Categories of personal information that we collected about you.
    • The specific pieces of personal information that we collected.
    • The categories of the sources of the personal information that we collected.
    • Our business or commercial purpose for collecting your personal information.
    • Any third parties with whom we shared your personal information.

Right to Request Deletion of Personal Information

  • Your Right to Deletion. You have the right to ask us to delete any personal information about you that we have collected and shared.
  • Information We May Keep. The California Consumer Privacy Laws allow us to keep personal information that we need in order to provide you with goods and services; to ensure the security and integrity of the information; to fix any errors; to exercise free speech; to use your information lawfully for our internal purposes; and to comply with the law.

Right to Opt-Out of the Sale or Sharing of Personal Information

  • Your Right to Opt-Out. If we sell or share any of your personal information, you have the right, at any time, to tell us to stop.  At the time this Privacy Policy was last updated, we do not sell any personal information.

Right to Correct Personal Information

  • Your Right to Correct.  You have the right to request the correction of any inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of processing it.  We will use commercially reasonable efforts to correct any inaccurate personal information that you call to our attention.

Right to Limit Use or Disclosure of Sensitive Personal Information (“SPI”)

  • Sensitive Personal Information.  SPI means personal information that reveals:
    • A consumer’s social security, driver’s license, state identification card, or passport number.
    • A consumer’s 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.
    • A consumer’s precise geolocation.
    • A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
    • The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.
    • A consumer’s genetic data.

SPI also includes personal information that is:

  • Involved in processing  biometric information for the purpose of uniquely identifying a consumer.
  • Collected and analyzed concerning a consumer’s health.
  • Collected and analyzed concerning a consumer’s sex life or sexual orientation.
  • SPI We Collect.  Typically, we collect SPI only to determine whether we are able to provide care to a resident or prospective resident or as a part of our ongoing care services for residents.  We use SPI in a reasonable and proportionate manner in order to provide a resident with the appropriate level of care.
  • Your Rights Regarding SPI.  You have the right to limit the use and disclosure of your SPI, if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services.  Please see the Tables “Categories of Personal Information” and “How We Use Your Personal Information” for more details about our practices around SPI and your rights related to SPI.

Right to Non-Discrimination for Exercising Your Privacy Rights

  • Our Non-Discrimination Policy.  We will not discriminate against you if you choose to exercise any of your privacy rights.

Asking Others to Exercise Your Privacy Rights

  • Authorized Agent. The California Consumer Privacy Laws allow you to ask someone else to exercise your privacy rights for you. This person is your “Authorized Agent.” Before we will share anything with your Authorized Agent, we will need receive your written permission or other proof, such as a valid Power of Attorney.  Please contact us if you would like us to know who your Authorized Agent is.
  • Verifying the Identity of Your Authorized Agent. Once we have your written permission, we will also ask your Authorized Agent to verify their identity with us directly.
  • Protecting Your Privacy. We will not share any of your information unless we have both your written permission and have verified the identity of your Authorized Agent.

Part III – Our Information Collection Practices

 

Information Collection and Use

 

  • Sources of Information.  During our interactions, we may request that you provide us with personal information, such as your name, email, and/or telephone number.  In addition to any personal information that you voluntarily provide to us, our website and other websites may collect your personal information through the use of cookies and other third-party analytics or advertising tools.  Please refer to the sections below on “Cookies,” “Third Party Analytics Tools,” and “Third Party Advertising Tools.”
  • Information Use.  We may use your personal information to provide you with services or with material that you have requested; verify that you are a resident or a prospective resident; send you information that you have signed up to receive, such as notices about our services; and improve the content of our website and our services.
  • Cookies.  We use both session ID cookies and persistent cookies.
    • A session ID cookie expires when you close your browser.  We use session ID cookies to make it easier for you to navigate our website and to improve our website.
    • A persistent cookie remains on your hard drive for an extended period of time.  Persistent cookies allow us to track, store, and target the interests or our users in order to enhance and improve our website.  You can remove persistent cookies by following the directions of your Internet browser.
    • If you reject cookies, you may still use our website.  However, in some areas, your use may be limited.
  • Third Party Analytics Tools.  In addition to the information you voluntarily provide to us, we utilize analytics tools, such as Google Analytics, to collect information for our analysis and advertising efforts.  The analytics tools collect certain types of personal information, such as geolocation, website usage and behavior, and device type.
  • Third Party Advertising Tools.  We also use third party advertising tools, such as Google Analytics, Google Ads, Facebook, or other similar types of tools, in order to display advertisements to consumers who have previously visited our website or who may be interested in our services.
    • This type of advertising is referred to as remarketing or retargeting.  Our remarketing and retargeting activities may use sessions ID and persistent cookies to assist our advertising efforts.
    • We may use aggregated consumer data to create “lists” or groups of consumers with similar online behaviors or demographics.
    • We use third party advertising tools to display advertisements to consumers based on their inferred interests and demographics.
    • You can learn more about the use of cookies by clicking on links in the websites of third party advertising tools like Facebook and Google.  This includes the ability to opt out of being tracked by these tools.

Personal Information We Collect

 

The California Consumer Privacy Laws define personal information as 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 California Consumer Privacy Laws 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”).

To help consumers make informed privacy decisions, the California Consumer Privacy Laws create and define categories of personal information.  Some types of personal information may apply to multiple categories.  We collect the categories of personal information described in Table 1 below.  Depending on your level of interaction with us, we may not have collected your personal information from all of the categories.

Table 1: Categories of Personal Information

 

Category

Examples

Collected

1. Identifiers

Name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, device, browser, email address, account name, or other similar identifiers.

Yes

 

2. Customer records information

Name, signature, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, or other similar 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, race, color, ancestry, national origin, citizenship, religion or creed, marital or familial status, medical condition, physical or mental disability, sex, veteran or military status, genetic information, and other similar information.

Yes

4. Commercial information

Records of products or services purchased; purchasing or consuming histories or tendencies.

Yes

5. Biometric information

Fingerprints, facial or hand imagery, or voice recordings. 

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, or similar information.

Yes

9. Professional or employment-related information

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

Yes

 

10. Education information

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

Yes

11. Sensitive personal information (“SPI”)

Social security number, driver’s license, state identification number, passport number, financial information, race, personal information collected and analyzed concerning health, or other similar information.

We do not collect this information for general marketing purposes. 

 

However, we collect SPI to provide care for our residents.

12. Inferences

Inferences drawn from any of the categories described above to create a profile about a consumer reflecting the consumer’s preferences and characteristics.

Yes

 

 

Table 2 below describes the sources for each category of personal information we collect, the business or commercial purposes for which we use each category of personal information, and the third parties with whom we may share your personal information with. 

 

Table 2: How We Use Your Personal Information

 

Category

Sources

Business or Commercial Purposes

Third Parties Shared With

1. Identifiers

  • Directly from consumers
  • Website cookies
  • Website analytics providers

 

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

 

  • Website providers
  • Analytics providers
  • Advertising providers
  • Telephone service providers

 

2. Customer records information

  • Directly from consumers
  • Website cookies
  • Website analytics providers
  • To fulfill specific consumer requests
  • To enhance the website experience
  • For marketing and analysis
  • Website providers
  • Analytics providers
  • Advertising providers
  • Telephone service providers

3. Characteristics of protected classifications under California or federal law

  • Directly from consumers
  • Website cookies
  • Website analytics providers
  • To fulfill specific consumer requests
  • To enhance the website experience
  • For marketing and analysis
  • Website providers
  • Analytics providers
  • Advertising providers
  • Telephone service providers

4. Commercial information

  • Directly from consumers
  • Website cookies
  • Website analytics providers
  • To fulfill specific consumer requests
  • To enhance the website experience
  • For marketing and analysis
  • Website providers
  • Analytics providers
  • Advertising providers
  • Telephone service providers

5. Biometric information

  • Telephone calls
  • To fulfill your requests
  • For internal training
  • For marketing and analysis
  • Telephone service providers
  • Analytics providers

6. Internet or other similar network activity information

  • Website cookies
  • Website analytics providers
  • To enhance the website experience
  • For marketing and analysis
  • Website providers
  • Advertising providers

7. Geolocation data

  • Directly from consumers
  • Website Cookies
  • Website analytics providers
  • Advertising providers
  • To analyze website traffic
  • For marketing and analysis
  • Website providers
  • Analytics providers
  • Advertising providers

8. Sensory data

  • Telephone calls
  • To fulfill your requests
  • For internal training
  • For marketing and analysis
  • Telephone service providers
  • Analytics providers
  • Advertising providers

9. Professional or employment-related information

  • Directly from consumers
  • To fulfill specific consumer requests
  • To enhance the website experience
  • For marketing and analysis
  • Website providers
  • Analytics providers

10. Education information

  • Directly from consumers
  • To fulfill specific consumer requests
  • For marketing and analysis
  • Website providers
  • Analytics providers

 

11. Sensitive personal information

  • Directly from consumers
  • To provide care for our residents
  • Vendors who are participating in the care of our residents

12. Inferences

  • Website analytics providers
  • Advertising providers
  • For marketing and analysis
  • Analytics providers
  • Advertising providers

 

If you have specific questions about the information we collect about you or would like to exercise any of your privacy rights, please let us know.  Please see the section “How to Contact Us About Your Privacy Rights” for the different ways you can contact us. 

 

Last Updated: December 8, 2022

 

Questions/consumer-personal-information-requests

If you have any questions regarding this Privacy Policy please contact us.

Requests Regarding Personal Information

This Privacy Policy was last updated: 2023-01-30 15:41:12 -0800

This Privacy Policy is effective as of: 2021-06-28 09:48:58 -0700