Information Collection: Sources and Basis for Collection
You can generally visit our Site without revealing any personally identifiable information about yourself. However, if you want to participate in certain channels on the Site, we may require you to submit certain personally identifiable information to us and we may invite you to submit questions, comments and request information.
For example, if you want to find out more about our senior living communities, you can click on the “Contact Us” button, or the “Request a Brochure" button, and you will be asked to provide your name and email address; providing your phone number is optional. Or you can schedule a tour of one our facilities by choosing the desired location and then providing your name, phone number (optional) and email address. This is necessary to enable us to follow up and provide you with the information or activity (such as a tour) that you have requested.
In the event that you are an employee of RPSLI, we will maintain standard US employment records in our Human Resources Department, which are treated with appropriate privacy and security.
In the event that you are or desire to become a resident of one of our facilities, we would obtain and maintain the following personal information about you: (1) When you sign up to live at a Regency Park facility, you fill out the standard admissions package, which contains the information you would provide when entering into any residential lease, plus the information necessary to enable us to provide the services required of state-of-the-art senior living facilities. We collect such personal identity documents as your driver’s license number, social security number, mailing address, email address and phone number. (2) In order to provide you with the senior living services that you may require, we obtain medical directives (e.g., DNR (do not resuscitate) instructions), powers of attorney (should you become incapacitated), health insurance information including Medicare number if applicable, pertinent medical records including prescription drug list and administration records, doctors’ information, medical orders and related information. Your physician must fill out for submission the medical assessment form, listing your medical conditions (e.g., COPD, dementia, cancer). If you purchase our medication management service, in which you require that we administer your medications, we maintain a list of the medications you take so that we can provide you with your medications, and maintain the MAR (medication administration record).
Information Use and Disclosure
We use your personally identifiable information to enable living in our facilities, deliver our services or the information you have requested, verify that you are a customer or prospective customer, send you information that you have signed up to receive, notices about our facilities 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 resident of one of our facilities and/or a user of our services, we may use your personally identifiable information to provide the services to you.
We may provide your personally identifiable information and the data generated by cookies and third party analytics tools such as aggregate information to the vendors and service agencies that we engage to assist us in providing our services to you. For example, we engage G5 Search Marketing, Inc. to assist us in creating and hosting this Site, and with Conversion Logix, a digital advertising agency, to create custom-tailored digital marketing campaigns aimed at specific audiences that may be interested in our senior living offerings, to drive traffic to the Site.
Correcting or Deleting Your Information and Opting Out
If you are a natural person, you have the right to request that we give you access and/or delete your personal information under CCPA, which is basically any information that could be used to identify you, such as name, address, telephone, email address that we might collect as we have indicated above. To exercise your right to access your personal information, you must send us a verifiable consumer request (“VCR”). Once received, we will disclose and deliver, free of charge to you, the personal information that we hold about you. We will deliver this information by mail or electronically, in the latter case it shall be in a portable and if technically feasible, readily useable format so that you can re-transmit this information to another entity without problem. We will deliver this information within 45 days of receiving a verifiable request from you, and if reasonably necessary, we can extend this for an additional 45 days if we provide you notice of the extension. Our disclosure will cover the 12-month period preceding receipt of your VCR, and we will deliver the disclosure by mail or electronically at your option . This is an obligation we are required to fulfill no more than twice in any 12-month period. We are not required to maintain your personal information from a single, one-time transaction.
To exercise your right to have your personal information deleted, you must send us a VCR to this effect. Once you request deletion, we shall delete your personal information from our records, and direct any service provider who has obtained your personal information from us also to delete such personal information from its records. However, we are NOT required to delete your personal information if we need it to (i) complete the transaction or sale for which the personal information was provided or otherwise perform a contract; (ii) detect security incidents, or protect against malicious or fraudulent or other harmful activity; (iii) debug to identify and repair errors that impair intended functionality; (iv) exercise free speech or ensure the right of another consumer to exercise free speech as provided by law; (v) comply with the California Electric Communications Privacy Act per Chapter 3.6 thereof; (vi) engage in public or peer-reviewed scientific, historical or statistical research in the public interest in accordance with applicable ethics and privacy laws if to delete would likely impair or render impossible the achievement of the research; (vii) enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the business relationship; (viii) comply with a legal obligation; (ix) otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
If we sell your personal information to third parties, we must inform you that your personal information may be sold, and then you have the right opt out of the sale of your personal information. However, we do not sell personal information.
To contact us, you can use the various methods of Contact Information set forth at the end of this Policy.
Non-Discrimination for Exercising Rights under CCPA
We will not discriminate against you or any consumer for exercising any of your consumer privacy rights under the CCPA , which includes but is not limited to: (i) Denying goods or services to the consumer; (ii) Charging different prices or rates for goods (e.g., our facilities) or services, including through the use of discounts or other benefits or imposing penalties; (iii) Providing a different level or quality of goods or services to the consumer, if the consumer exercises the consumer’s rights set forth in in the preceding section of this Policy; or (iv) Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a consumer a different price or rate, or from providing a different level or quality of goods or services to the consumer, if that difference is reasonably related to the value provided to the consumer by the consumer’s personal data. In addition, we have the right to offer financial incentives, including payments to consumers as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information, if we provide notice to you and give you the right to opt-out of such a program. Any financial incentive program must not be unjust, unreasonable, coercive or usurious in nature. We also have the right to offer a different price, rate, level, or quality of goods or services to the consumer if that price or difference is directly related to the value provided to the consumer by the consumer’s personal data.
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 our Site, we use session cookies to make it easier for you to navigate the Site by remembering your preferences and to improve and track the overall Site experience. Persistent cookies enable us to track, store and target the interests of our users to enhance the experience on our Site. If you reject cookies, you may still use our Site, but your ability to use some areas of our Site may be limited.
Third Party Analytics Tools
Beyond the personally identifiable information you voluntarily provide to us, our service providers described above utilize analytics tools including third party technologies, such as Google Analytics, to collect non-personally identifiable information utilizing cookies. Certain types of information, including geolocation, device type, onsite website usage and behavior, demographic data, is collected and aggregated across RPSLI Site users for our analysis and advertising efforts, in order to improve the Site and our services, and for promotional efforts regarding our facilities and services.
RPSLI uses Remarketing with Google Analytics and Google Adwords to display relevant advertisements to users who have previously visited our Site. Referred to as remarketing or retargeting, RPSLI 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 RPSLI 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.
RPSLI’s service providers also use Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting and Interest-Based Advertising to display advertisements to users based on their inferred interests and demographics. Any interest-based advertising campaigns that RPSLI runs only use anonymized personal information.
The Site may track the total number of visitors to our Site, the number of visitors to each page of our Site, browser type, IP addresses, 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 your personally identifiable information. We may use such aggregate information to analyze trends, administer the Site, track users' movement, and gather broad demographic information for aggregate use.
RPSLI 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 our Site, our senior living/assisted living facilities nor our services are intended for children under the age of 13. RPSLI does not target its services or this Site to children under 13. We do not knowingly collect personally identifiable information from children under the age of 13. While consumers under 16 must opt-in to any sale of their personal information under the CCPA, we do not sell personal information.
Links to Third Party Sites
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. RPSLI may use, without limitation, firewalls, password protection, secure socket layer, and other security measures to help prevent unauthorized access to your personally identifiable information.
Notice to European Users
Questions or Requests and Contact Information:
Regency Park Senior Living, Inc.
350 Cordova Street
Pasadena, CA 91101