Last modified: August 24, 2018

Introduction

We respect your privacy and are committed to protecting it through our compliance with this Policy.  This Policy describes the types of information we may collect from you or that you may provide when you visit the Portal www.seniorportal.com (our “Portal”) or when you use our web-based residential community engagement Portal (together with the Portal, our “Portal”), and our practices for collecting, using, maintaining, protecting and disclosing that information.  

This Policy applies to any information that we collect on the Portal, including any information in any e-mails, posts, texts and other electronic messages between you and the Portal and any information about you transferred to the Portal from other Portals.  This Policy does not apply to any information that we collect by any other means, including offline collection. This Policy also does not apply to information you share with your community management or staff members or agents thereof (your “Community”)—your Community has its own, separate policies and practices for how they use, maintain, protect and disclose information collected through the Portal and we encourage you to contact your Community directly and/or review their applicable privacy policies.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, you can choose not to use our Portal. By accessing or using our Portal, you agree to this Privacy Policy.  This Policy may change from time to time. Your continued use of the Portal after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

 

What Is Considered “Personal Information” and “Personal Health Information”?

Information we collect on our Portal falls into one of three categories:

  1. Information by which you may be personally identified, including but not limited to first and last name; physical street address; e-mail address; telephone number, including a mobile telephone number; and any other information collected that is combined with one or more of the categories of information listed here.
  2. Information that relates to your past, present, or future physical or mental health or condition; the provision of health care to you; or the past, present or future payment for the provision of health care to you.
  3. Other information that is about you but does not identify you personally, including but not limited to certain demographic information or information about which buttons or links users click on most frequently when they access our Portal.

For the purposes of this privacy Policy, information listed in the first category above is considered to be your “Personal Information.”  If information in the second category above is combined in any way with your Personal Information, or if there is a reasonable basis to believe that information alone can be used to identify you, it is considered to be your “Personal Health Information.”  All other information that does not identify you individually or that is “de-identified” is NOT considered Personal Information or Personal Health Information.

Information We Collect About You and How We Collect It

Direct Collection

The principal way we receive Personal Information about you is when you choose to provide it to us directly by filling out registration forms, creating a personal profile, and/or interacting with certain tools available to you via the Portal.  

  • At Registration.  When you first register for the Portal and your details are entered into our system by you or by your Community, we collect several types of information about you, including: your first and last name; a “user” or “screen” name for use on the Portal; contact information such as your telephone number, e-mail address and physical address; and a photo of yourself.
  • When You Create a Personal Profile.  If you choose to create a personal profile on the Portal, you may choose to include, in addition to the registration details noted above, some or all of the following: additional photos of yourself or otherwise as well as information about your hobbies, interests and activities.
  • When You Engage With the Portal’s Health/Wellness Tracker Application(s).  If you choose to utilize the Portal’s health/wellness tracker application (should this option be made available to you by your Community), we may collect both Personal Information and Personal Health Information through such application.  
  • User Contributions.  You also may provide information to be posted, published or displayed on public areas of the Portal (such as your personal profile, events pages, or in personal messages between you and other residents), including additional information about yourself or your interests (collectively, “User Contributions”).  Your User Contributions, including any Personal Information you include within your User Contributions, are posted on and transmitted to others at your own risk.  We cannot control the actions of other users of the Portal with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Collection

When you access, use and navigate through the Portal, the Portal may use certain technologies (described below) to collect automatically the following information:

  • Traffic Data / Usage Details. When you access and use the Portal, we may collect automatically certain details of your access to and use of the Portal, including traffic data, logs, and other communication data, your navigation paths through the Portal, the resources that you access and use on or through the Portal and the referring and exit pages.  
  • Computer and Device Information. When you access and use the Portal, we may collect information about your computer or mobile device and your internet connection, including your IP address or other similar “persistent identifiers,” your operating system, your browser type, your mobile device’s unique device identifier, your mobile network information and your device’s telephone number.

If you do not want us to collect this information automatically your choice is to not access or use the Portal.

We use the following technologies for automatic information collection:

  • Cookies (or mobile cookies). A cookie is a small file placed on your computer or mobile device. It may be possible to refuse to accept cookies by activating the appropriate setting on your browser or mobile device. However, if you select this setting you may be unable to access certain parts or features of the Portal.
  • Web Beacons. Certain pages or portions of the Portal may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related usage statistics (for example, recording the popularity of certain content and verifying system and server integrity).
  • Embedded Code.  Certain pages or portions of the Portal may use embedded hidden code to collect information about usage flows through the Portal and other similar usage statistics.

Online Tracking and How We Respond to “Do Not Track” Signals

Tracking involves the use of cookies, web beacons or other embedded code or tracking technologies to collect, analyze and store information on a user’s behavior over time on multiple sites, including information on the sites visited, products viewed, products purchased and other online interactions.  Tracking information can be used to enable companies to make interest-based (behavioral) advertising available to users on multiple sites that they visit.

We do not currently collect Personal Information about your on-line activities over time across third party sites for tracking purposes.  We do not currently allow third parties to collect Personal Information on the Portal that could be used by them to analyze and store information about your on-line activities over time and across third party sites for tracking purposes. Therefore, the Portal does not and will not respond to any “DO NOT TRACK” signals sent by your browser or otherwise.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information, to:

  • Provide you with the Portal, its contents, its features and any other information or services you request from us;
  • Display your personal profile for other users to see, which other users may then use your information to contact or communicate with you;
  • Share information with you and other users about events in your residential community;
  • Connect you with your Community from whom you have requested services;
  • Permit your Community to contact you with important e-mail or other communications, including information about events and news affecting your residential community;
  • Share your User Contributions with other users at your direction;
  • Share your Personal Health Information with your Community or others (such as family members), solely at your direction and in connection with your use of the Portal’s health/wellness tracker application;
  • Fulfill any other purpose that we describe when you provide the information;
  • Fulfill any other purpose for which you provide it;
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including our Resident Terms of Use [INSERT AS LINK TO TERMS OF USE];
  • Notify you when updates to the Portal are available and of any changes to any services we offer or provide through it; and
  • Notify you when updates to this Resident Privacy Policy occur.

The traffic data, usage details, and “persistent identifiers” we collect help us to improve the Portal and to deliver a better and more personalized experience by enabling us and your Community to:

  • Estimate our audience size and usage patterns.
  • Learn to improve the “flow,” organization and user interface of the Portal.
  • Recognize you when you use the Portal and store information about your preferences, allowing us to customize the Portal according to your individual interests.
  • Speed up your searches.

We use the feedback you provide in response to any surveys you complete at our request in order to improve the functionality of the Portal and ensure our expectations for quality service are being met by our employees and other service providers you may interact with through the Portal.

We do not sell or lease your Personal Information to third parties for marketing or promotional purposes.

Disclosure of Your Information

We may disclose your information, including your Personal Information:

  • To other users of the Portal to the extent you choose to include it in your personal profile or other User Contributions, in each case as you direct us to do so via the Portal’s forms and interactive features;
  • To your Community to the extent you choose to include it when you register for the Portal or in your requests for services from them;
  • To your Community or others (such as family members), solely at your direction and in connection with your use of the Portal’s health/wellness tracker application (this applies also to Personal Health Information collected through the use of such application);
  • To our directors, officers, employees, subsidiaries and affiliates;
  • To contractors, service providers and other third parties we use to support our business and help us operate, maintain and improve the Portal and who (1) need to know such information to support our permitted uses of Personal Information in accordance with this Privacy Policy, and (2) are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by the us about our Portal users is among the assets transferred;
  • To comply with any court order, law or legal process, including responding to any government or regulatory request;
  • To enforce our rights arising from any contracts entered into between you and us, including our Resident Terms of Use [INSERT AS LINK TO TERMS OF USE];
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, the Portal’s users or others;
  • For any other purpose disclosed when the information is provided; and
  • For any other purpose with your consent.

We may share anonymized or de-identified information that is not tied to your Personal Information—such as traffic data (e.g., audience size and usage patterns) that we collect from cookies, web beacons or other embedded code—with third parties without restriction.

Choices About How We Use and Disclose Your Information

You have certain choices regarding the Personal Information you provide to us:

  • You can set your browser to refuse all or some browser cookies.  To learn how you can manage your Flash cookie settings, visit the Flash player settings page on the Adobe website, accessible here.  If you disable or refuse cookies, some parts of the Portal may then be inaccessible or not function properly.
  • By accessing your account page on the Portal, you can adjust certain privacy settings with respect to your personal profile (for example, to choose not to be seen by certain users).

Your California Privacy Rights

California Civil Code Section 1798.83 permits users of our Website who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.  To make such a request, please send an e-mail to hello@seniorportal.com.  Please note that we do not currently make disclosures of Personal Information to third parties for marketing purposes.

Accessing and Correcting Your Information

You can review and change information included in your personal profile by logging into the Portal and visiting your account profile page.

You may also send us an e-mail at hello@seniorportal.com to request access to, correct or delete any Personal Information that you have provided to us.  We cannot delete certain portions of your Personal Information except by also deleting your user account.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Portal, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Portal users.

Children Under the Age of 13

Our Portal is not intended for children under 13 years of age, and no one under age 13 may provide any information to this Portal.  We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on this Portal, use any of the interactive or public comment features of this Portal or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.  If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at hello@seniorportal.com.

Users Outside of the United States

Our Portal is hosted in the United States and our services are provided from the United States.  It is possible that certain information will be stored on servers in multiple other countries on the “cloud” or other similar distributed hosting platforms.  If you are a user accessing our Portal or services from the European Union, Asia or any other region with laws governing personal data collection, use, and disclosure that differ from United States laws, please note that you are transferring your Personal Information outside your home jurisdiction, and that by providing your Personal Information you are consenting to the transfer of your Personal Information to the United States and other jurisdictions as indicated above, and to our use and disclosure of your Personal Information in accordance with this policy.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.  For example, all information that you provide to us is stored on our servers behind firewalls and certain Personal Information will be encrypted using secure socket layer (SSL) technology.

The safety and security of your information also depends on you.  When we have given you (or when you have chosen) a password for access to certain parts of our Portal, you are responsible for keeping that password confidential.  We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Portal such as message boards. The information you share in public areas may be viewed by any user of the Portal.

Unfortunately, the transmission of information over the Internet is not completely secure.  Although we have implemented security measures that we think are adequate, we cannot guarantee the security of your Personal Information transmitted to our Portal.  Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Portal.

Changes to Our Privacy Policy

We post any changes we make to our Privacy Policy on this page.  If we make material changes to how we treat our users’ Personal Information, we will endeavor to notify you by e-mail to the primary e-mail address specified in your account and/or through a notice on the Portal home page.  The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Portal and this Privacy Policy to check for any changes.

 

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Senior Portal, Inc.
103 Lloyd Street, Suite 200
Carrboro, NC 27510
Telephone: (984) 234-5287
E-mail: hello@seniorportal.com