Carlton Senior Living Privacy Policy

Carlton Senior Living, its affiliates, and related companies (collectively, “Carlton”) are committed to protecting the privacy of data that you submit to this website or to websites under our operation and control (collectively, the “Site”)

Please review this Privacy Policy carefully. We reserve the right to change our Privacy Policy at any time, in which event the Site will contain a notice of the change. Changes will be effective immediately upon posting to the Site. By accessing the Site, you are indicating your agreement to our Privacy Policy. If you have any questions regarding the Privacy Policy, contact us at info@carltonseniorliving.com. We are committed to protecting the privacy of information that you submit to the Site.

Residents of the State of California may be entitled to additional rights regarding their personal information. For more information about those rights and how to exercise them, please see our California Privacy Policy.

PRIVACY NOTICE TO CALIFORNIA RESIDENTS: Consumer Rights Under the CCPA and CPRA

This supplemental privacy notice applies to California residents (herein referred to as “you,” “the consumer,” or “California residents”) in order to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the Consumer Privacy Rights Act of 2020 (“CPRA”), and other California privacy laws. The CCPA and CPRA establish several rights for you, the consumer. We do not sell your personal information.

You have the right to submit several requests regarding the personal information we have collected about you. You may make such a request for disclosure or deletion of personal information twice within any given 12-month period. We will provide responsive information for a period of 12 months preceding the date of your request. We will provide this information to you within a period of 45 days from the date of your request. If needed, we may require up to an additional 45 days to complete the request but will provide notice to you of the need for the additional time prior to the expiration of the initial 45-day period.

In order to respond to your request, we may need to obtain information from you to verify that yours is a valid and legitimate request. This provides further protection for your personal information.

Right to Request Disclosure of Personal Information

You may request that we disclose the categories of personal information that we have collected about you, the specific pieces of personal information that we have collected about you, or both.

Right to Correct Inaccurate Personal Information

In the event that any of the personal information we maintain about you is incorrect, you have the right to request that we correct it.

Right to Limit Use and Disclosure of Sensitive Personal Information

You may request that we limit the use and disclosure of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, and other specific uses delineated in the CCPA and CPRA.

The CCPA and CPRA define “sensitive personal information” as personal information that reveals any of the following:

• 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;

Right to Opt-Out

You may request that we stop sharing your personal information for cross-context behavioral advertising. We do not share your information for this purpose, but are simply informing you of this right under the CCPA and CPRA.

Right to Request Deletion of Personal Information

You also have the right to submit a request that we delete the personal information we have collected about you. There are several exceptions to the consumer’s right to deletion; namely, we may retain your information despite your request for deletion if we require the information in order to do any of the following:

• Complete the transaction for which the personal information was collected;
• Provide a good or service requested by the consumer or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer;
• Otherwise perform a contract between the business and the consumer;
• Detect security incidents and protect against “malicious, deceptive, fraudulent, or illegal activity;”
• Use for internal debugging purposes or to repair software errors;
• Exercise free speech, ensure the right of another consumer to exercise free speech, or any other right provided by law;
• Use the information to comply with the California Electronic Communications Privacy Act;
• Engage in research in the public interest that follows all other privacy laws (with consumer consent);
• Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business;
• Comply with a legal obligation; or 20068737.1
• Otherwise use the information internally in a lawful manner that is compatible with the context in which the consumer provided the information.

How to Submit a Request

We offer consumers three distinct methods for submitting requests to exercise their rights under the CCPA and CPRA:

• Method one, such as calling a toll-free phone number; and
• Method two, such as filling out a form on our website.
• Method three, such as emailing info@carltonseniorliving.com.

Submitting a verifiable consumer request does not require that you have an active account with us, nor are you required to create an account. As previously noted, we will need to obtain enough information from you to verify your request in protection of your information before responding to your request. Information that we may need from you to verify your request may include the following:

• Legal name;
• Email address;
• Phone number;
• Date of birth;
• Last four digits of your social security number; and
• Billing address.

We may decline a consumer request if the time and resources that must be expended in order to respond to the request outweigh the reasonably foreseeable impact to the consumer from not responding, as provided by California law.

Requests by an Authorized Agent

A California resident may use an authorized agent to submit a right to know request or a request to delete. To use an authorized agent to submit such a request, the California resident must provide the agent with written authorization. In addition, the California resident may be required to verify their own identity with us or to authenticate the agent’s authorization. We may deny a request from an agent that does not submit proof, including written authorization from the resident, that the agent has been authorized by the California resident to act on their behalf. However, such requirements will not apply where a California resident has provided the authorized agent with power of attorney pursuant to California Probate Code Sections 4000 to 4465.

Right to Not be Discriminated Against for Exercising the Rights to Disclosure or Deletion

We will not discriminate against you for exercising your rights under the CCPA and CPRA. Unless otherwise permitted by the CCPA, the CPRA, or other California law, we will not deny you goods or services, charge you a different rate for goods or services, provide you a different quality of goods or services, or suggest that any aspect of your service will change if you exercise any of your rights enumerated here in this policy.

Categories of Information We Collected About Consumers in the Past 12 Months

Disclosure of Personal Information to Third Parties

The following chart lists the categories of information that we have collected about our consumers over the last 12 months that we have shared with third parties. We do not sell your personal information

We Do Not Sell Your Personal Information

We do not sell your personal information. Such third party access would be governed by a written agreement that limits such access, disclosure, and processing in accordance with the CCPA, CPRA, and other applicable law.

Our Right to Change Privacy Policy

The foregoing policy is effective as of December 19, 2023. We reserve the right to change this policy at any time by notifying visitors to our website of the existence and location of the new or revised privacy policy. Changes to the policy will be posted to this page, and if changes are significant, a summary of the changes will be posted at the beginning of the policy. By entering our website and by continuing to use our services, you are accepting all terms and conditions outlined in the above Privacy Policy. If you have any questions about this policy, you may contact us at info@carltonseniorliving.com or (800) 227-5866.

We may ask you to provide information about yourself in order to better serve you, for instance, in connection with an application for employment or to learn more about our communities that provide senior living services. Examples of information requested may include name, address, phone number, email address, and other relevant data. We do not require this information to obtain access to any area of the Site. We do not wish to receive, nor should you submit any medical information, information pertaining to any medical conditions, treatments, procedures, or providers of medical care to the Site. However, if you decide to provide personal information to us through our “Contact Us” form, please be aware that this information could be viewed by our marketing vendors. The “Contact Us” form is used only to deliver requested information and respond to your questions. Any information that you voluntarily share with us in a form will not be sold or provided to another for any other purpose except as described in this Privacy Policy. Information from the “Contact Us” form will be used only for the purposes of assisting you with your request or for furthering our business and those of our affiliates, and their respective successors and assigns, as set forth in this Privacy Policy

We may compile statistical information concerning the usage of the Site. This information allows us to monitor its utilization and continuously improve its quality. Examples of this information would include, but not be limited to, the number of visitors to the Site, or to sections or pages within the Site, patterns of traffic flowing through the Site, length of time spent on the Site, or in sections or pages of the Site, the other sites that refer visitors to the Site, the pages of the Site that visitors frequently use as entry and exit points, 20068737.1 utilization of the browser and operating systems and versions used by visitors to the Site, etc. In order to compile this information, we may collect and store on a server (managed by a third-party vendor) your IP address, your operating system version, your browser version, the pages you visit within the Site, the length of time you spend on pages within the Site, the site from which you linked to ours, search terms you used in search engines which resulted in you linking to the Site, etc. While all of this information can be associated with the IP address your computer had while you visited the Site, it will never be associated with you as an individual, or associated with any other information you may submit through the Site, or that we may store about you for any other purposes.

We may use website “cookies” in the process of compiling the statistical information mentioned above and to tailor certain pages of the Site for your browsing convenience. You have the option of setting your browser to reject cookies, but our Site may not function correctly if you do. Refer to the Help feature of your browser for information on disabling cookies

The Site is not directed to children. We do not knowingly collect any personal information from children. If you are concerned about your child’s use of the Site, you may use web-filtering technology to supervise or limit access to the Site.

This Privacy Policy is governed by the laws of the State of California in the United States, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Policy shall lie exclusively with the state and federal courts within the State of California. If any provision of this Privacy 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 Privacy Policy, which shall remain in full force and effect.

We may change, modify, add and/or delete all or portions of this Privacy Policy at any time, at our discretion, and modifications are effective upon being posted on the Site. If we decide to change this Privacy Policy, we will post those changes on the home page of the Site and any other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. You are responsible for reviewing this Privacy Policy periodically to ensure that you are aware of any changes to it. If we make material changes to this Privacy Policy, we will notify you by means of a notice on the Site’s home page.

We welcome your questions, comments and all feedback pertaining to your privacy or any other issue with regard to the Site. At any time, you may revoke your consent, cease further use of your email address to send you updates, and direct us to delete the information you have supplied. Although it is not always possible to remove or modify such information, we will make reasonable efforts to do so. If you have given us information for one of those third parties we mentioned above and we have already passed it on, we cannot delete or change the information. In the event that you have given us personal information in the past and then have second thoughts or want to update it, you may send an email or contact us by regular mail:

info@carltonseniorliving.com

Carlton Senior Living Home Office
4071 Port Chicago Hwy., Suite 130
Concord, CA 94520
Last Updated: December 19, 2023