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PRIVACY NOTICE TO CALIFORNIA RESIDENTS

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 California Privacy Rights Act of 2020 (“CPRA”), and other California privacy laws.

If you are an employee or job applicant of Avista Senior Living (“we” or the “Company”), please see the CCPA/CPRA Notice to Employees/Job Applicants that is available at this link and is posted in the breakroom for information that is more specific to you and details about the categories of information we have collected about our employees and job applicants over the past 12 months.

Consumer Rights Under the CCPA and CPRA

The CCPA and CPRA establish the following consumer rights:

Right to Know

You have the right to know what categories and specific pieces of personal information we collect or disclose; the categories of sources from which we collect or disclose; our business purpose or commercial purpose for the collection, use, or sharing of your personal information; and any categories of third parties with whom we share your information. We do not sell any of your personal information.  More information is available in the section below titled “Personal Information We Collect.”

Right to Delete

You have the right to request that we delete personal information we may collect about you. There are several exceptions where we may need to retain your personal information, such as in order to provide you with services related to your housing and care.

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

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

You have the right to limit use or disclosure of your SPI, if we are using your SPI beyond what is reasonably necessary and proportionate to provide the requested goods or services.

Right to Opt-Out of Sharing and Selling of Personal Information

You have the right to request that we do not share your personal information. We share your information as reasonably necessary and proportionate to provide you with our services.  We do not share your information for cross-contextual behavioral advertising.

You also have the right to opt-out of the sale of your personal information.  Because we do not sell any personal information, the right to opt-out of the sale of personal information does not apply.  In the event that we are considering a sale, partial or complete, asset transfer, partial or complete, or other financing matter, we would make any and all necessary disclosures to you before certain information we possess concerning you may be accessed, disclosed, and/or processed by third parties.  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.

Right to Correct

You have the right to request the correction of any personal information we maintain about you.

Right to Non-Discrimination

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.

Responding to Your Request

We will acknowledge your request within 10 business days of receiving your request. We will respond to your request within 45 calendar days from the date we receive it.  In some cases, we may require additional time to complete your request and will inform you if additional time is needed.  Where additional time is needed, we may take up to a maximum of 90 calendar days to complete your request.  We will provide our response in a readily usable format, which is usually electronic.

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

Personal Information We Collect

The CCPA and CPRA 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 CCPA and CPRA, 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 CCPA and CPRA create and define categories of personal information.  Some types of personal information may apply to multiple categories.  Depending on your level of interaction with us, we may have collected the categories of personal information described in the table below.  We may not have collected your personal information from all of the categories.

Except as otherwise noted, we retain each of the below categories of information for five years from the date of your last transaction with us for the same reasons that we collect the information: to enable us to provide goods and services to you, to manage and operate our business, to market our goods and services to you, and to comply with our legal and regulatory obligations.

CategoryExamplesCollected
1. IdentifiersName, 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 InformationName, 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 lawAge, 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 informationRecords of products or services purchased, purchasing or consuming histories or tendencies.Yes
5. Biometric informationFingerprints, facial or hand imagery, or voice recordings.

 

Yes

 

This information is generally retained for a period of 7 days.

6. Internet or other similar network activity informationBrowsing history; search history; information regarding consumer’s interaction with a website, application, or advertisement.Yes
7. Geolocation dataGPS coordinates or other location tracking information.Yes

 

8. Sensory dataAudio, electronic, visual, or similar information.Yes
9. Professional or employment-related informationEmployer, employment history, resumes and CVs, background checks, and other employment-related information.Yes

 

10. Education informationRecords 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, precise geolocation, racial or ethnic origin, genetic data, or other similar information.We do not typically collect this information for general marketing purposes.

 

However, we collect SPI in a reasonably necessary and proportionate manner to provide care for our residents.

 

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

 

Disclosure of Personal Information to Third Parties

The table below describes the sources for each category of personal information we collect, the business and/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.  We do not sell any of your personal information.  If required by law, regulation, or court order, we may share your personal information with third parties, such as government agencies.

CategorySourcesBusiness or Commercial PurposesThird Parties Shared With
1. Identifiers●       Directly from you

●       Website cookies

●       Website analytics providers

 

●       To fulfill specific your requests

●       To enhance the website experience

●       For marketing and analysis

●       To complete financial transactions

●       Website providers

●       Analytics providers

●       Advertising providers

●       Telephone service providers

●       Financial processors

 

2. Customer Records Information●       Directly from you

●       Website cookies

●       Website analytics providers

●       To fulfill specific your requests

●       To enhance the website experience

●       For marketing and analysis

●       To complete financial transactions

●       Website providers

●       Analytics providers

●       Advertising providers

●       Telephone service providers

●       Financial processors

3. Characteristics of protected classifications under California or federal law●       Directly from you

●       Website cookies

●       Website analytics providers

●       To fulfill specific consumer requests

●       To enhance the website experience

●       For marketing and analysis

●       To complete financial transactions

●       Website providers

●       Analytics providers

●       Advertising providers

●       Telephone service providers

4. Commercial information●       Directly from you

●       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

●       Security system at facilities

●       To fulfill your requests

●       For internal training

●       For marketing and analysis

●       Telephone service providers

●       Analytics providers

9. Professional or employment-related information●       Directly from you●       To fulfill specific consumer requests

●       To enhance the website experience

●       For marketing and analysis

●       Website providers

●       Analytics providers

●       Advertising providers

10. Education information●       Directly from you●       To fulfill specific consumer requests

●       For marketing and analysis

●       Website providers

●       Analytics providers

●       Advertising providers

11. Sensitive personal information●       Website analytics providers

●       Advertising providers

●       For marketing and analysis

●       To complete financial transactions

●       Analytics providers

●       Advertising providers

●       Financial processors

12. Inferences●       Website analytics providers

●       Advertising providers

●       For marketing and analysis●       Analytics providers

●       Advertising providers

How to Submit a Request

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

  • Method one, calling the community at 951-737-1600
  • Method two, sending an email to magnoliareception@avistaseniorliving.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 may need to obtain enough information from you to verify your request before we respond.  Information that we may need from you to verify your request will depend on the scope of your request and may include your name, phone number, address, and/or other identifiers.

We may decline a 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 exercise their rights under the CCPA and CPRA.  If you choose to use an authorized agent, we may require that you provide us with your written authorization.  Depending on your request, we may require you and your authorized agent to directly verify their identity with us.  These requirements do not apply if you have a power of attorney pursuant to California Probate Code Sections 4121 to 4130.

Our Right to Change Privacy Policy

The policy is effective as of January 1, 2023 and was last updated on May 1, 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.  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 this Privacy Policy.

If you have any questions, you may contact the community Executive Director at 951-737-1600 or emailing magnoliareception@avistaseniorliving.com

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