California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Information (as defined under CCPA) to third parties for their direct marketing purposes in the preceding calendar year.
Notice to California Residents
This section describes how we handle the Personal Information of California residents (as defined in Section 17014 of Title 18 of the California Code of Regulations), and the rights they have under the CCPA”) to the extent that (1) we collect and process such information in the context of providing services and selling goods (hereinafter, Customer Related Personal Information); and (2) the obligations imposed by the California Consumer Privacy Act of 2018 (“CCPA”) apply to such data. This section also notifies California residents of our collection practices regarding such Personal Information and describes your rights under the CCPA.
Notice at Collection
We collect the following categories of Customer Related Personal Information from you:
- Identifiers: We collect identifiers such as real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address (see “internet activity” below), email address, and account name.
- Internet /electronic network activity: When you browse our sites or otherwise interact with us online, we may collect browsing history, search history, and other information regarding your interaction with our sites, application or advertisements.
- Customer Records: We collect Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as name, signature, description, address, telephone number, bank account number, or other financial information. Some Personal Information included in this category may overlap with other categories.
- Characteristics of protected classifications under California or federal law: In some circumstances, we may collect information that is considered protected under California or federal law such as age but only when that information is relevant for our business purposes. We abide by the legal requirements imposed under applicable law regarding such information.
- Sensory data: In some circumstances, we collect audio information (e.g., records of calls made through our systems when call recording is activated), electronic and visual information (e.g. recordings from security cameras), or similar information.
- Geolocation data: If you interact with us online, we may gain access to the approximate location of the device or equipment you are using. If you visit our facilities, we may keep record of the fact that you visited, the location visited, and the day/time.
- Biometrical data: We do not independently collect biometric data such as DNA data, fingerprints, voice prints, retina scans, or face scans; however, we may collect data from which biometric data could be derived (such as voice recordings and pictures.)
- Commercial Information: We collect commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Professional or employment related data: Because we collect and handle information related to our services, we may collect from you professional or employment information such as company name, designation, work experience, etc.
- Inferences: We may draw inferences from other information we collect about you. For example, if you use our services, we may create a client profile reflecting our understanding of your personal preferences.
- For our internal efforts to operate and improve our business.
- For advertising and marketing purposes relating to our services and programs, including marketing on social media sites.
- For our general administrative purposes.
- For social-media engagement.
- For security purposes, as necessary to help us protect against, identify, or investigate fraud or other criminal activity.
- For other legal purposes, if we have a legal obligation, or need to pursue or defend against legal claims, for which we need to process your information.
- For communication purposes, to get in touch with you in connection with any of the reasons listed above.
We share Personal Information in the context of marketing and advertising in ways that may be considered selling under CCPA. You can opt-out out of the sharing as described in the California Rights section below. However, we do not authorize third parties to use your Personal Information for their own purposes unless you direct us to do so.
Collection and sharing practices in the last twelve (12) months
In the last twelve (12) months we have collected Customer Related Personal Information for all categories outlined in the Notice at Collection section above.
We collected such information from the sources described in our Privacy Notice. For example, we have collected Customer Related Personal Information:
- Directly from our customers (for example, information provided through the Site or other communications with us).
- From our business partners with whom you have consented to the sharing of your information.
- From consumers’ activity on the Site (for example, Site visit information collected directly or through third-party analytics providers).
- From a device’s GPS, Wi-Fi, Bluetooth, or IP address.
- From consumers’ activities on social media.
- From our interaction through social media.
We have shared Customer Related Personal Information for our operational purposes or other business purposes as described in our Privacy Notice. We also share Personal Information in the context of marketing and advertising in ways that may be considered selling or sharing under CCPA. The types of entities with which we have shared Customer Related Personal information include:
- Service providers
- Other members of our corporate group
- Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others).
- Business Partners and other third parties as necessary to provide services to our customers
Your rights under California law
If you are a California resident, you have the following rights under CCPA:
- Right to know/access information: You have the right to request that we disclose to you: (1) the specific pieces of Personal Information we have collected about you over the past 12 months; (2) the categories of Personal Information collected or shared over the past 12 months; (3) the purposes for which we collected or shared such Personal Information; (4) the categories of third parties to whom we have disclosed such Personal Information.
- Right to delete: You have the right to request in certain circumstances deletion of the Personal Information that we have received about you. As a general rule, we must delete the Personal Information at your request and require our vendors to do so as well. However, the law provides certain exceptions that allow us to retain the information even if you have requested that it be deleted. If we do not erase the information pursuant to one of those exceptions, we must inform you of that fact and of any rights you may have to appeal our decision.
- Right to Opt Out of Sale of Personal Information to Third Parties. You have the right to opt out of any sale of your Personal Information by Emeritus to Third Parties. We do not sell information to third parties.
- Right to Information Regarding Participation in Data Sharing for Financial Incentives. You have the right to be free from discrimination based on your exercise of your CCPA rights. We do not discriminate against anyone who chooses to exercise their CCPA rights.
California law also provides that California residents are entitled to know how we respond to “Do Not Track” settings. Like many other websites and online services, we do not currently alter our practices when we receive a “Do Not Track” signal.
How to exercise your Rights
You can make requests related to your California privacy rights by completing our Enquiry Form.
You may also make those requests by writing to us at firstname.lastname@example.org
Please be aware that we do not accept or process requests through other means (e.g., via fax, chats, social media etc.).
When you make a request, we may ask you to provide verifying information, such as your name, email, or phone number. We will review the information provided and may request additional information via email or other means to ensure we are interacting with the correct individual. Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of personal information or content you may have posted, and there may be circumstances in which the law does not require or allow us to fulfill your request.
If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.
You may only make a verifiable consumer request twice within a 12-month period. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request.