Sinceri Senior Living Privacy Policy

This Privacy Policy (“Policy”) applies to all websites, systems, and other services operated by JEA Senior Living, LLC, DBA Sinceri Senior Living, and its subsidiaries and affiliates (“Sinceri Senior Living”), including without limitation, Sinceri Senior Living’s website (as may be hosted here now and at other URLs from time to time) https://sinceriseniorliving.com (“Sinceri Senior Living’s Resources”). Any reference to “we”, “us”, or “our” in this Policy shall refer to Sinceri Senior Living. This Policy has been created in order to demonstrate and inform you of our firm commitment to privacy. The Policy describes how we collect, protect and use information we receive consumers, prospective consumers, or employees (which includes but is not limited to, current employees, job applicants, or sub-contracted employees) collectively referred throughout this Policy as (“consumer”) as they interact with Sinceri Senior Living’s Resources.  This Policy applies to information collected through Sinceri Senior Living’s Resources as well as information collected through any other means, including information consumers provide directly to Sinceri Senior Living. This Policy does not address the use of information that is subject to the Health Insurance Portability and Accountability Act (“HIPAA”). For information about how Sinceri Senior Living handles “protected health information” under HIPAA, please see https://sinceriseniorliving.com/hipaa-privacy-notice/. 

If you are a California resident, for more information about your additional privacy rights, please see the section of this Policy titled “California Privacy Rights. 

If you are a Virginia resident, for more information about your additional privacy rights, please see the section of this Policy titled “Virginia Privacy Rights. 

If you are a Colorado resident, for more information about your additional privacy rights, please see the section of this Policy titled Colorado Privacy Rights. 

If you are a Connecticut resident, for more information about your additional privacy rights, please see the section of this Policy titled Connecticut Privacy Rights. 

If you are a Nevada resident, for more information about your additional privacy rights, please see the section of this Policy titled Nevada Privacy Rights. 

If you are a Washington resident, for more information about your additional privacy rights, please see the section of this Policy titled “Washington Privacy Rights.” 

THE INFORMATION WE COLLECT 

Sinceri Senior Living collects directly from our consumers the following types of personal 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:  

  • Identifiers – this may include but is not limited to: your contact information, real name, alias, postal address, email address, online identifier or username, telephone number, social security number, driver’s license number, insurance policy number, or other similar identifiers. 
  • Contact and Financial Information – this may include but is not limited to: bank account number, debit card number, credit report information, and health information. 
  • Employment Related Information – this may include but is not limited to: compensation, bonuses, benefits, attendance, evaluations, performance reviews, discipline, personnel files, expenses, education, corporate credit card details, membership in professional organizations, professional certifications, work eligibility in order to comply with legal requirements, current and past employment history, employee preferences, such as preferred meals, seating and other travel preferences, desired work hours, work space preferences and preferred work supplies. 
  • Background Screening Information – this may include but is not limited to: background screening of criminal history or sex offender registration. 
  • Personal Information Categories From Cal. Civ. Code § 1798.80(e) – this may include but not limited to: photographs and physical description, medical information and benefits information.  
  • Internet and Electronic Network Activity Information – this may include but is not limited to: browsing history, search history, and information regarding Consumer’s interaction with our website or advertisement, IP Addresses assigned to your computer by your Insert Service Provider.  Web servers automatically identify your computer by its IP address. We use your IP address to help diagnose problems with our server, to administer Sinceri Senior Living’s Resources, avoid hacking attacks on Sinceri Senior Living’s Resource’s including our website servers, and may use it to gather broad demographic information. 
  • Protected Characteristics – this may include but is not limited to: sex, race, ethnicity, military/veteran status, marital status, religion, and disability. 
  • Geolocation Data – this may include but is not limited to: Although we do not collect precise physical location, we may collect information on your region or postal code, personnel device location, personnel movements, or personnel travel patterns. 
  • Commercial Information – this may include but is not limited to: transaction information, records of purchase history or purchase tendencies. 
  • Audio, Electronic, or Visual Information – this may include but is not limited to: video recording in communications or surveillance on a Sinceri Senior Living owned or managed community premises. 
  • Inferences from Personal Information Collected – this may include but is not limited to: creating consumer profiles reflecting preferences and predispositions. 
  • Education Information – this may include but is not limited to: education history, professional qualifications, work history and prior employer information. 
  • Anonymous Information – Anonymous Information is aggregate data that websites use to administer their website. It may include such information as your browser type or your Internet Protocol (IP) address. We may from time to time retain third parties to help us collect and aggregate visitor information on our website and through Sinceri Senior Living’s Resources. 
  • Sensitive Personal Information (“SPI”) – Sensitive Personal Information is personal information that reveals: Sensitive Personal Information (“SPI”) – Sensitive Personal Information is personal information that reveals:    
  • Social security number, driver’s license, state identification card or passport number; 
  • 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; 
  • Your precise geolocation; 
  • Your racial or ethnic origin, religious or philosophical beliefs, or union membership; 
  • Contents of your mail, email, and text messages unless  Sinceri Senior Living is the intended recipient of the communication; 
  • Genetic data; 
  • Biometric information used to identify a consumer; 
  • Health information; and 
  • Information regarding a consumer’s sex life or sexual orientation. 

 

Personal information does not include: 

(1) De-identified or aggregated information (which Sinceri Senior Living does not attempt to re-identify); 

(2) information that is lawfully made available from federal, state, or local government records, or information that Sinceri Senior Living has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media; or information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience; and 

(3) information excluded from the California Consumer Privacy Act (“CCPA”), such as health or medical information covered under HIPAA, medical information governed by the California Confidentiality of Medical Information Act, personal information disclosed pursuant to the Driver’s Privacy Protection Act of 1994 (“DPPA”), financial information covered under the Fair Credit Reporting Act (“FCRA”) or Gramm-Leach Bliley Act (“GLBA”). 

Sensitive Personal Information does not include publicly available information. 

When you submit your information on Sinceri Senior’s Resources, you agree to be contacted by a Sinceri Senior Representative at the telephone number you’ve provided, in response to your inquiry, between the hours of 7AM and 11PM ET. You agree that we may use automatic telephone dialing systems and technology to contact you by phone or text message at the telephone number provided, and send you email notifications regarding promotions and related material on senior living. 

 

HOW WE COLLECT INFORMATION 

There are several different ways Sinceri Senior Living collects your personal information.  The categories of sources in which may have collected your personal information includes the following: 

  • Directly from you via conversations, your interaction on our website, mail, e-mail, faxes, voicemails, and any documentation provided by you; 
  • Business transactions where we may buy, merge or partner with other companies or businesses, and in doing so, we would acquire consumer information.  
  • Directly from you via employment applications or employment contracts; 
  • Vendors, such as marketing advertising vendors, data analytic vendors, website analytic providers, professional service vendors, customer service vendors, banking and financial partners, and marketing firms; 
  • Social media platforms and networks; 
  • Healthcare providers; 
  • Referral agencies; and 
  • Government agencies 

HOW WE USE AND DISCLOSE COLLECTED INFORMATION 

The personal information collected by us may be used in a several ways including the following business and commercial purposes: 

  • Providing our services; 
  • Providing customer service; 
  • Providing you with promotional materials such as notifying you regarding certain services we provide, programs we provide and events that we are having; 
  • Understanding what information and services consumers want the most; 
  • Providing business support to Sinceri Senior operations; 
  • Performing analytics and quality control; 
  • To conduct internal investigations and audits; 
  • Researching and testing features and improvements; 
  • Detecting and preventing fraud and security incidents; 
  • Debugging or repairing technical errors; 
  • Marketing our services; 
  • Managing personnel; 
  • Recruiting purposes such as evaluating applicants’ qualifications for employment, communicating with applicants, for diversity and inclusion purposes, and for record keeping purposes. 
  • Security and internal identification purpose; 
  • Conducting legal analysis; 
  • To comply with any applicable laws, regulations or statutory requirements; 
  • Business transfers; in the unlikely event that a portion or substantially all of Sinceri Senior’s assets are sold or transferred to a third party, personal information would likely be transferred business assets; 
  • Developing and managing relationships with current or new business partners, vendors and other business partner personnel 

CATEGORIES OF INFORMATION WE COLLECT AND DISCLOSE 

The following chart provides information about the types of personal information we collect, the categories of sources from whom we collected the information, the business or commercial purposes for which collected the information, whether the information has been disclosed for a business purpose, and the categories of third parties with whom we have shared this information in the last 12 months. 

 

Type of Information  Categories of Sources  Business or commercial purposes for collection  Disclosed for a Business Purpose?  Third parties to whom Disclosed for Business Purpose 
Identifiers and Categories of Personal Information Under State Law – this may include but not limited to: contact information, real name, alias, postal address, email address, online identifier or username, telephone number, social security number, driver’s license number, insurance policy number, photographs and physical description, medical information and benefits information or other similar identifiers  Directly from the consumer; 

Vendors; 

Social Media Platforms and Networks; 

Healthcare providers; 

Referral agencies; and 

Government agencies 

As described above, e.g., to provide you with services, marketing our services, and for internal purposes such as managing personnel and employment matters.  Yes  Internet service providers; 

Analytics providers; 

Advertising networks; 

Healthcare providers; Professional services providers; 

Government agencies; and 

Sinceri Senior Living subsidiaries 

Contact and Financial Information – this may include but is not limited to: bank account number, debit card number, credit report information, health information  Directly from the consumer; 

Vendors; 

Social media platforms and Networks; 

Healthcare providers; 

Referral agencies; and 

Government agencies 

As described above, e.g., to provide you with services, complete transactions, legal reporting requirements and for internal purposes  Yes  Internet service providers; 

Healthcare providers; 

Financial and banking partners; 

Professional services providers; 

Government agencies; and 

Sinceri Senior Living subsidiaries 

Internet and Electronic Network Activity Information – this may include but is not limited to: browsing history, search history, and information regarding consumer’s interaction with our website or advertisements  Vendors; 

Social media platforms and networks 

For internal purposes such as quality assurance audits and security audits, and for marketing purposes  Yes  Internet service providers; 

Analytics providers; 

Advertising networks; 

and 

Sinceri Senior Living  subsidiaries 

Protected Characteristics – this may include but is not limited to: sex, race, ethnicity, military/veteran status, marital status, religion, and disability  Directly from the consumer; 

Social media platforms and networks; 

Healthcare providers; 

and 

Government agencies 

As described above, e.g., internal reporting and analytics purposes  Yes  Analytics providers; 

Healthcare providers; 

Professional services providers; 

Government agencies; and 

Sinceri Senior Living  subsidiaries 

Geolocation data – this may include but is not limited to physical location based upon your designated market area, region or postal code, device location, movements, or travel patterns  Platforms, including electronic device applications  For internal purposes such managing employee related emergencies and to monitor for compliance with Sinceri Senior Living policies, and for marketing purposes.  Yes  Internet service providers; 

Analytics providers; 

Advertising networks; and Sinceri Senior Living  subsidiaries 

Commercial Information – this may include but is not limited to: transaction information, records of purchase history or purchase tendencies  Directly from the consumer; 

Vendors; 

Referral agencies; and 

Government agencies 

As described above, e.g., for internal purposes, and marketing purposes.  Yes  Internet service providers; 

Analytics providers; 

Advertising networks; 

Professional services providers; 

Government agencies; and 

Sinceri Senior Living  subsidiaries 

Audio, Electronic, or Visual Information – this may include video recording in communications and audio recordings  Directly from consumer, directly from Sinceri Senior Living  locations; and 

Social media platforms and networks; 

Operational, safety and other business purposes; for internal training and quality assurance purposes.  Yes  Healthcare providers; 

Professional services providers; 

Government agencies; and 

Sinceri Senior Living  subsidiaries 

Inferences from Personal Information Collected – this may include but is not limited to: creating consumer profiles reflecting preferences and predispositions  The original sources are the above sources of the underlying data that is compiled and directly from the consumer.  As described above, in order to facilitate more targeted marketing, as well as for internal reporting, managing personnel and employment matters and analytics purposes  Yes  Analytics providers; 

Advertising networks; 

and 

Sinceri Senior Living  subsidiaries 

Employment and Professional Information  The original sources are the above sources of the underlying data that is compiled and directly from the consumer  To manage personnel and employment matters; to conduct monitoring, security and compliance, and to conduct our business and provide our services  Yes  Professional services providers; Government agencies; and Sinceri Senior Living  subsidiaries 
 

Background Screening Information 

 

The original sources are the above sources of the underlying data that is compiled and directly from the consumer and Government Agencies  To manage personnel and employment matters; to conduct monitoring, security and compliance, and to conduct our business and provide our services  Yes  Professional services providers; Government agencies; and Sinceri Senior Living  subsidiaries 
Sensitive Personal Information including: Social security number, driver’s license, state identification card or passport number; Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email, or text messages where Sinceri Senior Living  is not the intended recipient   Directly from the consumer; 

 

Vendors; Social media platforms and networks; Healthcare providers; Referral agencies; and Government agencies 

Internal reporting and analytics purposes, and providing our services.  Yes  Healthcare providers; Professional services providers; Government agencies; and Sinceri Senior Living  subsidiaries 

 

SALE AND DISCLOSURE OF PERSONAL INFORMATION FOR TARGETED ADVERTISING  

Sinceri Senior Living does not directly sell your personal information, we may share your personal information with third parties outside of Sinceri Senior Living as described below.  Certain states have adopted laws that contain a broad definition of “sale” or “share” and may view certain disclosures of personal information as sales or sharing under their respective definitions.  

For California consumers, in the previous 12 months, we have disclosed your personal information for cross-contextual or behavioral targeted advertising (which may constitute as “sale” or “sharing” under the California law), and we may continue to disclose, the following categories of personal information for the identified business or commercial purpose: 

Types of Personal Information  Sold or Disclosed for Targeted Advertising  Third Parties to Whom Sold or Disclosed for Targeted Advertising  Business or Commercial Purposes for Selling or Disclosing for Targeted Advertising 
Identifiers  Disclosed for Targeted Advertising  Shared with Analytics Providers and Marketing and Advertising Providers 

 

As described above, e.g., for Marketing and advertising our services and internal purposes. 
Internet and Electronic Network Activity Information  Disclosed for Targeted Advertising  Shared with Analytics Providers and Marketing and Advertising Providers  As described above, e.g., for Marketing and advertising our services and internal purposes. 
Inferences from Personal Information 

 

Disclosed for Targeted Advertising  Shared with Analytics Providers and Marketing and Advertising Providers  As described above, e.g., for Marketing and advertising our services and internal purposes. 
Geolocation data  Disclosed for Targeted Advertising  Shared with Analytics Providers and Marketing and Advertising Providers  As described above, e.g., for Marketing and advertising our services and internal purposes. 
Self-reported assisted living needs  Disclosed for Targeted Advertising  Shared with Analytics Providers and Marketing and Advertising Providers  As described above, e.g., for Marketing and advertising our services and internal purposes. 
Income  Disclosed for Targeted Advertising  Shared with Analytics Providers and Marketing and Advertising Providers  As described above, e.g., for Marketing and advertising our services and internal purposes. 
Current Living Needs  Disclosed for Targeted Advertising  Shared with Analytics Providers and Marketing and Advertising Providers  As described above, e.g., for Marketing and advertising our services and internal purposes. 

 

RETENTION OF PERSONAL INFORMATION 

Sinceri Senior Living will retain the information gathered in the above table as long as it is reasonably necessary for each disclosed purpose unless longer retention period is required by law.  

YOUR CHOICES REGARDING COLLECTION, USE AND SHARING OF PERSONAL INFORMATION 

Sinceri Senior Living supports the right of our visitors to choose. If you decide that you do not wish to receive special offers or promotional communications, you can contact us at info@SinceriSL.com or at the address provided below, indicating that you would like to opt-out and no longer want to receive information relating to Sinceri Senior Living’s Resources.  

Depending on your state of residency, you may have rights regarding your personal information, which are described below, and may include rights to correct, amend or delete your personal information. If you wish to exercise these rights, or make a request regarding your personal information, please contact us by email or postal mail at the addresses below or as described in the Exercising Your Rights section. 

If you have consented to a use of your personal information and would like to revoke that consent, or would like to opt out of emails or other marketing, please contact us. Although it is not always possible to remove or modify certain information, we will make reasonable efforts to do so. 

To make such a request, you may send an email or contact us by regular mail: 

800.254.9442 

info@SinceriSL.com 

Sinceri Senior Living 

5101 NE 82nd Ave. 

Suite 200 

Vancouver, WA 98662 

   

EXERCISING YOUR RIGHTS 

You can exercise the rights mentioned in this Policy by submitting a verifiable consumer request. 

To make such a request, you may send an email or contact us by regular mail: 

To make such a request, you may send an email or contact us by regular mail: 

800.254.9442 

info@SinceriSL.com 

Sinceri Senior Living 

5101 NE 82nd Ave. 

Suite 200 

Vancouver, WA 98662 

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to, correction of and/or deletion of your personal information, we may require you to provide additional information to help us identify you. 

Consumers may designate an authorized agent to make a request on their behalf. We will deny requests from agents that do not submit proof of authorization from you. To verify that an authorized agent has authority to act for you, we may require a copy of a power of attorney or require that you provide the authorized agent with written permission and verify your own identity with us. 

 

SECURITY 

Sinceri Senior Living’s Resources incorporates appropriate safeguards to protect the security, integrity, completeness, accuracy and privacy of the personal information we have collected. We have put in place reasonable precautions to protect information from loss, misuse and alteration. While on a secure page, the lock icon on the bottom of Web browsers such as Google Chrome, Mozilla Firefox and Microsoft Internet Explorer becomes locked, as opposed to unlocked, or open, when you are just “surfing”. Security of information communicated by or to us over the Internet is of utmost concern to us; unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Please note that your email or other electronic correspondence with us through Sinceri Senior Living’s Resources, like most, if not all, non-encrypted Internet communications, may be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to us. For that reason, to protect your privacy, please do not use email or the contact forms provided through Sinceri Senior Living’s website to communicate information to us that you consider confidential. While we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or through Sinceri Senior Living’s website, and you do so at your own risk. Once we receive your transmission, we will use reasonable efforts to ensure its security on our internal systems. Depending on the nature of the inquiry, your communication may be discarded or archived. If you wish, you may contact us instead via telephone at the numbers provided throughout Sinceri Senior Living’s Resources. 

 

OUR COMMITMENT TO CHILDREN’S PRIVACY 

Protecting the privacy of children is very important to us. The Children’s Online Privacy and Protection Act of 1998 (“COPPA”) defines a “Child” as anyone under the age of 13. We do not collect or maintain information obtained through Sinceri Senior Living’s Resources from those we actually know are under 13, and no part of Sinceri Senior Living’s Resources is structured to attract anyone under 13. If we learn that a visitor is under 13 and has submitted personal information to us, we will delete that information promptly or seek verifiable parental or legal guardian consent to retain such information. 

 

EXTERNAL LINKS 

Sinceri Senior Living’s website may provide links and/or ad banners to various websites or sponsors that we do not control for your convenience. When you click on one of these links, you will be transferred out of Sinceri Senior Living’s website and connected to the website of the organization or company that you selected. We are not responsible for the nature, quality or accuracy of the content or opinions expressed in such websites, and such websites are not investigated, monitored or checked for quality, accuracy or completeness by us. Inclusion of any linked website on Sinceri Senior Living’s Resources does not imply or express an approval or endorsement of the linked website by us, or of any of the content, opinions, products or services provided on these websites. Even if an affiliation exists between the Sinceri Senior Living’s Resources and a third-party website, we exercise no control over the linked website. Each of these linked websites maintains its own independent privacy and data collection policies and procedures. While we expect our partners, advertisers and affiliates to respect the privacy of our users, we cannot be responsible for the actions of third parties. If you visit a website that is linked to Sinceri Senior Living’s Resources, we encourage you to consult that website’s privacy policy before providing any personal information and whenever interacting with any website. 

 

CONSENT AND JURISDICTION 

Sinceri Senior Living’s Resources are controlled, operated and administered entirely within the United States. By using Sinceri Senior Living’s Resources, you signify your agreement to the terms of this Policy. If you do not agree with this Policy, please do not disclose any personal information through Sinceri Senior Living’s Resources. This Policy and the use of Sinceri Senior Living’s Resources are governed by Washington state law. Any claim related to Sinceri Senior Living’s Resources or this Policy shall be brought in a federal or state court in Washington, within one year after the claim arises. Users of Sinceri Senior Living’s Resources consent to the jurisdiction and venue of such courts as the most convenient and appropriate for the resolution of disputes concerning this Policy. This Policy and the notices outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any third party. 

 

MODIFICATIONS TO OUR PRIVACY NOTICE 

We may change, modify, add and/or delete all or portions of this Policy at any time, at our discretion, and modifications are effective upon being posted on Sinceri Senior Living’s Resources. If we decide to change this Policy, we will post those changes on the home page of Sinceri Senior Living’s Resources 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 Policy periodically to ensure that you are aware of any changes to it. If we make material changes to this Policy, we will notify you by means of a notice on the Sinceri Senior Living’s website’s home page. 

 

CONTACT US 

We welcome your questions, comments and feedback pertaining to your privacy.  In the event you have any questions and need to contact us regarding your privacy, please contact us. 

To make such a request, you may send an email or contact us by regular mail: 

800.254.9442 

info@SinceriSL.com 

Sinceri Senior Living 

5101 NE 82nd Ave. 

Suite 200 

Vancouver, WA 98662