Washington Privacy Rights

This Sinceri Washington Consumer Health Data Privacy Policy (“Policy”) provides information regarding how JEA Senior Living, LLC, DBA Sinceri Senior Living and its affiliates and subsidiaries (collectively, the “Sinceri Companies,” “we,” “us,” “our,” or “Company”) process consumer health data subject to Washington’s My Health My Data Act (“WMHMDA”). 

This Policy applies, subject to several exceptions, to personal information that is linked or reasonably linkable to the two categories of individuals noted below and that identifies your past, present or future physical or mental health status within the meaning of the WMHMDA. It applies only if a person is: 

  • A resident of the State of Washington; or 
  • An individual about whom information is collected in the State of Washington.  

 

We refer in this Policy to this data as “Washington consumer health data.” 

Note that this Policy does not apply to personal information that is not subject to the WMHMDA, including to information that is specifically exempted from the WMHMDA, which includes, among other things, protected health information subject to the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations. 

Additional information relating to how we process data not subject to the WMHMDA is available in the Privacy Policy (“Privacy Policy”) available online 

We collect Washington consumer health data in connection with our services and products and the type of Washington consumer health data depends on the specific service or product offering that you use or receive and your interaction with us. Examples of Washington consumer health data that we collect may include: 

  • 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 JEA’s Resources, avoid hacking attacks on JEA’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 JEA 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 JEA’s Resources. 
  • 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 JEA 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. 

 

 Washington consumer health data does not include data related to the shopping habits or interests of a consumer, where that information is not used to identify the specific past, present or future health status of the consumer. For example, if you search for or shop for health-related items on one of our sites or read an article about a health- related condition or service, we do not consider associated data consumer health data where it is not used to infer or identify your specific past, present or future health status. 

We primarily collect and use Washington consumer health data as necessary to provide you with the requested products or services. This may include, as further described in the Privacy Policy, the following: 

  • 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 JEA 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 JEA’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 

We may deidentify or anonymize Washington consumer health data so that it cannot reasonably be reidentified by us or by another person, and we may use this deidentified data for any reason permitted by applicable law. 

We may share each of the categories of Washington consumer health data described in this Policy as necessary to provide you with a product or service you request, with your consent, or for certain security-related purposes, as described above and as described further in the section on CATEGORIES OF INFORMATION WE COLLECT AND DISCLOSE in the Privacy Policy, such as: 

  • with our subsidiaries and affiliates; 
  • with service providers; and 
  • to facilitate a business transfer. 

 

As described further in the section on CATEGORIES OF INFORMATION WE COLLECT AND DISCLOSE in the Privacy Policy, we collect your information, which may include your Washington consumer health data, directly from you, automatically as you interact with our websites and mobile applications, and from other third party or public sources. The specific sources of Washington consumer health data depend on the service or product offering that you use and your interaction with us. 

As necessary for the purposes described above, we share Washington consumer health data with the following categories of third parties who are detailed in the section titled CATEGORIES OF INFORMATION WE COLLECT AND DISCLOSE, including: 

  • Sinceri Companies; 
  • service providers; 
  • parties to a business transfer; 
  • third parties, as required or expressly permitted by law, such as government agencies and law enforcement in response to legal process or other third parties as necessary to protect the Company, our users, and the public; 
  • other third parties as necessary to provide the services or products you requested; 
  • financial institutions and payment processors when you make a purchase or enter into a financial transaction; 
  • other users and individuals at your direction; and 
  • the public via voluntary collaboration areas. 

We will not sell Washington consumer health data unless we have a separate written authorization from you to do so. 

By default, when you use our online services, we will not share Washington consumer health data to third parties so those third parties can collect Washington consumer health data over time and across different websites or online services. We will only share this data when we have a separate written authorization from you to do so. Nonetheless, please note that third parties may still be able to collect consumer health data from you over time and across different websites depending on your browser, browser add-ons, and permissions you set on your device. Data collected by those third parties is unrelated to our collection of Washington consumer health data from you, and we recommend reviewing those third parties’ privacy notices for more information about their collection methods to opt of such collection. 

Under the WMHMDA, subject to certain exceptions, you may have the right to access or delete Washington consumer health data about you or receive a list of third parties and affiliates with whom your Washington consumer health data was shared or sold (with authorization). You also may have the right, subject to certain exceptions, to withdraw consent relating to the use, sharing, or selling (with authorization) of your Washington consumer health data. To exercise these rights, you may submit a request as outlined in our Privacy Policy or below. You may be required to submit proof of your identity for these requests to be processed. We will not be able to comply with your request if we are unable to confirm your identity. You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization. 

If you have questions about this Policy or would like to make a complaint, you can contact us at: 

JEA Senior Living 

5101 NE 82nd Ave. 

Suite 200 

Vancouver, WA 98662