California Consumer Privacy Statement

Sunrise Senior Living

CALIFORNIA CONSUMER PRIVACY STATEMENT 

Effective: January 1, 2020

This California Consumer Privacy Statement supplements the www.sunriseseniorliving.com Privacy Policy.  It applies solely to California consumers and addresses personal information we collect online and offline. This statement does not apply to (i) Sunrise personnel or job applicants seeking employment opportunities at Sunrise, or (ii) personnel working on behalf of business partners with whom we are conducting business.
  
This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”). 

             1. Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you: 

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, Social Security number, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, medical history, which could include ancestry, genetic information, disability, citizenship status, and military and veteran status
  • Commercial Information: commercial information, including records of account and payment history with Sunrise
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Geolocation Data
  • Sensory Information: audio, electronic, visual, and similar information 
  • Employment Information: professional or employment-related information 
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, behavior, or abilities.
We may use the categories of personal information listed above for the purposes described above in this Privacy Policy.  In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table: 

 

Purposes

Categories of Personal Information

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; and Inferences

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; and Inferences

Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Sensory Information; and Inferences

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information

Debugging to identify and repair errors that impair existing intended functionality

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information

Undertaking internal research for technological development and demonstration

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Employment Information; and Inferences

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences


       2. Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement.  For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose. 

          a. Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection

Categories of Personal Information

Directly from you or your device, such as through your use of our website, when you send us an email, visit or stay in our Communities, or otherwise communicate or interact with us

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences

Individuals, such as your family members or friends who may inquire about our services or other individuals who may refer you to us

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Employment Information; and Inferences

Your medical or care providers

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; and Inferences

Vendors to whom you have provided your information

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Employment Information; and Inferences

Advertising and social networks

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; and Inferences


          b. Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties

Categories of Personal Information

Our affiliates, owners, and licensees of our facilities

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; and Inferences

Vendors who provide services on our behalf

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; and Inferences

Professional services organizations, such as auditors and law firms

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Sensory Information; Employment Information; and Inferences 

Advertising and social networks and data analytics providers

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences

Government entities, including licensing  enforcement agencies

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; and Employment Information


          c. Sale of Personal Information

We do not sell your personal information in exchange for monetary compensation.  We may allow our online advertising providers to collect your personal information via cookies placed on our website in exchange for non-monetary consideration (such as an enhanced ability to serve you content and advertisements that may be of interest to you).  The categories of personal information that may have been collected in this manner include Identifiers, Online Activity and Inferences.  You have the right to opt out of this collection of your information by our online advertising providers by clicking here: 


We do not sell the personal information of minors under 16 years of age if we have actual knowledge of the individual’s age. 

          d. Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties for a business purpose the following categories of personal information about you: 

  • Sunrise discloses for a business purpose all the categories of personal information about you described in Section 1 above.
          e. California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below:

  • Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
  • Deletion: You have the right to request that we delete certain personal information we have collected from you.
  • Opt-Out of Sale:  You have the right to opt-out of the sale of your personal information.
  • Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.
How to Submit a Request:  To submit a request, email us at CCPAinfo@sunriseseniorliving.com, or call us at (866) 354-4812. To opt-out of the sale of your personal information email us at CCPAinfo@sunriseseniorliving.com.

Verifying Requests: 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 or deletion of your personal information, we may require you to provide certain information to help us identify you.  In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information: The CCPA prohibits discrimination against a consumer because the consumer exercised any of the consumer’s rights under the CCPA. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact CCPAinfo@sunriseseniorliving.com to request this Statement in an alternative format.