This privacy policy (the “Privacy Policy”) explains the collection, use, and disclosure practices of the websites, mobile applications, and other online and offline products and services, including, without limitation, our senior living referral services (collectively, the “Services”) owned and operated by A Place for Mom, Inc., A Place for Mom Canada Inc., and/or any of their affiliates (“APFM,” “we,” “us,” or “our”). For clarity, this Privacy Policy describes how we collect and use information when you access and use our websites, including but not limited to www.assistedliving.com; www.alzheimers.net; www.nursinghomes.com; www.agingcare.com; www.veteranaid.org; www.senioradvisor.com; www.OurParents.com and www.caregivers.com (individually and collectively, the “Site” or “Sites”). For the purposes of this Privacy Notice, “you” and “your” mean you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy. Please be advised that the practices described in this Privacy Policy also apply to how we handle information that you submit to us offline.

CONSENT

Privacy Policy. By using our Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Notice, please do not use or access the Services.

Phone Calls. By providing us with your telephone number through your use of our Services, you agree to be contacted by APFM and contracted senior care network providers to explore options relating to our Services. You agree to be contacted by telephone call or text message at the telephone number you provided, even if you previously registered on a Do Not Call registry.

COLLECTION & USE OF YOUR INFORMATION

We collect information from four primary sources: directly from you, automatically from your use of our Services, from third parties, and by using information we collect to derive new information. The types of information we collect about you depend on your interactions with us and are described in more detail below.

Information We Collect Directly from You. We collect information directly from you in a variety of ways. Any information you provide to us is voluntary, but some information may be necessary for us to provide you with our Services. The categories of information we collect directly from you may include:

Identifiers, such as your first name, last name, phone number, email address, and mailing address;
Health information, such as whether you have health insurance, whether you receive Medicare or Medicaid, medical conditions and history, disability information, and medical care needs;
Characteristics such as age, sex/gender, marital status, veteran status, ethnicity and religion;
Account information, such as your username and password;
Financial information, including your budget for senior care options and income;
Commercial information, including records of services provided to you by senior care network providers and your move-in status;
Information you choose to include in communications with us, including in response to surveys or through our customer service centers; and
User-generated content, such as reviews, submitted by you through our Sites (“UGC”). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Others may also have access to UGC and may have the ability to share it with third parties. If you choose to submit your UGC to any public area of the Services, your UGC will be considered “public” and will be accessible by anyone, including us.

You may also provide information to us about another person for whom you may be seeking the Services (“Resident”).

Identifiers, such as their first name, last name, phone number, email address, and mailing address;
Health information, such as whether they have health insurance, whether they receive Medicare or Medicaid, medical conditions and history, disability information, and medical care needs;
Characteristics such as their age, sex/gender, marital status, veteran status, ethnicity and religion;
Financial information, including their budget for senior care options and income; and
Commercial information, including services provided to them by senior care network providers and records of their move-in status.

Information Automatically Collected from Your Use of the Sites. We automatically collect information about you from your use of our Services, including by using website analytics tools or other technologies, like cookies and web beacons (which are described in more detail below).

The categories and types of information we collect automatically from your use of the Services include:

Identifiers, such as your IP address and unique device identifiers;
Internet or other electronic network activity information, such as the type of browser you use, app version, access dates and times, pages viewed, and the page you visited before navigating to our Sites;
Approximate geolocation data, such as the country from which you access our Sites;
Other information that relates to or is capable of being associated with you, such as information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, and mobile network information.

Cookies. Cookies are small text files that are stored on your computer when you visit certain online pages that record your preferences. We use cookies to track use of our Sites and other Services. We may also use cookies to monitor traffic, improve the Sites, make the Sites easier and/or relevant for your use, and improve the performance of our advertising on other websites. You can opt out of accepting cookies by adjusting your browser settings to not accept cookies or to notify you when you are sent a cookie. However, certain features of our Sites or other Services may not work if you delete or disable cookies.

Web Beacons. Some pages of our Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email, and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of your information when you visit various websites. To learn more about “do not track” signals, you can visit http://www.allaboutdnt.com/. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/.

To learn more about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit https://www.aboutads.info/choices. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

INFORMATION WE COLLECT FROM OTHER SOURCES

We may collect information about you from other sources. For example, we may collect information about you from:

From senior care network providers;
Third-party social media services, such as Facebook, Twitter, and Instagram, that you use to interact with our Services (e.g., to provide feedback on our Services) or that allow you to share information (e.g., via plugins, widgets, or other tools);
Analytics data we receive from analytics providers, which may include, without limitation, Google Marketing Platform, Amplitude, Segment, Content Square; and
Advertising networks, which may include, without limitation, Google Ads, Microsoft Ads, Meta Ads, Amazon Ads

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Links to Third Parties.

INFORMATION WE INFER

We may derive information or draw inferences about you based on the other information we collect about you. For example, we may infer your location from our collection of your IP address.

In addition to the specific uses described above, we may use any of the above information to provide you with the Services and to maintain our business relationship, including by enhancing the safety and security of our Services (e.g., troubleshooting, data analysis, testing, system maintenance, and reporting), providing customer support, sending service and other non-marketing communications, monitoring and analyzing trends, conducting internal research and development, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting the Services, our rights, and the rights of our employees, users or other individuals.

Finally, we may de-identify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be reasonably linked to you (“de-identified information”). We may also collect information about you that has already been de-identified/anonymized. We may use such de-identified information for any purpose, including but not limited to, sharing or selling to third parties for their own use. To the extent we possess or process any de-identified information, we will maintain and use such information in de-identified/anonymized form and not attempt to re-identify the information, except solely for the purpose of determining whether our de-identification/anonymization process satisfies legal requirements.

USE OF YOUR INFORMATION

For each category of information we collect about you or Resident (whether directly or automatically), we use such category of information for the purposes set forth below:

To provide you with the Services;
Communicate with you, including by telephone, text, email, and chat, regarding the Services;
Send advertising or marketing communications about products, services, offers, promotions, rewards, and events offered by us and our partners and other third parties to provide news and information that we believe may be of interest to you;
Offer and administer surveys, contests, prize draws, sweepstakes, and other promotions;
Conduct internal research and development;
Target or retarget advertisements to you on third-party platforms and websites;
Analyze your engagement with APFM and senior care network providers and your use of our Services to better understand your interests and behaviors and customize your experience;
Detect security incidents and protect against malicious, deceptive, or illegal activity, error, and negligence, and to protect against harm to the rights, property, or safety of APFM and our users, customers, employees, or the public;
Debug, identify, and repair errors that impair the functionality of our Services;
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with our business;
Comply with our legal obligations, including our tax obligations and those related to the prevention of fraud, and those required for you to benefit from rights recognized by law or any regulatory requirements or provisions; and
With our legal, financial, insurance, and other advisors in connection with the kinds of transactions described above or in connection with the management of all or part of APFM’s business or operations.

DISCLOSURE OF INFORMATION

We will disclose your information to third parties for legitimate purposes, subject to this Privacy Policy, including the following categories of third parties:

To Senior Care Network Providers. As your referral agent, we may disclose information about you as a Resident or as a person seeking Services on behalf of a Resident to senior care network providers to provide you with the Services. The senior care network providers may contact you directly via email, telephone, text, regular mail, or in-person visits.

To Partners. We may disclose your information to partners so that they can provide services to you; however, we do not disclose this information without first confirming that you wish to receive their services. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes unless you request that we do so. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties for marketing/promotional purposes.

To People Acting On Your Behalf. We may disclose information to the person who referred you as a Resident or to another person acting on your behalf.

To Our Service Providers and Vendors. We may disclose information to our service providers and vendors who help us provide the Services, including system administration, cloud storage, security, customer relationship management, marketing communications, and web analytics.

To Marketing Providers. We may disclose your information for marketing purposes.

To Affiliated Companies or Others Within Our Corporate Group. We may disclose your information to our parent company, subsidiaries, joint ventures, or other companies under common control with us.

For Legal and Other Compliance. We may disclose information when we believe it is appropriate for legal purposes, including to: (a) comply with the law; (b) enforce or apply this Privacy Policy or our other policies or agreements; (c) protect our or our users’ rights, property, or safety; (d) protect our users from fraudulent, abusive, or unlawful use of our Site; or (e) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

As Part of Business Transfers. We may disclose information as part of any merger, acquisition, debt financing, sale, or transfer of company assets, or other business transaction. In the event of a merger, acquisition, restructuring, reorganization, or other sale or transfer of some or all of company assets, your information may be part of the assets that will be transferred.

As Aggregated, Anonymized Information. We may disclose aggregated, anonymous, or de-identified information to our advertisers, business partners, and other third parties. This information cannot reasonably be used to identify you and may be shared or sold to third parties for their own use.

At your request. We may otherwise disclose information with your consent or at your direction, such as through your use of social media widgets or login integration.

PRIVACY RIGHTS

Depending on where you live, you may have some or all of the privacy rights listed below relating to information we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law, including if, in the event you reside in a state that does not currently grant you these rights.

Access, Correction, and Deletion

You may have the right to (1) request that we confirm whether we process information about you and give you access to that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment, (2) request deletion of your information, and (3) request correction of inaccurate information.

You have a right to request the following information about our collection, use, and disclosure of your information:

categories of information we have collected, disclosed for a business purpose, sold, or shared;
categories of sources from which we collected personal information;
the business or commercial purposes for collecting, selling, and/or sharing information;
categories of third parties to whom the personal information was disclosed for a business purpose, sold, or shared
specific pieces of information we have collected.

Opting Out of Targeted Advertising

We process information to understand and improve your experience with our Services and to serve you advertisements on non-APFM web properties. These activities may result in our engaging in targeted advertising. You have the right to opt out of targeted advertising by clicking here. You may need to renew your opt-out choice if you use a different browser or device to access our Services, or if you clear your cookies.

Opting out of Sharing and Sales

You have the right to direct us not to sell or share your personal information. To exercise this right, please use the following form: Do Not Sell My Personal Information.

Nondiscrimination

We will not discriminate against you for exercising your privacy rights, however, we cannot provide you with some of our Services if you do not share certain information.

How to Exercise Your Rights

You may exercise any of these rights by contacting us via email at privacy@aplaceformom.com or by visiting our privacy portal.

We may verify your request by asking you to provide information related to your recent interactions with us, such as by confirming your email address and/or your state of residence, before providing a substantive response to your request. In some cases, we may need to collect additional information to verify your identity, such as a government-issued ID. If we deny your request, you may appeal our decision by contacting us at privacy@aplaceformom.com. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfill your request or process your appeal. We will not require you to pay a fee for the verification of your request or appeal.

Authorized Agents

You may designate an authorized agent to exercise these rights on your behalf by providing your authorized agent with written permission to act on your behalf and by verifying your own identity with APFM. Alternatively, you may provide a power of attorney pursuant to Probate Code sections 4000 to 4465. We may verify your request by asking you to provide information related to your interactions with us, such as by confirming your email address and/or your state of residence. In some cases, we may need to collect additional information to verify your identity, such as a government-issued ID. If you are an authorized agent seeking to make a request, please contact us via email at privacy@aplaceformom.com or by visiting our privacy portal. We will not require your authorized agent to pay a fee for the verification of your request or appeal.

SOCIAL FEATURES

Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to access our pages on third-party platforms, and from there, “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, the information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. For more information, see the section below, Links to Third Parties.

LINKS TO THIRD PARTIES

We may provide links to third-party websites from our Sites, but we cannot control nor are we responsible for the privacy and data collection, use, and disclosure practices of third-party websites. When you click on links that take you to external websites, you will be subject to their privacy policies and practices and not ours. We encourage you to review and understand the privacy policies of such websites before providing them with any information.

SECURITY

We use reasonable security measures to store and protect your information while it is under our control. Please note, however, that no transmission of data over the internet is entirely secure. Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you use secure channels to send us sensitive or confidential information.

RECORDED TELEPHONE COMMUNICATIONS

Telephone communications between you and APFM may be recorded or monitored for quality control purposes or as required by state law. By participating in telephone communications with us, you expressly consent to the recording of these communications.

MINORS

Our Services are designed for adults, not persons under the age of 18. As such, we do not intend to collect personal information from persons under the age of 18, and our Services are not designed for such information. If we become aware that we have unknowingly collected information about a person under 18 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a person under the age of 18 who has provided us with their personal information, you may contact us using the information below to request that it be deleted.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section supplements this Privacy Policy for California residents and describes our data practices today and in the preceding 12 months. This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “Personal Information” shall include “Sensitive Personal Information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).

Processing of Personal Information

We collect the categories of Personal Information that are indicated in the table below. We collect this Personal Information from the following categories of sources: directly from you, automatically using certain technologies, and from third parties. For more information about the specific data points we collect and the sources from which we collect them, please see the Collection of Your Personal Information section above.

In the preceding 12 months, we have collected and disclosed your Personal Information and Sensitive Personal Information (denoted by *) as follows (described in more detail in the Use and Disclosure of Information sections above):

Category of Personal Information Collected	Purpose for Processing	Categories of Recipients
Identifiers: such as name, email, telephone number, physical address, and IP address	Providing the Services Communication Marketing and Advertising Conducting Analytics Protection and Compliance	Cloud storage service providers, marketing vendors, data analytics providers, internet service providers, email service providers, senior care network providers, and customer service providers
Personal Information Categories Listed in the California Customer Records Statute: such as name, physical characteristics, address, and telephone number	Providing the Services Communication Marketing and Advertising Conducting Analytics Protection and Compliance	Cloud storage service providers, marketing vendors, data analytics providers, internet service providers, senior care network providers, and email service providers, and customer service providers
Characteristics of Protected Classifications Under California or Federal Law: such as ethnicity, religion, sex (including gender and gender identity), age, physical or mental disability, and veteran status	Providing the Services Communication Marketing and Advertising Conducting Analytics Protection and Compliance	Cloud storage service providers, marketing vendors, data analytics providers, internet service providers, email service providers, senior care network providers, and customer service providers
Commercial Information: such as records of services provided to you by senior care network providers and your move-in status	Providing the Services Communication Marketing and Advertising Conducting Analytics Protection and Compliance	Cloud storage service providers, marketing vendors, data analytics providers, internet service providers, email service providers, senior care network providers, and customer service providers
Internet Or Other Electronic Activity Information: such as information regarding your interactions with the Sites	Providing the Services Communication Marketing and Advertising Conducting Analytics Protection and Compliance	Cloud storage service providers, marketing vendors, data analytics providers, internet service providers, senior care network providers, email service providers, and customer service providers
Geolocation Information: such as IP address	Providing the Services Communication Marketing and Advertising Conducting Analytics Protection and Compliance	Cloud storage service providers, marketing vendors, data analytics providers, internet service providers, senior care network providers, email service providers, and customer service providers
Audio: such as voice recordings of telephone communications	Providing the Services Communication Protection and Compliance	Cloud storage service providers, customer service providers
Financial Information: such as income and budget	Providing the Services Communication Marketing and Advertising Conducting Analytics Protection and Compliance	Cloud storage service providers, marketing vendors, data analytics providers, internet service providers, senior care network providers, email service providers, and customer service providers
Inferences Drawn from Personal Information	Providing the Services Communication Marketing and Advertising Conducting Analytics Protection and Compliance	Cloud storage service providers, marketing vendors, data analytics providers, internet service providers, email service providers, and customer service providers
Account Access Credentials*: such as account username and password	Providing the Services Communication Protection and Compliance	Cloud storage service providers, customer service providers
Ethnic origin and religious beliefs*	Providing the Services Communication Marketing and Advertising Conducting Analytics Protection and Compliance	Cloud storage service providers, marketing vendors, data analytics providers, internet service providers, senior care network providers, email service providers, and customer service providers
The contents of a resident’s mail, email, and text messages*	Providing the Services Communication Protection and Compliance	Cloud storage service providers, email service providers, and customer service providers
Personal Information concerning a resident’s health* such as medical conditions and medical history	Providing the Services Communication Marketing and Advertising Conducting Analytics Protection and Compliance	Cloud storage service providers, marketing vendors, data analytics providers, internet service providers, senior care network providers, email service providers, and customer service providers

Privacy Rights: Please see the Privacy Rights section above to learn more about your right to request access to your Personal Information, to request deletion or correction of your Personal Information, to request additional details about our information practices, to request to opt out of targeted advertising, “sales,” or “sharing” of your Personal Information, how to exercise those rights, and the right to not be discriminated against for exercising such rights.

Personal Information We “Sell” or “Share” (as defined by the CCPA): The CCPA requires that we provide transparency about Personal Information we “sell,” which, for purposes of the CCPA, broadly means instances in which APFM has disclosed Personal Information with partners and other third parties in exchange for valuable consideration, and “share,” which means to disclose for the targeted advertising purposes described above. We do not have actual knowledge that we “sell” or “share” (as those terms are defined under the CCPA and used throughout this section) personal information of residents under 16 years of age. However, we do sell and share certain categories of Personal Information and in the preceding 12 months, we have sold and shared the following categories of Personal Information to the following categories of third parties:

Category of Personal Information	Sold and/or Shared	Categories of Recipients
Identifiers	Shared	marketing vendors
Commercial information about the Services you request	Shared	marketing vendors
Internet or other electronic activity information	Shared	marketing vendors

For information about opting out of these “sales” or this “sharing,” please see the Privacy Rights section above.

Sensitive Personal Information: to the extent we collect Sensitive Personal Information, we use and disclose such information only as reasonably necessary to provide the Services.

Data Retention: We store Personal Information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy. To determine that period, we take into account a number of factors, including our legal and regulatory obligations, and whether we may need to retain Personal Information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes, and/or enforce our agreements.

ADDITIONAL INFORMATION FOR CANADIAN CONSUMERS

You have the right to submit a complaint or to object to the collection and use of your Personal Information by APFM at any time. Upon written request, you may access or request the deletion of your Personal Information that is in our possession and request a correction or update of any such information.

Acknowledgement and authorization: In making a request, you confirm that you are:

a Canadian resident; and
a user of our Services; or
an individual authorized to act on behalf of another individual who is seeking our Services and possesses legal documents, such as a Power of Attorney or Guardianship, or holds other proof of being the substitute decision-maker of the individual seeking our Services.

You can exercise these rights by contacting APFM at:

Email: privacy@aplaceformom.com
Toll Free: 888-552-1632

Canadian Mailing Address:
A Place for Mom Canada, Inc.
181 Bay Street, Suite 4400
Toronto, ON M5J 2T3

OPT OUT OF APFM COMMUNICATIONS

At any time, you may visit https://my.aplaceformom.com/preference-center to adjust your communication preferences.

Promotional Communications: When you receive a newsletter or other promotional communications from us by email or phone, you may indicate a preference to stop receiving further newsletters and other promotional communications by visiting https://my.aplaceformom.com/preference-center.

Mobile Push Notifications/Alerts: With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

If you wish to opt out of communications with senior care network providers, you must contact them directly, as we do not control communications from senior care network providers.

CHANGES IN THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

QUESTIONS AND CONCERNS

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@aplaceformom.com

WASHINGTON AND NEVADA CONSUMER HEALTH DATA PRIVACY POLICY

Effective date: March 31, 2024
Last updated: May 5, 2025

This section of the Privacy Policy applies solely to Washington and Nevada “Consumers,” as this term is defined pursuant to Washington’s My Health My Data Act and Nevada’s Consumer Health Data Privacy Law (collectively, the “Consumer Health Privacy Laws”).

Please note that certain terms used in this section of the Privacy Policy, such as “Affiliate,” “Consumer Health Data,” “Collect,” “Consent,” “Consumer,” “Personal Information,” “physical or mental health status,” “Process,” “Sale” and “Share” have the meanings given to such terms in the Consumer Health Privacy Laws, and not the common meanings of these terms in conversational English.

Below, please find a chart containing information about what categories of Consumer Health Data (“CHD”) we Collect, the purpose for such Collection, the categories of sources from whom we collect your CHD, the categories of CHD that we Share, and the categories of third parties and Affiliates with whom we Share the CHD.

Categories of CHD	Collected (Yes/No)	Purpose for Collection	Categories of Sources of CHD	Shared (Yes/No)	Categories of Third Parties and Affiliates with Whom We Share CHD
Individual health conditions, treatments, diseases, or diagnoses	Yes	To provide our services For advertising and marketing to you To improve our services	Customers and prospective customers Customers’ representatives Site users Our service providers Social media services that allow you to interact with us	Yes	Our Affiliates Our service providers Third parties, including referral sources and potential future service providers to you (e.g., elder care facilities we refer you to)
Social, psychological, behavioral, and/or medical interventions	Yes	To provide our services For advertising and marketing to you To improve our services	Customers and prospective customers Customers’ representatives Site users Our service providers Social media services that allow you to interact with us	Yes	Our Affiliates Our service providers Third parties, including referral sources and potential future service providers to you (e.g., elder care facilities we refer you to)
Health-related surgeries or procedures	Yes	To provide our services For advertising and marketing to you To improve our services	Customers and prospective customers Customers’ representatives Site users Our service providers Social media services that allow you to interact with us	Yes	Our Affiliates Our service providers Third parties, including referral sources and potential future service providers to you (e.g., elder care facilities we refer you to)
Use or purchase of prescribed medication	Yes	To provide our services For advertising and marketing to you To improve our services	Customers and prospective customers Customers’ representatives Site users Our service providers Social media services that allow you to interact with us	Yes	Our Affiliates Our service providers Third parties, including referral sources and potential future service providers to you (e.g., elder care facilities we refer you to)
Bodily functions, vital signs, symptoms, or measurements	Yes	To provide our services For advertising and marketing to you To improve our services	Customers and prospective customers Customers’ representatives Site users Our service providers Social media services that allow you to interact with us	Yes	Our Affiliates Our service providers Third parties, including referral sources and potential future service providers to you (e.g., elder care facilities we refer you to)
Diagnoses or diagnostic testing, treatment, or medication	Yes	To provide our services For advertising and marketing to you To improve our services	Customers and prospective customers Customers’ representatives Site users Our service providers Social media services that allow you to interact with us	Yes	Our Affiliates Our service providers Third parties, including referral sources and potential future service providers to you (e.g., elder care facilities we refer you to)
Gender-affirming care information	No	N/A	N/A	No	N/A
Reproductive or sexual health information	Yes	To provide our services For advertising and marketing to you To improve our services	Customers and prospective customers Customers’ representatives Site users Our service providers Social media services that allow you to interact with us	Yes	Our Affiliates Our service providers Third parties, including referral sources and potential future service providers to you (e.g., elder care facilities we refer you to)
Biometric data	No	N/A	N/A	No	N/A
Genetic data	No	N/A	N/A	No	N/A
Precise location information that could reasonably indicate a consumer’s attempt to acquire or receive health services or supplies	No	N/A	N/A	No	N/A
Data that identifies a consumer seeking health care services	Yes	To provide our services For advertising and marketing	Customers and prospective customers Customers’ representatives Site users Our service providers Social media services that allow you to interact with us	Yes	Our Affiliates Our service providers Third parties, including referral sources and potential future service providers to you (e.g., elder care facilities we refer you to)
Any information used to associate or identify a Consumer with other categories of CHD set forth above	No	N/A	N/A	No	N/A

As a Washington or Nevada Consumer, you have certain rights with respect to your CHD that we Collect or Process about you, including the rights to:

Request confirmation of whether we are Collecting, Selling, or Sharing your CHD, and to access such data (including obtaining a list of all third parties and Affiliates with whom we have Shared or Sold your CHD, and obtaining an active email address from the parties receiving the information).
Request deletion of any CHD that we hold about you.
Request to review and request changes to any CHD that we hold about you.
Withdraw your Consent to our Processing, Selling, or Sharing of your CHD.

To exercise your rights pursuant to the Consumer Health Privacy Laws, please email us at WAHealthDataRights@aplaceformom.com, or call [XXXX]. In your email to us, or on the phone, please be sure to:

Specify the nature of your request (e.g., request to delete).
Provide the first and last name, email address, and phone number that you think we have on file for you.

If we deny your request in whole or in part and you would like to appeal our decision, you may email us at WAHealthDataRights@aplaceformom.com or by calling to request that we reconsider your request. In your email to us, or on the phone, please be sure to:

Specify the date and nature of your original request.
Provide the first and last name, email address, and phone number that you think we have on file for you, the reason for your appeal, and any additional information you think might help us understand your request better.

We may change this section of the Privacy Policy from time to time. If we make changes, we will notify you by revising the effective date at the top, and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law.

ADDITIONAL INFORMATION FOR UK-BASED WEBSITE VISITORS

This section of the privacy policy applies to website visitors based in the UK (“UK Website Visitors”). We, A Place for Mom, Inc., are the controller of personal data obtained via our website, meaning we are the organization legally responsible for deciding how and for what purposes it is used.

The above sections of this privacy policy entitled ‘CONSENT’ and ‘RECORDED TELEPHONE COMMUNICATIONS’ shall not apply to UK Website Visitors. Please note that telephone communications between UK Website Visitors and APFM may be recorded or monitored for quality control purposes.

Legal bases of personal information processing

In this section, we have set out the legal bases under which we process your personal information. Where we process your personal information to:

provide you with services in the United States and/or Canada; complete transactions and/or referrals; perform contractual obligations; perform internal processes; and as otherwise anticipated within the context of our ongoing business relationship, the legal basis for this processing is our legitimate interests, namely the proper administration of our website, services, and business, offering the best possible experience for our website visitors and service users and ensuring that we have access to all the information we need to properly and efficiently run our business.
communicate with you regarding your use of the Services; and respond to your requests and any other communications from you, the legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers, and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
send advertising or marketing communications; to provide news and information that we believe may be of interest to you; and to offer and administer surveys, contests, prize draws, sweepstakes, and other promotions, the legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
conduct internal research and development; analyze your engagement and use of our Services; debug, identify, and repair errors with the Services; and customize your experience, the legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving, and securing our website, services and business generally.
detect security incidents and protect against malicious, deceptive, or illegal activity; and protect against harm to APFM and others, the legal basis of this processing is our legitimate interests, namely the protection of our website, services, and business, and the protection of others.
comply with our legal obligations, the legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

Retaining and deleting personal information

Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal information in the manner set forth in the Privacy Policy.

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, insurance or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of specific retention periods for different aspects of your personal data are available from us on request by email to: privacy@aplaceformom.com.
Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.
Notwithstanding the other provisions of this section, we may retain your personal information where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

UK Website Visitor rights

As a UK Website Visitor, you have the following rights:

(a) the right to access – you can ask for copies of your personal information;

(b) the right to rectification – you can ask us to rectify inaccurate personal information and to complete incomplete personal information;

(d) the right to restrict processing – you can ask us to restrict the processing of your personal information;

(e) the right to object to processing – you can object to the processing of your personal information;

(f) the right to data portability – you can ask that we transfer your personal information to another organization or to you;

(g) the right to complain to a supervisory authority – you can complain about our processing of your personal information; and

(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal information is consent, you can withdraw that consent.

These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

You may exercise any of your rights in relation to your personal information by written notice to us, at privacy@aplaceformom.com.

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See prior privacy policy