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In certain sections of this Site, we may require you to submit your personally identifiable information to us, and we may invite you to submit questions, comments, and request information. In addition to any personal information that you may voluntarily provide, the Site collects information using cookies and other third-party tools. Please refer to the sections below on “Cookies,” “Third Party Analytics Tools,” and “Third Party Advertising Tools” for more information about the information these tools collect and use.
We also may collect personally identifiable information about you if you are an individual potential resident or customer of one of our clients and you complete a reservation form or indicate an interest to become a resident in a property or to become a customer of a senior living facility (“Customer Data”). We also may collect any personally identifiable information and other information if you subscribe to our Reputation or Social Manager services that you elect to publicly post on social media websites (“Social Media Communications”).
Due to the nature of some of our services, you may provide us with personally identifiable information such as your name, email address, username, password, company name, website name, address, phone number, and other contact information that you voluntarily transmit in your communication to us or that you include in your Social Media Communications. If you are a potential resident or customer of a senior living facility, we may also collect your credit card number and information. If you are a client of our services, we will collect billing information and the features and amenities of your property. If you are a client of our Reputation or Social Manager services, we may collect your contact information and login credentials (such as username, password, and PIN) for third-party websites so our services can integrate with Facebook, Twitter, GoDaddy, Google Places, etc. If you post to our blogs, we may collect any other personally identifiable information that you include in your posting.
We may use your personally identifiable information to deliver our services, reports, or information you have requested, verify your authority to enter certain password- protected areas of the Site, verify that you are a customer or prospective customer, send you information that you have signed up to receive, notices about our products and/or services that you have used or that may be of interest to you and notices about events and improve the content and general administration of the Site and our services. If you are a potential resident or customer of a senior living facility, we may use your Customer Data, including your credit card information, to reserve an apartment unit for you pursuant to your request.
Compass Senior Living recognizes the privacy interests of children, and we encourage parents and guardians to take an active role in their children’s online activities and interests. Neither the Site nor our services are intended for children under the age of 16. Compass Senior Living does not target its services or this Site to children under 16. Compass Senior Living does not knowingly collect personally identifiable information from children under the age of 16.
We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period. You can remove persistent cookies by following the directions provided in your Internet browser’s “help” file.
On the Site, we use session cookies to make it easier for you to navigate the Site by saving your preferences and improving and tracking the overall Site experience. For the Site, we set a persistent cookie to authenticate your login and authorization to use the services. If you reject cookies, you may still use the Site, but your ability to use some areas of the Site may be limited.
Beyond the personally identifiable information you voluntarily provide to us, Compass Senior Living utilizes analytics tools including third party technologies, such as Google Analytics, to collect information using cookies. Certain types of information, including geolocation, device type, onsite website usage and behavior, demographic data, and purchase history, are collected and aggregated across Compass Senior Living Site users for our analysis and advertising efforts.
Compass Senior Living uses Google Analytics and Google Ads and similar types of technologies to display relevant advertisements to users who have previously visited the Site. Referred to as remarketing or retargeting, Compass Senior Living may utilize previous session information to serve display advertisements to you on the Site, and based on such session information Google may set a cookie and serve ads to you on third-party websites on the Google Display Network. Third-party vendors such as Google may display Compass Senior Living ads on websites across the Internet. Aggregated user data may be utilized to create remarketing/retargeting “lists,” or groups of users with similar onsite behaviors or demographics. Compass Senior Living also uses Google tools to display advertisements to users based on their inferred interests and demographics.
We automatically collect information about your interactions with the Site, including information about the device you use to interact with and/or access the Site, such as IP address, access dates and times, information about your approximate location (as determined through your IP address), hardware and software information, mobile, computer or hardware device information (e.g., operating system version, Hardware model, IMEI number and other unique device identifiers, MAC address, and device settings), device event information, and crash data. This information allows Compass Senior Living to understand how you have used the Site (which may include administrative and support communications with us or whether you have clicked on links to External Websites), and other actions you have taken in connection with your use of the Site. We automatically collect log data when you access and use the Site, even if you have not created an account or logged in.
The Site may track the total number of visitors to the Site, the number of visitors to each page of the Site, browser type, IP addresses, External Websites (defined below) linked to, and other aggregated data collected through our services and we may analyze this data for trends and statistics in the aggregate but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such aggregate information to analyze trends, administer the Site, track users’ movement, and gather broad demographic information for aggregate use.
We may provide your personally identifiable information and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our services to you. If you are a user of our services, we may provide your personally identifiable information to third parties at your request to provide additional functionality in and/or integrations with our services. Such third-party entities may be obligated to use your personally identifiable information solely to provide the services to us.
If you post to our blogs, other users of the Site will be able to see your posting and any other personally identifiable information you include in your posting. If you are a user of our services, we will publicly display the features and amenities of your properties on the websites that we create for you. If you are a potential resident of a property or customer of a storage facility, we may provide your Customer Data to the applicable property and/or storage facility owner or operator for the property in which you indicated an interest.
We employ industry-standard procedural and technological measures that are designed to help protect your personally identifiable information from loss, and unauthorized access, disclosure, alteration, or destruction. For example, Compass Senior Living may use, without limitation, firewalls, password protection, secure socket layer, and other security measures to help prevent unauthorized access to your personally identifiable information.
For purposes of this section “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could be linked, directly or indirectly, with a particular consumer or household. Personal information does not include:
● information that is lawfully made available from federal, state, or local government records.
● de-identified or aggregated information; and
● information excluded from the scope of the California Consumer Privacy Act of 2018 (“CCPA”), such as health or medical information covered under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and financial information covered under the Fair Credit Reporting Act (“FCRA”) or Gramm-Leach Bliley Act (“GLBA”).
In the last twelve (12) months, we have collected the categories of personal information described in the table below:
Real name (such as first name and last name); alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Customer Records Information (personal information categories listed in the customer records statute in California Civil Code Section 1798.80(e))
Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Characteristics of protected classifications under California or federal law
Age (forty (40) years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital or familial status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), medical conditions, political affiliations or activities, status as a victim of domestic violence, assault, or stalking.
Records of products or services purchased, personal property, or other purchasing or consuming histories or tendencies.
Fingerprints, facial or hand imagery, voice recordings from which an identifier template can be extracted, keystroke patterns, gait patterns, sleep, health, or exercise data.
Internet or other similar network activity information
Browsing history, search history, information regarding consumer’s interaction with a website, application, or advertisement.
GPS coordinates or other location-tracking information.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information
Employer, employment history, resumes and CVs, background checks, and other employment-related information.
Records maintained by an educational agency or institution that pertain to a student, such as grades and transcripts (as defined under 20 U.S.C. § 1232(g) and 34 C.F.R. Part 99).
Inferences drawn from any of the categories described above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
The table below describes the sources for each category of personal information we collect, the business and/or commercial purposes for which we use each category of personal information and the third parties with whom we share each category of personal information we collect.
Category of Personal Information Collected
Sources from Which Personal Information is Collected
Business or Commercial Purposes
Third Parties Shared With
● Sale of Personal Information
○ Compass Senior Living does not sell personal information.
● Disclosure of Personal Information for Business Purposes
○ Compass Senior Living discloses the following categories of personal information for business purposes:
○ Identifiers; Customer records information; Commercial information; Biometric information; Internet or other similar network activity information; Geolocation data; and Sensory Information.
If you are a resident of California, you have specific rights regarding your personal information. This section describes your rights and how to exercise them.
● Right to Know About Personal Information Collected, Disclosed, or Sold
○ You have the right to request that Compass Senior Living disclose to you what personal information we collect, use, disclose, and sell. You may exercise this right following the methods described under the subsection titled “Exercising Your Rights” below.
● Right to Delete Personal Information
○ You have the right to request that Compass Senior Living delete personal information we may hold about you. You may exercise this right following the methods described under the subsection titled “Exercising Your Rights” below.
○ Please be aware that we may not always be able to delete your personal information. For example, there may be business or operational reasons why we need to retain personal information. If we deny your request to delete personal information, we will inform you of the basis for our denial in our response to you.
● Right to Opt-Out of Sale of Personal Information
○ You have the right to opt out of the sale of your personal information. Because we do not sell personal information, this right does not apply to Compass Senior Living.
● Right to Non-Discrimination
○ You have the right to not receive discriminatory treatment from Compass Senior Living for exercising any of your rights described under this “Your Rights” section. This means we will not treat you differently for exercising any of the rights described above.
You may exercise each right once every twelve (12) months. To exercise your rights, you must submit a verifiable request to us. To submit a verifiable request, please follow the methods described below:
By email: You may submit requests to firstname.lastname@example.org
By mail: You may submit requests to: COMPASS SENIOR LIVING | 2300 Oakmont Way, Suite 201 Eugene, OR 97401
To verify your request, we will work on a case-by-case basis to confirm that you are authorized to make any such data privacy request.
You may designate an authorized agent to submit a request on your behalf. To designate an authorized agent, you must have the agent include with the request on your behalf a document signed by you that authorizes the agent to act on your behalf aligned with a valid form of government ID.
We will respond to your rights request within forty-five (45) days from the date we receive it. In some cases, we may require additional time to complete your request and will inform you if additional time is needed. Where additional time is needed, we may take up to a maximum of ninety (90) additional days to complete your request.
Compass Senior Living does not offer financial incentives or price or service differences in exchange for the retention or sale of personal information.
This Site and the services are targeted at users in the United States of America. The personal information that we collect is sent to and processed on servers located in the United States. Such transfer is necessary to process the information and provide the Site and services. The data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in your country of residence.