This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to other privacy policies or notices issued by Solstice Senior Living. (“SSL,” “us,” “we,” “our”). In the event of a conflict between any other SSL policy, statement, or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA.
In accordance with the CCPA’s requirements, this Notice describes our collection, use, disclosure, and “Sale” of California Consumers’ “Personal Information” or “PI” as defined by the CCPA, as well as the rights California Consumers have under the CCPA. Terms defined in the CCPA that are used in this Notice have the same meanings as in the CCPA.
Consistent with the CCPA, job applicants, current and former employees and contractors, and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered Consumers for purposes of this Notice or the rights described herein.
COLLECTION AND USE OF PERSONAL INFORMATION
We collect PI about California Consumers as described in the table below.
In addition, we may collect, use, and disclose your PI as required or permitted by applicable law. We do not treat “Deidentified” data or “Aggregate Consumer Information” as PI, and we reserve the right to convert, or permit others to convert, your PI into Deidentified data or Aggregate Consumer Information.
Subject to the CCPA’s restrictions and obligations, our affiliates, service providers, and vendors also may use your PI for some or all of the above-listed business purposes.
We may share your PI with certain business partners, service providers, vendors (including those that facilitate interest-based advertising and other advertising and marketing), and other parties as described in the table above.
SSL has not “Sold” (as the term “Sell” is defined by the CCPA) Consumer PI in the past year.
California Privacy Rights
Under the CCPA, California Consumers have certain rights which they may exercise independently or through an authorized agent. CCPA rights requests are subject to an identification and verification process. We will not fulfill a CCPA request unless we have been provided sufficient information for us to reasonably verify the identity of the requestor and the validity of the request.
Some PI we maintain about Consumers (e.g., clickstream data) is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI. Accordingly, we will not include such information in response to Consumer requests. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create an account with us to make a verifiable request, but you may use your account to do so. We will use PI provided in your request to verify your identity or authority to make the request and to track and document request responses, unless you also provided the PI to us for another purpose.
Your California Consumer privacy rights are described below. To make a request, email us at CAPrivacyrequest@islllc.com or call us at 877-837-3717. You may be required to provide certain PI to allow us to verify that you are the Consumer about whom the request is being made. If you request that we provide you with specific pieces of information about you, we will apply heightened verification standards. An authorized agent may submit a request on behalf of a Consumer if the Consumer has provided the authorized agent with power of attorney in accordance with California law; alternatively, the agent must (1) present verifiable written authorization from the Consumer that the agent has the Consumer’s permission to submit the request; and (2) independently verify the agent’s own identity with SSL.
We may collect, use, and disclose your PI as required or permitted by applicable law. Please note we are not obligated to comply with Consumer requests to the extent that doing so would infringe on our, or any other person’s or party’s, rights, or conflict with applicable law.
You have the right to request that we disclose the following information about your PI that we have collected and are maintaining for the 12-month period prior to your request date. Consumer requests of this nature may be made no more than two times in a 12-month period.
- The categories of PI we have collected about you.
- The categories of sources from which we collected your PI.
- The business or commercial purposes for collecting or Selling your PI.
- The categories of third parties to whom we have shared your PI.
- The specific pieces of PI we have collected about you.
- A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred.
You have the right to make or obtain a portable copy of your PI that we (1) collected in the 12 months prior to the request date, and (2) currently are maintaining. Please note that we retain PI for various time periods in accordance with applicable law and our internal recordkeeping policies and procedures.
“Do Not Sell” RightsWe do not Sell California Consumer PI as defined under the CCPA, and until such time as we change our practices by updating this Notice, will treat PI collected under this Notice as subject to a “do not sell” request.
Some browsers include features that may be characterized as “Do Not Track” signals. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. Further, we do not interpret “Do Not Track” signals to represent a “do not sell” request for CCPA purposes. We understand that various parties are developing “do not sell” signals and we may recognize certain such signals if we conclude such a program is appropriate. We do not interpret the use of third-party cookies as representing a sale of California Consumer PI.
Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with applicable laws and regulations, to exercise or defend legal claims, and to cooperate with law enforcement.
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.
Other California Notices
California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of PI to third parties for their own direct marketing purposes.
We do not share personal information with third parties for their direct marketing purposes. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us by sending a letter to Solstice Senior Living, Attention: Privacy Inquiry, 2333 State Street, Suite 300, Carlsbad, CA 92008. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per Consumer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
For more information regarding your California privacy rights, email us at CAPrivacyrequest@islllc.com, call us at 877-837-3717, or write to us at: Solstice Senior Living, Attention: Privacy Inquiry, 2333 State Street, Suite 300, Carlsbad, CA 92008.