PURPLE DOOR FINDERS

Privacy Policy

Last updates and effective 05/02/2023

Welcome to purpledoor.com and thank you for choosing us! This privacy policy (the “Privacy Policy”) explains our collection, use, and disclosure policies and practices across purpledoor.com, as well as all other websites and/or applications (individually and collectively, “Site” or “Sites”) that you may use to access and use our senior housing marketing and information services (the “Services”) (collectively, the Services and the Site may be referred to collectively as the “Services”) owned and operated by Purple Door, LLC (“Purple Door,” “we,” “us,” or “our”). This Privacy Policy does not apply to information collected by: (i) us offline or through any other means, including on any other website operated by us or any third party; or (ii) any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Site.

By accessing and continuing your use our Services, or by checking any authorizations boxes accompanying any links or messages by which you arrived at this Privacy Policy, you agree to be bound by this Privacy Policy and all other terms, such as our Terms of Use, as updated from time to time and incorporated hereto by reference.

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE THE SITES AND/OR THE SERVICES.

We reserve the right to change or modify any of the Privacy Policy at any time. If we decide to change our Privacy Policy, we will notify you by revising the date at the top of the Privacy Policy. Your use of the Sites and/or the Services following the posting of changes or modifications to the Privacy Policy will constitute your acceptance of the revised Privacy Policy. Therefore, you should review the Privacy Policy and applicable terms and policies from time to time to understand the terms and conditions that apply to your use of the Sites and/or Services. If you do not agree to the amended terms, you must immediately stop using the Sites and/or Services.

Purple Door is a senior housing marketing and information service that provides resources and personalized assistance in finding senior housing and care. As used in this Privacy Policy, “you” may refer either to individuals (or family members of individuals on the individual’s behalf) using the Services seeking residence at a Member Community (each a “Resident”) OR to Member Community (as defined below) and their representatives using our Services on behalf of the Member Community (whichever is applicable).

Our Site is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Site. We do not knowingly collect information from children under 18. If you are under 18, do not use or provide any information on this Site or through any of its features, register on the Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information about a child under 18, please contact us at security@purpledoorfinders.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

Consent to Automatic Telephone Dialing Systems and Recording

By providing us with your telephone number, either through the Site or over the telephone, you agree to be contacted by Purple Door and senior housing and/or care providers that have contracted with us to be part of our Services (individually a “Member Community” and collectively “Member Communities”) for purposes of either providing you with the Services or for the purposes of Member Communities following up on your requests. You agree to be contacted by telephone call or text message at the telephone number you provided using automatic telephone dialing systems, even if you previously registered on a Do Not Call registry, and consent is not a condition of any purchase. You also agree that telephone communications between you and Purple Door may be recorded or monitored for quality control purposes. By providing information to us, you expressly consent to the recording of these telephone communications.

Our Collection and Use of Your Personal Information

As used in this Privacy Policy, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, reasonably can be linked, directly or indirectly, with an individual or household, or as otherwise defined under applicable law.

We collect Personal Information from four primary sources: (1) directly from you (both Residents and Member Communities); (2) automatically when you use our Services; (3) from affiliated and unaffiliated third parties; and (4) by using information we collect to derive new Personal Information. The types of Personal Information we collect about you depend on how and when you interact with us and our Services, as detailed below. We also collect information about your internet connection, the equipment you use to access our Site, and usage details.

1) 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 please note that some information may be necessary for us to provide you the Services.

The categories of Personal Information we may collect directly from you include:

(i) Identifiers, such as your first name, last name, phone number, email address, and mailing address, and medical or health insurance information (as necessary to provide Resident information to Member Communities when Resident’s request more information or placement);

(ii) Characteristics of protected classifications under state or federal law, such as age, sex/gender, marital status, medical condition and disability information;

(iii) Information you provide on our Sites to request Services, for example your username, password, location, and the information previously listed;

(iv) Financial information, including the Resident’s budget for senior housing options and whether the Resident receives Medicare or Medicaid;

(v) Commercial information, including records of your move-in status with referred Member Communities;

(vi) Feedback you provide to us about our Services, including in response to surveys or through our customer service centers;

(vii) For Residents, their gender; household income; budget; senior care needs, including health information and medical conditions; and veteran status, as well as other information you may choose to voluntarily provide, such as marital status, religion, or ethnicity; and

(viii) For Member Communities, when you make a payment through our Services, your payment card information is collected and stored by our payment processing partner. Our payment processing partner collects your voluntarily provided payment card information necessary to process your payment. Such partner’s use and storage of information is governed by its applicable terms of service and privacy policy.

2) Information Automatically Collected from Your Use of the Sites

We may 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 (“Tracking Tools”) which are described in more detail below. Some of this automatically collected Personal Information may include:

(i) IP address;

(ii) domain server;

(iii) type of device(s) used to access the Services;

(iv) web browser(s) used to access the Services;

(v) referring web page or other source through which you accessed the Services;

(vi) geolocation information; and

(vii) other statistics and information associated with the interaction between your browser or device and the Services (collectively “Traffic Data”). Depending on applicable law, some Traffic Data may be Personal 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).

3) Information We Collect from Other Sources

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

(i) Residents (if you are not the Resident) or a person who contacts us seeking Services for a Resident;

(ii) From Member Communities;

(iii) 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); and

(iv) Unaffiliated parties, such as our service providers, analytics companies, advertising networks, affiliates, and other third parties that provide us with information, so we can better understand you and provide you with information that may be of interest to you.

4) 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.

How We Use Your Information

For each category of Personal Information and other information we collect about you (whether directly or automatically), we use such category of Personal Information and other information for the business and commercial purposes set forth below:

(i) Providing you with the products, services and information you request;

(ii) Responding to correspondence that we receive from you;

(iii) Contacting you when necessary or requested;

(iv) Providing, maintaining, administering or expanding the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;

(v) Customizing or tailoring your experience of the Services, which may include sending customized messages or showing you Sponsored Results;

(vi) Notifying you about certain resources or services we think you may be interested in learning more about;

(vii) Sending you information about Purple Door or our products or Services;

(viii) Sending emails and other communications that display content that we think will interest you and according to your preferences;

(iv) Combining information received from third parties with information that we have from or about you and using the combined information for any of the purposes described in this Privacy Policy;

(x) Showing you advertisements, including interest-based or online behavioral advertising;

(xi) Using statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;

(xii) Fulfilling our legally required obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities;

(xiii) Resolving disputes;

(xiv) Protecting against or deterring fraudulent, illegal, or harmful actions; and

(xv) Enforcing our Terms of Service and other agreements.

How We Share Your Information

We will share your Personal Information as follows:

1) Third Parties. We may share Residents’ Personal Information with Member Communities to provide you with the Services you’ve requested. The Member Communities may contact you directly, including by email, telephone, regular mail, or in-person visits. We may share Personal Information with the person who referred you as a Resident or to another person acting on your behalf. We may share your Personal Information and/or Traffic Data with our partners who perform operational services (such as hosting, billing, fulfillment, data storage, security, insurance verification, web service analytics, or ad serving) and/or who make certain services, features or functionality available to our users. We do not sell email addresses to third parties (except when providing Residents’ emails to Member Communities for purposes of providing our Services). We may share your Personal Information with our partners to customize or display our advertising.

2) Cross Device Matching. To determine if users have interacted with content across multiple devices and to match such devices, we work with partners who analyze device activity data and/or rely on your information (including demographic, geographic and interest-based data). To supplement this analysis, we also provide de-identified data to these partners. Based on this data, we may then display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of Services across devices.

3) Business Transfers. We may transfer your Personal Information to another company in connection with a proposed merger, sale, acquisition or other change of ownership or control by or of Purple Door (whether in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

4) Public Information and Submissions. You agree that any information that you may reveal in a review posting, online discussion or forum is intended for the public and is not in any way private. Carefully consider whether to disclose any Personal Information in any public posting or forum. Your submissions may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.

5) Protection of Purple Door and Others. We also may need to disclose your Personal Information or any other information we collect about you if we determine in good faith that such disclosure is needed to: (i) comply with or fulfill our obligations under applicable law, regulation, court order or other legal process; (ii) protect the rights, property or safety of you, Purple Door or another party; (iii) enforce the Terms of Use, this Privacy Policy, or other agreements with you; or (iv) respond to claims that any posting or other content violates third-party rights.

6) As Aggregated, Anonymized Information. We may share aggregated, anonymous, or de-identified information to our advertisers, business partners, and other third parties that cannot reasonably be used by those third parties to identify you.

7) At your request. We may otherwise share Personal Information with your consent or at your direction.
We strive to provide you with choices regarding the Personal Information you provide to us. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Site may then be inaccessible or not function properly. We do not control third parties’ collection or use of your Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Links to Third-Party Websites

We may provide links to third party websites from our Sites as a service to our users, but we have no ability to 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.

Storage and Security of Information

The security of your Personal Information is important to us. We endeavor to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and in storage. For example, when you enter sensitive information on our Site and/or our Services, we encrypt that information (both at rest and in transit) using Secure Socket Layer (SSL) technology.

We store and process your information on our servers in the United States. We maintain industry standard backup and archival systems.

Your Account (as defined in our Terms of Service) is protected by a password for your privacy and security. If you access your Account via a third-party site or service, you may have additional or different sign-on protections via that third-party site or service. You must prevent unauthorized access to your Account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately,and limiting access to your computer or device and browser by signing off after you have finished accessing your Account.

Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, we do not and cannot guarantee the security of your Personal Information. If at any time during or after our relationship we believe that the security of your Personal Information may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your Account. Please keep your e-mail address in your Account up to date. You can update that e-mail address anytime in your Account settings. If you have difficulty updating your e-email address or other information on your Account, please contact us at security@purpledoorfinders.com. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at security@purpledoorfinders.com. Please include your address when you submit your request. You can make this election any time, and it will apply to notifications made at a reasonable time thereafter as we will need time  to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.

How Long We Retain Your Information

We retain Personal Information about you for as long as you have your Account with us or as otherwise necessary to provide you the Services. In some cases, we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, prevent fraud, enforce our Terms of Service of this Privacy Policy, or as otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

Please note, Purple Door does not dictate how long third parties retain your Personal Information obtained through our Services. Each of those parties will have their own privacy policies and retention periods and you should review those policies.

Your Privacy Choices

You can always opt not to disclose information to us, but keep in mind some information may be needed to create an Account and to use certain features of our Site and our Services.

Note that Purple Door cannot control or guarantee these rights with regard to Personal Information obtained by Healthcare Providers or third parties who have requested and received your Personal Information through our Services and with your consent.

If you are a registered user of the Services, you can modify certain Personal Information or Account information by logging in and accessing your Account settings. The information you can view, update, and delete may change as the Services change.

If you wish to close your Account, please email us at optout@purpledoorfinders.com. Purple Door will use reasonable efforts to promptly delete your Account and the related information. Please note, however, that Purple Door reserves the right to retain information from closed Accounts, including to comply with law, prevent fraud, resolve disputes, enforce the Terms of Use and Privacy Policy or other agreement(s) between you and Purple Door and take other actions permitted by law.

You must promptly notify us if any of your Account data is lost, stolen or used without permission.

Your State Privacy Rights
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, see GDPR and CCPA. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to security@purpledoorfinders.com.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
• To exercise any of these rights please email security@purpledoorfinders.com.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: optout@purpledoorfinders.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

GDPR and CCPA

You may have certain rights to your Personal Information as a result of privacy laws around the world, such as the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). If those laws apply to you, Purple Door gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your Account information through your Account settings. You may also remove certain optional information that you no longer wish to be available through the Services, such as your name. You can also request to permanently close your Account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.

1) Right to Access & Portability: You can access certain Personal Information associated with your Account by visiting your Account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used.

2) Right to Correction: You have the right to request that we rectify inaccurate information about you. By visiting your Account settings, you can correct and change certain personal information associated with your Account.

3) Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.

4) Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of Purple Door.

5) Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your Account email settings.

6) Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your Account privacy settings. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your mobile device. This is without prejudice to your right to generally permanently close your account and delete your personal information.

If you are a resident of California, the CCPA provides you the following additional rights:

1) Right to Know: if you are a California resident, you may request disclosure of the specific pieces and/or categories of personal information that we have collected about you, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed about you, and the categories of third parties with which the information was shared.

2) Right to Opt-Out/ “Do Not Sell My Info”: To the extent that Purple Door “sells” personal information (as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time (see below for more information) (which can be done to by contact us at optout@purpledoorfinders.com.

Opt-Out of Purple Door’ Communications

In addition to your rights to opt-out pursuant to Your State Privacy Rights and GDPR and CCPA, at any time, you may adjust your communication preferences in the settings accessible from your Account profile.

Promotional Communications. When you receive a newsletter or other promotional communications from us, you may indicate a preference to stop receiving further newsletters and other promotional communications in the settings accessible from your Account profile.

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 Member Communities, you must contact them directly, as we do not control communications from Member Communities.

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.

Governing Law and Forum Selection

Any dispute arising from the Site and your use of the Services will be governed by and construed and enforced in accordance with the laws of the state of Delaware, except to the extent preempted by U.S. federal law, without regard to conflict of law rules or principles (whether of Delaware or any other jurisdiction) that would cause the application of the laws of any other jurisdiction. Any dispute between the parties that is not subject to arbitration or cannot be heard in small claims court shall be resolved in the state or federal courts of Oregon and the United States, respectively, sitting in Clatsop County, Oregon and you hereby consent to such jurisdiction.

Contacting Purple Door

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