Last Update: January 21st, 2020
- We use "AgingChoices,” “we,” “us” or “our" to refer to LifestyleCX, Inc. d/b/a AgingChoices
- We use "AgingChoices Services" to refer to the Site and any other Lifestyle website, application or other product or service made available to Users.
- We use "User,” “Users,” “you” or “your" to refer to people or entities visiting the Site or registered to use the AgingChoices Services as a Consumer User or a Senior Care Service Provider.
- A "Consumer User" refers to any individual who visits the Site in order to utilize the AgingChoices services to identify senior support services.
- A “Local Market Advisor” refers to businesses which act as brokers, placement advisors and/or agents in local markets to connect Consumer Users to Senior Care Service Providers.
- A "Senior Care Service Provider" is a provider of senior care, housing, and/or support services who AgingChoices may present to a Consumer User through the Site.
II. Your Information
a. Collection of Personal Information
"Personal Information" means all personally-identifiable information (e.g., your name, physical address, email address, telephone numbers) that you submit in connection with the AgingChoices Services. AgingChoices does not collect Personal Information unless you voluntarily submit it in connection with your use of the AgingChoices Services, send inquiries to AgingChoices, or participate in certain activities available via the AgingChoices Services.
We collect Personal Information when you choose to use certain features of the AgingChoices Services, including when you: (i) create an account; (ii) use the AgingChoices Services to connect with Senior Care Service Providers, (iii) communicate with AgingChoices, (iii) upload contents, comments, videos or photographs, or (iv) consent to receive commercial or promotional email and/or direct mail from AgingChoices. We also collect Personal Information for maintaining records and contact details for our business purposes.
Please do not share your medical records or personal health information with AgingChoices at any time. Choice does not collect medical or health information from its Users.
b. Collection of Consumer Information
"Consumer Information" includes Personal Information from Consumer Users as well as any additional information that AgingChoices receives from or about Consumer Users. Sharing information with AgingChoices is always voluntary and Consumer Users control what information they provide to AgingChoices when using the Site and AgingChoices Services. Consumer Users should note that once they have submitted information to the Site during or after registration, it may be shared with a Senior Care Service Provider in connection with the AgingChoices Services. Consumer Information may include, but is not limited to:
- Personal Information about a Consumer User; and
- Information about a Consumer User’s, lifestyle choices and preferences, financial condition, or receipt of aging care services and benefits;
- Anonymous Information (as explained in more detail below) that we receive about Consumer Users;
- Information we receive from third parties about Consumer Users, including, but not limited to, advertising partners, customers and vendors; and
- Any other information a Consumer User chooses to share with us when communicating with AgingChoices.
c. Collection of Information from Senior Care Service Providers and Local Market Advisors
We may collect this additional information from Senior Care Service Providers and Local Market Advisors in connection with the community profiles they create on the Site:
- Personal Information about a Senior Care Service Provider or Local Market Advisor;
- Company information; and
- Category descriptions of features, services, resources, amenities and other details about the Senior Care Service Providers with whom the Local Market Advisor has a relationship.
Senior Care Service Providers and Local Market Advisors should be aware that any information that is shared with AgingChoices and/or published or displayed on the Site:
- May be reviewed by AgingChoices before it is approved for publication and distribution through the Site;
- Will be accessible to all Users accessing the Site;
- Can be associated with Senior Care Service Providers and Local Market Advisors whether or not they are actively using the AgingChoices Services;
- Can be included in search results for Users utilizing the AgingChoices Services; and
- May be visible and accessible through general search engines like Google.
d. Online Account Registration
Users may register for an online account when using our Site. Once you have completed the User registration process with AgingChoices, you will be able to access the Site using your email address and a unique password. Your password is exclusively for your use and should not be shared except as needed to facilitate use of the Site by you and those individuals authorized to use the Site on your behalf. It is the responsibility of each User to safeguard its password. If you believe your password has been lost, stolen or otherwise compromised, or that your account security has been compromised in any way, please reset your password and contact AgingChoices immediately.
e. Information Gathered Automatically
Information We Collect About Your Interaction With The Site. We may collect additional information about your interaction with our Site (including metadata) that does not identify you as an individual (“Anonymous Information”), by using cookies, web beacons or other automated technologies (as explained in more detail in Section V below). For example, we may receive certain standard information that your browser sends to many or all websites you visit, including but not limited to:
- Time and date of your visit and the pages you visit;
- Your internet service provider, IP address and technical information about the IP address;
- Browser and operating system type;
- Information about the network and device you are using (such as whether it is a mobile device or a desktop computer); and
- Your geographic location
We may use Anonymous Information for any purpose in our discretion. For clarity, Anonymous Information means information that is not associated with or linked to your Personal Information and does not permit the identification of individual persons.
f. Your Content
The Site permits Users to submit certain content to the Site (“User Generated Content”), including reviews of Senior Care Service Providers and Local Market Advisors. AgingChoices assumes no responsibility for securing User Generated Content you submit via the AgingChoices Services. AgingChoices has no obligation to use, solicit or enable others to use any User Generated Content you submit to us.
WE ARE NOT RESPONSIBLE FOR THE PERSONAL INFORMATION AND OTHER NON-IDENTIFYING INFORMATION YOU CHOOSE TO SUBMIT IN ANY PUBLICLY ACCESSIBLE AREA OF THE AGINGCHOICES SERVICES.
III. How We Use Your Information
General Use. We may use your Information for the following purposes:
- To deliver, monitor and improve AgingChoices Services, and to operate the Site;
- To present Consumer Users with suggested choices for Senior Care Service Providers which match their stated preferences concerning location, amenities and type of care they are seeking;
- To facilitate our relationships with Business Partners and Industry Partners;
- To maintain the safety and security of AgingChoices, the AgingChoices Services and data submitted to AgingChoices;
- To ensure data accuracy and integrity, and to safeguard the rights of you, AgingChoices and other users and visitors to the Site;
- To send relevant emails to you concerning available services and promotions based on your stated preferences;
- To improve internal operations of AgingChoices, including for troubleshooting, research and enhancement of AgingChoices Services;
- To respond to your requests and inquiries and to provide you with requested customer support;
- To review Site usage in order to customize, measure and improve the AgingChoices Services and the content, layout and functionality of the Site;
- To communicate with you about important changes to the Site and/or our business;
- To identify and offer you new AgingChoices Services; and
- To tailor the Site to your needs and the needs of other Users.
Direct Marketing. We may send out marketing messages (such as a newsletter or alert) to Users who have provided us with contact information to communicate about developments with our business, to offer special promotions, or to announce important happenings in our industry. We will ask for your consent to receive marketing communications when we collect your contact information, and you can always choose to stop receiving newsletters or other communications from us by clicking the “unsubscribe” link at the bottom of a marketing message. Please understand that if you choose not to receive promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and/or communications with us.
IV. How Users’ Information Is Shared
Third Party Sharing. AgingChoices may allow third parties to access Consumer Information (including Personal Information) ONLY IF:
- You have voluntarily shared the information in a review or in posting comments about a Senior Care Service Provider using the AgingChoices Services;
- We have a legitimate business purpose for sharing such information with service providers, Business Partners and/or Industry Partners under contract with AgingChoices who help with our business operations;
- With respect to Personal Information, we have removed Your name and any other individually identifying information; or
- We have your express permission to do so.
AgingChoices cannot control whether or how third parties share your Information that you have shared with them, or your Information that third parties have accessed, through means other than the AgingChoices Services. If you share your information with Senior Care Service Providers or Local Market Advisors through the AgingChoices Services, please be advised that at that point, use and sharing of your shared information by the Senior Care Service Provider or Local Market Advisor, as the case may, will be governed by the Privacy Policies of that party.
Aggregated Research. We may also share aggregated non-identifiable information about our Users with third parties in order to help market our products and develop new vendor and customer relationships.
- Comply with applicable laws, regulations, legal process (such as a subpoena) or enforceable government request;
- Enforce our Terms and Conditions, including investigation of potential violations of such Terms and Conditions or to detect, prevent or otherwise address fraud, security or technical issues with respect to the Site;
- Facilitate fraud prevention, risk assessment, investigation, product development and debugging purposes; and
- Protect against harm to the rights, property or safety of AgingChoices, our Users or the public as required or permitted by law.
V. Cookies, Beacons and Other Automated Technologies
- Cookies. A "cookie" is a small computer file that is sent to your computer when you visit a website to make each visit more efficient. Cookies may store user preferences and other information. You may opt out of receiving cookies by instructing your browser to stop accepting cookies or to prompt you before accepting a cookie from websites you visit, by changing your browser options. Please note, however, that by blocking or deleting cookies used with the AgingChoices Services, you may not be able to use all aspects of the AgingChoices Services. You can learn more about cookies by visiting https://en.wikipedia.org/wiki/HTTP_cookie, which includes useful information about cookies and how to block cookies on different types of browsers and mobile devices.
- Web Beacons. A "web beacon" is a small piece of information or data stored on your computer or mobile device that is used to determine your preferences and to track your search terms and other behaviors or activities as you navigate around the Internet. If you object to this practice, you may erase or block certain web beacons. We recommend, however, that you allow web beacons to be stored on your computer or mobile device as they may be needed to properly use the AgingChoices Services.
- "Do Not Track” Requests. The Site currently honors “do not track" or similar signals from your browser.
We use commercially suitable physical, electronic and managerial procedures designed to safeguard and secure the information we collect on our Site. These procedures include, but are not limited to, encryption, passwords and physical security. We also limit access to Personal Information we receive to our employees, contractors, professional advisors, Business Partners and Industry Partners (as defined below) who need access to that information in order to do their jobs or provide services to us. However, no data protection procedures are entirely infallible. As a result, while we strive to protect your Personal Information, we cannot guarantee that it will be 100% secure. Your transmission of data to our Site thus is done entirely at your own risk.
VII. Business Partners
We use and work with certain third party application and technology companies (“Business Partners”) to provide hosting, payment processing, marketing, database integration, technology development, business intelligence, analytics and other services for us or for our Users. These Business Partners may have access to or process your information for the purpose of providing those services. Some functionality in the Site may use white-labelling techniques to serve content from Business Partners while providing the look and feel of our Site. Please note that, in some instances, you are providing your information to these third parties acting on behalf of AgingChoices. We have discussed certain of our Business Partners in more detail below.
a. Analytics Partners
b. Payment Processors
AgingChoices currently offers its Senior Care Service Providers and Local Market Advisors certain payment options through the Site, as explained in more detail in our Billing Terms and Conditions. AgingChoices does partner with a third-party payment processor (“Payment Processor”) so that Senior Care Service Providers and Local Market Advisors may pay fees to AgingChoices directly through the Site. For Senior Care Service Providers and Local Market Advisors paying fees through the Site, please note that your credit and debit card information (number, expiration date, security code) is provided directly to the Payment Processor and is stored by the Payment Processor and not by AgingChoices. The Payment Processor may share your information with AgingChoices so that we may complete transaction with you, but AgingChoices does not collect credit and debit card information directly through the Site and kindly asks you not to share this information with us when submitting requests for additional information.
VIII. Industry Partners
We partner with Senior Care Service Providers and Local Market Advisors (“Industry Partners”) across the country in order to provide you with high qualify options for senior care, housing and/or support services in your local communities. AgingChoices sometimes enters into contracts with Industry Partners and may receive a fee or share revenue with our Industry Partners in the event you choose a Senior Care Service Provider referred to you by AgingChoices. These arrangements allow us to offer the AgingChoices Services to you free of charge and also receive compensation if we are able to help you identify and select a Senior Care Service Provider. To be clear, we will ask your permission before engaging a Local Market Advisor to work with you to identify a Senior Care Service Provider and we will only collect a fee for this work on your behalf from the appropriate Industry Partner, and not from you.
IX. Links to Third Party Websites
The Site may contain links to other websites, including those of third parties or Business Partners. While we seek to link only to websites that share our high standards and respect for privacy, we cannot be responsible for the privacy practices of other websites. By accessing other third party websites or applications through our Site, you are consenting to the terms and privacy policies of those websites. It is possible that other parties may collect Personal Information about your online activities over time and across different web sites when you use the Site.
X. California Privacy Rights
Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2020 will receive information regarding 2019 sharing activities).
To obtain this information, please send an email message to [email protected] with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
XI. For Canadian Consumer Users
Canadian citizens, except under circumstances defined by law, are entitled to access their Personal Information collected by AgingChoices. If you believe that the Personal Information about you that we have collected is incomplete or inaccurate, please contact us and we will correct the information upon verification of the omission or error and of the identity of the person requesting the change.
Canadian citizens who wish to request further information about our compliance with Canadian privacy laws or who have questions or concerns about our privacy practices may contact us using the contact information set forth below.
XII. Other International Users and the General Data Protection Regulation
TThe AgingChoices Services are operated in the United States and we host all data received through the AgingChoices Services in the United States. By using the AgingChoices Services, you are consenting to the transfer of your Personal Information to the United States.
If you are a User from a member state of the European Union, please be advised that AgingChoices is committed to complying with the principles of the General Data Protection Regulation (the "GDPR") and has technology and business practices in place so that Users may take advantage of certain choices and protections encouraged by the GDPR. For example:
- Users can easily access their Personal Information stored in the AgingChoices Services at any time. Senior Care Service Providers may use access controls to select who is able to view their information.
- Users may also delete their profile at any time. If requested by a registered User of the AgingChoices Services, AgingChoices will promptly delete any information we store about the User, subject to retention on backup servers for up to ten (10) days.
- All marketing and transactional features of the AgingChoices Services rely on opt-in and/or opt-out features.
Please also know that you have the right to complain to your local information protection authority should you have concerns with respect to how we are processing your Personal Information. Your local data protection authority will be able to give you more information on how to submit a complaint.
XIII. Users Only of Legal Age of Majority
Our Site is designed and intended for those who are at least 18 years old. By using our Site, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a User’s misrepresentation of his or her age. No one under age 13 is authorized to submit any information to AgingChoices, directly or through the Site, whether or not it is Personal Information. Under no circumstances may anyone under age 13 visit or use our Site. Parents or legal guardians of children under 13 cannot agree to these terms on a minor child’s behalf.
XIV. Contact AgingChoices
LifestyleCX, Inc. d/b/a AgingChoices!
PO Box 43
Guilford, CT 06437
Email: [email protected]