1. Scope and Roles
This Notice explains how the Platform collects, uses, discloses, retains and protects personal information when acting as a controller, business or personal information controller. A provider may separately control information collected for housing, admission, care, employment or resident services and must provide its own notice.
If we process protected health information for a HIPAA-covered entity or other regulated organization under a business-associate or data-processing agreement, that agreement and the covered entity’s notice govern the regulated workflow. Ordinary browsing, search and marketplace data are not automatically HIPAA-protected merely because they relate to senior living.
2. Information We Collect
| Category | Examples | Primary source |
|---|---|---|
| Account and identity | Name, email, phone, country, login, identity or authority evidence | You; identity provider |
| Needs and preferences | Location, budget, timing, age eligibility, mobility, accessibility, language, culture, pet and lifestyle preferences | You; authorized delegate |
| Housing and transaction | Saved listings, messages, tours, reservation requests, applications, deposits, payments, cancellations and move-in status | You; provider; payment processor |
| Sensitive information | Accessibility, disability, care-related preferences or other sensitive data that you choose or a secure workflow requires | You; authorized representative |
| Provider verification | Business identity, ownership, license, insurance, staff authority, complaints and verification history | Provider; registries; authorities |
| Reviews and support | Ratings, review text, complaint records, safety reports and support communications | Users; providers; support teams |
| Device and usage | IP address, browser, device, pages, clicks, session, diagnostics, security and approximate location | Device; cookies; service providers |
| Marketing and partnerships | Campaign source, consent, interests, event registration and partnership inquiry details | You; partners; advertising tools |
3. Sensitive and Health-Related Information
- Collect only what is necessary for matching, accommodation, safety or an authorized admission workflow.
- Use explicit consent or another lawful basis where required, and provide an alternative where feasible.
- Do not use health, disability, care-need, precise-location or housing-vulnerability data for cross-context behavioral advertising.
- Restrict access by role; separate regulated clinical workflows; and execute required business-associate or data-processing agreements.
- Do not request full medical records in ordinary search, comparison, messaging or tour workflows.
4. How We Use Information
- Create and secure accounts; verify identity, authority and providers.
- Provide search, matching, comparison, messaging, tours, requests, reservations, guided admissions and concierge services.
- Process payments, refunds, payouts, invoices, taxes and transaction records through authorized providers.
- Personalize results based on stated needs while maintaining fair-housing, safety and non-discrimination controls.
- Operate support, complaints, incident response, review verification, fraud prevention, audit and legal compliance.
- Analyze and improve service quality, accessibility, reliability and marketplace performance using proportionate data.
- Send transactional communications and, with required choice, marketing communications.
- Establish, exercise or defend legal rights and protect users, providers, the public and the Platform.
5. Legal Bases
Depending on jurisdiction, we rely on performance of a contract, steps requested before a contract, consent, compliance with legal obligations, protection of vital interests, legitimate interests balanced against individual rights, and other lawful grounds. Where consent is the basis, it may be withdrawn prospectively. Where legitimate interests apply, they may include account security, fraud prevention, service improvement, provider verification, complaint handling and proportionate direct marketing.
6. How We Disclose Information
- Providers and counterparties, when you inquire, message, tour, request, reserve, apply or authorize a disclosure.
- Authorized family members, delegates or advisers according to workspace permissions and verified authority.
- Payment, identity, communications, hosting, security, analytics, accessibility, customer-support and professional service providers under appropriate contracts.
- Government, regulators, courts, emergency services or other parties when legally required or reasonably necessary for safety, rights or fraud prevention.
- Successors in a merger, financing, reorganization or asset transaction, subject to confidentiality and applicable notice requirements.
- Aggregated or de-identified information that is not reasonably linkable to an individual, subject to re-identification restrictions.
7. Sale, Sharing and Targeted Advertising
The recommended launch position is that the Platform does not sell personal information for money and does not use sensitive care, health, disability or housing-need data for targeted advertising. Some analytics or advertising technologies may constitute “sale,” “sharing” or targeted advertising under certain laws even without a monetary payment. Where applicable, users may opt out through Privacy Preferences, Cookie Preferences or a recognized opt-out preference signal such as Global Privacy Control.
8. Cookies and Similar Technologies
We use strictly necessary technologies for security, authentication, load balancing, consent storage and core functions. Functional, analytics, personalization and advertising technologies are optional and should remain off until valid consent where required. See Cookie Preferences for categories, purposes, providers and durations.
9. Automated Processing and Ranking
The Platform may use rules, scoring or machine-assisted tools to rank listings, identify fraud, moderate content or prioritize support. Material ranking factors may include availability, price, verified status, accessibility match, response time, listing quality, reviews and stated preferences. The Platform does not make solely automated clinical admission, care-level or housing-eligibility decisions. Where law grants rights regarding significant automated decisions, users may request information, correction or human review.
10. International Transfers
Information may be processed in countries other than the user’s country. Where required, we use approved contractual safeguards, adequacy mechanisms, consent or other lawful transfer tools and provide information about applicable safeguards on request. Provider disclosures may involve independent cross-border transfers governed by the provider’s notice.
11. Retention
We retain information only as long as necessary for the stated purposes, legal obligations, safety, fraud prevention and claims. The schedule below is a proposed default and is replaced by the approved data-retention standard before publication.
| Record type | Proposed default | Reason |
|---|---|---|
| Account/profile | Account life plus up to 2 years | Reactivation, disputes, fraud prevention |
| Transactions and payments | Up to 7 years or local legal period | Accounting, tax, chargeback and claims |
| Provider verification | Relationship plus up to 7 years | Audit, licensing and enforcement |
| Safety/complaints | Risk-based; commonly up to 7 years | Protection, investigation and claims |
| Marketing preferences | Until withdrawal plus suppression record | Honor consent and opt-out |
| Cookie identifiers | Session to 13 months unless justified | Consent, security and analytics |
| Backups | Rolling deletion, proposed within 90 days | Resilience and recovery |
12. Security
We use administrative, technical and organizational safeguards designed for the sensitivity and risk of the information, including access controls, encryption where appropriate, logging, vendor diligence, secure development, vulnerability management, backups, incident response and workforce training. No system is completely secure. Users should protect credentials and report suspected compromise promptly.
13. Individual Rights and Choices
Submit requests through Privacy Preferences or the privacy contact published at launch. We may verify identity and authority proportionately. Authorized agents must provide proof of authority. We will respond within the period required by applicable law.
- Access, know or obtain a copy of personal information.
- Correct inaccurate information.
- Delete information, subject to lawful exceptions.
- Restrict, object to or withdraw consent for certain processing.
- Receive portable data where applicable.
- Opt out of sale, sharing, targeted advertising or certain profiling where applicable.
- Limit certain uses or disclosures of sensitive personal information where applicable.
- Appeal a denied privacy request where applicable and complain to a regulator.
- Exercise rights without unlawful discrimination or retaliation.
14. Regional Notices
United States
State privacy rights vary. Where laws such as the California Consumer Privacy Act apply, the Platform will provide required collection notices, category disclosures, request methods, opt-out controls, sensitive-data limitations and recognized preference-signal handling. The Platform treats Global Privacy Control as an opt-out request where legally required.
European Economic Area, United Kingdom and Switzerland
Users may have GDPR-style rights, may contact the applicable supervisory authority and may request information about legal bases and international-transfer safeguards. Controller, DPO and representative details are inserted where required.
Canada
The Platform will apply accountability, identified purposes, meaningful consent, limited collection, appropriate use and retention, accuracy, safeguards, openness, access and complaint handling under applicable federal or provincial law.
Philippines
The Platform will apply transparency, legitimate purpose and proportionality, respect data-subject rights, maintain appropriate organizational, physical and technical safeguards, and register or appoint privacy roles where required under the Data Privacy Act and National Privacy Commission rules.
15. Children and Vulnerable Persons
The Platform is not directed to children under 13 and does not knowingly create child accounts. Adult users must not submit a minor’s information unless authorized and necessary. The Platform applies enhanced protections against exploitation, coercion, financial abuse and unauthorized disclosure involving older or vulnerable adults.
16. Changes and Contact
We will post updates with a revised effective date and provide additional notice for material changes where required. Privacy questions, complaints and requests: Privacy Preferences or the privacy contact published at launch.