CALIFORNIA CONSUMER PRIVACY NOTICE
Effective Date: January 1, 2024
This California Consumer Privacy Notice (“Notice”) is provided pursuant to the California Consumer Privacy Act (“CCPA”) and describes how Atria Senior Living, Inc., our subsidiaries, and our affiliates, including Holiday by Atria and Coterie Luxury Senior Living, (“Atria,” “us,” “we,” or “our”) process Personal Information of California consumers, collected through your interactions with us and our websites (including atriaseniorliving.com, holidayseniorliving.com, coterieseniorliving.com, atriacares.com, and atriahomecare.com). This Notice supplements our other privacy policies and notices, including our Privacy Policy. In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to California consumers.
Job applicants can find additional disclosures in our California Careers Privacy Notice. If you are an Atria employee, please see our California Employee Privacy Notice for additional disclosures.
Unless otherwise noted, the disclosures that describe how and why we collect, use, and disclose Personal Information also describe how we have collected, used, and disclosed personal information in the preceding twelve (12) months.
Personal Information We Collect and Why We Collect It
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information includes “Sensitive Personal Information.” Personal Information does not include information that is publicly available, de-identified, or aggregated.
We collect the following categories of Personal Information about California consumers. Note that the Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.
| Category of Personal Information | Categories of Sources from which Information was Collected | Purposes for Collection and Use |
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| Personal Information | ||
| Identifiers including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers |
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| Personal Information described in Cal. Civ. Code § 1798.80(e), including 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 other financial information, medical information, or health insurance information |
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| Characteristics of protected classifications under California or federal law, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, and disability |
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| Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
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| Biometric information, including physiological, behavioral, and biological characteristics used to establish identity, such as fingerprints, faceprints, voiceprints, and other similar data |
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| Internet or other electronic network activity information, including Internet or other similar activity, browsing history, search history, information on a consumer's interaction with a website, application logs, device data and registration, social media account information or advertisement |
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| Geolocation data |
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| Audio, electronic, visual, thermal, olfactory, or similar information |
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| Professional or employment-related information. If you are an Atria employee, please see our California Employee Privacy Notice for additional disclosures. Job applicants can find additional disclosures on the California Careers Privacy Notice page. |
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| Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
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| Sensitive Personal Information | ||
| Personal Information that reveals a consumer’s Social Security, driver’s license, state identification card, or passport number |
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| Personal Information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account |
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| Personal Information that reveals a consumer’s precise geolocation |
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| Personal Information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership |
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| Personal Information that reveals the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication |
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| Personal Information that reveals a consumer’s genetic data |
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| The processing of biometric information for the purpose of uniquely identifying a consumer |
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| Personal Information collected and analyzed concerning a consumer’s health |
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| Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation |
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We also collect some Personal Information that does not directly fit within one of the categories defined by the CCPA. For example, we collect the contents of communications you send to us by phone, email, text, or online chat. Unless otherwise specified, the sources of this Personal Information, the purposes for which we use it, and the categories of persons to which we disclose it are the same as those listed for Commercial Information.
We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
How Long We Keep Your Personal Information
We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
- Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
- Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
- Your Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case);
- Your Personal Information may be maintained indefinitely according to legal or regulatory requirements, including applicable legal holds, or for data backup or recovery purposes; or
- We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.
Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
How We Sell, Share, and Disclose Personal Information
As defined in the CCPA, we sell, share, and disclose for a business purpose Consumer Personal Information to our service providers, contractors, and third parties.
Sales and Sharing of Personal Information
Under California law, a “sale” of Personal Information does not necessarily involve an exchange of money. Instead, the term also includes disclosures of Personal Information to third parties that may use the information for their own purposes, such as cookie providers. Similarly, under California law, “sharing” Personal Information refers to disclosing of Personal Information to third parties for cross-context behavioral advertising. In this context we sell and/or share the following categories of Personal Information.
As defined by California law, we sell and/or share identifiers, Personal Information described in Cal. Civ. Code § 1798.80(e), internet or other electronic network activity information, geolocation data, and inferences for analytics, marketing, and advertising, including targeted advertising and cross-context behavioral advertising. We sell to and share with advertising networks; service providers, vendors, and suppliers; data analytics providers; and social networks. We do not sell or share Personal Information obtained for text messaging purposes (e.g. opt-in consent information,) with any third parties for those third parties’ own marketing purposes. We do not have actual knowledge that we sell or share the Personal Information of consumers under sixteen (16) years of age.
Disclosures for a Business Purpose
We disclose the categories of Personal Information listed in in the “Personal Information We Collect and Why We Collect It” section to our affiliated and related companies; our service providers, vendors, and suppliers; our professional advisors; public authorities or government bodies; and external auditors for the following business purposes:
- Auditing related to ad impressions;
- Ensuring security and integrity of Personal Information;
- Debugging to identify and repair errors that impair existing intended functionality;
- Short-term, transient use, including, but not limited to, non-personalized advertising;
- Performing services on our behalf;
- Providing advertising and marketing services (except for cross-context behavioral advertising);
- Undertaking internal research for technological development and demonstration;
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us;
- Processing, maintaining, or collecting Personal Information on our behalf;
- Detecting or protecting against malicious, deceptive, fraudulent or illegal activity; and
- For internal use by the service provider.
Submitting Requests Relating to Your Personal Information
If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request to CAprivacyrequest@atriaseniorliving.com or call us at (800) 928-9145. Please note that, if you submit a request to know, delete, or correct, you may be asked to log into your account or to provide two-to-three (2-3) pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.
Right to Know. You have the right to know what Personal Information we have collected about you, which includes:
1. The categories of Personal Information we have collected about you, including:
- The categories of sources from which the Personal Information was collected;
- Our business or commercial purposes for collecting, selling, sharing, or disclosing Personal Information;
- The categories of recipients to which we disclose Personal Information;
- The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information; and
- The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to whom we disclosed that particular category of Personal Information.
2. The specific pieces of Personal Information we have collected about you
Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.
Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Opt-Out of Sales and Sharing of Personal Information. You have the right to opt-out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. To opt-out, please visit our cookie preference center located in the footer of this Site. If you choose to use the Global Privacy Control (“GPC”) browser signal, you will only be opted-out of online sales or sharing of Personal Information, and will need to turn it on for each browser you use.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA. For this reason, we do not offer a way for you to submit such a request.
Rights Related to Automated Decision-Making. You have the right to opt-out of automated decision-making, including profiling, that we use to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.
Other California Notices
California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of personal information 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 emailing us at CAprivacyrequest@atriaseniorliving.com or by sending a letter to Atria Senior Living, 300 East Market Street, Suite 100, Louisville, KY 40202 (Attention: Legal Counsel – Shine the Light). Any such request must include “California Privacy Rights Request – Shine the Light” 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.
How to Contact Us
If you have any questions about how we handle your Personal Information, please contact us at:
Phone: 1-800-928-9145
Email: CAprivacyrequest@atriaseniorliving.com
Address: Atria Senior Living, Attention: Privacy Inquiry, 300 East Market Street, Suite 100, Louisville, KY 40202
